Double Assault on Endangered Species Act - Letters Needed

December 2003

On 18 August 2003 the Department of the Interior’s Fish and Wildlife Service (FWS) proposed a draft policy that would make it easier for US sport hunters to import trophies of endangered animals into the United States. This policy would also assist other animal users, including circuses and exhibitors, to import endangered live animals. In addition it would loosen restrictions on importation of derivatives of endangered animals, such as fur and hides.

On 10 September 2003 a second assault on the Endangered Species Act was launched. New regulations to facilitate commercial exploitation of endangered wildlife, both overseas and inside the United States, were proposed.

These new regulations would allow previously illegal activities, including the killing of endangered animals, to take place in return for payment to be used for alleged "conservation."

IPPL is working to defeat both proposals and seeks the help of our worldwide membership.

Assault 1

The FWS administers the program under which permits are granted for international trade in endangered species. Permits are issued based on the Convention on International Trade in Endangered Species (CITES) and the more rigorous Endangered Species Act (ESA).

Public comments on the draft policy were due by 17 October 2003. IPPL, along with many other wildlife protection organizations, was able to submit timely comments. In addition we contacted members of our e-alert list and circulated an Internet petition. Thanks to everyone who helped!

IPPL has little doubt that corrupt wildlife officials around the world will be thrilled at FWS’s proposal, and that honest officials will be dismayed.

The draft FWS policy

FWS proposed to issue permits for killing or trade in foreign wildlife "if such action enhances survival of the species in the wild" and if the habitat country has an effective conservation program for the species. Hunters’ fees would qualify as contributions to conservation. That the agency could consider that US nationals shooting endangered animals overseas would constitute part of an effective conservation program is appalling to IPPL!

IPPL submits comments

IPPL submitted detailed comments on the proposals. Extracts follow.

If this "Draft Policy" were to be implemented, unscrupulous circus owners and trophy hunters in the United States would be given an unprecedented opportunity to despoil other nations’ wildlife under the guise of conservation...

In many cases native people are not permitted to shoot, even for food, the same animals that the rich Western safari hunters would be allowed to kill. The spirit behind the proposal will certainly be viewed as racist at worst, and insensitive at best, by many in developing world nations...

The Service has offered no proof that the profits gained by killing any of the animals mentioned in the "Draft Policy" would go the protection of these same species...the US has no way to monitor any overseas wildlife protection programs.

IPPL also drew attention to a permit application filed in 1978 by the US-based Safari Club International, for import of sport-hunted gorillas, orangutans, Zanzibar red colobus monkeys, and hundreds of members of other highly endangered species and wondered how a similar application would be considered under the new policy.

Species Survival Network comments

Carroll Muffett of Defenders of Wildlife prepared excellent comments for the Species Survival Network, a coalition of animal protection organizations of which IPPL is a member. Speaking for 31 organizations, Muffett stated,

In our collective view, the Draft Policy is only one manifestation of a growing and increasingly disturbing trend in the FWS’s implementation of our nation’s most important wildlife laws. Our organizations have a long and fruitful history of collaboration and cooperation with your agency. Regrettably, however, we are confronted by an ever-expanding array of regressive decisions and policy proposals-that elevate form over substance, private interests over the public good, and politics over law. We urge the Service to reverse this trend, and reclaim its proper role as they leading advocate and protector of wildlife, both in the United States and around the world.

Other Comments

• Dr. Jane Goodall commented, "It stinks, quite honestly. It’s an open door to corruption. It’s disgusting."
• Christine Wolf of the US-based Fund for Animals commented, "It’s the method through which FWS is attempting to regulate our strongest environmental law into oblivion."
• Karl Ammann, Kenyan crusader against the bushmeat trade, stated, "Never mind the local poachers, as is already happening in Cameroon, making the point that they see no reason why they cannot kill a few of THEIR elephants now and then, for a meal or some cash income, while rich foreigners can buy licenses to hammer the species FOR FUN."

Washington Post runs story

On 11 October 2003 the influential newspaper Washington Post ran a story about the proposed policy. Reporter Shankar Vedantam explained FWS’s rationale.

Giving Americans access to endangered animals, officials said, would both feed the gigantic US demand for live animals, skins, parts and trophies, and generate profits that would allow poor nations to pay for conservation of the remaining animals and their habitats...Safari Club International gave $274,000 to candidates during the 2000 election cycle, 86 percent of it to Republicans. It also spent $5,445 printing bumper stickers for the Bush presidential campaign.

Writing for The Battalion, the Texas A and M University student newspaper, Justin Hill wrote,

Bald eagles, the national bird, were on the endangered species list just a few years ago...the United States fought hard to saved the bald eagles and was successful. What if Americans had be told the best way to save the bald eagles was to kill or export the birds? Americans would not tolerate foreigners coming in and killing the US national bird and Americans must not tolerate policies making it OK to kill endangered species in other countries...

Dangerous is an under-statement. The idea that it is necessary to kill endangered species to save them defies all logic.

Assault 2

The second assault on the Endangered Species Act consisted of proposed regulations affecting all endangered species, including those in the United States.

Katherine Meyer of the Washington law firm Meyer and Glitzenstein prepared comments,

The Bush administration is now proposing new regulations that will define the term "enhance the survival of the species" to allow it to issue permits for a whole host of previously illegal activities including the direct killing of an imperiled species as long as the permittee contributes funds or other support to some kind of conservation program for the species as a whole...this is nothing short of a sea change in the way the ESA is administered and will return us to the days when there was rampant commercial exploitation of exotic species, precisely what led to enactment of the ESA in the first place...

The regulations are a blatant gift to the exploiters-hunters, zoos, circuses, developers, commercial entrepreneurs, ect.-who have been lobbying for such changes in the ESA for years.

WHAT YOU CAN DO We request our US members to write letters opposing the draft policy, referring to "Draft Policy for Enhancement of Survival Permits for Foreign Species Listed Under the Endangered Species Act" and the draft regulations, referring to the "Revisions to the Regulations Applicable to Permits Issued Under the Endangered Species Act" to their congressional representative and both their senators. Addresses: House of Representatives Washington DC 20515, USA Senate Office Building Washington DC 20510, USA You can locate your representatives’ names at www.ideacenter.org/contactreps.htm We request our overseas individual and organizational members to help by contacting the US Embassy in their country of residence. Letters from overseas are really helpful as they are relayed to the US State Department via the embassies and the State Department is very sensitive to public opinion overseas. Among the points for letter-writers to make: The Department of Interior’s Fish and Wildlife Service has proposed a new policy and regulations under the Endangered Species Act that would relax restrictions on international trade in endangered species-both living and killed as trophies or for their skins and hides. Species are listed on the Endangered Species List because they are facing extinction. To allow US nationals to kill or remove from the wild animals belonging to these species will bring them closer to extinction and will set a bad example to local people who are not allowed to kill them. Request that your representatives (or the US Ambassador to your country) contact the Secretary of the Interior to express their opposition to both the proposed policy and regulations.