Trouble in Tanzania

Tanzania’s Selous Game Reserve is one of the most storied landscapes in Africa. Roughly the size of Switzerland, the reserve was included on the World Heritage List by the United Nations Educational, Scientific and Cultural Organization (UNESCO) in 1982. It is a key area for the conservation of biodiversity with grasslands, Acacia savannas and wetlands providing homes to big game such as elephants and lions in addition to 12 percent of endangered African wild dogs. Now, as a direct result of U.S. policies restricting the importation of hunting trophies from Tanzania, the health of the larger Selous Ecosystem is in serious doubt as declining revenues force hunting operators to leave the reserve’s surrounding wildlands and the rich habitats found there become increasingly vulnerable. The return of the hunting blocks comes at a time when logging and hydro-electric development projects are expanding in the Selous Game Reserve itself and the government of Tanzania is turning its multiple-use Game Controlled Areas into agricultural zones. This looming ecological crisis in the Selous highlights how U.S. conservation policies can have unintended negative consequences for international conservation efforts as well and the need to reexamine how much discretionary authority agencies like the U.S. Fish and Wildlife Service (USFWS) should have when applying the Endangered Species Act (ESA) to foreign-listed species. This would provide greater assurances that the law is an asset, and not an obstacle, to securing the world’s natural heritage.

This past March, Eric Pasanisi, whose family owned the largest trophy hunting operation in Tanzania, announced the surrender of all of the family’s hunting blocks adjacent to the Selous Game Reserve. Their holdings totaled more than 6.6 million acres, roughly the equivalent of three Yellowstone National Parks, into which they had reinvested a significant share of their revenues toward conservation efforts. The hunting operation had provided more than $2 million in financing for counter-poaching operations covering in excess of eight million acres around the Selous Game Reserve. This included salaries and bonuses for over 100 counter-poaching scouts, the deployment of 25 Land Rovers and an airplane for use in surveillance and reconnaissance. The Pasanisi’s also employed an innovative finance approach to support lion conservation, leveraging donations of 21-day safaris to raise $500,000 in partnership with the Shikar Safari Club International Foundation. (See editor’s note.)               

In a message that was widely distributed to professional hunters and conservationists, the family directly attributed its need to surrender the lands to increased U.S. restrictions on the importation of elephant trophies that began in 2014. “We cannot book enough 21-day safaris to make a profit or stay in business without…elephant trophy imports into the U.S. Our losses are escalating so we have to stop,” Eric Pasanisi said, noting that the business had declined from 126 safaris per year to less than 20 because of U.S. policies.

"Wildlife in Tanzania is in grave danger—largely due to actions by the Obama administration to 'save' wildlife by restricting hunting," said Erica Rhoad, Director of Hunting Policy for NRA-ILA. "Hunting outfitters fund and operate counter-poaching efforts. They work with local communities and provide incentives for healthy, abundant wildlife. Without them in remote areas, there is no one to protect wildlife and stop poachers."

The 2014 moratorium on the importation of elephant trophies from Tanzania was abruptly imposed by the USFWS without the benefit of consultations with Tanzanian authorities or public comment. The agency justified its action as necessary to address an increase in elephant poaching that peaked in 2011. The fact that such disruptive shock to Tanzania’s hunting industry and related conservation programs was even possible is due to the African elephant having been listed as a “Threatened” species under the ESA and that listing’s triggering of permitting authorities, under Section 4(d) of the law, for which the USFWS has broad discretion.

Commonly known as “Enhancement Permits,” these permissions are required of all U.S. hunters seeking to import trophies of ESA-listed species legally acquired overseas. What is demanded for a permit to be obtained is subjective proof that the hunting program under which the trophy was acquired is “enhancing the survival of the species.” With the United States’ position as the largest market for hunting trophies worldwide, this discretionary import permitting authority gives the USFWS unparalleled influence over the conservation programs of other countries, especially emerging markets like Tanzania that utilize hunting and other forms of sustainable use to raise funds and create economic incentives for wildlife conservation. This power stems from the ESA permitting process, creating an additional set of arbitrary standards exporting range nations must meet on top of those already agreed to by the United States and the other 182 nations that are parties to the Convention on International Trade in Endangered Species (CITES), a multilateral agreement governing the global trade in biodiversity, including hunting trophies.

Despite its name, CITES does not designate species as either “threatened” or “endangered,” but rather assigns them to one of three appendices. Both the African elephant and African lion are currently assigned to Appendix II of CITIES, meaning that the convention’s parties have agreed to control trade to avoid utilization incompatible with the species’ survival. With regard to elephants, this control is reflected in a complete prohibition on international, commercial trade in ivory and Tanzania having export quotas of 50 elephants in 2017.

Quotas such as these are set by the CITES managing authority in each range nation, typically a national level wildlife agency, and represent a ceiling beyond which harvest and export should not exceed. Quotas are governed under a set of formal guidelines and agreed to via the Conference of Parties to the Convention held every three years. Businesses that depend on CITES export permits for their viability, such as hunting outfitters, plan around these agreements. However, the United States’ ability to suddenly, unilaterally and arbitrarily second-guess the judgment of its international allies in wildlife conservation and the CITES process itself via the ESA import permitting process makes such planning increasingly difficult. This can lead to disastrous consequences like those being witnessed in Tanzania.

The capriciousness of current permitting authority is underscored by the fact that the Obama administration’s elephant trophy import moratorium was eventually abandoned following successful litigation brought by the National Rifle Association and Safari Club International. This victory highlights the need for the agency’s permitting authority to be revisited by Congress and the Trump administration so that it is exercised more in concert with international agreements to conserve biodiversity, like CITES, and is heavily informed by range nation and NGO (Non-Governmental Organizations) partners in advance of any final decisions being made. Establishing better frameworks for such cooperation can help to ensure that hunters remain able to serve as stewards of the world’s wildlands and that events like those that unfolded around the Selous do not befall other areas critical to conservation.

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Editor’s Note: As referenced above, Shikar Safaris, operated by Kaan Karakaya—recipient of the SCI International Professional Outfitter of the Year in 2015—is yet one more example of how hunting operations give back to the collective hunting community and the future of wildlife conservation. Karakaya is a member of the NRA Ring of Freedom and a member of the President’s Founders Club of the NRA Hunters’ Leadership Forum. In 2012 he donated to the NRA Freedom Action Foundation and in 2013 donated a hunt to the NRA Women’s Leadership Forum’s annual fundraising auction. To read how this Turkish citizen learned the importance of wildlife conservation and the NRA’s vigilance in protecting the Second Amendment, click here.