Ban Info

Dear Folks,

With many people inquiring with us about the ivory regulations imposed by the US Fish & Wildlife Service we have the below information to help you understand what the more recent (2016) regulation entails. We are not your law firm nor are we the USFWS nor the State Department so if you desire answers from those folks you need to ask them. To the best of our knowledge the information seen below is accurate because it came from USFWS.

USFWS has put a regulation into place that took effect on July 6, 2016 and affects the sale of pre-ban African elephant ivory in the USA. The new regulation forbids the interstate sale of ivory in the US unless the item qualifies as an ESA (Endangered Species Act) antique OR if the item meets the "de minimis" exemption. Below are the requirements of these two exemptions:

1) To qualify for the ESA antiques exemption, an item must meet all of the following criteria [seller/importer/exporter must demonstrate]:

  1. It is 100 years or older.
  2. It is composed in whole or in part of an ESA-listed species;
  3. It has not been repaired or modified with any such species after December 27, 1973; and
  4. It is being or was imported through an endangered species “antique port.”

Under Director’s Order No. 210, as a matter of enforcement discretion, items imported prior to September 22, 1982, and items created in the United States and never imported must comply with elements A, B, and C above, but not element D.

2) To qualify for the de minimis exception, manufactured or handcrafted items must meet all of the following criteria:

  1. If the item is located within the United States, the ivory was imported into the United States prior to January 18, 1990, or was imported into the United States under a Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) pre-Convention certificate with no limitation on its commercial use;
  2. If the item is located outside the United States, the ivory was removed from the wild prior to February 26, 1976;
  3. The ivory is a fixed or integral component or components of a larger manufactured or handcrafted item and is not in its current form the primary source of the value of the item, that is, the ivory does not account for more than 50 percent of the value of the item;
  4. The ivory is not raw;
  5. The manufactured or handcrafted item is not made wholly or primarily of ivory, that is, the ivory component or components do not account for more than 50 percent of the item by volume;
  6. The total weight of the ivory component or components is less than 200 grams; and
  7. The item was manufactured or handcrafted before the effective date of this rule. (editor's note: July 6, 2016)

What this means for most of us is that items made with pre-ban ivory can only enter interstate commerce if they are small parts (cue stick parts, piano keys, gun grips , etc.) that are part of a larger item (such as a gun or cue stick) and the ivory was from pre-ban (pre-1990) tusks AND the item was made prior to July 6th, 2016. Any ivory item can sell within a state (intrastate commerce) so long as it was made from pre-ban (pre-1990) ivory.

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The Truth about Ivory & Elephants

I thought a few words about wildlife conservation, as it relates to elephants, might be of interest. My grandfather started working in ivory in the early 1900's and my dad, as a kid, in the 1930's. I started working in this beautiful material when I was a kid in the 60's. Dad started buying old tusks from collections in the 1950's and I continued and expanded on this practice in the 1970's and beyond. In 1989 it became illegal to import ivory into the US with a few UN sanctioned exceptions (Big game hunting, antiques, and for people's property when moving internationally). Because I worked in pre-ban material this regulation had no effect upon my work.

In 2013 with executive order # 13648 there was a push to make commerce in old pre-act ivory in this nation illegal. This resulted in a regulation put forth by US Fish & Wildlife on July 6, 2016 that has made the interstate sale of most pre-ban ivory items illegal. This is environmentalism. As thinking people we should be in favor of programs of properly managing wildlife. This is known as wildlife conservation and it is at variance with environmentalism. This treatise will explain the differences between these two ideologies and of how wildlife conservation works and of how environmentalism fails us.

As the reader continues it should be kept in mind that this most recent federal regulation stops the sale of OLD ivory within the US. This is not about new ivory coming into this nation but about the sale and use of the OLD antique ivory that was brought here legally prior to 1990.

The truth about elephant populations in Africa is something nobody wants to talk about because the truth reflects upon politics in Africa and here in America. When the European countries colonized Africa in the 18th and 19th centuries they brought with them the European model of wildlife conservation. This model worked well, elephant populations were healthy, and yet people were able to develop the land. I will detail some of the conservation methods employed because they are interesting but first let's look at what went wrong.

 When western colonialism went by the wayside and the African people started "controlling their own destiny", the northern countries, in rebellious fashion, threw out the western model of conservation and with it went the quality control and methods for these animals to thrive in and under. The southern countries in Africa did not throw out the European system and those countries have a superabundance of elephants to this day.

To see how well the western model works one need only to look at the astounding wildlife populations and the continuation of species in Europe where human civilization has historically been the hardest on nature and wildlife. Europe has been the scene of the most intense wars, plagues, famines and pestilences, where, time and time again, people were thrown into situations where they have had to live off the land. Through such perils and environmental hazards their wildlife management model continued to work and it continues to work very well to this day. It also worked very well in Africa where elephant populations were healthy in the days of western colonialism.

The new way of thinking in the northern countries, especially Kenya, was that wildlife was to be considered a natural resource no different than natural gas and oil. Their philosophy towards wildlife was that "when it is gone, it is gone". It was only when the elephant and other animals were nearly eradicated from these countries, and they were losing tourism dollars, that they realized they had made a mistake and then tried to backpedal and to blame their problems on others.

The European model is very scientific and has many aspects to it but let's first look at a few elephant facts that will make the conservation methods more understandable. Elephants are herbivores and grind their teeth to dust as they consume a lot of earthy grit along with their food. An elephant goes through a set of teeth in 6 to 10 years. When these teeth are worn out, they are replaced by a new set but there is a limit as elephants have the capacity for only six sets of teeth in their lifetime. The last set comes in at around age 40 and when these last teeth wear out the elephant dies a slow and unpleasant death by starvation. With no natural enemies, elephants are faced with disease and starvation as the only limitations to their continued success in the wild. For this reason elephant herds grow rapidly and they quickly overpopulate their range and soon destroy their habitat. The Sahara desert was once a sub-tropical paradise until elephants turned it into a desert. An average elephant eats its weight in food every 20 days (usually between 500 and 750 pounds per day) and drinks 60 gallons of water per day. That is per elephant per day. A proper population balance is important if the ecosystem wherein they live is to be kept from becoming a desert.

These and other facts of nature regarding elephants caused the conservationists to develop a program that was designed to protect the elephant, keep the herds healthy and numerous, and at the same time protect the land from deforestation by these creatures.

Let's look at a few of the hunting rules. Permits were sold, usually at a hefty price, to sportsmen who were escorted by professional hunters who were licensed by the government and trained in acceptable hunting methods. The permit fees paid for the conservation efforts maintained by the government just as they do in most countries. Female elephants could only be shot in self defense. Sex had to be determined prior to shooting. If a man tracked a particular elephant for weeks and then discovered he had tracked a female - the hunt was over - he could not shoot. Diseased and old elephants had the highest priority for being shot.

These hunting regulations made sense. As long as there is one bull elephant around during mating season, every female gets pregnant and has a calf. Many bulls are not needed and diseased and old bulls are not wanted for the job. You have the healthiest herds if you breed young and healthy stock. The older matriarchs teach the younger one's how to migrate, attain water, etc.. Sport hunters want the biggest tusks and these are found on the oldest bull elephants. These are bulls who are past their prime breeding years and who are beginning to starve to death because they are on their last set of teeth or have no teeth left with which to eat.

The old tusks I have bought over the years came from these situations. The hunters were Americans who went to Africa and obtained hunting permits from the national governments in the countries they chose to hunt in. They hired professional hunters to guide them and all of them were apprised of the laws and rules of the hunt.

The number one killer of elephants has always been disease. Number two has always been starvation in old age. Number three is man. When an old or diseased elephant senses the end of its life is near it leaves the herd so as not to slow down the migration and it wanders off to die alone in the countryside. This fact has given rise to the myth of a secret elephant graveyard. Because man does not see the old and diseased die but do see the hunted die he has always assumed he was the biggest killer until scientific research done by the European colonialists proved otherwise.

Pliny the Elder, writing in the first century AD, noted the amount of ivory being brought up from Africa for use in the Roman Empire was so great as to assure the extinction of the elephant within two human generations. Uninformed and misguided people have been making similar claims ever since. The heyday of ivory consumption was from the years 1890 to 1923 and many claims were made at the time that the elephant would be extinct within a few years however National Geographic and Encyclopedia Britannica both confirm that 5 of every 6 tusks brought to market in those years came from "dead ivory". These were tusks the native chieftains had amassed and handed down to successors for centuries. In most tribal areas such collections were symbolic of great wealth but when offered gold coin for their ivory the chieftains opted for the ready cash.

It is of interest that the environmental groups today still make thunderous claims of the impending extinction of the elephants but have never spent a dime of their funds on research in curing elephant diseases which still sits at the top of the chart for elephant kills. Nor do they send money to the wildlife departments of nations in Africa to help fund their wildlife conservation programs where they cull out the diseased and aged to retain healthy young herds. The few environmental groups that spend money on the elephant are busy funding chemical castration programs in conjunction with the African nations. So you are asked to donate money to save the elephants and then your money finances a chemical castration program for elephants. Interesting.

The environmentalists who live in Africa and are closer to the intricacies of this topic have repeatedly warned that an extended ban on the sale of ivory will result in the eradication of elephants. Their reasoning is very interesting and easily understood once a few facts are before you.

We live in an industrialized society and we need to understand that Africa is a developing continent and, with few localized exceptions, is in an agricultural state. As an agricultural society their world view is significantly different than yours or mine. In an agricultural society people cultivate crops they can sell to make a living. If their government or the United Nations passes a law that says it is illegal to sell corn then they have to switch to another crop because if they grow corn they cannot sell it and they cannot make a living.

The elephant, in their eyes, is a crop. In addition, if it does not yield a return it is rightly viewed as a significant liability. Remember that an elephant eats its weight in food every 20 days and drinks 60 gallons of water each day. Understand also there is no fence that can contain an elephant. So if you have an animal that can eat you out of house and home, destroy your crops, travel anywhere to find more food, and is of no commercial value - what are you going to do with it ? Ask your ancestors what they did with the American bison that posed these exact same set of conditions and problems in the 1800's when we as a nation were an agricultural society. The animal goes. In the case of the bison - to the brink of extinction. In the case of the elephant - it will depend on our ability to show the people of Africa that their crop of elephants has value and is worth keeping around for their own benefit and that of their children and grandchildren. If we continue to tell them they cannot sell elephant products they will soon enough say "let's get rid of this crop and get a crop in here we can make money on".

As the human populations of the African countries grow, the elephants have increasingly less space to call home. With no commercial value currently attached to the elephant herds, there is little incentive for the local inhabitants to preserve this majestic ‘land hog’. The answer lies in restoring the European wildlife management methodology and in allowing the harvested animal products to enter the marketplace so there is a monetary incentive for these people to keep elephants around. Likewise, political stability in Africa needs to be promoted because the lack of it causes people to live off the land during civil wars and social-political upheavals. In these harsh times people decimate herds of elephants in order to stay alive. The push for socialism is the root cause of most political instability in Africa.

Info from Godfrey Harris

Godfrey Harris, Managing Director of the Ivory Education Institute, has this to add about wildlife conservation practices:

Crocodiles were the very first species to be placed on Appendix 1 of the Convention on International Trade in Endangered Species— those species threatened with extinction — at the initial Conference of Parties in Washington, DC in 1976. Wild crocodiles were being hunted for their distinctive hides, then in high demand to meet Western fashion trends.

To restore crocodiles to their former robust place in the scheme of things that had been evolving for 100 million years, while realistically recognizing the economic benefits they provide to native populations, crocodile eggs were removed from their swamp nests and taken to private ranches where they were incubated, protected from attack, and nurtured. Since crocodiles are known to lay 50 to 60 eggs at a time, captive areas were soon literally crawling with these amphibians. Harvesting the skins of some of the animals as they passed beyond reproductive usefulness provided the income that allowed the process to thrive. As just one example, Zimbabwe earned $300,000 from crocodile product exports in 1991; by 2014 it was above $24 million.

Managed conservation practices can be instrumental in saving wild animal populations from destructive forces that may lead to their extinction. We just have to remember the Nile crocodile and remind others what can be done when man thinks instead of rearranging his prejudices.

Making an Animal Extinct.

Making an animal extinct is a very difficult thing to do. It is almost impossible to do as a commercial venture because as the population decreases of the specie being hunted, it becomes commercially infeasible to find and harvest the animals in the more remote regions where they can be found and where they are more sparsely populated. At the same time that it becomes a financially losing proposition to seek out and kill the animals, the rising price of the product in the marketplace causes the buying public to seek alternatives to the product such that, in the end, with competition in the marketplace, the price of the product plummets and harvesting the animals becomes a totally losing proposition.

The history of the North American sea otter is the best example of this. Never has an animal been more hunted in the world for commercial purposes than this creature which is an exceedingly easy animal to harvest and was harvested intently in the 1700's and 1800's before any protection laws were in place in their range. But they were never hunted to extinction nor even near extinction. The free marketplace factors just mentioned imploded the price of sea otter pelts and man left the critters alone. Had scientific wildlife management been in place the price would have plummeted earlier and there would have been an even stronger base from which they could repopulate.

The introduction of competitive products is what really saved the elephant. Plastic was first invented in the early 1850's and was developed specifically to replace ivory. Plastics were improved from there with one purpose in mind - to replace ivory in the marketplace for utilitarian items such as billiard balls, combs, brush backs and handles of every type. Vulcanized rubber was also invented in the 1800's for the specific product/market niche of replacing ivory in utilitarian items.

As we have seen that it is difficult to make an animal extinct as the result of commerce in its' products we need to note that it is far more likely to make an animal extinct if there is a willingness to get rid of the animal. If an animal is considered by mankind to be a pest then man can and will find a way to be rid of it. Let's look at the North American bison example again. The bison was viewed as a pest and an animal that could not co-exist with the development of an agricultural society and nation. It carried diseases that decimated domestic cattle herds and it was, in itself, an animal of low product yield. It was also a wild animal that could not be domesticated. These factors led to a national thought process that said this animal needed to be eradicated.

When I was in grade school I was taught the bison would be extinct soon because there were only a few hundred left in the country at the time but soon enough man found a way to commercially farm the beasts and now you can buy bison meat in many supermarkets. Commercial viability saved the animal just as commercial non-viability nearly made it extinct. The same will be true of the elephant. If you tell people they cannot sell elephant products they will rightly view this giant animal as the greatest of all pests and, with a willingness to rid themselves of this pest, they will purge this animal from their land and then plant crops they can manage and profit from. In the case of the bison the commercial non-viability of the animal was due to the lack of technology. In the 1800's a man on a horse was no match for a bison so men were not able to manage the animals. Today, men in trucks, tractors and helicopters can manage these animals.

People in an agricultural society will plant and harvest crops that yield the greatest amount of monetary return. If you tell people that corn is of no value they will plant sorghum. If sorghum is of lower value than wheat then they will plant wheat. If you think elephants and their resulting products of hide, bones, meat and ivory are not a crop than you are ignorant of the facts. If you tell the nations of Africa they cannot sell their elephant products they will, in time, simply get rid of that crop and turn to a crop that can and does produce. The answer is to farm these animals with European style conservation techniques and that is exactly what most of the southern countries in Africa do and they are the countries with the largest and healthiest herds of elephants but they will not be able to continue in this work if they are not allowed to sell the resulting products.

Are Elephants Hunted For Their Ivory?

 I wanted to touch briefly on a topic that I have heard my life through, namely that elephants are hunted for their ivory and that if elephants did not have tusks they would not be threatened but would be left alone to live their lives in peace and quiet. The African elephant has never landed on the endangered species list. While this fact speaks volumes it is not to say the animal does not need our protection but to keep people from using ivory is not the answer. If you need proof of this then consider the tusk facts of the 3 species of elephants on this planet in relation to the animal's endangerment. The Ceylon elephant is almost extinct - there are a couple dozen of these guys left and, interestingly enough, they are a tuskless elephant. The next critter to look at is the Indian elephant. It has been on the endangered species list since the list came out. It does not yield ivory in quantity or quality and its' ivory has been bypassed for centuries in the ivory world in favor of the high quality African ivory. That leaves us to look at the third critter - the majestic African elephant with the highest quality ivory known to man - yet it is not on the endangered list. The resulting truth is stark - the elephants with the largest and best tusks are the least endangered. The elephants that are naturally tusk less are nearly extinct. It makes sense that the elephant specie with the highest quality and highest value ivory tusks are going to be cultivated by man by virtue of adopting a working wildlife conservation program for them. Likewise the elephant species that hold little or even negative commercial value would engender little or no such conservation programs and, being viewed as pests, mankind would work to be rid of these non-commercially-viable animals.

 All one has to do is to think of cows and chickens. If they had no value to man they would have been extinct long ago because they are defenseless and stupid animals. Because they have the greatest value to man of all the animals on the planet we have learned to domesticate them and breed them into the hundreds of millions. Modern environmentalism has been working for 60 years to destroy the trade in ivory and hence the value in ivory. By de-valuing ivory they are de-valuing the elephant. Sixty years of this has shown us it is not a working program.

 Less than 1% of the animals and plants that are placed on the endangered species list actually go extinct. This is good statistic until one realizes that less than 2% of these species recover. Simply put, once on the list, these species will not be making a comeback. The ESA and CITES simply do not work and by their own admission they do not work. They fail to address the key factor necessary for a specie population rebound and that is having a monetary incentive for people living among the species to benefit from a comeback.

 When the African elephant becomes value-less because of environmental pressures worldwide to stop the legal sale of ivory in every possible jurisdiction on the planet then the people and nations who have elephants will have absolutely no monetary incentive to keep these animals around. The environmentalists who are trying to save the elephants are actually the people who will be responsible for making them extinct. Their current misguided actions are due to their lack of understanding of market forces and true wildlife conservation and of how the two have worked together, historically, to balance wildlife in its habitat.

What environmentalism is trying to do today is the exact opposite of what has been proven to work, historically, to preserve wildlife. Historically, wildlife management hinged on a two point system. First, the free market was not controlled or tampered with by the government but was left alone to determine the value of the wildlife products in question. Secondly, and very importantly, the wildlife was scientifically managed at the location/range where the animal or plant existed. This wildlife management system has worked very well in every area where it has been implemented and it worked very well for the African elephant until it was abandoned, gradually, starting in the 1960's. Since then there has been more governmental control of the marketplace and less control of the actual wildlife management on the ground where the animal lives. Modern environmentalism is working on this new theory - that of controlling the marketplace and not managing the wildlife where it lives. This has never been tried before - do we want to risk the extinction of the African elephant by continuing to implement a system that has never been tried before and that is the opposite of what has proven to work? What has been implemented of this new system these past 60 years has shown itself not to work. Should we continue or go back to what works?

Info from Ron Thomson

Ron was deeply involved in the management of both Hwange and Gonarezhou National Parks in Zimbabwe. He is the author of many books on conservation in Africa (http://www.ronthomsonshuntingbooks.co.za). He is an expert who has lived and managed wildlife. Read his words about elephant populations in southern Africa, the animal rights groups, and the attitude of American government agencies toward the environmental and conservation problems that Africa is experiencing.

Here is what Ron has to say:

Wildlife in Africa will only survive in the long term if it has a true value for Africa’s rural people. Once the rural people of Africa ‘own’ their own wild animals, and they are able to make a legitimate living from the sale of their products (such as rhino horn and ivory), will they (the rural people of Africa) start to look after (and NOT ‘poach’) these animals. This will happen because it makes no sense for anybody to steal something that already belongs to them. If the people already own the rhinos and the elephants in Africa, and they are making a good and sustainable living from the management of these animals, why WOULD they want to poach them?

Africa needs the help of the Chinese people to make this happen. Those Western-based animal rightist NGOs who oppose the Chinese trade in rhino horn and elephant ivory, are making a very good criminal living from the controversies that they perpetuate. Let’s use the African elephant as an example. In southern Africa, there are ‘too many elephants’. All the southern African national parks are stocked with elephant populations that grossly exceed the elephant carrying capacities of their habitats - by as much as ten and twenty times! This is causing the total destruction of the game reserve habitats - and ALL WILD SPECIES in these game reserves (of both plants AND animals) - are, therefore, under a long-term threat of ultimate extinction. And, this being the case - the fact that there are too many elephants in southern Africa - confirms that the elephant is certainly not anywhere near being ‘endangered’ - or facing extinction. Nevertheless - the Western animal rights NGOs - in their propaganda campaigns - tell their societies that the elephant is ‘facing extinction’ (which is a contrived lie). They then solicit donations from ‘the people’ to help STOP the elephant from “becoming extinct”. (How can anybody help an animal from becoming extinct when it is not anywhere near BEING extinct?). Such niceties, however, don’t bother these NGOs. Their purpose is not to tell the truth. Their purpose is also not to help the elephant. Their purpose is to make money out of ignorant and gullible people in the big Western cities.

These NGOs - altogether - make hundreds of millions of US dollars from these scams every year. And their recent escapades in Hong Kong - to stop the sale of rhino horn artifacts - is all part of their pernicious scheme. When someone tells a lie and then makes money of that lie - that activity is called “common fraud”. When that fraud is carried out a second time (or ‘more than once’) it legally becomes a ‘racket’; and racketeering is one of 35 other such crimes that - according to the American Racketeering Influenced and Corruption Act (The RICO Act) - have been constituted (by American law) as being part of “organized international crime”. These are the kinds of people who are stopping China from pursuing their traditional ivory carving and rhino horn traditions. These are the people who are stopping the establishment of a legal rhino horn and elephant ivory trade between Africa and China. Africa is a legal producer of ivory and rhino horn; and China represents a potential legal market for both these products. It makes sense, therefore, for Africa and China to open up mutually beneficial and legal trade in both these wildlife commodities. The Chinese people are being treated like ignorant peasants by these Western NGOs. The Chinese, therefore, must take the trouble to understand just WHAT these NGOs really are, and HOW they operate. And they should take offense at the fact they are being treated by these NGOs like imbecilic fools.

If Africa’s rural people cannot make a better living from the controlled and sustainable harvest of our wildlife resources, than they can get from their cattle, sheep and goats, and growing mealies (maize), they will opt for what they know best: cattle, sheep, goats and mealies. Our valueless wildlife will then be up against the wall and it will be decimated by the hordes of human beings (4 billion) that are expected to be living in sub-Saharan Africa at the end of this century. There are only 750 million today!

Is there a direct link between the commercial poaching that is going on and the increase in the size of rural populations? “Yes.... largely, but most greatly the poaching can be linked to bad governance, personal avarice and political incompetence. It got really out of hand only after each country shed its colonial yoke. That is why serious commercial poaching started in East Africa - in Kenya and Tanzania - in the 1970s. They were the first countries in east and southern Africa to gain their independence. And that is where the most horrific commercial poaching events took place. Kenya’s elephant population, for example, declined from 270 000 to 20 000 - due to poaching that was orchestrated by the Kenyatta family - in just 20 years. And decolonization, decade by decade, crept inexorably ever more southwards. If you follow the pattern, commercial poaching moved down the African continent in concert with the decolonisation process. It did not rear its ugly head in South Africa until after 1994 when apartheid was dismantled.”

End of Ron's information.

Here is a piece from the True Green Alliance - a genuine environmental group in Africa:

If CITES — the UN Convention on International Trade in Endangered Species — did not exist we would want to invent it. This treaty was signed, and its secretariat authorized, in 1975 to regulate commerce in wild flora and fauna to prevent their extinction. It was the proper step to take to stop indiscriminate and irreversible damage to wildlife species. Over the years, however, the Geneva-based organization charged with enforcing the treaty’s provisions has been hijacked by Western animal rights groups. Their goal is to block all forms of trade in wildlife products even in cases where it is scientifically justified.

In particular, the CITES organization has failed to serve Southern African countries, specifically with regard to their elephant and rhino populations. Therefore, CITES’ relevance to the member states of the Southern African Development Community (SADC) on matters affecting these iconic species is now highly questionable. CITES has frustrated many people in Southern Africa, ranging from presidents and government ministers to the leaders of the rural communities that live side-by-side with these animals. The frustration is most palpable where rural communities pay the costs of living with wild animals without realizing any of the benefits.

Worse, the trade ban in elephant ivory and rhino products imposed at the insistence of the animal rights groups has neither stopped poaching nor diminished interest in the products, but it has eliminated local communities’ benefits from wildlife. Ironically, trade bans only help to increase poaching. Professor Marshall Murphree writes in a recent issue of Conservation: “Everyone agrees that the illegal ivory trade continues despite the international trade ban. It has (in fact) been an abject failure. CITES has had 27 years to evaluate (this) experiment and, far from being part of the solution to illegal elephant killing in Africa, the ban must be seen as part of the problem.”

But this lesson has never been learned by the animal rights groups, some CITES member states or the CITES Secretariat because it is something they didn’t want to learn.

The animal rights groups attract enormous contributions from Western donors by claiming that donated money will stop poaching from driving iconic species into extinction. Apart from paying big salaries for animal rights groups’ staff, the money also helps fund CITES delegates’ travel and member country involvement in CITES activities as well as Secretariat expenses. Little, if anything, goes towards protecting the animals.

This corrupt cycle will continue unless the countries, whose wildlife is suffering at the hands of CITES, are willing to end it. Japan did just that in a recent decision to resign its membership in the International Whaling Commission (IWC). Japan saw how the big international non-governmental organizations influence the prevention of any form of trade in wild species — even where the evidence is clear that some whale species are no longer in danger. Japan will now resume whaling in its territorial and economic zone waters. The countries of SADC should take the Japanese example to heart — declaring now that if CITES votes to enforce policies that individual SADC countries deem to have failed its wildlife, rural populations or national interests — they will in response refuse to abide by such harmful decisions.

“At every (major CITES) meeting the animal rights groups spend their time illegally ‘buying’ votes from sovereign states to the extent that they now control all the important issues on the agenda (either by means of outright bribery; or by means of ‘underwriting’ the delegates’ expenses at the convention),” said Ron Thomson, an ecologist and CEO of the South Africa-based True Green Alliance. “Sovereign states can no longer rely on CITES for an honest outcome when it comes to ‘trade in wildlife’.”

If CITES continues to maintain a position that bans trade in elephants and rhino products, serious environmental damage will be done in the Southern African region. If these keystone populations were to collapse, it could bring down the entire ecosystem that people depend on for their food and livelihoods. “The reality in Africa is that no wildlife will survive this century unless its ‘needs’ are integrated with the ‘needs’ of Africa’s rural people in a state of symbiotic harmony,” said Mr. Thomson. The CITES rhino and elephant “conservation ship” is sinking.

Shouldn’t SADC countries work for its replacement or reform? If they don’t do something, their elephant and rhino populations will be victims of a now well-known and man-made wildlife die-off. Responding to this danger, the world’s largest rhino breeder, South Africa-based John Hume said: “At a certain point, sovereign countries need to do as Japan did to the IWC; ditch conservation partnerships that do not benefit their wildlife and the people.”

Will SADC countries make a courageous and principled decision before the CITES meeting in Sri Lanka in May 2019 that responds to the needs of their elephants, rhinos, and people? We hope so. Africa can no longer surrender its sovereignty to Western animal rights organizations that are intent on controlling its wildlife to support their fundraising interests.

WHY?

The answer to the question of why animal activist groups and political hacks would work to implement these policies is best answered by saying "money and power". The foot soldiers in the groups are thinking they are doing what is best for the animals but without a background in true scientific wildlife management they are easily led into believing what their leadership wants them to believe. The leaders in this movement are true socialists and so they seek money, power and control.

 Let's look at the money. It comes to them in three forms:

1) Donations to environmental groups surge when hot topics such as elephants, panda bears and snow leopards are thrown on the screen. In addition to individuals donating money there is a continual flow of corporate donations and private foundation donations into the coffers of these extremely wealthy environmental groups. In recent years journalistic research has exposed that several such groups have been sheltering hundreds of millions of dollars each into offshore bank accounts. Below this treatise of mine I have reprinted a TimesFreePress.com article that expands upon this topic.

2) These environmental groups are the ones that receive many millions of dollars each year in grant money from the US government, private foundations and the UN to study these animals. This is also why the studies always report that these animals are in great danger. If the studies showed there is no problem then they cannot request more grant money for future studies.

3) Fine money. Deep in the hundreds of detail pages of any regulation are the protocols of where the fine money goes. When the EPA, NOAA, FWS and other regulatory agencies fine a company for a violation of a regulation we all think the fine money goes to the US Treasury but it does not. When the EPA fines Exxon $ 200 Million dollars for an oil spill, the case then goes to a judge to determine the payment and details of the fine. Referencing the fine print seen deep in the hundreds of pages of regulation details, the judge then determines which environmental group or groups will receive the fine money. It may sound crazy but this is true.

The environmental groups are actively developing and writing regulations for the regulatory agencies to implement. They list themselves as the beneficiaries of the fine money. The Federal employees who spearhead and push the successful environmental regulations are given lucrative jobs with the environmental groups. This is how a FWS employee who is making $ 135,000 a year is able to instantly land a $ 530,000 per year job as a lobbyist, director, etc. for an animal activist group. All of this activity is called corruption. 

Let's look deeper - at the power and control end of their work. All of these factors result in managing public opinion and this is political power for these organizations. The politicians are scared to death of the environmental groups and their voting minions. The politicians think they will be voted out of office if they are seen as anti-environmentalism. This is called being a weasel of a politician. I know, I have them from my district.

Let's think about who these people are and realize that there is a human tendency which is called the Dunning-Kruger effect. The people who know the least about a topic frequently have the strongest opinions and the greatest confidence in their opinions. They know so little that they don't know how much they don't know. They view our complex world merely in terms of simple-minded sound bytes and they tend to have absolute confidence in their uninformed opinions. This correctly describes the animal rights people from their foot soldiers to their leadership. In our day to day world these are the bumper sticker people who's stickers scream "Ban Ivory- save the Elephants" or "Stop Pipelines- Save our Planet". In our political and business world these are the political types who move businesses and nations in these directions. Complex issues require nuanced solutions, but getting people to think in nuanced terms is about like trying to push a rope. The Dunning-Kruger effect results in a good bit of harm. It causes illiterate, ignorant, but highly confident people, to drive a group toward destructive "answers."

Just in case you thought I was upset...

Now, lest the reader, after enduring this long diatribe of information be left with the sense that the writer is aggrieved and bitter towards all that has happened in the ivory world, be assured that such is far from the case. As with the Assyrians afflicting the ancient people of Israel we now have modern day Assyrians, the populace of government agencies and environmentalism, afflicting the modern day American people. This is from the hand of God, has a divine purpose, and is welcome.

It is important to leave those who love to complain with something to complain about. The environmentalists and their minions have been the ones that have made my business and life go so well over these past 40 years and to you I extend a sincere thanks. This started with their work in making the importation of ivory illegal so many years ago. This created a situation where there was a national market for a beautiful material with no foreign competition. There were many intricacies of laws, regulations and social pressures, on both federal and state levels, fomented by environmentalism, that contributed significantly to my continued success over the course of many decades. Ebay joined the environmental fray late in the game and made listing ivory items on their website against their rules. This assured me of an even greater market as their national sales platform of this material was now extinct. This was but one of many situations that contributed to a tighter market and one in my favor. To my customers and my adversaries in this cultural warfare battle, I extend a sincere thank you.

My only regret in being forced out of business by governmental regulation in 2016 was that I was no longer able to help the several charities I have donated to for so many years. Beyond the necessity of making a living, my work in life has been to generate money to help others. This new inability of mine to help others is not a fault laid at my feet but at the feet of those who stopped me from being of greater help to others via the removal of income from me. This new regulation that stopped American's from buying and selling old pre-ban ivory within the United States should rightfully be viewed as a form of financial and cultural persecution.

We are taught that we are to pray for our persecutors, to rejoice when we are persecuted and to flee to the next city when we are persecuted. I pray for our persecutors because they are to expect great wrath from the hands of God in this world and the next. A few words from Matthew Henry regarding persecution: "This must be considered not only as the suffering of the persecuted, but as the sin of the persecutors. The ruin of a people is always introduced by their sin and nothing introduces a surer or sorer ruin than the sin of persecution. This is a sign that God's wrath is coming to the uttermost when their wrath against the servants of God comes to the uttermost." I rejoice of this persecution because I know it is important to do what is right and creating beautiful artwork from God's beautiful natural materials is right.

Lastly, I flee from the city of ivoryville to the next city. As one can see by perusing this website, and my other websites, I have already developed other markets and other products that have proven to be fun and profitable! Yet I pray to our heavenly Father that justice be served to those who have worked to stop the use of this beautiful God-given material from their fellow man. I pray that poetic justice finds itself at work here. That those who have removed this beloved material from the people, have their beloved materials removed from their lives. That those who would remove our income, financial security and retirement have the same removed from their lives. That those who would have us live in a country we do not recognize be made to live in a country they do not recognize.

 I enjoin the employees of USFWS to change their minds in their work. Their present work is not to study and promulgate scientific wildlife conservation but to follow the world's path of top down heavy handed and mean spirited control over good and innocent people by developing laws and regulations that harm good people as well as the wildlife they mistakenly believe they are protecting. Modern environmentalism is the infrastructure of socialism - it is the method by which governmental authorities and socialist groups are deriving their power to control people's lives in every aspect. The free market, as opposed to government controlled markets, linked with scientific wildlife management at the source (where the animal or plant lives) is the answer to having abundant wildlife as well as having a society of free people who can enjoy life, liberty and the pursuit of happiness.

 The world is changing fast and I have every hope that USFWS employees will start to study true wildlife management and to study their obligations to their fellow man in order to be ready for the changes from the current falsehoods of their work to the truths that have been and will be revealed. The truth, in the end, wins in every case and situation God has placed before us. People who do not learn the truth and apply it to their lives & work end up being humiliated, crushed and judged by it - that is just how God does things. It is highly doubtful that the USFWS will change to be a force for good and so I consistently pray, daily, for the complete dismantlement of this federal department. There is nothing they are needed for that our individual state wildlife departments cannot handle. It is time for this department of our federal government to cease to exist.  

Sincerely,

David Warther

Dover, Ohio USA

Listed below are websites that serve as a good start for those who are truly interested in wildlife conservation, especially as it pertains to African elephants. By employing scientific wildlife management principles that have historically been proven to work we can expect to sustain and properly manage African elephant wildlife populations. The US and UN are currently employing an animal rights approach to wildlife management, as they have for 60 years now. By their own admission, their systems are failing. It is time to return to true scientific wildlife management.

https://www.mahohboh.org. The True Green Alliance.

This is a pro-wildlife and anti-animal rights organization. Anyone interested in this topic should sign up for their free newsletters as the information they yield and the perspective from their position as people living in Africa is extremely insightful. TGA is concerned that the foundation elements of the animal rights philosophy contradicts all the principles and practices of successful wildlife management, globally; and that they promote bad choices within society regarding desirable current and potential human-wildlife relationships. They also create false expectations for wildlife population management; they erode society’s confidence in the decades of knowledge gained from extensive scientific exploration of wildlife and habitat management practices; and they seek to force change in accepted national wildlife cultures within human societies.

www.perc.org A conservative wildlife conservation think tank located in Montana. This group has done extensive research worldwide on wildlife management techniques especially in relation to free market economies.

A Forbes magazine article about how banning ivory equates to banning elephants: Click Here

There is great information at www.ronthomsonhuntingbooks.co.za/books.html . A great book "Elephant Conservation - The Facts and The Fiction" is available there. Written by Africa’s foremost expert, Ron Thomson, on the African Elephant.

An article published Tuesday, October 9th, 2012 by the TimesFreePress.com:

Public funds WWF schemes.

With 4 million members and efforts in 100 countries, the World Wildlife Fund is the largest and, likely, the best-known environmental nonprofit organization in the world. The WWF claims to do a great deal of good for endangered species and environmental protection efforts. However, when the Taxpayers Protection Alliance took a closer look at WWF funding, projects and scandals in a report released last week, a very troubling picture emerged. The organization is a tremendous burden on taxpayers and a dangerous threat to the indigenous people in the areas where the WWF is active. Too often, the WWF does more harm than good to the animals and lands they profess to protect.

 A 2011 documentary titled “The Pact with the Panda,” exposed that the WWF was responsible for displacing more than a million native inhabitants in India in an effort to protect the local tiger population. This modern-day “Trail of Tears” is even more outrageous considering that the Indians driven from their lands under the guise of protecting tigers lived alongside the tigers for centuries. Not only did the WWF destroy the lives, culture and society of more than a million people, there are fewer tigers left in these areas now than before the atrocious displacement efforts began. One reason for the failure of the WWF’s efforts to protect the tigers might have something to do with what they did with the tigers’ habitat after they drove away those pesky human from their homes. The WWF gives tourists who shell out about $10,000 the opportunity to pile in one of 155 jeeps and chase the few tigers that remain around their preserves for eight hours a day. This may be terrible for the tigers, but it’s big business for the WWF, which seems all too happy with the millions of dollars brought in through this ecotourism scheme. This troubling instance of the WWF forcing people to uproot from their homes in India is not even the most despicable example of forced migration by organization in recent years. In Nov. 2011, Prince Charles, who serves as president of WWF UK, visited Tanzania to present five local leaders with “Living Planet” awards for their work.

According to an article in the London newspaper The Telegraph, “Shortly before the Prince’s arrival, it was revealed that thousands of villagers had been evicted from the forest, their huts in the paddy fields torched and their coconut palms felled. This was carried out by the Tanzanian government’s Forestry and Beekeeping Division, with which the WWF has been working.”

Besides driving poor native populations from their land and destroying their homes, the WWF also keeps busy ensuring these people remain poor. WWF led a lobbying effort to impose trade restrictions on Indonesian pulp, paper and palm oil products, ostensibly to protect the forests of Indonesia. In reality, the WWF was serving as a front group for North American, European and Australian competitors who produce the same products as the Indonesian companies, but were being threatened by the lower price of the Indonesian goods. The area of Indonesia responsible for producing these products is one of the poorest places in the world. Workers in the region were given the opportunity to make a decent living and provide for their families, only to see it taken away because the WWF worked in cahoots with developed nations to kill their jobs.

  In Dec. 2011, allegations of “inappropriate expense reporting” were reported in the WWF’s Tanzanian office. The WWF commissioned Ernst & Young to conduct an independent investigation to get to the bottom of the accusations. The audit found that more than $400,000 was “misappropriated by the WWF local staff who forged hotel [and] taxi receipts,” according to the Daily News, a newspaper in Tanzania. This widespread fraud related to the WWF’s efforts in Tanzania resulted in the termination of eight employees and the resignation of six others. It is a misfortune when a nonprofit organization has its money stolen by disreputable workers. It is an outrage when most of the money stolen came at the expense of taxpayers. According to the audit, on top of the $400,000+ pilfered by corrupt WWF workers, five more WWF employees in Tanzania stole money from a USAID-funded project. In total, taxpayers were out hundreds of thousands of dollars because bureaucrats and elected officials were careless enough to shower the WWF with tax dollars, despite the organization’s troubling track record.

 A few hundred grand is, unfortunately, chump change compared to the tens of millions of dollars the federal government regularly hands out to the WWF. Since 2000, the WWF snatched up $97 million in federal grants and other handouts funded by tax dollars, according to the Taxpayers Protection Alliance’s tally. A lot of those tax dollars go straight in the pockets of the WWF’s well-compensated employees. Carter Roberts, WWF’s president, pocketed a $425,000 salary in 2009. The chief operating officer of the World Wildlife Fund, Marcia Marsh, earns over $300,000 in salary and benefits. “In fact, in 2009, no fewer than 18 U.S.-based WWF employees raked in more than $200,000 in salary and benefits,” according to the government watchdog group responsible for the reports. Perhaps most shocking for tax payers is the fact that the WWF currently has $238.1 million in the bank. That means that tax payers are forced to pour millions of dollars each year into an organization sitting on nearly a quarter of a billion dollars. The WWF is extraordinarily rich and certainly does not need an annual bailout courtesy of American taxpayers to keep its lights on. The idea that tax dollars would go to support a rich international nonprofit might not raise red flags at first blush, but a closer look is enough to infuriate any hardworking tax payer. It is simply unthinkable that, with the government $16 trillion in debt and tens of millions of Americans out of work, federal lawmakers and bureaucrats find it acceptable to hand out tax dollars to an organization that forces people from their homes, prevents some of the poorest workers in the world from earning a decent living, harms the endangered animals it claims to help and has proven irresponsible with money. Congress should immediately stop wasting Americans’ money subsidizing the WWF.