Dear Secretary Zinke,
Thank you for taking the time out to read this letter. I fully realize how compressed your schedule must be, so I’ll keep this brief.
My name is Carla van der Vyver and I am writing to you on behalf of the South African Predator Association. Most of our members breed and keep lions and many of them supply lions to the hunting industry. In this we are in step with the rest of the game farmers in South Africa. This industry has wrought one of the greatest conservation miracles in the history of the world. South Africans, like the citizens of the United States, come from a proud hunting industry. When, as a result of industrialization and commercial farming, stocks of prey animals were running low, they started breeding game on extensive farms.
These days some 10,000 farms cover an accumulative area of around 108,000 square miles, accommodating between 16- and 20-million wild animals which live in pristine, unsullied natural surroundings. Thousands of hunters flock to South Africa in search of prime hunting opportunities. Of all the prey coveted by hunters, the supreme animal is the lion. It is especially American hunters who value the lion as the ultimate trophy and many of them consider taking a lion as the pinnacle of his or her hunting career.
You are surely aware that wild lion numbers have declined disastrously over the last few decades. There is really only one way of making lions available to American hunters without putting undue pressure on wild populations, and that is to breed them. Our Association works around the clock to make sure that this is done according to our very high norms and standards and that the hunting is conducted in a fair, ethical and humane way.
Because of the lion’s elevated status, anti-hunting activists have focused on the captive-bred lion hunting segment as a vulnerable target. In this they have been aided and abetted by the same mainstream press which is so vehemently resisting Mr. Trump. We have so far been able to absorb their most aggressive assaults, but last year our industry was dealt a real body blow.
During the previous administration the U.S. Fish and Wildlife Service listed the lion (in this case Panthera leo melanochaita) as threatened under the Endangered Species Act (ESA.) This was done "in response to the dramatic decline of lion populations in the wild."
We find this decision understandable. The one thing all admirers of the lion agree on is that the main focus and priority of lion conservation must be to protect the wild lion populations. The USFWS also demonstrated a clear grasp of the conservation benefits of trophy hunting.
"Sustainable trophy hunting as part of a well-managed conservation program can and does contribute to the survival of the species in the wild, providing real incentives to oppose SAPA letter to Secr Zinke – Lion hunting South Africa Page 2
poaching and conserve lion populations," according to the former director of the USFWS who was at the helm when these decisions were made, Mr. Dan Ashe.
The USFWS subsequently ruled that permits may be issued for the import of wild lion trophies from South Africa. However the import of captive-bred lion trophies has been prohibited. We humbly submit that this step is an inconsistent implementation of the regulations. The USFWS clearly differentiates between wild and captive-bred lions, but then lumps them together when listing the lion under the ESA, only then once again to differentiate between them. Either captive-bred lions are wild, in which case the import of their trophies should be regulated in the same way as other wild lions, or they are not wild, in which case they are not part of the USFWS’ purview and they do not have the authority to prohibit the import of captive-bred lion trophies. We suggest that the USFWS is morally obliged to make a choice in this matter.
The USFWS could however only implement the ban by following all the regulations. As such, the would-be importers of captive-bred lion trophies have been given the opportunity to prove that the import thereof would serve a purpose in lion conservation.
"Regardless," Director Ashe wrote in an opinion piece for the Huffington Post, "our decision to prohibit such imports is based solely – as the law requires – on our evaluation of the conservation benefits of captive lion hunts. If and when such benefits can be clearly shown, we may reevaluate our position."
What exactly these benefits to be proven are has not been explained or otherwise established. In fact, it must be clear to any objective observer that the captive-bred lion population is immensely important to the well-being of the remaining wild lions:
The mere existence of a healthy and, make no mistake, happy, disease-free and thriving population of lions with carefully screened DNA is an enormous benefit. As long as this industry exists, the lion is not under threat of extinction. To be sure, SAPA has demonstrated that captive-bred lions easily adapt to the wild. This makes it possible to augment wild lion populations or to reintroduce lions into wild areas from which they have disappeared decades, even centuries, ago. If one take into account that as many as 80% of the animals in SA’s biggest meta-population wild lions, those in the Kruger National Park, are stricken with either feline AIDS or bovine distemper, the existence of the captive-bred lion population could be more than just academically reassuring.
The presence of the lion in the hunting industry has had a very positive regenerating effect in large areas of the country. Where lions are present, there are no cattle. The farms become fully-fledged wilderness areas. Lesser predators like jackal and caracal return, as do small animals like rabbits and meerkats, followed by insects and reptiles. Soon the vegetation is regenerated. These are demonstrable, immensely valuable benefits; conservation benefits. Remove the captive-bred lion from this situation and many of these farms will be reconverted to cattle farms to the obvious detriment of conservation in South Africa.
The captive-bred lion industry has many other, direct conservation benefits. By serving the need for the trophy hunting market these lions take the pressure of the wild lions. Fewer than ten wild lions have been hunted annually before the import ban. There will without a doubt now be a shift of focus towards the hunting of wild lions.
The captive-bred lion industry also adequately provides the domestic and foreign traditional medicine markets with lion bones and other bodily parts. Lion poaching was almost unheard of in South Africa until the ban took effect after which there was an immediate uptick in lions brutally slain and butchered for these parts. SAPA letter to Secr Zinke – Lion hunting South Africa Page 3
The captive-bred lion industry supplies thousands of jobs in the poorest areas in South Africa, handsomely donates meat and supplies to rural communities, and injects capital into districts which depend on it. SAPA members also pay a hefty levy for every lion which is hunted and every cent of this goes to direct conservation efforts.
The effect of the ban on the import of captive-bred lion trophies has been devastating on the industry. Feeding and maintaining almost eight thousand predators is prohibitively expensive and the only way these breeders can pay for it, is to make some of these animals available to hunters. Without American hunters this industry will shrink precipitously. These farmers will not see their animals starve to death, so thousands of lions will be euthanized. The lush, wild habitat will once more become dusty cattle farms. Thousands of other animals will have to make way for it.
The South African game farming industry has a long and proud history. It has saved a number of flagship species from extinction and it did it by supplying hunters with huntable animals. Captive-bred lions are a valuable segment of this economic sector. We ask your help in preserving this enormously valuable and crucial industry.
Mrs. Carla van der Vyver
On behalf of the South African Predator association