Dear FWS: Is This Really a Solution?

The U.S. Fish and Wildlife Service has released a new policy on reviewing trophy imports of African species, including lions and elephants. Read my letter that reveals the plan's flaws and highlights my concerns. 

Dear Fish and Wildlife,

After reviewing the Memorandum that announced the withdrawal of certain findings for ESA-listed species taken for sport-hunted trophies, I am appalled at the decision FWS reached. I understand that the court ruling obtained by the NRA and Safari Club International complicated the matter of sport-hunted trophy imports from Africa, forcing FWS to change its process of extending or withholding import permits. However, I disagree with the premise of making judgments on an individual basis. 

CITES has given African elephants Appendix I status around the world in all but 5 nations. Zimbabwe, Zambia, South Africa, Botswana and Namibia have all shown a reluctance to extend their best efforts to protect the future survival of elephants, allowing the trade, sale and export of these creatures, despite the dwindling numbers of herds across the continent. 

I am sure you're aware of the critical race to preserve the future existence of these animals in the wild, which could disappear within 10 years. As a nation who adheres to the Appendix I classification of elephants, the US is required to extend the most stringent regulations when it comes to the trade, import and export of live animals or animal parts. How, then, are we upholding this promise if we withdraw all general regulations on elephant trophy imports? 

The 2014 ban placed on African elephant imports from Zambia and Zimbabwe was enacted because of a lack of confidence in the conservation efforts of these two nations toward their elephant populations. In order to approve elephant trophy imports, African governments had to show that the funds gained from sport hunting were being spent on furthering the future of elephants within their borders. When there was no sufficient evidence to support this claim, the FWS placed a temporary ban until satisfactory evidence was provided.

However, powerful sport-hunting organizations challenged the ban and its subsequent governmental decisions. They won their case and the door for sport hunting of critically endangered species has been thrown wide open. This begs the following questions:

Where will the extra revenue come from in order to pay FWS employees to review every trophy import case individually?
What rules, if any, will trophy hunters have to meet in order to bring their dead animal into the US?
What precautions and oversight will be in place to prevent bribery and corruption when making these individual rulings? Where will the funding for this oversight come from?
What does this mean for these African nations that do not have satisfactory conservation efforts? Are we going to hand them funds anyway?

While a general ban on specific nations or species imports may not be the best option, I cannot believe that individual rulings will be a better solution. This decision places a heavy burden of work on FWS employees and opens the door for conjecture and corruption. Even though this new policy is the result of a court case, I predict that it will be further complicated by a series of cases when sport hunters are denied the right to import trophies. This will cost even more taxpayer dollars and further the belief that the US cannot make up its mind when it comes to wildlife conservation. 

If the principle at stake is the desire to protect elephants and lions, how does this new policy uphold that? If an African nation is not turning its sport hunting revenue into meaningful conservation efforts, Americans should not be giving them money, period. The Service will "continue to monitor" the status of conservation efforts in these nations, but if they will not deny funds to corrupt governments, what good will this do? What happens when "information available to the Service as to the status of and management program for the species or population" is not provided? 

General bans clearly represent the desire of the American people to protect wildlife around the globe, but rulings on a case-by-case basis say the opposite. I do not support this FWS decision, and I will do my part to convince others to do the same. I strongly urge you to reconsider this ruling and change your policy.