Policy Statements » Letters from the President:

October 16, 2003

Chief, Division of Management Authority
U.S. Fish and Wildlife Service
4401 North Fairfax Drive
Room 700
Arlington, VA 22203

Dear Chief;

The Ecological Society of America urges you to reconsider the proposed Endangered Species Act (ESA) rule change titled “Draft Policy for Enhancement-of-Survival Permits for Foreign Species Listed Under the Endangered Species Act”. The Ecological Society of America is the country's primary professional organization of ecological scientists, representing more than 8,000 scientists in the United States and around the world. Founded in 1915, the Ecological Society of America is a scientific, non-profit organization dedicated to the advancement of the ecological sciences.

You are well aware of the extinction crisis facing the globe. This crisis is unique in geologic history and may have repercussions, not only for biodiversity, but possibly ecosystem function. It is critical that the United States contribute fully to slowing the rate of extinctions worldwide.

We disagree that legalizing trade in endangered species will contribute to their conservation. While economic incentives can be useful conservation tools, the US lacks both the monitoring capabilities and enforcement authority to ensure that plans are implemented and successful on the ground. Furthermore, by opening up a legal trade, it becomes nearly impossible to keep animals that have been harvested illegally – such as from a country with out a conservation plan – from entering the market and being absorbed into the supply of legally harvested animals.

Furthermore, areas with successful conservation and management plans would have very few ‘surplus’ individuals for harvest. In the case of the Asian Elephant, the ‘problem’ animals suggested for removal to US zoos and circuses often arise because of human encroachment into elephant habitat. Were a viable, supportable conservation plan in place, these animals would not be a problem. Thus, the very concept of ‘surplus’ individuals of an endangered species and a workable conservation plan are mutually exclusive.

We ask that the ban on trade in endangered species remain in place. Any advantages to lifting the ban are far outweighed by the negative impacts of such an action. The needs of zoos, circuses and trophy hunters must not outweigh the biological imperative of maintaining these species in their natural habitat.


Dr. William H. Schlesinger