February 12, 2019

Connecticut General Assembly Environment Committee

Via email

RE: In support of SB20, An Act Prohibiting the Import, Sale, and Possession of African , Lions, Leopards, Black Rhinoceros, White Rhinoceros, and Giraffes, and HB5394, An Act Concerning the Sale and Trade of and Rhinoceros Horn in the State.

Good afternoon to the Environment Committee Co-Chair Cohen, Co-Chair Demicco, Vice Chair Gresko, Vice Chair Kushner, Ranking Member Harding, Ranking Member Miner, and Members Arconti, Borer, Dillon, Dubitsky, Gucker, Haskell, Hayes, Horn, Kennedy, MacLachlan, McGorty, Michel, Mushinsky, O’Dea, Palm, Piscopo, Rebimbas, Reyes, Ryan, Simms, Slap, Vargas, Wilson, Young, and Zupkus:

Animal Defenders International offers the following in support of SB20 (sponsored by Senator Duff, Representative Kupchick, and Representative Michel, and drafted as an ENV Committee Bill) and HB5394 (sponsored by Representative Bolinsky and drafted as an ENV Committee Bill), with our thanks to the sponsors for their efforts to address the challenges facing these species, including, among other things, legal and illegal trade.

In its 2030 Agenda for Sustainable Development, the UN General Assembly underscored the import of sustainable tourism that protects wildlife, directing Member States to “prevent, combat, and eradicate the illegal trade in wildlife, on both the supply and demand sides.”1 To that end, the US should not promote or enable the demand for trophy , given its demonstrated ties to illicit trafficking; however, US federal policy has reversed in recent years to do just that. For example, the US Fish and Wildlife Service (USFWS) instituted its inaptly named International Wildlife Conservation Council to promote, expand, and enable international trophy hunting and to ease trade in wildlife products, including the import of threatened species as hunting trophies, into the US. The US is already the world’s largest trophy importer, bringing in almost 5,000 trophies alone, since the year 2000.2 Crosta (2015) shed a bit of light on the potential impact of US policymaking to global wildlife efforts, given its central role in trophy imports:

The Chinese government’s real motivation for issuing the recent ban on the importation of hunting trophies is to force the US to make some tough decisions on how to address its own ivory policies. Zhou Fei, Head of TRAFFIC’s program in China, stated that “among all the promises made by the US and China, in terms of the prohibition of the importation of hunting trophies, China is creating pressure on the US to see equal action from the US prohibiting hunting trophy imports and the reason is simple: Chinese do not trophy hunt as many elephants as Americans in .3

Increasing data identifies overexploitation, including hunting, as the biggest threat to biodiversity.4

[T]rophy hunting has not delivered the promised conservation successes to countries that continued to allow hunting after Kenya’s ban.5

[I]ndiscriminate killing of wildlife including wholly protected, endangered, and rare species has negative implications for conservation. 6

At CITES’ Standing Committee 69, the Secretariat described continued organized criminal elements moving large quantities of ivory out of Africa, citing continued corruption among wildlife protection officials, including at points of entry and exit, as well as judicial failings, lackluster enforcement, and minimal penalties.7

The poaching and illegal trade is driven by international criminal networks and cartels, which fuels corruption, undermines the rule of law and security, and, evidence suggests, provide funding to those associated with organised crime and terrorist activities.8

Elephants and other big game in Africa are blood currency for terrorist organizations, and they are being killed at an alarming rate. Stopping poaching isn’t just about saving the world’s most majestic animals for the future – it’s about our national security.9

Since 2010, the United States federal government has documented 2,963 violations related to the import of sport-hunted trophies … About 54 percent of the listed infractions concerned violations of the Endangered Species Act (ESA) but only 14 people had to serve time in jail and 546 violators had to pay criminal fines, ranging from US $25 to US $390,700. 10

In November 2015, the Investigative Unit revealed concerns from wildlife advocates and a former top U.S. official over the US’s ability to vet trophy hunting programs abroad, before determining whether certain trophy shipments should be granted approval to enter the United States. 11

Wildlife trafficking in the USA is a profitable crime, according to Assistant Attorney General John C. Cruden with the Justice Department’s Environment and Natural Resources Division. ‘Illicit transactions like this are fueling a global market and leading us closer to a day when rhinoceroses, elephants and countless other species are extinguished from the earth12

[I]n 2014 the World Bank approved a US $46 million grant to Mozambique to bolster tourism and alleviate poverty. US $700,000 of that was directly earmarked to promote trophy hunting of elephants and lions. Under the Bank’s initiative, 80 hunting permits at US $11,000 each will soon be issued annually for elephants. But it has been structured that the bulk of the revenue from sales of the permits will go directly to the Mozambican government, which is notorious for corruption and embezzlement.13

It goes without saying that importing trophies of endangered species should be banned ... The whole world should do it. Johnny Rodrigues, Zimbabwean Conservation Task Force14

Zimbabwe has been set a massive export quota of tusks as trophies, the biggest of the six countries – 1,000 annually, which has been in place since 2004. This means each year 500 elephants could be legally shot by trophy hunters and their tusks exported. The CITES trade database reveals that in the period 2003-2013, a total of over 28 metric tons of tusks have been exported from Zimbabwe by trophy hunters alone.15

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CITES trade database showed in 2010 that China suddenly began importing trophy hunted ivory … In all the years prior there was zero elephant trophies imports into China. … this hints at a link between trophy hunted animals and the illegal ivory trade where China is the main recipient.16

[I]n October 2015, revenue for the communities from hunting was negligible with “very little off-take”. This may partially be because hunters and poachers have targeted big tuskers resulting in fewer mature bulls; and partially because the bulk of revenue goes to the professional hunter, hunting outfitter and a central government department where the permit is issued. … In his report the chairman suggested a switch from hunting to more profitable non-consumer based tourism for future revenue. Coincidentally, in countries where trophy hunting elephants is most popular and trophy hunted ivory exports and discrepancies the highest – Tanzania, Mozambique and Zimbabwe – it also happens to be where poaching is most rife, and where good governance is most absent. 17

A documentary by HBO’s Real Sports called Blood Ivory aired in November 2015, has correspondent David Scott expose the sport in Tanzania. Teresa Hagerman, a former co-owner of a large hunting outfitter there, told Scott that hunters often adopt illegal and unscrupulous practices and routinely killed more than the allowed quota. She believes that trophy hunters have illegally killed thousands of elephants over the years. … Hagerman says that many hunting outfitters allow clients to kill extra elephants because they can double, triple and sometimes quadruple their money depending on how many extra elephants are killed, even though they have violated the official government quota of permits. Bribing government officials in charge of permits with cash and prostitutes, says Hagerman, was a constant and easy exercise. At one time she handed over US $30,000 to an official to issue additional permits illegally.18

[T]rophy hunting elephants in Tanzania not only isn’t sustainable, but is accelerating the demise.19

Crosta (2015) identified disturbing ties between trophy hunting and illicit ivory trade, noting even “[l]egitimate businesses and business people participate in and facilitate the laundering of illicit ivory through the legal ivory market,” including trophy hunting:20

What appears to be a large quantity of ivory from past and present trophy hunting specimens is in the hands of ivory traders even though all trophy hunting specimens are required to be kept for personal use; legally permitted trophy hunting in Africa is advertised by traffickers as a means to acquire ivory, rhino horn, and other wildlife items … Although completely illegal, rhino horn was present and available for sale in all the locations and at almost all the companies visited by EAL investigators; rhino horn (new or from old specimens) is relatively easy to smuggle into China due to its size and/or enters the market through trophy hunting21

A 2015 Marist poll found 86% of Americans oppose big game hunting; 62% say it should be banned, including 34% of hunters.22 Americans increasingly participate in and spend their dollars on non- consumptive activities such as wildlife watching (~35% of the US population),23 up 21% since 2006.24 A recent USFWS survey found that the “biggest increases in participation involved wildlife watching … [which] surged 20 percent to 86 million participants. Money spent on these activities also rose sharply from $59.1 billion to $75.9 billion.”25 3

[A]pproximately 95% of federal, 88% of non-profit, and 94% of total funding for [US] wildlife conservation and management come from the non- hunting public.26

Despite long alleged claims of its conservation benefit, big game hunting has utterly failed to protect iconic species against the escalating threats to their survival. Mounting scientific evidence consistently points to the opposite effect;27 indeed, many species have suffered staggering decline over the last century. The ties between trophy hunting, illicit trafficking, and poaching are only now beginning to be understood.

Trophy-hunting-as-conservation arguments tend to be based on outdated theories largely based on an economic speculation that the practice will prevent human-animal conflict by providing financial value to an animal commonly thought of as a danger, problem or damage-causing without acknowledging the abundance, or lack thereof, of the species targeted. In the past trophy hunting has often been held up as the answer to sound conservation management practices and the only solution to saving a species but in reality trophy hunting is an activity that fuels corruption, it encourages the unfair redistribution of the wealth generated without adequate involvement of communities, causes the loss of healthy individuals that are still key for reproduction and social cohesion but, most importantly, it contributes to the decline of all five species analysed in this report. 28

Lindsey, et al (2012) concluded that trophy hunting has limited benefit, and actually disincentivizes conservation: “returns from trophy hunting in most concessions are low, reducing available funds for anti-poaching, regardless of whether lions are hunted ... leases of hunting concessions are short, undermining incentives for operators to invest in protecting wildlife.”29

Trophy hunters’ search for the largest and strongest reaches well beyond the individual animal taken, to its pride and the wider population. Numerous studies underscore the detrimental impact to population densities and demographics, with social disruptions that can effectively lead to increased human-wildlife and wildlife-wildlife conflict.30

Dramatic consequences of social disruption have been documented in two protected areas in South Africa, where orphaned male elephants exhibited abnormal hyper-aggressive behaviour that resulted in the killing of 107 rhinoceroses over a period of 10-years. Crucially, such traumatic events are also predicted to have more subtle effects on learning, in particular interfering with abilities to gauge appropriate responses to social and environmental stimuli.31

The second major impact, namely a loss of opportunities for exposure to appropriate older role models, is likely to accompany any direct effects of social disruption on knowledge acquisition and decision-making. This is particularly relevant in long-lived and cognitively advanced species where older individuals play a key leadership role and co-ordinate decision- making in the context of social and ecological threats. Where these experienced individuals are absent, younger group members may be presented with fewer opportunities to learn the most appropriate response in dangerous situations. In addition, any abnormal behavioural patterns that have arisen from socially disruptive events have the potential to be passed between the generations and may persist in the long term.32

Long-lived species such as elephants, cetaceans and non-human primates naturally exist in complex societies where behaviour and fitness is strongly 4 affected by social relationships and exposure to older individuals is likely to influence knowledge acquisition by younger group members. These critical facets of social living are often compromised in wild populations subjected to human disruption … Of particular concern, given the longevity of such species, is that the marked effects of these disruptions persist in the long- term.33

[W]orrying reduction in trophy tusk sizes in consecutive years between 2005 and 2010. … a direct result of hunters targeting the mature bull elephants. It’s “akin to that famously described by John Whitfield in Nature in 2003 with regards to big-horn sheep” … The taking out of the most impressive rams meant imminent harm to the species’ gene pool. The same has happened in Zambia with elephants. “There are very few large bulls left,” … research shows that younger male elephants can become aggressive when older bulls aren’t around … selective removal of a few large trophy or older males led to destabilization of social structures and loss of essential social knowledge. The consequences were infanticide, reproductive females using sub-optimal habitats and changes in offspring sex ratios (this is not just true of elephants, but rhinos, big carnivores, and many species of antelope). 34

Giraffe face significant decline across core ranges in east, central, and west Africa; according to the International Union for the Conservation of Nature, giraffe have declined ~40% in 30 years, due to habitat loss, civil unrest, and illegal hunting.35

Lions have also suffered precipitous declines and, in some cases, extirpation; their numbers are predicted to sink even further, as many now exist in small, isolated groups.36 Trophy hunting can and does negatively impact lion populations.37 In 2013, Economists at Large (EAL) described little debate remains, even among hunters, that “the long-term viability of wild lion populations will be enhanced if fewer lions are shot by trophy hunters.”38 In 2015, USFWS concluded:

[I]n some areas of Africa improper management has resulted in reduced lion numbers due to excessive lion harvests from trophy hunting. Subsequently, some lion populations are negatively impacted by infanticide following pride takeovers by new males. … [T]he government retains a significant portion of revenue from wildlife; therefore, those that bear the costs of wildlife do not receive benefits … Although there are laws meant to protect wildlife, including lions and their prey species, the drastic and continuing decline of the species and its prey indicate these regulatory mechanisms are not adequate to ameliorate threats to P. l. leo. … One of the greater stressors on lions, excessive harvests of lions for trophies, can negatively impact the reproduction of a lion such that it causes local extirpations. Harvesting males that are too young causes male replacements, which results in increased infanticide rates, death of the surviving male coalition, and a 100 percent fatality rate for males that are prematurely forced to disperse. Furthermore, the population will be driven to extinction as female populations collapse as they eventually are unable to mate. The species is largely not able to rapidly recover from population declines. This is evidenced by long-term population trends that indicate an overall 43 percent decline in lions over 21 years and higher regional rates of decline in western and eastern Africa. 39

5 The trophy market preference for larger, mature, male, often patriarchal, individuals compounds the impact, as natural social constructs such as pride succession and infanticide typically result in additional female and cub deaths by intervening males who then seek to establish new leadership.40

[S]pecifically targets adult males, and each male replacement has profound effects on the reproduction of multiple females.41

Packer, et al (2010) described trophy hunting as “the primary driver of a decline in lion abundance,” including those in Katavi National Park and Tarangire National Park and, by comparison, noted largely unchanged lion densities in two of three photo-tourism areas having minimal trophy hunting.42 Palazy (2011) declared lion trophy hunting is unsustainable: “trophy hunting constitutes a greater menace to threatened species than previously realized.”43 The balance of the evidence demonstrates that trophy hunting poses a real threat to lion survival.

Good protection within a protected area is not sufficient if there is unrelenting killing of lions outside it.44

As wild tiger populations dwindle, trade in the bones of lions, jaguars, and leopards rises to meet continued market demand. Skeletons obtained via canned trophy hunting operations have stirred demand, with related spikes in poaching of both captive and wild lion populations.45 The South African Predators Association admits its members sell lion skeletons to feed the lion bone trade,46 which has demonstrated a marked uptick,47 fueled by a supply that legitimizes and thereby stimulates demand. A market preference for wild-sourced specimens - viewed as the better, rarer, more potent product (that’s also easier and cheaper to poach than to raise in captivity) – is likely to develop, just as it has in tiger trade. Captive farming for sport hunting or other trade hasn’t worked to protect wild populations as promised for tigers in Asia or lions in Africa; limited legal trade in ivory proved tragic for elephants, and conservationists worldwide predict legal trade will be similarly disastrous for rhinos.

All but one species of rhino are listed as Appendix I. South African and Swaziland southern white rhino populations were downlisted to Appendix II, purportedly to allow for hunting trophy exports,48 though that purpose is detrimental to the species’ survival. Legal trade of farmed horn impacts wild populations, by providing cover for illegal operations and which, by its typically high costs, incentivizes illegal markets to draw from wild populations.

Through their trophy hunting connections in South Africa, the associates of Beijing Mammoth Art are apparently able to import rhino horns using a new method. After the rhino has been killed the whole animal is preserved by a taxidermist as a trophy. The full body mount is then sent to China and is imported legally as a hunting trophy. Once inside the country the real horn is removed and replaced with a fake one.49

In 2013, EAL reported “hunting companies contribute only 3% of their revenue to communities living in hunting areas.”50 In Tanzania for example, a mere 3.10% of income from trophy hunting was spent on community development.51 Corruption ratings for Tanzania remain high,52 and most of its lions live at risk in hunting areas.53 EAL concluded “in the context of national economies, the industry is tiny, contributing at best a fraction of a percent of GDP. Nature based tourism does play a significant role in national development, but trophy hunting is insignificant. Across the investigated countries, trophy hunting revenue was only 1.8% of tourism revenues.”54 Earlier in 2008, another author made this point, noting that “probably closer to 3-5 percent of hunting revenues actually reached villages where hunting occurred.”55

6 Additional analysis in 2017 criticized assumptions and methodologies relied upon by trophy hunting industry-supported studies, including the failure to consider marginal economic benefit versus simply gross economic benefit.56 The 2017 EAL analysis again found that claimed “[e]conomic benefits have been heavily overstated”:57

▪ [T]he total economic contribution of trophy hunters is at most about 0.03% of GDP ▪ Foreign trophy hunters make up less than 0.1% of tourists on average58 ▪ Trophy hunting tourism employment is only 0.76% or less of average direct tourism employment in study countries 59 ▪ There are 1,000 tourists for every trophy hunter on average60 ▪ Overall, the share of tourist spending from trophy hunters is low, ranging from nearly 0% in Ethiopia, to a high of 10.5% in Namibia61 ▪ 132x as many people are employed in non-trophy hunting tourism than in the trophy hunting industry62

A 2016 US House report identified negative impacts of trophy hunting in sub-Saharan Africa, finding “many troubling examples of funds either being diverted from their purpose or not being dedicated to conservation in the first place,” “no merit to claims that hunting deters poaching,” and current permitting to be “arbitrary, confusing, and not based on sound science.”63 Shockingly, US taxpayers cover “92% of all permit fees,” “subsidizing” trophy hunting,64 despite the typical affluence of its participants.

Trophy hunting is a very small part of the tourism industry in most countries. Overall trophy hunting accounts for less than 2% of tourism revenues. 65

As a portion of any national economy, trophy hunting is completely insignificant, with revenue never accounting for more than 0.27% of GDP … Authors … who claim trophy hunting can account for several percent of GDP are misguided. 66

[T]rophy hunting revenues fail to reach rural communities. Any suggestion that trophy hunting can play a significant role in economic development at a wider scale is completely implausible when the industry is considered in the context of national economic activity.67

Sachedina (2008) found similarly disturbing results:

[W]ildlife benefits are concentrated in the hands of the elite, and have limited livelihood or conservation impacts. … The tourist hunting industry in Tanzania is non-transparent and controlled by powerful cartels. … [E]xcluded local communities from the economic benefits from hunting … [F]ocus on revenue generation through trophy fees could indeed have contributed to wildlife declines … Tourism hunting contributed to declines of several antelope and predator species in Tanzania … Hunting seemed to be a cause of lion declines … Outfitters were aware of the declining viability of hunting. Yet, hunting quotas were not set scientifically. 7 … Corruption is a day to day reality in Tanzania … Hunters themselves spoke openly of these bribes … While outfitters and the [wildlife division] focused on maximising profits, wildlife declined in areas under their management. In Simanjiro, poor relations between outfitters and villages, the lack of benefit sharing, maximising trophy off-take and little to no anti-poaching protection probably contributed to wildlife declines. … [A] professional hunter in Tanzania discussed the rampant corruption he had witnessed as well as the poaching and abuses that his colleagues in Tanzania regularly engage in to please clients 68

Sachedina (2008) challenged the notion that local communities prefer trophy hunting proceeds over other possible revenue sources, finding a demonstrated concern regarding potential lost future revenues:

We’re more closely allied with the photographic operators than the hunters. They are finishing off the wildlife before we‘ve had a chance to realize a profit from it. Hunters don‘t recognize us; they only recognize the government ... 25 percent of hunting fees goes into the ‘hole’ at the district. We‘re supposed to get 5 percent: we don‘t even see that.69

The potential role of ecotourism as a powerful tool for conservation and sustainable development is clearly articulated70

By contrast, eco-tourism was found to generate substantial economic benefit in direct earnings – more than 15 times that for game farming and trophy hunting.71 Non-consumptive tourism is not only sustainable, providing local communities lasting economic benefit, it actually incentivizes wildlife conservation.

Trophy hunting may actually deter growth in other forms of tourism, and these costs may overwhelm any economic benefits (already recognized to be minor) of the trophy hunting industry. 72

Most tourism in African lion range countries is non-consumptive nature tourism. Among holiday and leisure visitors, nature-based attractions are the dominant motivations for travelling to southern Africa. Aside from tourists who are visiting friends and relatives, tourism industries in lion range countries is almost entirely based on nature tourism73

The growth of nature-based tourism is significant for both the protection of biodiversity and generating financial resources for local communities74

[Nature-based tourism] is a large and a fast growing segment of the global tourism industry … This growth is significant in generating money for developmental purposes and biodiversity conservation in developing countries where a large portion of the world’s biodiversity is concentrated75

The evidence demonstrates that industry claims of financial benefit from trophy hunting to local communities are largely exaggerated, and bear little actual connection to successful in situ conservation.76

Hunting contributions to GDP and States' national budgets are insignificant, especially when considering the size of the areas concerned. Economic returns per hectare, for the private sector and for governments 8 are insufficient for proper management. Returns for local populations … are insignificant, and cannot prompt them to change their behaviour regarding poaching and agricultural encroachment. The number of salaried jobs generated (15 000 all over Africa) is low … To summarise, the hunting sector uses up a lot of space without generating corresponding socio-economic benefits. … Good governance is also absent from almost the entire big game hunting sector in many countries. Those who currently have control of the system are not prepared to share that power and undertake adjustments that would mean relinquishing control. They attempt, thanks to a fairly opaque system, to keep a largely exhausted management system going. This position serves individual interests, but not those of conservation, governments or local communities. … the relatively poor results of the big game hunting sector and the clearly low potential in the other countries would seem to indicate that the future for conservation in West African countries does not lie in setting up big game hunting areas.77

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As the human population continues to grow and expand, we must begin to assess our impact to this planet, its finite resources, and the many species who share this world.

We thank the Committee for its consideration of SB20 and HB5394, and we ask for your YES vote to address the challenges facing these species, in hopes we may save them, before it’s too late.

Thank you for the opportunity to weigh in on this important matter.

Christina Scaringe, General Counsel Animal Defenders International www.ad-international.org cc: SB20 sponsors: Senator Bob Duff, Representatives Brenda Kupchick and David Michel HB5394 sponsor: Representative Mitch Bolinsky

1UNGA Resolution 69/314 July 30, 2015 (emphasis added) at http://www.un.org/en/ga/search/view_doc.asp?symbol=A/RES/69/314. 2 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016); see also USFWS webpage, acknowledging the uniquely US role in international hunting, https://www.fws.gov/international/permits/by-activity/sport-hunted-trophies-lions.html. 3 Crosta, Sutherland, Beckner, Blending Ivory China’s Old Loopholes, New Hopes, Elephant Action League (2015). 4 Maxwell, The Ravages of Guns, Nets, and Bulldozers, Nature, vol.536 (Aug. 2016), at http://www.nature.com/news/biodiversity-the-ravages-of-guns-nets-and-bulldozers-1.20381 . 5 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 6 Acquah, E., Human-Wildlife Interactions, Nature-Based Tourism, and Protected Areas Management: The Case of Mole National Park and the Adjacent Communities in Ghana, University of Cape Coast (1997); M.Sc., Kwame Nkrumah University of Science and Technology, (2006). 7 CITES SC69, Doc. 29.3

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8 CITES SC66, Doc. 47.6, submitted by for itself and EPI members Tanzania, , Gabon, Ethiopia, Malawi, Uganda, Kenya, and Gambia, at https://cites.org/sites/default/files/eng/com/sc/66/E-SC66-47-06.pdf. 9 November 20, 2017 Press Release, US House Foreign Affairs Chair Ed Royce, at https://foreignaffairs.house.gov/press-release/chairman-royce-statement-big-game-trophy-decision/ 10 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 11 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 12 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 13 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 14 The Myth of Trophy Hunting, Save African Animals (2004) at www.saveafricananimals.org/attachments/article/136/The_%20Myth_of_Trophy_Hunting_as_Conservation.pdf (accessed 1/19/16). 15 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 16 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 17 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 18 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 19 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 20 Crosta, Sutherland, Beckner, Blending Ivory China’s Old Loopholes, New Hopes, Elephant Action League (2015). 21 Crosta, Sutherland, Beckner, Blending Ivory China’s Old Loopholes, New Hopes, Elephant Action League (2015). 22 Americans Oppose Big Game Hunting … More than Six in Ten Favor a Legal Ban, Marist Poll (Nov. 24, 2015), at http://maristpoll.marist.edu/1124-americans-oppose-big-game-hunting-more-than-six-in-ten-favor-legal-ban/ . 23 See https://wsfrprograms.fws.gov/Subpages/NationalSurvey/nat_survey2016.pdf and http://www.sltrib.com/artsliving/outdoors/2017/09/27/number-of-hunters-on-the-decline-according-to-new-federal- survey/, citing USFWS statistics. 24 See https://wsfrprograms.fws.gov/Subpages/NationalSurvey/nat_survey2016.pdf and http://www.sltrib.com/artsliving/outdoors/2017/09/27/number-of-hunters-on-the-decline-according-to-new-federal- survey/, citing USFWS statistics. 25 See https://wsfrprograms.fws.gov/Subpages/NationalSurvey/nat_survey2016.pdf and http://www.sltrib.com/artsliving/outdoors/2017/09/27/number-of-hunters-on-the-decline-according-to-new-federal- survey/, citing USFWS statistics. 26 Smith, Molde, Wildlife Conservation and Management Funding in the US, Nevadans for Responsible Wildlife Management (2014, 2015). 27 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf, noting “A number of published studies have consistently shown that trophy hunting can have a detrimental effect on wildlife populations.” 28 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 29 Lindsey, P.A., The Significance of African Lions for the Financial Viability of Trophy Hunting and the Maintenance of Wild Land, PLoS One, vol.7, no. 1 e29332 (2012). 30 Becker MS, Watson FGR, Droge E, Leigh K, Carlson RS, Carlson AA, Estimating past and future male loss in three Zambian lion populations. J Wild Manag. (2012); Davidson Z, Valeix M, Loveridge A, Madzikanda H, Macdonald D, Socio-spatial behaviour of an African lion population following perturbation by sport hunting. Biol Conserv 144(1):114– 121 (2011); Loveridge A, Searle A, Murindagomo F, Macdonald D, The impact of sport-hunting on the population dynamics of an African lion population in a protected area. Biol Conserv 134:548–558 (2007); Yamazaki, Social variation of lions in a male-depopulated area in Zambia. J Wildl Manag 60(3):490–497 (1996); Riggio, Jacobson, et al, The size of savannah Africa: a lion’s (Panthera leo) view, Biodiversity and Conservation, Duke University, University of Oxford, Pfeiffer University, Montana State University, Tshwane University, Zambian Carnivore Programme, African Wildlife

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Conservation Fund (2012); see also African Savannah and its lions declining at Alarming Rates, Science Daily, citing Biodiversity and Conservation, Duke University (2012) and Booth, The Contribution of Hunting Tourism: How Significant is this to National Economies? International Council for Game and Wildlife Conservation and the Food and Agricultural Organisation of the United Nations, (February 2013). 31 Shannon et al., Effects of social disruption in elephants persist decades after culling, Frontiers in Zoology, 10:62 (2013) (emphasis added), citing Bradshaw, Schore, How elephants are opening doors: developmental neuroethology, attachment and social context, Ethology 113:426–436 (2007); Bradshaw, et al., Building an inner sanctuary: complex PTSD in chimpanzees, J Trauma Dissoc 9:9–34 (2008); Slotow, et al., Older bull elephants control young males, Nature 408:425–426 (2000); Slotow, Dyk, Role of delinquent young “orphan” male elephants in high mortality of white rhinoceros in Pilanesberg National Park, South Africa, Koedoe 44:85–94 (2001); Bradshaw, et al., Elephant breakdown, Nature 433:807 (2005); Lukas, et al., Early life stress impairs social recognition due to a blunted response of vasopressin release within the septum of adult male rats. Psychoeuroendocrino 36:843–853 (2011); Lupien, et al., Effects of stress throughout the lifespan on the brain behaviour and cognition, Nat Rev Neurosci 2009, 10:434–446 (2009); McComb, et al., Matriarchs as repositories of social knowledge in African elephants, Science 292:491–494 (2001); McComb, et al., Leadership in elephants: the adaptive value of age, Proc R Soc B 278:3270–3276 (2011); McAuliffe, et al., Eusociality, menopause and information in matrilineal whales,Trends Ecol Evol 2005, 20:650 (2005); Van, et al., Social learning and evolution: the cultural intelligence hypothesis, Phil Trans R Soc B 366:1008–1016 (2011); Thornton,et al., Social learning and the development of individual and group behaviour in mammal societies, Phil Trans R Soc B 366:978–987 (2011); Gobush, et al., Long-term impacts of poaching on relatedness, stress physiology and reproductive output of adult female African elephants. Conserv Biol 22:1590–1599 (2008); Gobush, et al., Behavioural correlates of low relatedness in African elephant core groups of a poached population. Anim Behav 78:1079–1086 (2008); and Clubb, et al., Compromised survivorship in zoo elephants. Science 322:1649 (2008). 32 Shannon et al., Effects of social disruption in elephants persist decades after culling, Frontiers in Zoology, 10:62 (2013) (emphasis added), citing Bradshaw, Schore, How elephants are opening doors: developmental neuroethology, attachment and social context, Ethology 113:426–436 (2007); Bradshaw, et al., Building an inner sanctuary: complex PTSD in chimpanzees, J Trauma Dissoc 9:9–34 (2008); Slotow, et al., Older bull elephants control young males, Nature 408:425–426 (2000); Slotow, Dyk, Role of delinquent young “orphan” male elephants in high mortality of white rhinoceros in Pilanesberg National Park, South Africa, Koedoe 44:85–94 (2001); Bradshaw, et al., Elephant breakdown, Nature 433:807 (2005); Lukas, et al., Early life stress impairs social recognition due to a blunted response of vasopressin release within the septum of adult male rats. Psychoeuroendocrino 36:843–853 (2011); Lupien, et al., Effects of stress throughout the lifespan on the brain behaviour and cognition, Nat Rev Neurosci 2009, 10:434–446 (2009); McComb, et al., Matriarchs as repositories of social knowledge in African elephants, Science 292:491–494 (2001); McComb, et al., Leadership in elephants: the adaptive value of age, Proc R Soc B 278:3270–3276 (2011); McAuliffe, et al., Eusociality, menopause and information in matrilineal whales,Trends Ecol Evol 2005, 20:650 (2005); Van, et al., Social learning and evolution: the cultural intelligence hypothesis, Phil Trans R Soc B 366:1008–1016 (2011); Thornton,et al., Social learning and the development of individual and group behaviour in mammal societies, Phil Trans R Soc B 366:978–987 (2011); Gobush, et al., Long-term impacts of poaching on relatedness, stress physiology and reproductive output of adult female African elephants. Conserv Biol 22:1590–1599 (2008); Gobush, et al., Behavioural correlates of low relatedness in African elephant core groups of a poached population. Anim Behav 78:1079–1086 (2008); and Clubb, et al., Compromised survivorship in zoo elephants. Science 322:1649 (2008). 33 Shannon et al., Effects of social disruption in elephants persist decades after culling, Frontiers in Zoology, 10:62 (2013) (emphasis added), citing Bradshaw, Schore, How elephants are opening doors: developmental neuroethology, attachment and social context, Ethology 113:426–436 (2007); Bradshaw, et al., Building an inner sanctuary: complex PTSD in chimpanzees, J Trauma Dissoc 9:9–34 (2008); Slotow, et al., Older bull elephants control young males, Nature 408:425–426 (2000); Slotow, Dyk, Role of delinquent young “orphan” male elephants in high mortality of white rhinoceros in Pilanesberg National Park, South Africa, Koedoe 44:85–94 (2001); Bradshaw, et al., Elephant breakdown, Nature 433:807 (2005); Lukas, et al., Early life stress impairs social recognition due to a blunted response of vasopressin release within the septum of adult male rats. Psychoeuroendocrino 36:843–853 (2011); Lupien, et al., Effects of stress throughout the lifespan on the brain behaviour and cognition, Nat Rev Neurosci 2009, 10:434–446 (2009); McComb, et al., Matriarchs as repositories of social knowledge in African elephants, Science 292:491–494 (2001); McComb, et al., Leadership in elephants: the adaptive value of age, Proc R Soc B 278:3270–3276 (2011); McAuliffe, et al., Eusociality, menopause and information in matrilineal whales,Trends Ecol Evol 2005, 20:650 (2005); Van, et al., Social learning and evolution: the cultural intelligence hypothesis, Phil Trans R Soc B 366:1008–1016 (2011); Thornton,et al., Social learning and the development of individual and group behaviour in mammal societies, Phil Trans R Soc B 366:978–987 (2011); Gobush, et al., Long-term impacts of poaching on relatedness, stress physiology 11 and reproductive output of adult female African elephants. Conserv Biol 22:1590–1599 (2008); Gobush, et al., Behavioural correlates of low relatedness in African elephant core groups of a poached population. Anim Behav 78:1079–1086 (2008); and Clubb, et al., Compromised survivorship in zoo elephants. Science 322:1649 (2008). 34 Cruise A., The Effects of Trophy Hunting on five of Africa’s iconic wild animal populations in Six Countries, Conservation Action Trust (2016) 35 http://www.iucnredlist.org/details/9194/0 36 Riggio, Jacobson, et al, The size of savannah Africa: a lion’s (Panthera leo) view, Biodiversity and Conservation, Duke University, University of Oxford, Pfeiffer University, Montana State University, Tshwane University, Zambian Carnivore Programme, African Wildlife Conservation Fund (2012). 37 Packer C, et al, Sport Hunting, Predator Control and Conservation of Large Carnivores, PLoS ONE, vol. 4, no. 6 (2009). 38 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (February 2013) at http://www.ecolarge.com/wp-content/uploads/2013/06/Ecolarge-2013-200m-question-FINAL- lowres.pdf. 39 USFWS Endangered and Threatened Wildlife and Plants; Listing Two Lion Subspecies; Final Rule, Federal Register, vol. 80, no.246 (2015), at https://www.federalregister.gov/documents/2015/12/23/2015-31958/endangered-and- threatened-wildlife-and-plants-listing-two-lion-subspecies. 40 Booth, The Contribution of Hunting Tourism: How Significant is this to National Economies? International Council for Game and Wildlife Conservation and the Food and Agricultural Organisation of the United Nations, (February 2013) at http://www.wildlife-baldus.com/download/8_.pdf. 41 Packer, C et al, Effects of Trophy Hunting on Lion and Leopard Populations in Tanzania, Conservation Biology (2010). 42 Packer, C et al, Effects of Trophy Hunting on Lion and Leopard Populations in Tanzania, Conservation Biology (2010). 43 Palazy, L. Cat Dilemma: Too Protected To Escape Trophy Hunting? PLoS ONE, vol. 6, issue 7, e22424 (2011). 44 Riggio, Jacobson, et al, The size of savannah Africa: a lion’s (Panthera leo) view, Biodiversity and Conservation, Duke University, University of Oxford, Pfeiffer University, Montana State University, Tshwane University, Zambian Carnivore Programme, African Wildlife Conservation Fund (2012). 45 See, for example, Williams, et al, Bones of Contention: An Assessment of the South African trade in African Lion Panthera leo bones and other body parts, TRAFFIC 7 WILDCRU (2015), available at http://www.traffic.org/home/2015/7/16/new-study-throws-light-on-south--lion-bone-trade.html;see also Williams, et al, Shining light on lion management practices and bone trade TRAFFIC (2015), at http://theconversation.com/shining-light-on-lion-management-practices-and-bone-trade-46472. 46 Van der Vyver, South African Predators Association to DOI Secretary Zinke (Oct. 2017), at http://www.sapredators.co.za/a14/general-articles/sapa-letter-to-secretary-zinke.html. 47 Williams, et al, Bones of Contention: An Assessment of the South African trade in African Lion Panthera leo bones and other body parts, TRAFFIC 7 WILDCRU (2015), available at http://www.traffic.org/home/2015/7/16/new-study-throws- light-on-south-africas-lion-bone-trade.html;see also Williams, et al, Shining light on lion management practices and bone trade TRAFFIC (2015), at http://theconversation.com/shining-light-on-lion-management-practices-and-bone- trade-46472. 48 Crosta, Sutherland, Beckner, Blending Ivory China’s Old Loopholes, New Hopes, Elephant Action League (December 2015). 49 EAL Press Release at https://elephantleague.org/blending-ivory-chinas-old-loopholes-new-hopes-the-report/, referencing report: Crosta, Sutherland, Beckner, Blending Ivory China’s Old Loopholes, New Hopes, Elephant Action League (December 2015). 50 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (2013). 51 Booth, The Contribution of Hunting Tourism: How Significant is This to National Economies? International Council for Game and Wildlife Conservation and the Food and Agricultural Organisation of the United Nations, (February 2013) at http://www.wildlife-baldus.com/download/8_.pdf. 52 Zimbabwe’s corruption ranking is 154/175; Tanzania’s is 111/175; Zambia’s is 87/176, according to Trading Economics (i.e. higher number is more corrupt), see https://tradingeconomics.com/country-list/corruption- rank?continent=africa. 53 Riggio, Jacobson, et al, The size of savannah Africa: a lion’s (Panthera leo) view, Biodiversity and Conservation, Duke University, University of Oxford, Pfeiffer University, Montana State University, Tshwane University, Zambian Carnivore Programme, African Wildlife Conservation Fund (2012).

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54 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (February 2013) at http://www.ecolarge.com/wp-content/uploads/2013/06/Ecolarge-2013-200m-question-FINAL- lowres.pdf. 55 Sachedina, H.T. 2008. Wildlife Is Our Oil: Conservation, Livelihoods and NGOs in the Tarangire Ecosystem, Tanzania, Word Journal of The International Linguistic Association, University of Oxford (2008), at http://african- environments.ouce.ox.ac.uk/pdf/sachedina_dphil.pdf. 56 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 57 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 58 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 59 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 60 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 61 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 62 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 63 Missing the Mark, US House Natural Resources Committee (2016), at http://democrats- naturalresources.house.gov/imo/media/doc/Missing%20the%20Mark.pdf . 64 Missing the Mark, US House Natural Resources Committee (2016), at http://democrats- naturalresources.house.gov/imo/media/doc/Missing%20the%20Mark.pdf . 65 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (2013) (emphasis added). 66 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (2013) (emphasis added). 67 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (2013) (emphasis added). 68 Sachedina, H.T. 2008. Wildlife Is Our Oil: Conservation, Livelihoods and NGOs in the Tarangire Ecosystem, Tanzania, Word Journal of The International Linguistic Association, University of Oxford (2008), at p. 165. See http://african- environments.ouce.ox.ac.uk/pdf/sachedina_dphil.pdf. 69 Sachedina, H.T. 2008. Wildlife Is Our Oil: Conservation, Livelihoods and NGOs in the Tarangire Ecosystem, Tanzania, Word Journal of The International Linguistic Association, University of Oxford (2008), at p. 165. See http://african- environments.ouce.ox.ac.uk/pdf/sachedina_dphil.pdf. 70 Sachedina, H.T. 2008. Wildlife Is Our Oil: Conservation, Livelihoods and NGOs in the Tarangire Ecosystem, Tanzania, Word Journal of The International Linguistic Association, University of Oxford (2008), at p. 165. See http://african- environments.ouce.ox.ac.uk/pdf/sachedina_dphil.pdf. 71 Sims-Castley, Kerley, Geach, A questionnaire-based assessment of the socio-economic significance of eco-tourism- based private game reserves in the Eastern Cape, Terrestrial Ecology Research Unit, University of Port Elizabeth, November 2004 at http://ace.nmmu.ac.za/ace/media/Store/documents/Technical%20reports/TERU-Report-51-Indalo- Socieconomic-Survey.PDF. 72 Murray, The Lion’s Share? On the Economic Benefits of trophy hunting, Economists at Large (2017), at http://www.hsi.org/assets/pdfs/economists-at-large-trophy-hunting.pdf. 73 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large, (2013), citing Scholes and Biggs (2004). 74 Acquah, E., Human-Wildlife Interactions, Nature-Based Tourism, and Protected Areas Management: The Case of Mole National Park and the Adjacent Communities in Ghana, University of Cape Coast (1997); M.Sc., Kwame Nkrumah University of Science and Technology, (2006). 75 Acquah, E., Human-Wildlife Interactions, Nature-Based Tourism, and Protected Areas Management: The Case of Mole National Park and the Adjacent Communities in Ghana, University of Cape Coast (1997); M.Sc., Kwame Nkrumah University of Science and Technology, (2006). 76 The $200M Question, How much does trophy hunting really contribute to African communities? Economists at Large (February 2013) at http://www.ecolarge.com/wp-content/uploads/2013/06/Ecolarge-2013-200m-question-FINAL-

13 lowres.pdf; Booth, The Contribution of Hunting Tourism: How Significant is This to National Economies? International Council for Game and Wildlife Conservation and the Food and Agricultural Organisation of the United Nations, (February 2013) at http://www.wildlife-baldus.com/download/8_.pdf; Sachedina, H.T. 2008. Wildlife Is Our Oil: Conservation, Livelihoods and NGOs in the Tarangire Ecosystem, Tanzania, Word Journal of The International Linguistic Association, University of Oxford (2008), at http://african-environments.ouce.ox.ac.uk/pdf/sachedina_dphil.pdf; Becker MS, Watson FGR, Droge E, Leigh K, Carlson RS, Carlson AA, Estimating past and future male loss in three Zambian lion populations. J Wild Manag. (2012); Davidson Z, Valeix M, Loveridge A, Madzikanda H, Macdonald D, Socio-spatial behaviour of an African lion population following perturbation by sport hunting. Biol Conserv 144(1):114– 121 (2011); Loveridge A, Searle A, Murindagomo F, Macdonald D, The impact of sport-hunting on the population dynamics of an African lion population in a protected area. Biol Conserv 134:548–558 (2007);Yamazaki, Social variation of lions in a male-depopulated area in Zambia. J Wildl Manag 60(3):490–497 (1996); see also African Savannah and its lions declining at Alarming Rates, Science Daily, citing Biodiversity and Conservation, Duke University (2012) at http://www.sciencedaily.com/releases/2012/12/121204145555.htm. 77 Big Game Hunting in West Africa. What is its Contribution to Conservation? IUCN (2009), at https://portals.iucn.org/library/sites/library/files/documents/2009-074-En.pdf.

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