Latest Lion Aid News
Saturday 9th November 2019
The public consultation about the UK import and export of hunting trophies has now been launched and we urge everybody to take the time to return the questionnaire issued by the Government by the deadline of the 25th January 2020. The link to begin the consultation is here.
This consultation is quite long, 15 questions in all to be answered, and the questions are interspersed with much “explanatory” but perhaps sometimes rather selective text from the UK Government. It also seems to us that a more detailed knowledge of CITES and the EU Wildlife Trade Regulations are assumed, despite the “explanatory” text passages included throughout the questionnaire.
So, in order to help you complete this questionnaire, we have provided you with a summary of points that need to be made in your answers and also we have reprinted the questions you will be asked and shared with you the main points that we consider important that you may wish to consider in your answers.
Main points, information and background to trends in the information requested of you.
1. CITES and the IUCN Red List.
There are a number of questions that allude to whether the species to be banned from imports of their hunting trophies should be taken from CITES Appendices or the IUCN Red List. You should be very clear in your answers that CITES is only concerned with trade in plant and animal products and does not consider trophy hunting to be “trade” in wildlife products. Therefore, a large number of species that are trophy hunted are not listed on any CITES appendix and the impact of trophy hunting is not considered by CITES when a species comes up for review in terms of the Appendix that it is listed on. For example, when lions have been considered in the past as a candidate species to be placed on Appendix 1, this was always rejected because the trade in lion products was confined to trade in skins, teeth and claws and did not at all consider hunting trophies. As trade in lion products is minimal compared to trophy hunting offtake, CITES always considers trade in lions to be non-detrimental to conservation of the species. Also CITES has very many shortcomings in terms of their record keeping especially when it comes to numbers of specimens involved in trade as reported by the importer versus the exporter of such products. These discrepancies can be very large and therefore it is almost impossible to derive any meaningful trade statistics from the official CITES trade database. CITES trade database does have a “trophy” category but again a trophy can be listed as a “trophy”, as a “skin”, as a “skull”, as “tusks” etc. So again it is impossible to determine how many hunting trophies have actually been exported and/or imported.
As for the IUCN Red List, this is probably a better source of species from which hunting trophies should be banned. However, the IUCN Red List also contains many flaws – eg the IUCN does not consider sub-species designations of many species like giraffes, elephants, lions, leopards, buffalos etc. Also the red List is not regularly updated for many species and population estimates are often flawed. For lions, which should have been listed in the IUCN “endangered” category, the reviewers used highly contentious data from lion populations
occurring in fenced, private reserves in South Africa to claim that lion populations in all of Africa were not “endangered enough” to be placed in the “endangered” category. Similarly, African elephants with a population of over 400,000 are considered to be endangered while African lions with a population of 15,000 are only considered as “vulnerable”.
2. Benefits of trophy hunting
Throughout the consultation document, preambles to the questions state frequently and repeatedly that well regulated trophy hunting can bring conservation benefits to both the species being hunted and communities living with those species. There is a wide diversity and large volume of evidence that questions such supposed benefits – for example it has been shown that trophy hunting is the least economically valuable form of land use in Africa, that financial benefits to communities are minimal to non-existent, that in most cases there are still significant questions about the assumed relationship between trophy hunting and conservation that there is no evidence whatsoever that trophy hunting is a sustainable activity simply because there have been no independent wildlife counts in any trophy hunting concession (while there is considerable evidence that trophy hunting operators frequently lure animals out of protected areas to be shot), that trophy hunting does not promote community tolerance of wildlife as evidenced by continued involvement of communities in commercial and bushmeat poaching, that claims of schools, clinics and bore holes provided to communities and funded by trophy hunting profits are often empty and/or exaggerated, that hunting concession tenders have been shown to be frequently corrupt and non-transparent, that there are no penalties for bad stewardship of hunting concessions resulting in great decreases of all wildlife in hunting concessions across many African nations that permit trophy hunting etc etc. In short, claims of positive benefits of trophy hunting to wildlife conservation are completely lacking in independent scientific proof and are nothing more than rhetoric and propaganda. It is sad to see that, nevertheless, such unsupported statements are frequently repeated in this call for public consultation.
3. There are several questions to do with enforcement.
It would seem that the UK for some reason is quite concerned about enforcement of any particular ban on the import of hunting trophies. It seems to us that this concern is misplaced as a number of other nations have already instituted similar bans on imports of hunting trophies covering either selected species or a much more comprehensive ban. These nations include the USA, France, Netherlands, Australia, Kenya etc. These nations have not reported any particular difficulties in terms of enforcing their bans and if the UK has any particular concerns in this matter, it would be a simple thing to consult with those nations directly.
AND NOW TO THE SPECIFIC QUESTIONS:
Questions 1 to 4 relate solely to your personal details.
Question 5: Is there anything you would consider to be a hunting trophy that falls outside of the definition found in CITES and the EU Wildlife Trade Regulations (WTR)?
Question 6: Is there anything that falls within the definition used in CITES and the EU WTR that you consider should not be treated as a hunting trophy?
Question 7: Do you envisage any challenges or difficulties which might arise from using the definition in CITES and EU WTR, for example, when it comes to enforcement?
Question 8: Please state your first and second preferred option
· Option 1: a ban on hunting trophies from certain species entering or leaving the UK. We rank this as our preferred option
· Option 2: Stricter requirements for clear benefits to conservation and local communities to be demonstrated before hunting trophies from certain species are permitted to enter or leave the UK. We rank this as our second most preferred option.
· Option 3 – a ban on all hunting trophies entering or leaving the UK. We ignored this option.
· Option 4 - do nothing – continue to apply current controls based on internationally agreed rules. We ignored this option.
Please add any comments on your preferred options, including any reasons for your preference or suggest alternatives.
Question 9: Options 1 and 2 introduce further restrictions for certain species, Which species do you think these further restrictions should apply to?
Question 10: Do you think there should be different restrictions on hunting trophies imported and exported to and from countries to and from countries within the EU compared with countries outside the EU?
Question 11: Do you have additional information or evidence on potential impacts of increased restrictions as set out in Options 1 to 3
Potential enforcement problems which might arise as a result of using a definition of hunting trophy based on the one used in CITES and the EU WTR?
Potential barriers to implementation for Options 1 to 3?
Question 12: In Options 1, 2 and 3, do you think there should be different restrictions on hunting trophies obtained from wild animals, animals that have been bred in captivity to be hunted, or animals which have been hunted in confined enclosures?
Question 13: For Options 1,2 and 3, do you think there should be any exemptions considered? Please state your reasons why.
Question 14: Do you agree with our proposed enforcement regime?
Question 15: Overall, how satisfied are you with our online consultation tool?
Posted by Chris Macsween at 14:01
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