On Thursday, October 16, Conservation Force submitted a 34-page comment critiquing the FWS's July 22, 2014 negative enhancement finding for the import of tourist-hunted elephant trophies from Zimbabwe.

As explained in the comment, the enhancement finding is not based on the best available information. It did not consider the vast majority of documents submitted by Conservation Force, the Zimbabwe Parks and Wildlife Management Authority, and the CAMPFIRE Association after the trophy import suspension was announced on April 4, 2014.

John Jackson, President of Conservation Force, noted that "more than enough documentation was furnished to refute the anecdotal information cited by FWS to impose the suspension." Mr. Jackson pointed to the binders of documents submitted to FWS by Conservation Force on June 6 and the stacks of documents submitted by the Parks and Wildlife Management Authority, and said: "Enhancement has been shown. FWS may wish to ignore the evidence, but the benefits of tourist hunting to Zimbabwe's elephant conservation strategy, the significant revenue generated by tourist hunting which is then shared with local communities who are impacted by elephant, and the substantial anti-poaching contributions of hunting operators which have kept poaching in Zimbabwe low and allowed elephant to thrive - these benefits to the elephant speak for themselves."

Conservation Force's comment breaks down the enhancement finding by subheading and highlights re-used language, misreported information, or instances where significant, up-to-date data was not reviewed or considered, concluding that the enhancement finding does not satisfy the FWS's obligations under the Endangered Species Act or the Administrative Procedures Act.

Among other things, Conservation Force's comment demonstrates:

- Management Plans: The enhancement finding's emphasis on a national management plan ignores the structure of wildlife management authority in Zimbabwe. Authority to adaptively manage elephant and other wildlife has been devolved to private landowners and rural district councils - this is Zimbabwe's strategy for elephant management. At the same time, the finding never considers or acknowledges that Zimbabwe is responding to international concerns and holding a workshop to update its elephant management plan in December.

- Population Status: The enhancement finding re-uses language from the April 17 interim finding and fails to review or consider updated estimates provided by Conservation Force and the Parks and Wildlife Management Authority. These documents show Zimbabwe's elephant population has been surveyed repeatedly in the past ten years, and is growing. Instead of considering best-available data, the finding over-relied on the AfESG Elephant Database. The database is a valuable source but incomplete - it is not up-to-date and does not incorporate all surveys and censuses provided to FWS by Conservation Force and the Authority. Further, the finding's edicts on technology that should be used in Zimbabwe's current national survey shows FWS is out-of-touch with international survey standards and the substantial forward progress of the Great Elephant Census.

- Regulations and Enforcement: The best available information shows that the Parks and Wildlife Management Authority has effectively managed elephant in Zimbabwe for decades, with support from Zimbabwe's hunting operators. These operators make a considerable difference in the war against poaching and have kept poaching in Zimbabwe fairly low as compared to the rest of Africa. The asserted lack of data provided to FWS is baseless and indicates only that FWS failed to review provided documents or did not ask for specific data.

- Sustainable Use: The Parks and Wildlife Management Authority provided exactly the data, especially quota-setting information, which FWS requested. Conservation Force submitted additional data showing the negligible effect of tourist hunting on elephant population growth. The enhancement finding does not consider or counter this information but rather relies on undisclosed "anecdote" to implausibly conclude that an offtake of far less than 500 elephant a year - in a population of over 90,000 - is unsustainable.

- Revenue Utilization: The "updated" enhancement finding's almost verbatim reuse of 17-year-old language, without acknowledging that it comes from a positive finding, raises concern about the finding's quality and credibility. Coupled with its complete inattention to a report from the CAMPFIRE Association cataloguing the wealth of benefits tourist hunting revenue supplies to local communities who are impacted by elephant, the July 22 enhancement finding analysis is clearly capricious. The enhancement finding ignores the CAMPFIRE Association report, which demonstrates, with citations to source documents - unlike the finding - that tourist hunting benefits over one million people in Zimbabwe.

- Local Conservation Efforts: The finding mislabels a number of documents submitted by Conservation Force. It also fails to appreciate that the government has created a mechanism to promote and sustain local conservation efforts in Zimbabwe - the devolution of authority to manage and benefit from wildlife populations at the local level. FWS's inability to appreciate the

- Enhancement Is Irrefutable and Irreplaceable: Through its June 6 comment and its October 16 comment, Conservation Force has submitted tens of documents showing the benefits tourist hunting generate for the elephant species by supporting conservation and anti-poaching programs and reducing human-elephant conflicts. Using an example of just one hunting operator, Conservation Force demonstrated significant financial and in-kind benefits - and showed the considerable impact a continuing trophy import ban will have on decreasing these benefits. As stated by one of Conservation Force's partners: "in 2015 ... what happens? Do the local communities lose 35 or 40% of their revenue and do we disband the Dande Anti-Poaching Unit and let the elephant poaching get back out of control, until such time there are no elephants and therefore no problem? For certain, we do know that we simply cannot afford to continue being responsible stewards of 500,000 acres without the income received from elephant hunting. It is also unfair and unrealistic for the US to expect poor rural communities to starve and lose their crops to elephants that will hold little or no value to them at all...."


Jackson summarized Conservation Force's position: "The suspension jeopardizes the longstanding enhancement generated by tourist hunting. Zimbabwe's elephant and conservation strategy largely depend on the revenue and incentives that come from a limited hunting offtake and trade, particularly since Zimbabwe's hope for any other trade to give its elephant economic value appears more and more unlikely. We are concerned that little reason remains for Zimbabwe to maintain a large and costly elephant population, and we ask who will bear the costs of protection, management, and habitat for over 90,000 elephant in Zimbabwe if hunters are not there to do it."

For more information, please visit www.conservationforce.org or contact John J. Jackson at cf@conservationforce.org or by phone at (504) 837-1233.


Our purpose is to establish and further conservation of wildlife, wild places and our outdoor way of life. Conservation Force stands for three forces. First, that hunters and anglers are an indispensable and essential force for wildlife conservation. Second, that Conservation Force is a collaborative effort combining forces of a consortium of organizations and, third, that Conservation Force itself is a proactive force to be reckoned with because of its record of conservation successes.

http://www.huntingreport.com/c...ion_force.cfm?id=336



Revealed: USFWS “Information” that “Poaching Levels are Increasing” in Zimbabwe are Merely News Articles and Anecdotal Reports
Written By John J. Jackson III, Conservation Force Chairman & President
(posted November 2014)

By Regina Lennox, Staff Attorney


We are concerned that USFWS is sustaining the Zimbabwe trophy import ban on the worst available information: news articles and unsubstantiated reports from a "conservation task force" in Zimbabwe that is known to rely on false information.

In early August, we received a letter sent to a partner organization, dated August 5, and signed by the Principal Deputy Assistant Secretary for Fish and Wildlife and Parks. The letter responds to concerns about the elephant trophy import suspensions and states in part (with added emphasis):

For Zimbabwe, the picture is less clear, but we have information that indicates the situation there may be deteriorating and that elephant numbers are being reduced by widespread poaching. Although, as you stated in your letter, representatives of the Government of Zimbabwe have asserted that elephant populations there are increasing, there is information to the contrary, and while they have provided a considerable amount of documentation about their elephant and conservation programs, there is no data to refute the information that the Service has from other sources to indicate that poaching levels are increasing.

On August 19, Conservation Force sent a Freedom of Information Act request to USFWS seeking documents to support the Principal Deputy Assistant Secretary's concern about increased poaching and a "deteriorating situation." We asked for expedited treatment of this request based on the public's right to know and duty to act. If the USFWS really has significant new information of a poaching crisis in Zimbabwe, it is their duty to share it. USFWS failed to respond to the FOIA request or provide expedited treatment. On September 9, we re-sent the FOIA. We heard nothing until we sent yet another reminder on October 17. Then we finally received an email response stating that "all of the documents you are requesting … were provided with previous FOIA requests," and a subsequent letter confirming "the Division of Management Authority has reviewed our files and was unable to locate any records responsive to your request." (The FOIA was not directed to the DMA, but was rather sent to the Principal Deputy Assistant Secretary and Assistant Director for International Affairs.)

And here's the rub. USFWS has not previously produced information on a poaching crisis in Zimbabwe. Apparently, USFWS does not have information about a "deteriorating situation" or "widespread poaching" there. The press release that elephant were under "siege" was wholly uninformed. The absence of any hard evidence calls into question the trophy import ban, and the USFWS's credibility.

In several productions in response to FOIA requests, USFWS has provided a collection of news articles and email dating back from 2002-2006. These documents describe poaching in Zimbabwe eight to ten years ago, in a period of heightened political turmoil. USFWS also produced CITES and TRAFFIC reports warning of increased illegal killing and trade which cover all of Africa (and sometimes Asia) and date to CoP15 and CoP16 (Conference of the Parties to CITES). Finally, USFWS produced a handful of articles from late 2013/early 2014 describing the Hwange poisoning tragedy. A few of these report the number of elephant poisoned as fewer than 90; others put the number somewhere between 200 and 300. Most of these articles quote the head of the "Zimbabwe Conservation Task Force," Johnny Rodrigues, who is not well-known or well-regarded among scientists and conservationists for good reason. In a 2002 email from the USFWS productions to Conservation Force, a WWF specialist noted - and told USFWS - he had not heard of Mr. Rodrigues, but Mr. Rodrigues was claiming to have a "report on his desk" about a poaching crisis in a Zimbabwe conservancy that did not exist. In other words, USFWS has known since 2002 that information from the "Zimbabwe Conservation Task Force" is suspect and not respected by experts in the field, including WWF. (Conservation Force is pleased to share the USFWS's responses and productions upon request.)

A Principal Deputy Assistant Secretary has put in writing that USFWS has information about increased poaching in Zimbabwe which trumps the Government of Zimbabwe's information. But apparently USFWS has only news accounts. USFWS continues to rely on these accounts, even though the Principal Deputy Assistant Secretary's letter is dated after the Zimbabwe Parks Authority responded to an USFWS questionnaire and updated the USFWS on the status of the Hwange poisoning (and poaching in Zimbabwe in general), and after Conservation Force submitted its comment on the April enhancement determination, documenting that poaching in Zimbabwe is fairly well-controlled. It is disappointing and deeply troubling that USFWS continues to base the trophy import ban - which reduces the benefits available to elephant from tourist hunting - on unsubstantiated, anecdotal, and ultimately false reports.

What a mess. Typical