We will be discussing this Periodic Review with CITES authorities soon, but meanwhile wanted to let all of you know the content of our report. Your assistance could be needed to put pressure on the Animals Committee and your CITES representatives to urge that this draft Periodic Review is rejected and sent back to the authors for significant modification.
Under the auspices of the Plants and Animals Committees of CITES, certain species can be included in “Periodic Reviews” to satisfy the Convention that species are appropriately listed, based on up-to-date population information and an assessment of sustainability of current levels of trade.
In the case of the African lion, the CITES Animals Committee approved the Periodic Review for African lions in July 2011, and Kenya and Namibia volunteered to conduct the review. Kenya and Namibia began consulting African lion range states in October 27 2011 with a deadline for input of December 27, 2011. Kenya and Namibia have now, 28 months later, produced the draft of the Periodic Review for the 27th meeting of the Animals Committee in Veracruz, Mexico (April 28-May 3, 2014).
A total of 15 lion range states made submissions (Benin, Central African Republic, Cote D’Ivoire, Gabon, Kenya, Malawi, Mozambique, Nigeria, Namibia, Rwanda, South Africa, South Sudan, Tanzania, Zambia and Zimbabwe). Of those 15 states, lions are known to be extinct in Cote D’Ivoire and Gabon, virtually extinct in Malawi, Nigeria and Rwanda, and of unknown population size in South Sudan. Yet the title of the report is “CITES Periodic Review of the Status of African Lion Range Across Its Range”?
2. Overview and Criticism
As a general statement, the report is internally inconsistent and extremely outdated in sections. Given that the report has only recently been submitted, much more emerging information could have been included that could have made the report both stronger and much more relevant to the current status of lions. Data recently emerging is especially relevant to the critical status of western African lions but also concerns the trade of captive-bred lions in South Africa. In some cases newer information is included, but such data is highly selective.
2.1 Criticism of data used
- The report uses data from the UNEP-WCMC CITES trade database, but the only data used was from 1999-2008 (the Appendices, in contrast, list information from 2000-2009 but this data was not used in drawing conclusions). Inferences about the appropriateness of lion listings are therefore based on data almost six years old. This is NOT acceptable.
- The report mentions, based on IUCN Red List data, that the African lion occurs in “30 countries excluding a few countries with uncertain status”. That information was published in the Red List in 2008 but was actually gathered in 2006 and is therefore about eight years old. This is NOT acceptable. In actual fact, the true situation concerning lion distributions is as follows: Of the 49 continental African countries the lion is extinct in 25 countries, existing as small, scattered and highly vulnerable populations in eight countries, perhaps existing as unknown populations in two countries, and known to be present in 14 countries. This actual distribution of lions is very different than that presented in the report, and much more accurately reflects the current status of lions in Africa.
- The population size is listed as 23,000 to 39,000 lions in Africa based on questionnaires sent out over 12 years ago, and between 32,000 and 35,000 based on a remote sensing/satellite survey of savanna habitats and extrapolation of lion populations into “suitable” areas (Riggio et al., 2013). The authors of that report themselves mention that the detection of savanna habitats does not imply there are lions there, and mention that many such habitats are extensively used for livestock grazing (Riggio et al., op cit). The IUCN in 2006 estimated a maximum population of 36,000 lions. However, The IUCN estimate was based largely on “information” from delegates at two meetings – Yaounde, Cameroon for western and central African delegates and Johannesburg, South Africa for eastern and southern African delegates.
- The Yaounde delegates estimated a maximum of 1,920 lions in western Africa. More recent estimates based on more reliable surveys indicate the total population is about 400 (Henschel et al., 2010, 2014). The Yaounde delegates, for example, estimated the population of Niokolo-Guinee at 500 – 1000 lions, but recent surveys suggest that <20 lions remain. The Yaounde delegates also estimated a total of 2,050 lions in central Africa. More recent estimates indicate that perhaps 630 lions remain. The Yaounde delegates estimated the Chad-RCA population to number over 1,000 animals, whereas more recent estimates from this politically highly unstable area involved in a significant amount of civil strife suggest that optimistically 400 lions remain. In sum, the IUCN delegates estimated a total of 3,970 lions in western and central Africa – more recent and reliable estimates put the combined total at perhaps 1,030 lions. Surveys undertaken in 2010 and 2014 concluded that lions were extinct in 13 of 20 Lion Conservation Units identified by the Yaounde delegates, and probably had been for some time (Henschel et al, op cit). The report mentions that the IUCN lists western African lions as regionally endangered, but the official Red List page on lions shows no such increased concern. The report neglects to mention that in western Africa, lions now only occupy 1% of their historic range.
- The Johannesburg delegates estimated between 27,000 and 32,000 lions remaining in eastern and southern Africa. This estimate included highly speculative lion populations in Somalian war zones, significant populations in South Sudan currently subjected to enormous civil strife, significant populations in Angola that have never been adequately assessed, and a population of no less that 5,500 lions in the Selous region in Tanzania, the location of unprecedented elephant population declines due to very heavy poaching, reducing the elephant population by over 80% since 2007.
- A more sober assessment of remaining lion populations in eastern and southern Africa was undertaken by LionAid (December 2012) incorporating factors like % of human population involved in agriculture, % of population living below the poverty estimate of $1.25/day, the Failed States Index, the Human Development Index, the Corruption Perception Index, and presence of an effective government department charged with wildlife protection. Given that information, more current information from remaining lion populations in range states like Kenya, Uganda, Zambia, Ethiopia and Tanzania, an assessment of the impact of civil strife, as well as an assessment of trophy hunting export declines as an indirect method of determining numbers of adult male lions remaining in protected areas designated as hunting concessions, our considered assessment is that not more than 14,500 lions remain in the region.
2.2 Internal inconsistencies.
- Given the long delays before the Periodic Review of African lions reached any semblance of readiness to be presented in draft form to the 27th Meeting of the Animals Committee, it is surprising that the authors could not present a more cohesive report.
- For example, throughout the report mention is made that lion hunting trophies constitute the largest category of commercial trade. Mention is also made that range states like Kenya and Botswana have banned trophy hunting of lions due to concerns over the effects and lack of sustainability of the practice. No mention is made of several studies conducted in Benin, Cameroon, Tanzania, Zambia and Zimbabwe that indicate strong negative consequences of trophy hunting on lion population size and structure (Sogbohoussou et al., 2014, Croes et al., 2011; Packer et al., 2011; Yamazaki 1996; Loveridge et al., 2007). No mention is made that Zambia placed a recent moratorium on trophy hunting of lions (and leopards) at the start of 2013 due to similar concerns and the total confusion about the number of lions in the country, that Uganda banned the practice many years ago, that Cameroon has for the last four years declined to issue export permits for lion trophies, and that Ethiopia has had sufficient concern about trophy hunting to only issue a handful of permits over the ten years 2003-2012.
- Yet on p8 of the report, it is stated that “It is very important to note that in some countries in southern and Eastern Africa, restrictions on lion hunting would affect the overall profitability of trophy hunting and thus reduce the competitiveness of wildlife-based land uses relative to alternatives such as livestock production. In addition to the potential loss of habitat, restrictions on lion hunting could potentially reduce the tolerance of communities in some areas. Restrictions on lion hunting may also reduce the funds available for management activities such as anti-poaching and community outreach. Such restrictions would also weaken the justification for setting aside the extensive areas gazetted as hunting areas acting as buffer zones of National Parks and ecological corridors between National parks, thus exposing these areas to the risk of conversion to non-wildlife-based land uses such as agriculture and livestock rangeland.” This is unmitigated pro-trophy hunting propaganda that has no place in any Periodic Review. It is an opinion statement without any scientific reference or credence.
- In direct contrast to that statement on p8, the report on p14 states: “The high demand for lion trophies has caused trophy offtakes to be too high in most countries. This has been explicitly recognized in Botswana (which banned lion sport hunting from 2001 - 2005 and again in 2007 - 2009), Zambia (banning lion hunting in 2000 - 2001 and halving their quotas in 2009), Zimbabwe (banning lion hunting in the western part of the country 2005 - 2008) and Mozambique (reducing quotas in Niassa Reserve in 2009). Recently Tanzania has taken measures to limit lion offtakes to males that are at least 6 years of age. However, most of these responses came after dramatic declines in lion harvests that resulted from over-hunting. Given the overall rarity of the species and its extreme sensitivity to habitat loss and problem animal conflict, hunting offtakes should be monitored far more closely so as to minimize the impact of international trade.”
- The statement on p8 also ignores that Zambia placed an indefinite moratorium on lion trophy hunting in January 2013 due to concerns about a rapidly declining lion population, that Uganda has a complete ban on lion hunting, and that both Kenya and Botswana have banned trophy hunting of all species.
- On page 17, the report states: “The leading major threats across lion range are recognized by each lion range state to be habitat loss and retaliatory killing, and not international trade”. That statement contradicts what was said on page 14 (…hunting should be monitored much more closely … to minimize the impact of international trade) and what is said consistently throughout the report – that hunting trophies form the largest part of commercial trade. In addition, that statement, mentioning “…recognized by each lion range state…” is misleading as the report is materially based on replies of 15 lion “range” states – and as mentioned above, of those 15, lions are known to be extinct in Cote D’Ivoire and Gabon, virtually extinct in Malawi, Nigeria and Rwanda, and of unknown population size in South Sudan. It is noteworthy that range states with either significant and/or regionally important lion populations like Uganda, Ethiopia, Cameroon, Burkina Faso, Chad and Botswana did not reply to requests for information. Therefore the report can hardly claim to represent “…each lion range state…”
2.3 Factual errors and errors of omission
- The report mentions several times that there have been significant declines in lion populations remaining in western Africa and central Africa. The report does not mention that these populations are highly significantly genetically different from those in southern and eastern Africa, and more closely resemble the remaining population of lions in India. As a consequence, there have been recent calls (based on genetics and morphology) to revise the taxonomy of lions and/or at least recognize western and central African lion populations as distinct and highly threatened “Evolutionarily Significant Units” requiring appropriate additional conservation consideration (Dubach et al, 2005; Barnett et al., 2006a, 2006b; Bertola et al, 2011, Dubach et al, 2013, Barnett et al, 2014). Omission of any mention of such highly important biological information is NOT acceptable.
- While recognizing the alarming declines of western African lions that now only occupy 1% of their historic range, the report makes no recommendations for any additional protection from international trade. While also recognizing the almost complete lack of information about central African lion populations in Chad, Central African Republic and Sudan, and recognizing that populations in Nigeria and Cameroon are now small, scattered and highly vulnerable, the report makes no similar suggestions for additional protection of central African populations from international trade. This is NOT acceptable.
- The report in some sections acknowledges that there are major gaps in scientific assessments of remaining lion populations but does not acknowledge the subsequent weakness of any conclusions reached. For example, there is no adequate information of lion populations in Angola, South Sudan, Central African Republic, Democratic Republic of Congo, and Chad. In addition, the report fails to acknowledge that population estimates in by far the majority of African lion range states are based on little more than “guesstimates” and reports issued by vested interest organizations and reports using various extrapolations from remote sensing data. This type of uncertainty should be clearly stated in the conclusions of the Periodic Review instead of glossed over.
- The report presents a very garbled representation of the true situation of lions in South Africa. The report neglects to mention that since a Supreme Court of Appeals ruling in 2010 lions are no longer included as Threatened or Protected Species in South Africa. The report neglects to mention that there are now over 160 captive lion breeding farms in South Africa housing an estimated 8,000 captive animals. The report neglects to mention that over 99% of South African hunting trophies and other products are derived from captive bred lions, and that there is rampant erroneous listing of such trophies as “wild” by South African CITES authorities. The report does mention that while the lion bone trade from South Africa has increased, it does not mention that such trade in 2010 and 2011 grew exponentially to include, for example, 2743 lion bones and 547 skeletons mainly sent to Laos and Viet Nam. The report does mention that this trade in lion bones has led to increased demand in China, Laos and Viet Nam, and that poaching incidents of wild lions in other African lion range states are increasing. The report does not express any concern that such CITES authorized trade from South Africa involves known Illegal Wildlife Trade Kingpins like Vixay Keosavang in Laos (a reward of $1 million was recently offered by the US State Department for his arrest). The report neglects to mention that there is increasing evidence that captive lion breeding is expanding to Namibia and Zimbabwe, and that only recently has Botswana banned export of captive bred lions to South Africa destined for the canned hunting trade. The report does mention, in passing, that lion cubs are captured from the wild to be fed into the captive breeding industry. The report neglects to mention that South Africa exports large numbers of live lions from captive breeding facilities to destinations like the United Arab Emirates (pet trade), Thailand, Myanmar, Viet Nam and China without any assurance that such lions are destined for bona-fide zoos registered by WAZA. Ignorance of the true situation in South Africa is NOT acceptable.
- The report mentions that “an average of 38 lions were destroyed per year [in Namibia] for problem animal control … this figure includes most of the lion trophy hunted during the same period, as problem animals in Namibia are mostly trophy hunted to offset the cost of the communities living with lions”. This is a highly surprising statement as it implies that adult trophy lions are highly represented (28 in 2010) among problem animals. It is also factually incorrect as international hunting clients are booked a significant time ahead of their arrival – before the existence of any problem animal could be known. Hunting reports from Namibia do not mention such reliance on problem animals as trophies.
- Resolution Conf. 9.24 (Rev. CoP16) on Criteria for amendment of Appendices I and II, establishes criteria to ensure that decisions to amend the Convention’s Appendices are founded on sound and relevant scientific information. We submit that this Periodic Review is not based on sound and relevant information, that it presents dated, inconsistent and factually incorrect information, and that it fails to make conclusions relevant to the actual status of African lion populations.
- We urge the Animals Committee to reject this document submitted by Namibia and Kenya as being a substantive and correct Periodic Review of the status of the African lion based on the following objections:
- The information presented in the review is no longer applicable to the current status of lions. This is clearly indicated by a lack of true representation of lion numbers in western, central, eastern and southern Africa; a lack of knowledge of the number of range states where lions still occur; a belief in data that is neither sound nor relevant to an assessment of remaining lion populations.
- The information presented in the review is not factual. This is indicated by a complete misrepresentation of current lion commercial trade from South Africa (the MAJOR African nation involved in international trade of lion products) and by an over-reliance on anecdotal and grey literature while ignoring scientific literature.
- The information presented in the report omits significantly important population genetic information about the lion populations. Western and central African lions are so different from eastern and southern African lions they more resemble lions in India. While CITES might have difficulties with the recognition of subspecies, there are precedents for requiring different levels of protection from continued international trade based on geographic origin of specimens. Since remaining lion populations are significantly isolated from each other, a geographic categorization would suffice to correctly identify genetically unique entities.
- The information presented in the review is internally conflicting, reflecting a lack of adequate preparation and involvement by the authors. It additionally does not reflect the view of the many African range states with important lion populations that did not contribute, and therefore is not acceptable as an adequate Periodic Review. The inclusion in the review of range states where lions are already extinct, unknown, or so small that they are not involved in international trade is highly questionable.
- The conclusions do not reflect the data presented in the report, and are therefore invalid.
The Periodic Review of lions submitted to the 27th Meeting of the Animals Committee is flawed in many aspects. It uses dated information, does not consider crucial biological information about the species, and most surprisingly states that trade has no negative impact on African lion populations.
Lions have greatly declined in geographic range and occurrence, and it is clear that trade, including trophy hunting, has had a significant contributory impact.
In this regard, the US Fish and Wildlife Service placed a temporary ban on all imports of elephant ivory hunting trophies from Tanzania and Zimbabwe. The Management Authority reasoned that “Additional killing of elephants in these countries, even if legal, is not sustainable and is not currently supporting conservation efforts that contribute towards the recovery of the species.” Poaching was considered to have led to significant decreases in elephant populations, much the same as habitat loss, human/wildlife conflict and excessive trophy hunting has led to significant decreases in lion populations. Therefore, the CITES Animals Committee should similarly consider that additional killing of lions, even if legal, is not sustainable and is not currently supporting conservation efforts that contribute towards the recovery of a species in significant decline across its range, especially in western and central Africa.
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