Trophy Hunting and Conservation Science

pride lion

photo: Hilton

“The truth is rarely pure and never simple.”― Oscar Wilde

Washington, D.C.— Few things stoke the fires of emotion like the idea of endangered species dying unnecessarily. The African lion, one of the most iconic species on the planet, has become a symbol of conservation worldwide. But while Disney’s The Lion King personalizes an anthropomorphic view of animals in the American psyche, the debate on how best to conserve lions and other threatened species is not always consistent with pop culture notions. The science vs emotionalism debate is guaranteed to heat up with the recent introduction of the Prohibiting Threatened and Endangered Creature Trophies Act of 2019 (ProTECT) Act (H.R. 4804) to the U.S. House of Representatives by Texas Democrat, Sheila Jackson-Lee. It has been assigned to the House Committee on Natural Resources.

H.R. 4804 not only seeks to prevent the hunting of lions or any species listed as endangered or threatened under the Endangered Species Act (ESA), but would undermine captive breeding projects that were exempted from ESA by the Obama Administration; projects that have successfully saved the scimitar-horned oryx, and other endangered hoof stock from extinction— returning them to the African savannah.

“As human-lion contact increases, so does human-lion conflict, resulting in reductions in lion numbers (through poisoning, trapping and shooting) and lack of support for lion conservation among local communities.” ~ IUCN SSC Cat Specialist Group

While the debate in Washington regarding the best way to conserve wildlife continues, animal rights groups stoke the fires of emotionalism surrounding H.R. 4804, cultivating an irrational hatred for hunters on social media pages. Despite the rhetorical hyperbole, real conservation deserves a fair understanding of the facts.

All agree that populations of lions have declined significantly. According to a study authored by Professor Stuart Pimm of Duke University in 2012, about 75 percent of Africa’s savannahs and more than two-thirds of the lion population once estimated to live there have disappeared in the last 50 years. There are likely between 32,000 and 35,000 free ranging lions on the African continent today. According to professor Pimm, “massive land-use change and deforestation, driven by rapid human population growth” is the primary reason for the decline of the lion. This same human-wildlife conflict dynamic holds true as the primary threat to other listed species as well.

Sixty percent of big game hunted in Africa are destined for trophy rooms in the United States. Proponents of the ProTECT Act say allowing hunters to export trophies back to the U.S. sends the wrong conservation message. They say lions and other listed species would be best conserved by blocking access to American hunters, thereby reducing pressure on populations.

Jeff Flocken of the International Fund for Animal Welfare (IFAW) once wrote, “Why should anyone spend money to protect an animal that a wealthy American can then pay to go kill?” Mr. Flocken characterized his argument as common sense, but acknowledged that, habitat loss and human-lion conflict, not hunting, are the primary causes of the lions’ disappearance from Africa.

In August 2019, Science magazine published an open letter, “Trophy hunting bans imperil biodiversity,” led by five scientists from Oxford University’s Wildlife Conservation Research Unit and the International Union for Conservation of Nature (IUCN), and signed by 128 more. The letter stated that hunting has many positive impacts on conservation, and Amy Dickman, one of the letter’s lead authors, appeared on the BBC, where she stated that imposing a complete trophy hunting ban is likely to cause “more animals to die.”

Kitty Block, CEO of the Humane Society of the United States (HSUS), is critical of of the Science letter. She argues that the scientists who signed the letter should be ignored, implying that there is a conflict of interest because some have received conservation dollars derived from hunting interests to help pay for their research. Ms. Block calls the research money a corrupting influence, resulting in what she refers to as, “a web of lies.”

“For years now, trophy hunters have spun a web of lies to tie their ruthless killing of some of the world’s most at-risk animals to fake conservation benefits.”— Kitty Block, CEO HSUS, October 30, 2019

It is absolutely essential that local communities identify the presence of lions and other wildlife as a direct benefit to them. Reducing human-wildlife conflict is critical to conservation success. According to Dennis Ikanda, of the Tanzania Wildlife Research Institute’s Kingupira Research Centre, his country generated $75 million in lion hunting from 2008 to 2011. Opponents of the ProTECT Act assert that trophy hunting is the only thing standing between the lions and extinction. Although those claims may seem counter intuitive, the money generated by hunting is being plowed back into the local economy, into conservation measures, and into protecting lions from poaching. Hunting advocates say the only chance for survival of the lions is management as a valuable and sustainable natural resource.

Although the idea of trophy hunting does not enjoy wide popularity, its value as a pragmatic conservation tool has proven to have great merit. The questions are: 1) will a hunting ban relieve pressure on threatened animal populations? or 2) will public policy ignore scientific evidence, and remove economic incentives necessary to protect valuable wildlife resources?

Animal rights advocates completely dismiss the conservation benefits of hunting. They value protecting individual animals over actions that favor preservation of species. However, a study of trophy hunting by the University of Zimbabwe supports claims of conservation success tied to responsible hunting practices. Peter Lindsey, the lead author of the study, wrote, “trophy hunting is sustainable and low risk if well managed.” Lindsey continued, “Trophy hunting was banned in Kenya in 1977, in Tanzania during 1973–1978, and in Zambia from 2000 through 2003. Each of these bans resulted in an accelerated loss of wildlife due to the removal of incentives for conservation. Avoiding future bans is thus vital for conservation.” When local communities are not incentivized to protect lions they are subsequently killed.

To date there appears to be no clear evidence that would support the premise that banning Americans from trophy hunting would inure conservation benefit to wildlife in Africa. To the contrary, banning hunting could undermine real conservation efforts by diminishing the value of lions and other listed species to local African communities. Remove economic incentives and conservation dollars, and you remove the only thing holding back the tide of human population growth and habitat destruction that is overwhelming the once prolific lion.

“…conservation policy that is not based on science threatens habitat and biodiversity.”— Amy Dickman, University of Oxford

Trophy hunting is by no means a perfect solution, but the IUCN Cat Specialists Group says, “Properly managed trophy hunting was viewed as an important solution to long-term lion conservation.” There will always be some abuse from unscrupulous individuals. But the monetary incentive to mange sustainable populations for hunting is the only protection lions currently have. Removing economic incentive for Africans to conserve lions has been demonstrated to be disastrous. Until a better conservation model proves it’s mettle, responsibly managed hunts are the best chance for lions and other species to survive the human population explosion in Africa.


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 former National Security Advisor John Bolton in the “Green Room” at FOX & Friends

“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, 2019. 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.

H.R. 6362: Injurious Wildlife Revisited

Burm_2018

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.

(e) PREVIOUSLY LISTED INJURIOUS SPECIES.—

(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.

SEC. 8. PERMITS.

(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.

Conclusion
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…

SEC. 7. PROHIBITIONS.
      (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.