H.R. 6362: Injurious Wildlife Revisited


Large Burmese python captured in the Florida Everglades

Washington, D.C.— On July 13th, U.S. Senator Kirsten Gillibrand (D-NY), and U.S. Congresswoman Elise Stefanik (R-NY), announced through a press release, the bicameral reintroduction of the Invasive Fish and Wildlife Prevention Act as H.R. 6362; formerly H.R. 669— the Nonnative Wildlife Invasion Prevention Act. The bill seeks to strictly regulate the import, possession and transport of potentially harmful non-native wildlife by giving the U.S. Fish and Wildlife Service (FWS) greater authority to employ risk assessment protocols, screen for potentially invasive species, and designate “injurious wildlife.”

“injurious wildlife, cannot be imported into the United States or its territories, or be transported through interstate commerce”— Rep. Elise Stefanik

Legislative History
“Injurious Wildlife” is the issue I cut my political teeth on. Former CEO of the Defenders of Wildlife, Peter Jenkins, outlined early iterations of the bill in his 2007 Broken Screens report. Subsequently, H.R. 669 was introduced in 2009 by Del. Madeline Bordallo (D-Guam), and was soundly defeated in the House Natural Resources Committee when I coordinated a massive grass roots letter writing campaign on behalf of the United States Association of Reptile Keepers (USARK).

We delivered almost 50,000 hand written (NO on H.R. 669) letters to the House Natural Resources Committee— literally wheeling in stacks upon stacks of letters on carts to the committee hearing room. It wasn’t the only factor in the defeat of H.R. 669, but the dramatic impact of one of the largest letter writing campaigns in 30 years, put the nail in the coffin of a partisan special interest bill.

H.R. 669 was resurrected in 2013 as H.R. 996 by Rep. Louise Slaughter (D-NY). The name was changed to the Invasive Fish and Wildlife Prevention Act, but the primary function— to create a “guilty until proven innocent” white list that expedited the arbitrary process to add species to the injurious wildlife list of the Lacey Act remained intact. However, the Republicans on the Natural Resources Committee had no appetite for partisan favors to special interest groups. As a result, Rep. Slaughter was never able to garner bi-partisan support from the Committee— where it languished until it’s death at the close of 113th Congressional session.

What would H.R. 6362 do if passed?
The main function of H.R. 6362 would give the Secretary of the Department of the Interior (DOI) authority to define and regulate “injurious wildlife taxon or taxa.” Further, it would establish a process of risk assessment and risk management for all non-native species “not in trade.” in the United States. H.R. 6362 would prohibit the import, possession and interstate transport of any species designated as injurious wildlife or not in trade. H.R. 6362 lets the Secretary of DOI arbitrarily make the calls to designate and regulate injurious wildlife unilaterally.

Negative Impact on Herpetoculture
The favorable ruling regarding the question of what constitutes interstate transport under the Lacey Act that USARK received from the U.S. Court of Appeals, D.C. Circuit, would be completely negated (USARK v. Ryan Zinke 2017) by H.R. 6362. Possession and trade of all 9 constrictor species listed as injurious wildlife under the Lacey Act would be prohibited; including Burmese pythons and reticulated pythons. Additionally, all of the 201 salamander species listed as injurious wildlife would be prohibited. Nothing currently on the injurious wildlife list could be possessed or traded if H.R. 6362 were to pass as written.


(1) IN GENERAL.—On the date of enactment of this Act, any wildlife designated as injurious by sec- tion 42(a) of title 18, United States Code, including any designation made under that section (as in effect on the day before the date of enactment of this Act), shall be designated as an injurious wildlife taxon or taxa under this Act.

Impact on Zoos
There is no exemption for zoos in H.R. 6362. Any specimens that zoos keep in their collections that is considered injurious wildlife, or not in trade, would require a rigorous permit for import, possession or transport of these species. H.R. 6362 would cost zoos time, money and man power in applying for permits. Even without the injurious wildlife designation, I could see many of the species in zoo collections falling into the “not in trade” category— therefore requiring the same permitting as injurious wildlife. Zoos that operate on thin financial margins could be in jeopardy of insolvency should this measure pass.


(a) IN GENERAL.—The Director may issue to a qualified institution a permit that authorizes the import into the United States or transport between States of wildlife designated as an injurious wildlife taxon or taxa for scientific, zoological, medical research, or educational purposes if the Director finds that qualified institution properly demonstrates—

Solution for Constrictor Snakes listed as injurious?

When I outlined the strategy in 2012 for the USARK Board of Directors to file a simple administrative lawsuit against DOI to clarify the transportation clause, I never meant the favorable outcome to be a permanent solution to the issue of trade in large constrictors. The real question was whether large constrictors deserved the “injurious wildlife” designation.

Even if the government was overreaching their authority to enforce a prohibition on interstate transport of injurious wildlife, nobody really thinks it’s a good idea to transport injurious wildlife across state lines. An administrative lawsuit was always just a stopgap ploy to buy more time should constricting snakes get listed. That’s why I also laid all of the groundwork for a lawsuit on the “merits” to challenge the science used by U.S. Fish and Wildlife Service to justify the decision to list the large constrictors as injurious wildlife under the Lacey Act in the first place.

The real question for herpetoculture is not whether injurious wildlife should be traded across state lines. But rather— Do 9 constrictor snakes belong on the injurious wildlife list?—Andrew Wyatt

A lawsuit on the merits would be much more involved and expensive to litigate than USARK v. Ryan Zinke. However, I already did most of the public record work and filed formal challenges of the science under the Information Quality Act as CEO of USARK. I established that the rule making fell into the “major” rule context, requiring the government do an exhaustive economic impact study and use only information held to a high quality standard. Further, I collected dissenting opinions from top science experts from around the world. If USARK wants to save constrictors “in trade” from H.R. 6362, or something like it, they better figure out a way to get them off the injurious wildlife list. I left a template for this “lawsuit on the merits” strategy with USARK in 2013 when I resigned over philosophical differences with the Board of Directors. Regardless, they have it sitting on their desk. Hopefully they will have the same kind of success they did with my idea for USARK v. Ryan Zinke.

Why is H.R. 6362 more dangerous than H.R. 669?
In short… Republican lawmakers. Although all of the usual suspects who have supported the bill in the past are still likely to support it in the future, invasive species and associated parasites and pathogens are a grave concern, not only to native wildlife, but to agribusiness. We aren’t just talking about a bunch of left wing crazies championing the bill anymore, but also the likelihood that Republican lawmakers will will support H.R. 6362, or its follow up, in order to protect ranchers and farmers from the threat of business losses due to invasive species related threats.

Let’s face it, the majority of lawmakers, Republican and Democrat alike, don’t think it’s a good idea to have injurious non-native wildlife in this country— and they certainly don’t think transporting injurious species, parasites and pathogens across state lines without rigorous regulation is a good idea. H.R. 6362 is bad for a lot of reasons. But that doesn’t mean it won’t pass— or something like it. My biggest problem is a fundamental one— the arbitrary authority given to the Secretary of DOI to do what he thinks best, without real recourse from legitimate stake holders. NO on H.R. 6362.

***The lobbyist for USARK doesn’t think that the language from the H.R. 6362 will outright ban possession of injurious wildlife. She may be right, but it could very well be a point that must be clarified in court, should this measure pass. You be the judge…

      (a) IN GENERAL.—Subject to subsection (b) and section 8, it is unlawful for any person subject to the jurisdiction of the United States—
        (1) to import into the United States or transport between States any wildlife designated as an injurious wildlife taxon or taxa;
          (2) to possess any wildlife designated as an injurious wildlife taxon or taxa, or a descendant of that wildlife, that was imported or transported in violation of this Act;

Andrew Wyatt is a government affairs and policy consultant dedicated exclusively to the wildlife sector. Vitello Consulting for the Win!

Andrew_Bolton 2018

Andrew Wyatt and National Security Advisor John Bolton in the “Green Room” at FOX News

“In an arena known to be dominated by powerful special interest groups, Vitello Consulting has created a niche providing tailored advocacy strategies that are leveling the playing field for wildlife clients on Capitol Hill— And in 2014 we began offering state level advocacy that has negated most of the legislative and regulatory initiatives impacting our clients in state capitols across the country. Please follow The Last Word on Wildlife for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the advantages of creating a comprehensive business/government affairs strategy, or a more targeted issue campaign, please call or email me.” — Andrew Wyatt

©Andrew Wyatt and The Last Word on Wildlife, 2018. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Andrew Wyatt and The Last Word on Wildlife with appropriate and specific direction to the original content. Material posted from guest writers is the sole intellectual property of the author. Please seek permission directly from the author prior to reproducing in whole or in part.

HSUS—AZA: Golden Bridge to Zoo Obsolescence


Sun Tzu, the famous Chinese General who wrote the classic text ‘The Art of War,’ said ‘Build your enemies a golden bridge’. He meant corner your enemy, and then rather than fighting, create a path of escape in the direction that you want them to go. The Golden Bridge works by closing off all options except the one you have strategically chosen.

A Change in Tactics
Why has Wayne Pacelle and the Humane Society of the United States (HSUS) taken such a proactive interest in the Association of Zoos and Aquariums (AZA)? After decades of opposing zoos and all forms of captive conservation, Wayne Pacelle appears to have changed tactics in his bid to close the book on zoos. What if he could harness the active cooperation of AZA? He may then be able to influence a change of direction from within. To that end Pacelle spent the summer of 2017 speaking about how collaboration between HSUS and AZA is the way of the future. With long time friend and political ally, Dan Ashe, now at the helm of AZA, Pacelle may be empowered to usher zoos into a self enforced obsolescence.

The new twist in the HSUS—AZA partnership was unveiled when Dan Ashe announced that Wayne Pacelle, CEO of the Humane Society of the United States, would be the keynote speaker at the AZA Annual Conference 2017. Ashe added, “[Wayne] Pacelle has an important perspective to share with conference attendees.” Facebook blazed with opposition posts, and an online petition to disinvite Pacelle from the conference garnered more than 700 signatures. Nevertheless, Wayne Pacelle was welcomed as the keynote address.

Will Wayne Pacelle be “invited” to join the AZA Board of Directors?

The HSUS stance on zoos had been straight forward until recent years. HSUS had always opposed zoos and all captive breeding. In the 1990’s HSUS said that, “if the right policies were pursued, we would need no zoos at all.” In 2004, Nicole Paquette, Vice President of Wildlife Protection for HSUS, told the Los Angeles Times that she opposed “keeping animals in zoos.” However in his 2017 address, Wayne Pacelle declared, “The AZA and The HSUS have many shared ideals.” 

As has become his signature, Pacelle couldn’t resist reaching into his bag of dirty tricks. He has targeted the zoo community, lawmakers and government agencies with a smear campaign designed to brand any non-AZA facility with the pejorative of “Roadside Zoo.” Near the close of his keynote speech at the AZA Annual Conference, there was a moment reminiscent of Star Wars— when Darth Vader appeals to Luke Skywalker to, “feel the power of the dark side.” While calling dissenters “divisive,” Pacelle openly urged AZA members to turn on their zoo colleagues, and join him in condemning the Zoological Association of America (ZAA), the second largest zoo accreditation organization in the U.S.— Keep in mind, these are well respected, fully accredited zoos, duly licensed and inspected by the USDA.

There is no doubt that for the last decade, HSUS has been pressuring and using the AZA as a surrogate to advance animal rights based legislation and zoo policy. Ron Kagan, the Director of the Detroit Zoo, has spearheaded the HSUS crusade to win hearts and minds at the AZA, and he has been actively forging stronger ties with more radical members of the animal rights movement. While many AZA members have been more than dubious of Pacelle and Kagan’s efforts to co-opt the organization,  the cooperation of AZA leadership has lent much needed zoological legitimacy to the animal rights behemoth— and in exchange HSUS has exempted AZA from ongoing anti-zoo legislative initiatives at the local, state and federal level.

“I believe the animals on exhibit [at zoos] should be rescues.” —Wayne Pacelle, 4th International Animal Welfare Congress 2017

The Golden Bridge
According to their own statements, Kagan and Pacelle believe zoos should “transition to the sanctuary model,” and forgo the keeping of any large charismatic species in captivity— in this vision of the future, zoos would cease to exhibit cetaceans, elephants, great apes, and large carnivores. Under this “sanctuary model” zoos would become “last stop” sanctuaries, and conservation based captive breeding programs would be terminated. The AZA Species Survival Plans (SSP’s) have been vital to conservation, and a return to the wild, of endangered and even previously extinct species like the scimitar horned oryx, but captive breeding is a sin in the world of animal rights.

The reality is, animals are rarely taken from the wild for exhibit, especially endangered animals. So if there is no breeding, there are no zoo animals. If the transition to the sanctuary model combined with the dissolution of captive conservation projects (SSP’s) becomes policy, in 20-40 years AZA zoos would not have any animals to exhibit, nor would they have the archive of genetic stock for hundreds of endangered species. The long held HSUS paradigm of “one generation and out” would come to pass. This is the “Golden Bridge” that Wayne Pacelle, Dan Ashe and Ron Kagan envision for the AZA to retreat across—a strange new land where zoos are sanctuaries, and SSP’s are a memory— and anyone who is not on board is “cruel,” a “bad actor,” or a “roadside zoo.”

Andrew Wyatt, of Vitello Consulting, is a government affairs and policy consultant dedicated exclusively to the wildlife sector. Vitello Consulting for the Win!

WyattP1“In an arena known to be dominated by powerful special interest groups such as the Humane Society of the United States and People for the Ethical Treatment of Animals (PeTA), Vitello Consulting has created a niche providing powerful advocacy strategies that are leveling the playing field for it’s wildlife clients on Capitol Hill.  In 2014 we began to offer state level advocacy that has negated most of the legislative and regulatory initiatives pushed by HSUS and PeTA against our clients in state capitols across the country. Please follow ‘The Last Word on Wildlife’ for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the potential advantages of creating a comprehensive business/government affairs strategy, or a more targeted issue campaign, please call or email me.” — Andrew Wyatt

©Andrew Wyatt and The Last Word on Wildlife, 2018. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Andrew Wyatt and The Last Word on Wildlife with appropriate and specific direction to the original content. Material posted from guest writers is the sole intellectual property of the author. Please seek permission directly from the author prior to reproducing in whole or in part

U.S. Now Allows Elephants From Zimbabwe, Zambia To Be Imported

“It’s not too late to reverse restrictions imposed by the Obama Administration that were not based on facts and science.” — Andrew Wyatt

Hunt Forever

Elephants legally hunted in Zimbabwe and Zambia between 2016-2018 now can be imported into the United States, the U.S. Fish and Wildlife Service (FWS) announced today in Africa.

At the African Wildlife Consultative Forum (AWCF) co-hosted by Tanzania and Safari Club International Foundation, the FWS announced that it had made positive enhancement findings for elephants legally hunted in Zimbabwe and

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Animal Ambassadors: 21st Century Conservation — Doc Antle’s Tiger Tales

I attribute the perfect safety record here at TIGERS/RSF to the fact that we have evolved our zoological model to focus on socialization, training and rigorous enrichment opportunities. — Doc Antle, October 2017

Read more via Animal Ambassadors: 21st Century Conservation — Doc Antle’s Tiger Tales

The Elephant’s Armageddon: Part III


By guest writer Ron Thomson

THE GREAT ELEPHANT CENSUS (GEC) (Part One): Its faults and its foibles
The elephant population figures produced by Africa’s Great Elephant Census (2016) were just a list of numbers. The report did not record anything about the ecological management status of the elephant populations that were counted. For example, there was no information at all about the elephant carrying capacities of the habitats in which each population lived. So we have no idea which populations were SAFE, UNSAFE and/or EXCESSIVE.

This is a pity because a lot of people expended a lot of energy to produce the figures. But – whichever way you look at them – they are still just a bunch of numbers. And I lament the fact that “numbers” are seemingly all that matters in the present day and age! Certainly, whenever elephant numbers are up from previous counts – everybody rejoices. And they produce long faces when the numbers are “down”; and “poaching”- without any substantiation – is always blamed for any and all declines.

The census results indicate there were 352 271 elephants, ranging over 18 countries across Africa, in 2016. Nineteen countries were omitted from the census.  But, the scientists say that, statistically, the numbers counted represent 93 percent of Africa’s savannah elephants.  If that is so, then the total number of elephants in Africa now stands at 380 000. (An extra 28 000?)

The authors concluded that Africa’s savannah elephants had declined by 30 percent (equal to 144 000 elephants) between 2007 and 2014.  If these figures are true, this reflects an average annual net loss during that period of 20 571 per year; 56 per day; 2,3 per hour; or one every 26 minutes. The declines, the report concluded – without any substantiation – were “primarily due to poaching”. These facts paint a dismal picture at the start of the 21st Century, but let’s have a look at the whole story before we go ballistic.

“Poaching” was not defined in the report, and “the poachers” were not identified. To make any sense of what the report claimed, therefore, requires that we examine the history of Africa’s commercial elephant poaching pandemic.

During the 1970s and 1980s “the political elite” in Kenya were said to have been responsible for the reduction of elephant numbers in that country, from an estimated 275 000 (1970) to 20 000 (1989); the killing of ten thousand black rhinos; and the killing of thousands of several other species, such as zebra and colobus monkeys, for their skins.  Two village hunters, on one occasion, were arrested for having 26 000 colobus monkey skins in their possession. The day after their arrest they were released from prison when “official papers” (from the highest office in the land) were produced to indicate the hunters were in legal possession of the skins.

All the contraband was exported from Kenya’s east coast seaports directly to illegal markets in the Far East without any kind of CITES documentation; but with tacit presidential approval.

A similar tale emerges from Tanzania.  Between 1976 and 1986 the elephants of Tanzania’s Selous Game Reserve were reduced from 110 000 to 55 000 (ref. Dr Rolf Baldus; confirmed pers.com. 2017). And over a much longer period of time (1977 – 1993) Baldus claims that Tanzania’s elephant “poachers” reduced the overall elephant numbers, throughout Tanzania, from 365 000 to 53 000.   Baldus further reported:

The poaching had its roots in political and business circles in Tanzania, the villages bordering the SGR (Selous Game Reserve) and partly within the conservation system itself (i.e. government game rangers).

He goes on to say:

Village poachers and game scouts did the shooting, but ‘big people’ – politicians, civil servants, businessmen and even hunting operators – masterminded the slaughter.

In Zimbabwe and Zambia in the 1990s – similarly – the political elites of those countries were also involved in the slaughter of elephants and rhinos for their tusks and their horns.

I make mention of all these incidents to indicate a seemingly “politically acceptable” trend of massive elephant and rhino poaching events in East Africa, and south-central Africa, that were all orchestrated by the political elites and their cronies, during the latter three decades of the 20th Century.

All these events are “elephants in the room” that nobody, who values his life, talks about in Africa. Whistleblowers in Africa have a very short life expectancy! Yet everybody knows about these terrible events. And a great deal of this information, at the time, was reported in local and overseas newspapers. The involvement of the Kenyan president and his family – especially the First Lady Ngina Kenyatta – in the country’s poaching pandemic (1970s and 1980s) – was often, apparently, mentioned in the Kenyan parliament; and one individual who threatened to “expose it all” was murdered. And the British government knew all about what was happening.

Then, in the new millennium, the poaching started up all over again. Between 2008 and 2014 – 44 000 elephants were poached inside the Selous Game Reserve in Tanzania under circumstances that were entirely orchestrated by (as before) members of that country’s political, social and business elite; including the army and police. There was no serious attempt by the government to stop the poaching; and a lot of the poachers – the people who pulled the triggers – were reported (by Tanzanian residents “in the know”) to have been given immunity from prosecution.

As happened in Kenya, all the contraband was exported from Tanzania’s seaports directly to illegal markets in the Far East without any kind of CITES documentation; but also, it would appear, with tacit presidential approval.

At about the same time as the Selous slaughter, “tens of thousands” of elephants were reportedly also removed from northern Mozambique under the auspices of this same government-elite class of people in that country.

These latter two sets of poached elephants – the 44 000 (in the Selous) and “several tens of thousands” in the Niassa Province of Mozambique, are included in the 144 000 elephants that were recorded as having been killed “by poachers” (between 2007 and 2014) in the Great Elephant Census (GEC) Report.

The term “poacher” is not defined in the GEC, so it is left to the reader’s imagination to believe just what he wants to believe. The massive weight of continuous animal rights propaganda over the years, however, has seemingly convinced the whole world that elephant poaching in Africa is all controlled and organised by a mysterious “Chinese Mafia”; and the killing is carried out by “greedy” village poachers. So, I must suppose that that is what most people believe – because it is a statement that has been repeated many, many times since CITES 1989, and rarely refuted.

It is a huge, mischievous and criminal distortion of the truth to attribute the 144 000 “poached” elephants that were recorded in the GEC report, to Africa’s “greedy” village hunters; to the so-called Far Eastern poaching “mafia”; and/or to any other criminal elements in general African society – unless you include within this group those members of the political elite who orchestrated the really BIG poaching events in Africa’s recent history. So, the inferences made in the GEC report – that the poaching must come to a stop if Africa’s elephants have any chance of being saved – is VERY and, in my opinion purposefully, misleading. I believe that if you want to point fingers at the culprits in Africa, several of the continent’s political elites should be named, shamed and held accountable. They are the ones who are most responsible for the great losses of elephants and rhinos that Africa has suffered during the last fifty years. The big question that comes out of the GEC report is: WHO do we have to pressure to stop the poaching?

THE whole world needs to be told who we should be fighting, if it is truly everybody’s intention to stop commercial elephant poaching in Africa! In my book, Africa’s political elite are more to blame for the decline in elephant and rhino numbers in Africa, than any other single group of people. And the biggest link to the demise of Africa’s elephants is bad governance.

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Andrew Wyatt, of Vitello Consulting, is a government affairs and policy consultant dedicated exclusively to the wildlife sector.

WyattP1“The debate regarding trade in antique ivory in the U.S. is highly charged and contentious. I specialize in articulating clear policy ideas and getting them in front of key decision makers. Please follow ‘The Last Word on Wildlife’ for insight and analysis particular to the 21st century wildlife sector. If you would like to discuss the potential advantages of creating a comprehensive business/government affairs strategy, or a more targeted issue campaign, please call or email me.” — Andrew Wyatt

©Andrew Wyatt and The Last Word on Wildlife, 2017. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Andrew Wyatt and The Last Word on Wildlife with appropriate and specific direction to the original content. Material posted from guest writers is the sole intellectual property of the author. Please seek permission directly from the author prior to reproducing in whole or in part.

The Elephant’s Armageddon: Part II

top-bg-2By guest writer— Ron Thomson

I am going to jump in at the deep end and say that if world society carries on the way it is going at the moment, it is going to cause the extinction of the African elephant before the end of the current century. And the poachers are not the ones who are going to kill the species off. The supposed “do-gooders” in the Western World will achieve that milestone long before the poachers could ever do. Practically every elephant conservation proposal the developed world is trying to force on Africa will only exacerbate the elephant’s dire predicament. So – please – let’s consider the issues involved with an open mind and with some good common sense!

First of all, let me assure you that the elephant is NOT a so-called “endangered species” and it is NOT facing extinction. So don’t listen to the propaganda put out by the animal rights NGOs. They broadcast such emotional diatribe purely for the purpose of making money out of a gullible public. You must understand that the animal rights movement is a confidence industry which we will discuss in a later blog. Just remember, however, if you believe animal rights propaganda you have allowed yourself to be duped.

The so-called “endangered species” concept is a fallacy. Wild animals don’t organise themselves at the species level so the endangered “species” ideal has no application anywhere in the science of wildlife management.

A species can be defined as group of animals that share the same physical and behavioural characteristics (they look alike and they act alike) and which, when they breed, produce fertile offspring with the same physical and behavioural characteristic.

The common African Bush elephant – which is the main species we are concerned about – has 150 different populations in 37 countries across Africa. Each population – totally separate from any and all other populations – lives in its own unique habitat; and the environmental conditions that apply to each such population are unique to that population. Some populations live in montane forests; others in grasslands; others in grassland savannahs; others in various kinds of woodlands; others in thick bush; others in swamps; and yet others in deserts. Some occur in areas of high rainfall. Others live in areas of very low rainfall.

A population can be defined as a group of animals of the same species, the individuals of which interact with each other, in continuum, on a daily basis; and which breed only with other animals in the same group.

Some elephant populations in Africa are “SAFE”. This means they occur in good numbers, consistent with the carrying capacities of their habitats. Safe populations are healthy; their habitats are healthy; and they breed well. Such populations require “conservation” management which means they are able to sustain a high level of sustainable utilisation. They should be culled every year in numbers equivalent to the rate of their respective annual increments. This is necessary to make sure SAFE populations do not become “EXCESSIVE”. (See below).

Some populations are “UNSAFE”. They are low in number and not breeding well. Their numbers are declining and the reasons for these bad situations cannot be ascertained or reversed. These animals face possible local extinction. They require “preservation” management – protection from all harm.

Other populations are “EXCESSIVE”. This means their numbers are above (often grossly above) the carrying capacities of their habitats. Most excessive populations are breeding well – adding to the problem of over-population. Their habitats, however, have been trashed over the years and they continue to be degraded annually. Many such habitats are unrecognisable compared to what they looked like 50 years ago. The biological diversities of such habitats are deteriorating all the time; many have suffered the local extinction of both plant and animal species; and a lot more species are seriously threatened. If the numbers of elephants in such populations are not reduced in number – drastically and quickly – the game reserves that support them will become deserts. In many, desertification is already well advanced. Excessive populations require immediate population reduction management.

What I am trying to convey here is that the environmental pressures being exerted on Africa’s 150 different elephant populations are unique to each population. No two are the same; and they are sometimes chalk-and-cheese different. There is no “one size fits all” management application. So Africa’s 150 elephant populations need 150 different management strategies, each one custom-designed to fit the needs of each specific population.

Now we can discuss the “endangered species” concept. Just where, within this conundrum, can this idea fit into the elephant management equation? It can’t – anywhere. The very title – “endangered” – conveys the idea that each and every elephant population in Africa is UNSAFE; that it is declining; that it is not breeding well; and that it should be managed according to the “preservation management” principle ONLY. And preservation management requires that every single elephant should be protected from all harm. And that is clearly not what is required at all.

When the elephant was declared to be an “endangered species” at CITES 1979 – a decision which was pushed through with brutal force by every animal rights organisation in creation – the world actually imposed MIS-management on every SAFE and EXCESSIVE elephant population in Africa. And demanding the MIS-management of an animal species population, under any circumstances, is NOT in the best interests of the species concerned; nor of the habitats that support them; and also not in the interests of maintaining species diversity in their sanctuaries.

It is necessary to record here that most of the “elephant range states” at CITES in 1979 voted against having the elephant placed on the endangered species list (Appendix 1) that year, but their opinions were ignored. Surely the opinions of the elephant management experts who live in the range states in Africa – who know more about elephants and their management needs than anybody else – should have held more water than the opinions of the animal rights organisations that are based in Washington DC, London or Paris? But the animal rightists won the day on that occasion – and they have continued to push their luck at every CITES meeting ever since.

It is because of incidents like this that the animal rightist NGOs – and their fellow travellers in the powerful governments of the First World – are going to cause the demise of the African elephant in Africa.

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Question and answer with Ron Thomson and Andrew Wyatt

AW: Your article implies that African elephants are designated as “endangered species.” They are actually designated “vulnerable” by IUCN. Why is there so much confusion about the designation?
RT: Many in the public domain call elephants an “endangered species”, so that is the preception the public has and the public cannot understand how ANYONE can kill an “endangered species”.  Surely when a species is declared to be “endangered” its needs 100 protection? And governments don’t like opposing public perceptions!

AW: U.S. Fish and Wildlife Service designates African elephants as “threatened” under the Endangered Species Act, but not “endangered.” Why is there so much incongruity in the discussion?
RT: Discussion in the public domain with FWS officials, reveals they often speak of species (many species – including the African elephant) as being “endangered” – and they never deny any statement by anyone who proclaims ANY species to be “endangered” when it is not. Officials – including Barack Obama in the USA – regularly referred to elephants as being “endangered.”  I suspect they actually welcome the public’s mis-interpretation because it is easier for the officials to drive home their insistence that “their” extra-protection purpose needs radical acceptance.

AW: Why are some populations of elephants listed CITES Appendix I, implying endangered status?
RT: Every animal rights NGO delegate that attends CITES meetings – when talking about the elephant – infers that the convention is dealing with an “endangered species”.  And within the CITES debates (which are TOTALLY swamped by animal rightist delegates) they purposefully use no other term than “endangered” – which the media picks up and disseminates into the public domain . And that is, perhaps, understandable.  CITES, after all, is an acronym for “Convention on International Trade in Endangered Species“.   And when the elephant was placed on the Appendix 1 list of CITES, the media – all over the world – referred to the elephant as being “an endangered species” (which they picked up from the animal rights propaganda).  Furthermore, NOBODY corrected that interpretation – not the IUCN; not WWF; & not FWS.  That perception cannot now be shaken..  In the public mind – constantly reinforced in all animal rights propaganda – and by the media world-wide – the elephant IS “an endangered species.”

AW: Would you care to continue your clarification regarding the non-uniformity across NGO’s and government entities in referring to elephants as “endangered?”
RT: Sure, I will clarify – but understand that the media’s, the public’s and general governmental perceptions are now so heavily skewed that even my explanation may not be acceptable – even to you!  Many people/ organisations have different (their own) interpretations of what constitutes an “endangered species” – which adds to the confusion.  In the public mind, however, the term “endangered species” denotes or implies “facing extinction“.   And the media’s projection of “endangered species” in wildlife has a lot to with that.  So has the animal rightists’ propaganda – which uses the endangered species concept as its main means of stirring up public emotions (and makes them more fraudulently-acquired money than anything else).  If you take the trouble to examine every piece of animal rights propaganda that you are exposed to, you will quickly see that “EVERY LIVING THING” is classified by them as being “endangered”.

All this renders public acceptance of “REALITY” almost impossible – and the REALITY is that no species is “threatened with extinction” until its VERY LAST POPULATION is declining and the reasons for the decline cannot be arrested.  The northern white rhino is a good candidate for what represents a REAL endangered species – with only four individuals still alive (three females and one male – and the male is beyond breeding).  REALITY is that even official and august bodies like the IUCN, WWF and USF&WS TALKabout “endangered species”.  The USF&WS even enacts a law called the “Endangered Species Act” (ESA) – when, in fact, the concept of “endangered species” has no application at all within the general principles and practices of Wildlife Management (a.k.a. {eroneously} “CONSERVATION”) – except in those very rare examples such as the current sad status of the Northern White Rhino. So the USF&WS is guilty of perpetuating the myth, too.

All these official “acceptances” of the endangered species concept leads the public away for REALITY.  And this is NOT just a game of semantics.  I wish it were!  With respect to Africa’s elephants we are actually talking about the practical survival management of the species – the elephant; the survival of whole ecosystems (Africa’s national parks); and the survival of the bulk of Africa’ s current wildlife species diversity (plants AND animals).  The survival of all these things – depends not only on stopping the poaching, but ALSO (perhaps more-so, in the case of southern Africa) upon Africa’s EXCESSIVE elephant populations being drastically REDUCED in number. In southern Africa every single one of the elephant populations – HALF of today’s entire extant elephant numbers – fall into the category of being EXCESSIVE.  And they need to be urgently reduced in number (for the sake of the elephant; for the sake of Africa’s National Parks; and for the sake of the maintenance of Africa’s wildlife species diversity).  THIS is REALITY.

Now how is such a “best practice” management programme going to be possible when everybody in creation believes in the concept of “endangered species”.  If only people would start believing in the fact that wildlife cannot be “managed” at the species level; only at the population level; and that a species’ (ANY species) many populations comprise those that are SAFE, UNSAFE and EXCESSIVE, would the general public begin to understand the wisdom and principles of wildlife management.  And they have to understand that every single one of Africa’s elephant populations need to managed separately according to their individual environmental circumstances.  When the “endangered species” ideal is applied to the elephant in Africa it results in MIS-management – which is the last thing Africa needs.  It is the last thing that the elephant needs – the total protection of ALL populations of elephants on the entire continent irrespective of what their true population status is.

Everyone needs to be led into the very serious understanding that Africa’s national parks were set aside to preserve the integrity of the national parks’ biological diversities.  THAT is the parks’ Number ONE wildlife management objective.  And THAT should be everybody’s priority consideration! As much as I love Africa’s elephants, I love Africa’s biological diversity more.  The parks were NOT set aside for the uncontrolled proliferation of elephants – and the whole world needs to understand this.  In many of Africa’s national parks (especially in southern Africa) too many elephants are destroying the very reason why the national parks were set aside in the first place.   And explaining all THIS is the whole purpose of me sending those blogs to you in the first place.

It is very clear to me that the whole world is demanding of Africa that it maintains elephants in numbers that its national parks simply CANNOT sustainably support.  Excessive elephant populations cannot be maintained indefinitely.  Sooner rather than later, the park ecosystems will collapse.  And when they do crash the massive elephant herds we see in these game reserves today, will crash with them. And in one drought year, the world will lose tens of thousands of elephants – BECAUSE they have been “over-protected”.   And they will lose billions of plant and animal species BECAUSE world society has not allowed Africa’s national parks to be properly managed. The reality is that southern Africa is carrying far too many elephants already – and the effects of what amounts to terrible and prolonged mis-management are already becoming manifest.  South Africa’s Kruger National Park, for example, has lost MORE THAN 95 percent of its vitally important top canopy trees because it has been carrying far too many elephants for far too long; and the damage continues unabated. Even if you are not a biologist; not an ecologist; and not a qualified wildlife manager – but just an ordinary intelligent member of society – the ultimate disaster that looms must be obvious.

So, if the public really wants to save Africa’s elephants, I propose that – instead of creating a huge furore every time an elephant is killed by a hunter – or culled by a game ranger –  that the general public start petitions to raise funds for the purchase of extra land in Africa where elephants can be maintained in symbiotic harmony with Africa’s rural people.  Symbiotic harmony means the elephants will be “used” sustainably for the benefit of Africa’s rural communities – because THAT is the ONLY way to secure a future for elephant in Africa into posterity.