We all know the bad news by now. The federal government has finally disgorged the listing of lions under the Endangered Species Act (ESA). SCI members have been waiting for this proverbial second shoe to drop since the official notice of proposed listing was issued in October of 2014. But it’s important to remember that the process leading to the listing actually began in March of 2011. That’s when the Humane Society, Defenders of Wildlife and a handful of the other usual suspects turned in a petition demanding the listing. That means that the government had more than five years to consider this issue and its ramifications.
The very lengthy notice is odd in many respects. It was released on December 23, 2015, a day when few Americans are scrutinizing the machinations of the federal bureaucracy. That alone gave it the flavor of a bomb tossed over the parapet just as the federal castle was locking itself down for the holidays. And the rest of the notice illustrates why its bureaucratic authors may not have wanted to hang around to answer questions.
After the requisite discussion of taxonomy, the listing cites the population numbers of lions in various range states – but only after noting that all such numbers are estimates, since lions are hard to count. It then goes on to assume that lion populations will plunge dramatically, using the word “likely” in three places to qualify its assumption. And of course, climate change makes several cameos throughout the notice. In this section, the report loftily assumes that “the impacts of these threats are likely to be exacerbated by climate change.” And while the listing encompasses captive-bred lions in its new permit restrictions, it does not consider captive populations in its estimates. More on that later.
The regulation then goes on to discuss increases in human population that will lead to habitat loss. Again here, science is hard to find. There is an entire chart of assumed increases in population listed by country, but you have to read the fine print to see the source – the United Nations. Presumably that’s because we all know the UN headquarters building is packed full of the top scientists that world governments have to offer.
There’s more, much more, but you get the idea. The “science” in the listing notice is really an aggregate of speculations from a variety of sources, much of it purporting to predict a variety of conditions fifty years out, when no one can say what other factors may be at play. Where have we seen this before? The polar bear ESA listing was also full of conjecture and assumptions about environmental conditions far in the future. And the 2015 notice that selectively banned elephant imports admitted, in print, that the government simply didn’t have the information it wanted.
Much fanfare also attended the new “Director’s Order” that was announced along with the listing. Justified as part of the Obama Administration’s “National Strategy for Combating Wildlife Trafficking,” the Order “establishes policy and procedure for Service employees to assert our full legal and regulatory authority to deny wildlife violators the ability to obtain wildlife permits, certificates, and licenses.” The criteria here are wide-ranging, including any criminal conviction or civil penalty for “any statute or regulation relating to the activity for which the permit is filed.” Other factors for which a permit may be denied include “a lack of responsibility” or failure “to demonstrate a valid justification.” As SCI Past President Don McMillan used to say, they may also check to make sure you are wearing the proper shoes.
The discussion about captive-bred lions is the most absurd part of the listing. After noting that fully 99% of lion exports from South Africa are captive-bred, the listing admits that captive breeding “may reduce the pressures of trophy hunting on wild populations.” But it goes on to state that “additional research is needed to verify this claim.” Perhaps they can also confirm the sky is blue if they ever get around to checking. But again here, climate change gets an unquestioning embrace when they note that it is “likely to become a main driver of change in large mammal populations in the future.”
The reality is that this is a political document, intended to meet a political objective ordered down from on high. In that respect, it bears an unmistakable resemblance to the series of executive orders the White House recently ordered to restrict our Second Amendment rights. It’s a gasping stab from an administration desperate to create a legacy. Your Washington team is already canvassing Capitol Hill to illustrate its fallacies to interested Members of Congress. Several of them have rightly asked why the Service also has made no preparation for the permitting process, particularly given the fact that they had more than five years to do so. We will harness and focus their energies into productive efforts to probe and push the administration for resolution.
SCI Foundation is also part of the answer, given the longstanding working relationships it has cultivated with regulators in range states. If the U.S. government is unable or unwilling to find the information needed for enhancement findings, we will bring it to them.
Your SCI teams in both Washington and Tucson are uniquely positioned to fight this listing. But in the end – as with all things political – it may require a purely political solution. Sometimes the best way to change policies is to change politicians. And 2016 is our opportunity to replace this Administration with one that values hunters and our tremendous contributions to conservation worldwide. Traveling hunters have taken some body blows from Washington bureaucrats in the past several years, but that’s just the beginning of what would be aimed at us during another four to eight years of zealous anti-hunting regulations and restrictions. The SCI Political Action Committee is the tip of our spear, and all members will be receiving requests this year to contribute to its success. The future of hunting depends on you.
This information and photos posted by firstforwildlife at http://tracking.safariclub.org/dm?id=4398D7DDDCD806C53A93CAA6FDB2423E