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Almost three years ago, a number of US-based conservation organizations submitted a proposal to the US Fish and Wildlife Service to list African lions as “Endangered” under the US Endangered Species Act. If so designated, the USFWS could impose a number of stringent conditions on any further import of lion products (including hunting trophies) into the USA and would also be able to release funding to improve conservation measures for lions in the remaining African range states.

The process of listing lions is now in the last stages – after a final “public comment” round ending January 27th, the USFWS will make their decision. The USFWS has proposed listing lions as “Threatened” rather than “Endangered”, but with the additional application of a rule under Section 4(d) requiring import permits for all lion products. The import permits can be withdrawn for those range states the USFWS is not satisfied have an adequate conservation plan in place and do not have accurate estimates of lion numbers to justify offtakes. This decision is open to public comment until the January 27^th deadline.

The USFWS has not surprisingly been lobbied extremely vigorously by various groups and individuals opposed to any restriction on trophy hunting of lions, including US organizations like the Safari Club International, African professional hunting associations and even African range state governments preferring to maintain the stream of trophy hunting fees over scientifically informed lion conservation measures. Consequently, LionAid, recognising that this is at least a step forward, elected to accept the compromise of a “Threatened” listing with application of Rule 4(d) with the strong recommendation that as better information becomes available about lion populations in the future, the USFWS will again revisit the opportunity to more correctly list lions on the US ESA as “Endangered”.

LionAid provided the USFWS directly with an extensive response, listing a number of areas where we felt the USFWS proposal was incorrect in their assessment to list lions as only “Threatened”. You can see our response below:

LionAid response to USFWS proposal to list lions as “Threatened” with a Rule under Section 4(d) of the Endangered Species Act

29th December, 2014

Introduction

LionAid appreciates the attention paid by the USFWS in considering all aspects of African lions in their evaluation. While we feel that the USFWS did not go far enough to adequately consider the needed “Endangered” status of lions, we would accept as a compromise the status of “Threatened” with a Section 4(d) listing, with the proviso that as better actual information becomes available about lion populations that the USFWS might amend this status to the more appropriate ESA listing as “Endangered”.

We will address the various sections listed in the Federal Register of October 29, 2014 (vol. 79, no. 209, 50 CFR Part 17) identified in the document as follows:

1. The subspecies’ biology, range and population trends;

2. The factors considered by the USFWS under section 4(a)(1) of the Act (16 U.S.C. 1531 etc).


1.1 Taxonomy

The USFWS review of the taxonomic literature is comprehensive but lacking in perception. While the USFWS is willing to accept current genetic information to list the Asiatic lion as a separate subspecies, there is no such acceptance, based on similar (and more comprehensive) information that the western African lion should either be listed as a third separate subspecies or provisionally included under Panthera leo persica.

While the USFWS argues that the proposed genetic distinctiveness of western African lions is largely based on mitochondrial DNA evidence rather than evidence from nuclear DNA and therefore that the USFWS does not consider western African lions as genetically distinct from southern and eastern African lions, it should be noted that the current taxonomic status of Panthera leo persica is based on no better information.

We would advise the USFWS to revise their statement on the taxonomic status of western African lions in accordance with the precautionary principle.

We would also like to inform the USFWS that while Bauer and Nowell 2004 stated that the IUCN has adopted a “regionally endangered” status for western African lions, this has not been formally accepted by the IUCN – such a listing is absent from the current and official IUCN Red List status of lions. While the IUCN might be commissioning a “Cat Classification Task Force”, such results will not benefit the conservation concerns of lions in the short term to address the immediate, urgent and short-term concerns of western African lions.

1.2 Distribution and Abundance

The USFWS states that “Estimates, particularly range-wide or broad region-wide, tend to rely on expert opinion or inference”. This is particularly true as estimates made by Bauer and Van der Merwe (2004), Chardonnet (2002), and IUCN 2006a,2006b are all derived from surveys of “experts” and are largely based on guesstimates and or “mail surveys”. Later “surveys” by Chardonnet et al 2009, Pellerin et al 2009 and Mesochina et al 2010 were also based on similar mail surveys and have been criticized by Riggio et al 2013 as being “scientifically debatable” and “speculative”. In addition, Riggio et al 2103 question the validity of the IUCN reports (“However dedicated and well-intentioned the participants, there is at least the potential for numbers to reflect wishful thinking or national policies that put a positive spin on numbers to ensure continued funding support”) and those by Chardonnet et al 2009, Pellerin et al 2009 and Mesochina et al 2010 (“… assessments of natural resources by user-communities are consistently more optimistic than independent estimates”).

The methodology used by Riggio et al 2013 can also be subjected to criticism, and indeed they mention this in their own paper. The methodology basically relied on remote sensing to detect savannah habitats and then using “best available information” to extrapolate lion numbers. Riggio et al 2013 specifically discuss the example of the Niokolo-Koba area in western Africa “… there is only a small amount of land-use conversion within protected areas” – yet a later ground survey by Henschel et al 2014 estimated a total of 16 lions in the entire area. In fact, Henschel et al 2014 estimated only 406 lions in western Africa, a far cry from the 1,640 lions estimated by the IUCN conferences and a clear indication of the need for great caution when accepting such estimates.

Further, the IUCN conferences identified a number of Lion Conservation Units (LCUs) in central and eastern Africa that are currently significantly affected by civil strife and commercial poaching. These areas occur in at least in Chad and Central African Republic in central Africa, and in South Sudan and Somalia in eastern Africa. It is highly unlikely, therefore, that central Africa contains the 2,267 lions estimated by Riggio et al 2013.

In addition, areas with significant levels of commercial poaching (ivory, bushmeat) are also unlikely to contain the number of lions proposed. One such area proposed to contain the most significant lion population by Riggio et al 2013 is the Selous in Tanzania (7,644 lions total, 4,963 in protected areas, a “stable population”) has been severely impacted by poaching, resulting in an elephant population decline to 13,084 remaining from 39,000 in 2009. Such heavy levels of elephant poaching undoubtedly have significant impacts on the entire fauna. It should be noted that there have never been dedicated lion surveys in the Selous, save for the small northern section of Mikumi National Park by Creel and Creel in 1997.

In summary, we contest the lion population data presented by Riggio et al 2013 and previous authors on a number of levels including that it is almost entirely based on unscientific (and possibly biased) methodology; that it is (especially in western Africa) contradicted by actual survey data; that it assumes survival of lions (and their prey) in areas subject to considerable political instability and civil unrest; and that heavy poaching especially of elephants but likely also bushmeat is expected to occur without consequences for the resident lion populations. We note that the USFWS report refers to a theoretical study by Packer et al (2013) indicating the significant likelihood of further declines of lion populations in protected and unprotected areas and a report by Craigie et al 2010 indicating that large mammal populations are not adequately safeguarded in many African protected areas. While the USFWS report is doubtless dependent on the “best” scientific information available, it is disappointing that the USFWS nowhere makes a statement that these “best” estimates of continental, regional and even local populations are largely based on indirect techniques and therefore likely to be of limited significance except for the few locations where more direct survey methods have been used.

Again, we would strongly advocate the use of the precautionary principle in assessing the reliability of current lion population data, and would urge the USFWS to strongly advocate the need for accurate surveys before considering any further commercial offtake of remaining lion populations – especially those in western and central Africa.

1.3 Disease

The USFWS report can be strongly criticized for their discussion of disease, especially the conclusion that “based on the best scientific and commercial information available, that disease is not a significant threat to the species”. Perhaps this rather surprising conclusion was facilitated by a rather restricted use of the voluminous published information on diseases that can and have affected lion populations; a lack of understanding of how diseases are monitored in wildlife populations; and a lack of appreciation of the difference between epidemic and endemic diseases.

The USFWS report, in the main, mentions three diseases that have affected or are affecting lion populations, and these will be discussed below. However, the main evidence for the presence of disease among lion populations is based on antibody surveys with occasional information on blood parasites such as Babesia and Ehrlichia and intestinal parasites such as tapeworm and hookworm. By definition, antibody surveys indicate survival of the individuals sampled, with some indication of antibody titers to suggest recency of infection. In other words, such surveys indicate little more than presence of the diseases in the environment, not their impact on lion populations.

In addition, there are very few instances when intact carcasses are available for necropsy studies to attempt to determine the cause of death. Even when those are available, it is often difficult to determine whether such mortality occurred from a single factor or a combination of factors as lions are usually exposed to and infected by a diversity of pathogens. Even more complicated is the association between disease, age of the individual, nutritional status, and other considerations that could predispose morbidity and eventual mortality. In many cases, lions could become debilitated by diseases while their ultimate cause of death could be caused by fights with lions and other large predators or even caused by large prey animals like buffalos.

The role of disease in determining a variety of factors such as longevity and reproductive potential is also almost completely unknown among lion populations. As mentioned above, many diseases could act to debilitate rather than cause mortality, or cause mortality among cubs that are still in natal dens, or cause stillbirths that are not recorded. From antibody surveys among adult lions, diseases like feline herpesvirus, feline panleucopenia, feline calcivirus and feline enteritis are present among lion populations at variable levels of seroprevalence but do not seem to cause morbidity or mortality (e.g. Packer et al 1999; Hofmann-Lehman et al 1996). These viruses, however, largely cause mortalities among kittens in domestic cats – the causes of lion cub mortality are almost never determined in the wild as fresh carcasses are not found.

As a general comment, the actual role of diseases among wildlife populations is very poorly understood as diseased animals are not usually individually monitored to determine the eventual outcome of infections, especially among young animals. In addition, wild animals are not individually and continuously monitored to determine when they contract viruses and other pathogens to determine effect on health. We mentioned above that the information about wildlife diseases is almost always retrospective via seroprevalence surveys of specific antibodies, and that such surveys, while providing information about occurrences of specific pathogens in the environment, deliver little information about the significance of infection when it occurred.

We also mentioned above the difference between epidemic and endemic diseases. As a definition, epidemic diseases occur sporadically in populations and can have high levels of mortality and morbidity. Such epidemic diseases among wild lions can originate from the lions themselves through migratory individuals, but more usually involve other host species as in the case of canine distemper (discussed further below). Endemic diseases occur almost continuously among populations with perhaps variable rates of seroprevalence over time, and are considered to be less threatening than epidemic diseases although this is not always the case. One such disease is feline herpesvirus encountered at high rates of seroprevalence among almost all lion populations tested (e.g. Packer et al 1999), resulting in the almost inevitable conclusion that while the virus circulates among lions, there has been a sufficient level of host-parasite co-adaptation to mitigate almost all consequences of infection.

The USFWS report mentions three diseases among lions in some detail – canine distemper, bovine tuberculosis, and feline immunodeficiency virus. We will consider each of these in turn.

a) Feline immunodeficiency virus

FIVple has been classified as an endemic disease among lions, as many populations show antibody prevalence rates of over 95%. Not understanding the slow course of the disease within an infected host (FIV is after all classified as a lentivirus), early reports (e.g. Packer et al 1999) mentioned that infection was inconsequential. This mistaken opinion is reiterated in the USFWS report – “However, there is no evidence that it poses a threat to wild populations…” and “FIV does not appear to be impacting lions in Kruger National Park, and no evidence of AIDS-like illnesses or decreased lifespan has been found in FIV lion populations in the Serengeti”.

Such statements are puzzling because there are very few FIV-free lions in these populations to form a comparative base. These statements are also at odds with results reported by Roelke et al 2006 and Roelke at al 2009. Those authors reported the following:

i) “We conclude that over time FIVple infections in free-ranging lions can lead to adverse clinical, immunological, and pathological outcomes in some individuals that parallel sequelae casued by lentivirus infection in humans (HIV), Asian macaques (SIV) and domestic cats (FIVfca)”.

ii) ”Results from FIV-infected lions and pumas parallel human and Asian monkey CD4+ diminution in HIV and SIV infection, respectively, and suggest that there may be unrecognized immunological consequences of FIV infection in these two species of large cats.”

It is clear from those studies and others that FIV infection among lions has significant consequences on immune competence. Such infections can significantly impact the ability of affected lions to mount an appropriate and effective immune response to the various pathogens they are constantly challenged with. It is therefore a disease needing considerable further investigation, especially as it has been shown that some of the six identified FIVple strains circulating among lions are more pathogenic than others, especially FIVple strain E, examined by myself and co-authors (McEwan et al 2008) and discovered to be significantly genetically divergent from other strains.

We would strongly urge the USFWS to adjust their stance on the consequences of infection with this immune deficiency virus based on a more careful evaluation of the current scientific literature.

b) Canine distemper

Based on serosurveys, canine distemper virus is encountered by many lion populations across Africa. The origin of this virus is largely assumed to be populations of unvaccinated domestic dogs living in close contact with wild carnivores, although there is a possibility of sylvatic cycles being maintained among wild carnivores. Canine distemper occurs as an epidemic disease among lions, with considerable recorded mortality among some monitored populations (Roelke-Parker et al 1996). There is a diversity of opinion as to whether CDV infections alone or in combination with other diseases cause mortality among lions, but the epidemic that caused over 1000 lion deaths in the Serengeti cannot be ignored. Further research on existing strains of CDV in wildlife and domestic dog populations and their levels of pathogenicity is required.

c) Bovine tuberculosis

Surveys of the prevalence of BTb in wildlife populations, especially lions, is complicated by the absence of a reliable serological test and further confused by a test not sufficiently specific to differentiate among the various Mycobacterium species in the M. bovis complex. However, a comparative study among 16 uninfected lions in the north of Kruger and 16 infected lions in the south of the Park evaluated over four years indicated that five of the southern lions died of advanced tuberculosis and seven lions died as a result of apparent social disruption in the prides after prominent members of the hierarchy died of tuberculosis. All three prides in the north remained intact at the conclusion of the study while only one pride remained in existence in the south (http://www.wcs-ahead.org/gltfca_grants/pdfs/lion_tb_risk_report_final.pdf - pp11-12).

Dr Dewald Keet, the principal researcher of BTb among lions in Kruger National Park has some years ago resigned to conduct private veterinary practice (pers. comm.) and as a result, such research languished. As far as we are aware, there is no current research progress on BTb in Kruger, while the disease appears to be spreading to previously uninfected populations in the north of the Park and indeed to neighbouring protected areas in Zimbabwe.

1.4 The impact of trophy hunting on lion populations

The USFWS report, after considering a variety of evidence, comes to the surprising conclusion that “…based on the best scientific and commercial information available, that trophy hunting is not a significant threat to the species.”

Our opinion, based on the same evidence, is considerably at variance with this conclusion. We base this opinion on a number of concerns:

a) We revert back to what we said in section 1.2 above – there are few reliable or scientifically credible lion population surveys in Africa, save for a few ground surveys in selected areas. By definition, trophy hunting is therefore taking place without information about the size of the resource. The USFWS mentions that trophy hunting largely occurs on a “quota” basis, but such quotas are not scientifically derived. Indeed, the quota allocations are largely based on hunting operator-derived information in Tanzania, Mozambique, Zimbabwe, Central African Republic.

b) The USFWS report only considers CITES trade database exports under the “trophy” category. However, many trophies are exported from source countries under the “skins” category. Over the ten years 2003-2012 (where accurate records end) the following numbers of skins and trophy exports are as follows (database accessed 17 December 2014): total trophy lions exported from African countries where lion trophy hunting is conducted: 3,568. Total skins exported from African countries where lion trophy hunting is conducted: 900. These totals exclude South Africa, where it is estimated that over 95% of lions hunted are captive bred for trophy hunting. During the ten years 2003-2012 South Africa exported 6,657 lion trophies and 734 skins. Of the countries exporting wild lion trophies, Tanzania accounts for 40% of the total, Zimbabwe for 19%, and Zambia for 17%.

c) Apart from South Africa, lion trophies exported are almost exclusively adult and subadult males. Adult male lions generally comprise about 10% of lion populations and as a category specifically targeted by trophy hunters are utilized at non-sustainable levels. The USFWS states that “It appears that most range countries that allow trophy hunting of lions restrict offtake to 2-4 percent of their lion populations for trophy hunting annually…” There is no such restriction, and even if there was, this would assume a source population of male lions far exceeding any estimates by whatever means of remaining lion populations in Africa. From the CITES records mentioned above and excluding South Africa, an average of 357 male lions are hunted annually. This would imply that at the minimal offtake rate of 2%, the source population of huntable male lions (the only trophy animals sought) should stand at 17,850 males. The USFWS erroneously uses a 2-4% estimate of a total “population” offtake while admitting that trophies only include male lions. This is nothing less than playing with statistics. We elaborate on this below.

d) It should be noted that there has never been an independent scientific survey of lion populations in hunting concessions, entirely because concession owners will not allow such surveys. Therefore, it remains an open question how lion populations fare under consumptive offtake of adult and sub-adult males that form the exclusive trophy hunter preferences. Such surveys should be conducted to determine a diversity of indicators such as male-female ratios compared to non-utilized populations, reproductive success, maintenance of intact prides, etc.

e) Hunting concessions in very many cases border directly on nationally protected areas. As a consequence, lion populations at the edges of these protected areas have suffered considerable male depletion either by hunters conducting operations within national parks or luring lions out of national parks with baits and in some cases recorded calls. This has resulted in considerable damage to the integrity of lion populations in protected areas across Africa. The USFWS mentions but skims across scientific publications by Davidson et al 2011, Loveridge et al 2007, Packer et al 2009, Croes et al 2011, Yamazaki 1996. Most recently, Rosenblatt et al 2014 published an article in Biological Conservation that indicated severe consequences of lion trophy hunting on the borders of Zambia’s South Luangwa National Park. The study indicated that trophy hunting was the leading cause of male lion mortality with 46 protected area male lions harvested. This harvest resulted in a declining protected area population, low sub-adult and adult male survival, depletion of adult males and a senescing adult female population.
f) If hunting concessions remained viable with sustainable offtake levels of male lions, this situation of harvesting male lions from neighbouring protected areas would not be expected to occur. The fact that hunters resort to such illegal measures should indicate to the USFWS that lion trophy hunting is not sustainable across many lion range states in Africa.

g) Unless and until independent lion population surveys can be undertaken within hunting concessions, the USFWS conclusion that trophy hunting has no impact on lion population survival can only be considered as wishful and unscientific.

h) The USFWS states that “Five countries maintain quotas to allow for approximately 6-15 lion trophies to be taken per year: Benin, Burkina Faso, Cameroon, Mozambique and Namibia.” In fact, Mozambique exported an average of 21 lion trophies per year 2003-2012 and Namibia exported an average of 21 trophies per year 2003-2012. As mentioned above, such totals could be higher as “skins” can also be considered within the “trophy” category.

i) The USFWS states that “Based on the best scientific and commercial information, infanticide, as a result of the removal of lions through hunting, is not a threat to African lions.” This is not a credible statement because, as mentioned before, there have been NO credible scientific surveys of lion populations in hunting areas. However, long-term research in protected areas bordering hunting concessions where male lions are specifically targeted by hunters, include statements like the following: “Mark-recapture models fit to data from intensive monitoring of 210 individual lions in 18 prides and 14 male coalitions indicated a declining population, low recruitment, low sub-adult and adult male survival, depletion of adult males and a senescing adult female population. Trophy hunting was the leading cause of death, with 46 males harvested.” (Rosenblatt et al 2014). The USFWS is strongly urged to revise their statements.

In summary, trophy hunting of wild lions targets a small percentage of the lion population – adult and subadult males. There is no indication whatsoever that such trophy hunting in any way positively influences the conservation of lion populations – indeed the opposite has shown to be true in a number of scientific studies ranging from Cameroon to Zambia to Zimbabwe to Tanzania. While some lion range countries like Tanzania and Zimbabwe might wishfully indicate that quota and age minima are in place to regulate lion male offtakes, there is currently no means to scientifically establish the impact of lion trophy offtakes. This is largely because concession operators will not allow evaluation of lion population demographics under offtake regimes, and because hunting operators are engaged in illegal activities to source male lions from protected areas that border their hunting concessions. The USFWS would be well-advised to revise their statements about trophy hunting “not being a threat to the species” as such conclusions are not based on best scientific information. Once again, we would advise the USFWS to apply the precautionary principle to the issue of lion trophy hunting as a conservation measure for the species.

1.5 Community benefits from trophy hunting

I would refer the USFWS to an overall summary of community benefits from trophy hunting, or rather the lack thereof, in these comprehensive summaries:

http://www.lionaid.org/news/2010/11/community-based-wildlife-management-programmes-do-the-communities-benefit.htm

http://www.lionaid.org/news/2011/04/a-socio-economic-analysis-of-trophy-hunting-areas.htm?password=reset

The USFWS should by now realize that hunting concessions in all areas of Africa benefit the hunting operators and not the communities. The USFWS should also realize that hunting concessions are awarded via corrupt practices at least in Tanzania, Zimbabwe and formerly in Zambia. The USFWS should be aware that the former Minister of Tourism and Arts of Zambia, Sylvia Masebo, fired top officials in the Zambia Wildlife Authority and the organization Board over corrupt allocations of hunting concessions. The USFWS cannot seriously claim that hunting concessions in African countries benefit rural communities rather than political and business elites. The USFWS cannot in any way claim that African hunting concession fees and trophy fees benefit wildlife conservation. The USFWS is surely able to access a great diversity of information from US Embassies in lion range state hunting countries to be better informed about corrupt practices in the hunting industry.

In addition, the USFWS recently adopted a moratorium on elephant trophy hunting imports from Zimbabwe and Tanzania into the USA because the agency felt that trophy hunting of that species in those countries had not proven to be a beneficial conservation strategy. The same level of scrutiny should be applied to lions.

In summary, the USFWS should much more carefully and rigorously evaluate the benefit to local communities from trophy hunting operations on their lands. The USFWS should not rely on anecdotal reports provided by hunting operators celebrating their donations to communities involving schools, clinics, boreholes and jobs. These “benefits” have never been independently evaluated and communities involved in hunting concessions have not been adequately surveyed as to their satisfaction of land use for trophy hunting. No community in Tanzania, Zimbabwe, Zambia and even Namibia has been granted “owner rights” of wildlife on their land and are therefore not significant stakeholders in conservation.

2. Listing African lions as Threatened with a Rule under Section 4(d) of the ESA

We welcome the possible addition to listing lions as a “threatened” species by provisions available under section 4(d) as an initial measure. As we understand section 4(d) this would provide the following:

1. African lion range states engaged in consumptive offtake must be able to justify rates of male lion offtakes via independent scientific analyses that would establish not only the size, composition and reproductive capacity of the source populations but also the impact of such offtakes and the conservation contribution of trophy hunting to the maintenance of the species;

2. African lion range states engaged in consumptive offtake must have a current and enacted national lion conservation plan that ensures offtake is sustainable and significantly beneficial to local communities expected to live with lions;

3. African lion range states engaged in consumptive offtake must show that trophy fees flow back to the maintenance of nationally protected areas and species conservation rather than being absorbed by the national Treasuries as is currently the case.

4. African lion range states engaged in consumptive offtake of lions must engage independent surveys of trophy hunting areas to be able to evaluate the benefits versus detriments of trophy hunting.

In addition, we would alert the USFWS to the following:

1. Most African lion range states involved in trophy hunting do not have national lion conservation plans in place, or have conservation plans in place not in any way cognizant of the accurate numbers of lions that form the basis of their quota allocations. We would caution the USFWS that Zambia, for example, does not have an enacted lion conservation plan though this is mentioned several times in the USFWS document. We were requested by the then Minister of Tourism and Arts, Sylvia Masebo, to make a presentation to the then Zambia Wildlife Authority Board of Directors in 2013. The Board of Directors acknowledged a draft of a national lion conservation plan, but said this had never been signed. This conservation plan mentioned that there were over 4,000 lions in Zambia – more recent estimates mention a more realistic estimate of less than 400.

2. The call for national lion conservation measures originated from the Kenya proposal to list African lions on CITES Appendix I in 2004. Kenya withdrew the proposal with the expectation of subsequent lion conservation conferences. These were duly organized by the IUCN in late 2005 and early 2006. Very few of the conference resolutions have since been adequately addressed by the lion range states. There is a very urgent need to conduct independent and scientifically valid lion population assessments by range states in both protected areas and areas used in so-called sustainable utilization wildlife “management” areas. This total lack of verifiable and scientifically based information cannot be accepted by the USFWS to support further offtake of lions via trophy hunting as a “conservation” measure.

3. The European Union is expected soon to pass a resolution to require import permits for all lion trophies under their Wildlife Trade Regulations. The EU Scientific Review Group has already passed negative opinions on imports of lion parts (including trophies) from western African nations like Benin, Burkina Faso and Cameroon. We would urge the USFWS to establish dialogue with their EU counterparts to harmonize wildlife trade restrictions. CITES recommendations must always be interpreted and amended by national opinions based on better science.

In summary, we would urge the USFWS to impose an immediate import moratorium of all lion hunting trophies from all lion trophy hunting countries until independent and scientifically credible surveys in hunting areas and adjoining nationally protected areas have been undertaken to record demographics of lion populations subjected to trophy hunting offtake. All indications from past studies have shown that specific depletion of subadult and adult male lions strongly negatively affects lion populations. The provision to impose such moratoria is available under Section 4(d) of the US Endangered Species Act of 1973 and should be taken immediately as it is abundantly evident that US trophy hunters contribute most significantly to African lion population harvests. Further, the USFWS should provide independent funding for such direct surveys to ensure that vested interest groups and NGOs with specific agendas no longer dominate the continental, regional and national lion population survey landscape.


References quoted not in the USFWS report:

William A. McEwan, Elizabeth L. McMonagle, Nicola Logan, Rodrigo C. Serra, Pieter Kat, Sue VandeWoude, Margaret J. Hosie, and Brian J. Willett. 2008. Genetically Divergent Strains of Feline Immunodeficiency Virus from the Domestic Cat (Felis catus) and the African Lion (Panthera leo) Share Usage of CD134 and CXCR4 as Entry Receptors. J. Virol. 82: 10953-10958.

Elias Rosenblatt, Matthew S. Becker, Scott Creel, Egil Droge, Thandiwe Mweetwa, Paul A. Schuette, Fred Watson, Jonathan Merkle and Henry Mwape. 2014. Detecting Declines of Apex Carnivores and Evaluating their Causes: An Example with Zambian Lions. Biol. Cons. 180: 176-186.

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