March 20, 2023

CSF Submits Comment on Proposed FWS Revision for the African Elephant

Why It Matters: Efforts to conserve – not “preserve” – African species are generally honorable, but they must be made in coordination with the range nations where the species are located. To implement a process that creates unreasonable hurdles on these nations poses to, among many things, curb hunting in Africa and sideline the coordination called for under the Convention on International Trade in Endangered Species (CITES). In submitting a letter of opposition, the Congressional Sportsmen’s Foundation made it clear that implementing additional hurdles that certain African nations must clear to receive an annual certification from the FWS is counter to an existing CITES Resolution and has the potential to thwart much-needed, sport-hunting generated dollars away from elephant conservation.


Earlier today, the Congressional Sportsmen’s Foundation weighed in on the U.S. Fish and Wildlife Service’s (FWS) proposed revision to the rule for the African elephant under section 4(d) of the Endangered Species Act of 1973. This rule would require “range countries that export sport-hunted trophies to the United States to provide the Service with information about the management and status of African elephants and the hunting programs in these countries” in order to obtain an annual certification – a burdensome hurdle that would serve to undermine hunting in Africa.

In its letter of opposition, CSF highlighted the fact that this proposed rule runs counter to the collaborative spirit laid forth by Resolution Conf. 6.7 of the Convention on International Trade in Endangered Species (CITES), which states that “[E]ach Party intending to take stricter domestic measures pursuant to Article XIV, paragraph 1, of the Convention regarding trade in specimens of non-indigenous species included in the Appendices make every reasonable effort to notify the range States of the species concerned at as early a stage as possible prior to the adoption of such measures, and consult with those range States that express a wish to confer on the matter” (emphasis added). Additionally, CSF emphasized the significant economic role that regulated hunting plays in generating revenue for conservation and anti-poaching efforts in Africa, as well as the fact that the proposed rule fails to account for the input of African host countries and their ability to manage wildlife – a right that belongs solely to these countries and their governments.

With the comment period closing at midnight tonight, the FWS will have its hands full reviewing the wave of comments it has received. CSF would like to thank the many organizations and sportsmen and women who submitted comments on this topic, calling for the FWS to reject the proposed rule. This issue is ongoing, and CSF will remain engaged and provide additional updates as they are made available.

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