A public comment submitted to the U.S. Fish and Wildlife Service in opposition to the proposed revision to the section 4(d) rule for the African elephant.
- Elephant hunting and the trophies it produces are a significant source of conservation funding in range countries subject to strict, internationally accepted standards. Imposing additional requirements will likely undermine those economic incentives for elephant conservation.
- Conditioning trophy imports on range countries’ adoption of CITES-implementing legislation will have known harms for elephant conservation in the near future, while long-term benefits for elephants are speculative.
- Requiring range countries to annually certify that elephant populations are stable or increasing places an undue burden on those countries and is unlikely to benefit elephant conservation.
PERC believes the U.S. Fish and Wildlife Service can be a valuable partner of African wildlife agencies in conserving elephants and other species. As the Service recognizes, however, the proposed modification of the existing 4(d) rule will negatively impact African wildlife agencies’ ability to effectively manage elephant populations. It will undermine economic incentives for elephant conservation created by the safari-hunting industry. Such impacts risk making the United States an obstacle to African-led conservation efforts at a time when more cooperation is needed. We urge the U.S. Fish and Wildlife Service to abandon this proposal and work with their African counterparts to find a more constructive way forward.