Scaringe, Christina, General Counsel
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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 Elephants, Lions, Leopards, Black Rhinoceros, White Rhinoceros, and Giraffes, and HB5394, An Act Concerning the Sale and Trade of Ivory 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 hunting, 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 elephant 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 Africa.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 2 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.