QUESTIONS & ANSWERS
Why is the Service issuing permits for the import of a black rhino sport-hunted trophy?
A: Namibia implements a science-based management strategy for black rhinos that outlines clear goals and objectives for conservation of the country’s black rhino population. In 2003, Namibia instituted the Black Rhino Conservation Strategy for Namibia with specific management goals in the areas of range expansion, biological management, protection, policy and legislative framework, capacity-building and sustainability. As part of this strategy, Namibia authorized an annual harvest of up to five male black rhinos. The removal of limited numbers of males has been shown to stimulate population growth in some areas. Removing specific individuals from a population can result in reduced male fighting, shorter calving intervals, and reduced juvenile mortality. All known black rhinos in Namibia are ear-notched to assist in identification and monitoring. This ear-notching system makes it possible for the Namibian government to select specific individuals for culling based on age, reproductive status and other factors that may contribute to the overall health of the population.
A: The Service has received four applications to date, three for rhinos from Namibia – one of which was issued in April 2013 and two others that are being issued in April 2015 – and one from South Africa, which was withdrawn. Although we anticipate receiving additional applications now that we have issued permits, the Service can issue only up to 10 import permits annually (five each for Namibia and South Africa), since this would be the maximum number of exports that could be made under South Africa’s and Namibia’s CITES-approved quota. However, we have not determined whether imports from South Africa would meet the requirements for import under the ESA and CITES.
A: The black rhino is listed in Appendix I of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and as endangered under the U.S. Endangered Species Act (ESA). Before an import permit can be issued for a CITES Appendix-I species, the Service must determine that the import will not be detrimental to the survival of the species. For a species classified as endangered under the ESA, the Service must determine that allowing the import will enhance the species’ survival. The ESA also requires that any federally authorized activity may not jeopardize the continued survival of the species. To make these findings, the Service looks at the biology and overall management program for the species. Factors we consider include: the biological needs of the species, possible threats to populations, current population estimates, management plans, legal protection (for sport-hunted trophies this includes hunting regulations and any applicable quotas), local community involvement and, if any funds are generated by the import, how funds are used for conservation. Obtaining the information on a country’s management program may entail a lengthy consultative process between the country of export and the Service.
A: The On March 26, 2015, the Service announced its intention to issue two permits for the import of a sport-hunted black rhinoceros trophy. The Service also issued one permit for the import of a sport-hunted black rhinoceros trophy in April 2013. Upon issuance of the April 2015 permits, three permits will have been issued.
A: Recently, the government and other rhino custodians in the country have taken aggressive, ambitious steps to combat poaching, including changing patrol patterns, escalating law enforcement presence and capabilities in sites at risk, and proactively de-horning rhinos in insecure areas. Now more than ever, it is vitally important for Namibia to safeguard its rhino population by boosting security in communal lands and protected areas – efforts that will require significant funding.
A: When the Service published receipt of the application (a requirement under the ESA), we received several comments that supported the import of this black rhino trophy from Namibia.
The World Wildlife Fund (WWF) supported the import of the trophy. WWF has worked in Namibia for more than 20 years and has provided technical support and assistance to Namibia’s Ministry of Environment and Tourism on a range of programmatic issues and species conservation activities, including monitoring black rhino populations, expansion of rhino range to wildlife conservancies organized and overseen by local communities, and development of a National Black Rhino Management Plan.
We also received positive comments from the Namibian Association of Community-Based Natural Resource Management Support Organization, a national body of 14 non-government organizations (NGOs) and the University of Namibia, as well as the Texas Wildlife Association, Safari Club International (SCI), Conservation Force, Rocky Mountain Elk Foundation, a hunting and conservation organizations coalition, and the National Rifle Association (NRA).
We did not receive any comments in opposition.
A: During a 30-day public comment period, we received more than 15,000 public comments and 135,000 petition signatures regarding these two applications, the vast majority of which were opposed to the issuance of these permits. One of the applications was related to an auction held by the Dallas Safari Club that generated broad public interest.
The primary purpose of the ESA is the conservation and continued existence of wild populations of endangered species and the ecosystems on which they depend. An open and transparent public process is paramount to successful implementation of the ESA; however, the final decision must support the primary purpose of the ESA and be based in sound science, rather than public opinion. The Service reviewed each of those comments for scientific or technical information to inform its decision and carefully considered the concerns and perspectives of commenters.
A: Black rhinos are very territorial. The removal of post-reproductive males or males whose genes are already well represented in the population can reduce competition with younger bulls, potentially providing those younger bulls with a greater opportunity to reproduce, enhancing the survivability of the overall population.
A: In the United States, CITES-implementing regulations (50 CFR 23.55) clearly state that an Appendix I sport-hunted trophy may only be used for non-commercial purposes. Selling such a trophy after import constitutes a violation of the ESA. Sale in interstate or foreign commerce would violate the wildlife trafficking provisions of the Lacey Act. ESA violations carry a maximum penalty of one year in prison and a $100,000 fine; conviction under the Lacey Act is punishable by a prison term of up to five years and a $250,000 fine. Furthermore, the CITES requirements for black rhino trophies require that all parts of the trophy be marked with identifying information; these requirements are incorporated into the U.S. CITES regulations.
A: In general, the ESA prohibits the import, export, interstate commerce or foreign commerce of any listed species, including its parts or products, without a permit. The “take” prohibition, including harassment, applies within the United States or on the high seas. (Generally accepted animal husbandry practices, such as veterinarian care and other activities outlined in the Service definition of “harassment”, are not considered take.)
A: In large part, CITES prohibits international trade in specimens of Appendix-I species except when the purpose of the import is not commercial, for instance, scientific research. In these exceptional cases, trade may take place provided it is authorized by the granting of both an import permit and an export permit (or re-export certificate).
A: The Service has found that the import of trophies from bontebok, an endangered antelope from South Africa, benefits the species by supporting the overall species management program established by the South African government. The Service routinely issues import permits for sport-hunted bontebok. If we can determine that the import will enhance the survival of the species and not jeopardize the continued existence of the species, the Service could issue import permits for sport-hunted trophies of other endangered species. Under the ESA, otherwise prohibited activities, including import, export, take and interstate or foreign commerce, may be permitted if the Service finds that the activity will enhance the propagation or survival of the affected species and is determined to be consistent with the purpose of the ESA. The Service would look at the overall management program for a species in each country. Factors considered include: the biological needs of the species; possible threats to the populations; and current population estimates, quotas, management plans, legal protection, local community involvement, and use of hunting fees for conservation. Obtaining the information on management programs may entail a lengthy collaborative process between the country of export and the Service.
A:Here in North America, trophy game hunting has led to the restoration of the white-tailed deer, elk, moose and a number of other species. As the IUCN and other international wildlife management and conservation organizations recognize, well-managed wildlife programs that include limited, sustainable sport hunting can and have provided significant long-term benefits to the populations of many species. Regulated waterfowl hunting and upland game bird hunting have helped preserve millions of acres of habitat that benefits not only the game species, but a host of native wildlife, including threatened and endangered species.
U.S. hunters – the vast majority of who strongly support sustainable game management – make up a significant share of foreign hunters who book trophy hunts in Africa, Asia and elsewhere. That gives us a powerful tool to support countries managing wildlife populations in a sustainable manner – and other nations a strong incentive to strengthen their management programs.
By law, we cannot and will not allow trophies of certain protected species into the United States that were hunted in any nation whose conservation program fails to meet high standards for transparency, scientific management and effectiveness. If we have concerns about a country’s management program or a species’ population status, we will not issue permits, as we have demonstrated with the suspension of elephant trophies from Zimbabwe and Tanzania.
The Wildlife Without Borders Rhinoceros and Tiger Conservation Fund is working to restore rhino and tiger populations to healthy numbers in the wild. Learn more.
Click here for details on Operation Crash, a nationwide undercover investigation of illegal trafficking in rhinoceros horn.