Oppose plans to undermine Endangered Species Act

October 2003

Dear member of IPPL’s Alert List,

I am writing to ask your help in opposing a plan of the US Fish and Wildlife Service (USFWS) to weaken the Endangered Species Act. The USFWS has proposed a “Draft Policy” that would make it easier for trophy hunters to bring endangered animals they have shot overseas into the United States, for circuses and zoos to import endangered animals for their collections, and for manufacturers to bring in skins and hides from endangered animals. The USFWS intends to offer permits that specifically allow individuals to legally import endangered animals (or their body parts) into the United States.

One might wonder why the USFWS has come up with such a ridiculous proposal and why staff time has been spent drafting it. Well, the reason is, according to the government’s argument, that increasing international trade in rare animals will generate income that will ultimately contribute to the conservation of endangered species in their native countries. IPPL suspects, however, that some of the rich international safari hunters and zoo and circus owners may have used their influence to create this policy.

Please send your protests to the USFWS Division of Management Authority by the October 17 deadline. Comments from overseas will also be welcome. Specify in your letters that you are addressing the “Draft Policy for Enhancement-of-Survival Permits for Foreign Species Listed Under the Endangered Species Act” 68 Fed. Reg. 49512 (August 18, 2003). Address your comments to:

Chief, Division of Management Authority
US Fish and Wildlife Service
4401 North Fairfax Drive, Room 700
Arlington VA 22203
Fax: 703-358-2280
E-mail: ManagementAuthority@fws.gov

IPPL has sent the USFWS a lengthy submission, a version of which you may read below. Feel free to review IPPL’s letter to get ideas for your own, and to circulate this message to your friends, Internet mailing lists, and organizations to which you belong. The full “Draft Policy” can be found at: http://policy.fws.gov/library/03-20941.pdf

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Dear Sir,

On behalf of the International Primate Protection League and its 17,000 members in the United States and around the world, I wish to protest the “Draft Policy for Enhancement-of-Survival Permits for Foreign Species Listed Under the Endangered Species Act” 68 Fed. Reg. 49512 (August 18, 2003). If this “Draft Policy” were to be implemented, unscrupulous trophy hunters and zoo owners in the United States would be given an unprecedented opportunity to despoil other nations’ wildlife under the guise of “conservation.”

The Service argues that “By allowing importation of dead and live wildlife originating from endangered species, we would be providing a real incentive for foreign nations to establish programs that conserve both wildlife and habitat.” IPPL doubts that the Service’s laudable intentions would be apparent to the nations concerned. In many cases, native people are not permitted to shoot, even for food, the same animals that the rich Western safari hunters are allowed to kill. They may feel very resentful over the double standard (“If that rich American can shoot a gorilla, why can’t I?”). The spirit behind the proposal will certainly be viewed as racist at worst, and insensitive at best, by many in developing world nations.

This kind of double-dealing will also make it harder for authentic local groups, often fighting indifferent or corrupt governments, to work for wildlife protection. The perception might well be that our nation’s politically influential people have sought and found a way to bring home the endangered animals killed during their safaris. On my overseas travels I have met many people who associate this kind of behavior with residents of Texas!

In addition, the Service has offered no proof that the profits gained from killing any of the animals mentioned in the “Draft Policy” would go to the protection of these same species. In recent years, the deluge of Canadian-origin polar bear permits applied for and issued cannot be proved, by actual data, to have helped polar bear survival. I am aware that safari hunters may pay an outfitter huge fees in connection with their excursions, including guide fees, getting their victims’ carcasses stuffed, shipping them to the United States, etc. How much of this money is plowed back into the protection of these same species, however, is never clear.

Nor is it clear, precisely, how zoos would work to benefit the native populations of endangered animals once the zookeepers have imported their desired specimens. The Service has no way to verify that funds generated by sport-hunting or trafficking in rare animals would, in fact, fulfill the intended purpose. The US has no way to monitor any overseas wildlife protection programs. In addition, even if the fraud were obvious, the US Government would be unlikely to challenge a nation’s veracity or set up a standard that would apply to some countries, but not others.

Further, although interstate sale of endangered species is banned on paper, many endangered primates (including lemurs, gibbons, cottontop tamarins, and Diana monkeys) are sold interstate as pets or to roadside menageries. If the Service can’t or won’t stop this, how can it assure proper spending of funds generated by killing or international trade in endangered animals?

Another part of the rationale presented by the Service for implementing the “Draft Policy” is that some of the policy’s proposed types of animal exploitation are taking place already. However, it is not reasonable to promote increased attacks on endangered animals by sanctioning current abuses. For example, the Service points out that US nationals are already allowed to travel the world exploiting animals belonging to endangered species, by killing or other means, as long as they don’t bring the live or dead animals into the United States. In fact, the current prohibition may be a deterrent to killing these animals, since many safari hunters seek status and admiration for their feats by displaying what they killed on the walls of their homes in the United States. I am sure that the many animals not killed by US hunters—-thanks to US laws that ban the import of trophies belonging to endangered species—-greatly appreciate being alive.

IPPL remembers the Safari Club International’s 1978 application to import on an annual basis:

• 5 sport-hunted gorillas,
• 5 orangutans,
• 25 tigers,
• 15 Zanzibar red colobus monkeys,
• 100 cheetahs,
• 10 northern white rhinoceros,
• 100 mountain zebras, and
• dozens more species.

One wonders if this club has had a change of heart—-or if some of its members might not hanker after these same species. Under the proposed “Draft Policy,” would a similar application be granted?

Reading the numerous Federal Register permit applications for importation of wildlife killed by US big game hunters is sickening to those who value the lives of wild animals as beings sharing our earth. We cannot accept the pretense that somehow the slaughter of these unconsenting animals—-be they unlucky polar bears from Canada or hapless bontebok from various African nations, or any other unfortunate trophy animal—-is helping their species survive. We cannot agree that individual animals must pay with their lives or sanity in order for their species to have a place in the world.

A similar example of current animal exploitation cited by the Service involves the Convention on International Trade in Endangered Species (CITES). Under CITES, if an endangered animal has been “captive-born,” he/she can be categorized as “merely threatened,” and thus can be used for commercial purposes. The Service should be aware that this “captive-bred” provision is a serious loophole in CITES. Many countries are notorious for issuance of false certificates of captive birth. One recent case involved the transfer of four infant gorillas from Nigeria to Malaysia on certificates falsely claiming that the animals were born at Ibadan Zoo, Nigeria, which has only one gorilla. The same happens with animals belonging to many other species. Sadly, CITES was unable to prevent this abuse or to remedy it after the fact.

This example illustrates how even zoos can contribute to the decline in endangered species. IPPL would deplore any loosening of restrictions on importing endangered animals by US zoos. US zoos are notorious for getting rid of surplus animals via the back door to make room for animals coming in by the front door (see Linda Goldston’s February 1999 four-part series “Zoo Animals to go” in the Sacramento Bee and Alan Green’s book "Animal Underworld," Center for Public Integrity, 1999). Some of these zoo animals have ended up being killed in canned hunts or falling into the hands of animal dealers supplying the exotic pet trade. By making it easier for zoos to acquire “trendier” species through import, the Service may encourage “dumping” of animals belonging to species which have lost their “glamour.”

IPPL does not accept that “the only way for the United States to participate in programs to improve the status of an endangered species is to allow import of specimens, parts, or products from well-regulated taking programs, if the programs are designed to promote conservation of the species in the wild.” The Service fails to mention, for example, the role of eco-tourism or other non-exploitative uses of animals that would help local people and wildlife in developing nations. Why couldn’t a would-be safari hunter take his trip, photograph (not kill) the trophy animal, and view his trip expenses as a donation to wildlife protection? The killing of animals does not have to be part of an overseas vacation.

Instead of using an alleged lack of funds as a rationale to encourage US nationals to exploit endangered animals, the United States should greatly increase its financial support of overseas wildlife conservation and protection programs. The fact that current support is “limited” (as noted in the “Draft Policy”) is because our government unfortunately has other priorities. Finally, IPPL would like to see the Endangered Species Act amended to ban exploitation of endangered animals anywhere in the world by persons subject to US jurisdiction.

IPPL sees no underlying problem that would be “fixed” by relaxing restrictions on the import of endangered animals. Therefore we are strongly opposed to the proposed changes. Obviously, implementation of the policy would “enhance” zoo and circus collections and the walls of safari hunters, but this was not the intention of those who wrote the Endangered Species Act. It appears to IPPL to have been a waste of taxpayers’ money to spend staff time on preparing this unnecessary policy which would hurt, not help, endangered species and bring further disrepute on the current administration’s environmental policies.

Yours sincerely,

Dr. Shirley McGreal
Chairwoman, IPPL