Open Letter to Greg Sheehan

Acting Director of Fish and Wildlife Service should
Reinstate Ban on Import of Ivory and Elephant Trophies

Thanks to Christina Picci, Bao Chau Nguyen Vu and Austin Farley for helping to inspire these notes.

Greg Sheehan and Elephants


ear Mr. Sheehan,

I am deeply dismayed by the news today that your department has reversed a ban on the import of ivory and other elephant trophies in the United States from Zimbabwe and Zambia.  

Americans are deeply opposed to this ban reversal, and their case is much better supported than the case put together by the Department of Fish and Wildlife Service.  

In fact, 98% of all U.S. citizens oppose laws which support the import of ivory into the United States.  

As acting secretary of the U.S. Fish and Wildlife Service, I urge you to resist and reverse this indefensible action by this administration.

Here are the reasons:

The Way we Protect Iconic Species Matters

Animal rights are as old as civilization, and these moral laws against cruelty toward animals is especially strong among Americans.  We spend $11 billion a year in animal rights charities, and according to a recent Gallup poll, only 3 percent of Americans say that animals don’t need much protection.  

But Americans draw a moral line in the sand with large, sentient mammals.  We agree that killing great apes, cetaceans and large iconic keystone mammals like elephants and rhinos is indefensible from a moral standpoint.

While your department has argued that the sport killing of elephants will help conservation efforts, this argument ignores the fact that Americans find the sport killing of these intelligent, sentient animals morally repugnant.

Here is an analogy. If the Trump Administration argued that the sport killing of Blue Whales or Chimpanzees would help promote their conservation, would we support laws that promoted thos killings?

Of course not, for one because there are better alternatives to their conservation, and second because we have strong moral convictions about the killing of these sentient mammals that forbids us from making the case for their killing.

This leads to a very important point. If all the Polar Bears, Hyacinth Macaws, tigers, pandas and elephants died tomorrow, the world would go on, although it would be a diminished one.

But we live in a world where we are actually fighting to protect the very biodiversity that keeps our world and atmosphere functioning in a way that can support our biosphere and our global economies. We are in a fight for the survival of our coccolithophores, the foraminifera, the tiny crustaceans and molluscs, the fabric of biodiversity upon which civilization rests.

In this world threatened by complex issues like ocean acidification and climate change, the way we protect our elephants, tigers, pandas, macaws and polar bears matters, a lot. The finite set of species which inhabit our idea of nature and help inspire people to conserve are important particularly in this way. They are what turns our children into environmentalists and make people more interested in the bigger ecological issues we face.

The notion that triumphing Don Trump. Jr. greedily and luridly holding the bloody tail of an elephant which he just killed with a semi-automatic weapon from the comfort of a helicopter or a Land Rover is not the image we should present to a world as the face of conservation. The conservation of iconic keystone species like elephants is the public face of conservation at large. The American face of conservation should resemble Jane Goodall, not cowardly Walter Palmer.

All Genuine Conservation Involves Locals

The idea of tying a game exclusive only to the foreign ultra-wealthy, and presenting that to Africans as a solution to conservation is troublesome. In mainstream, modern conservation efforts around the world, incorporating the local community is central to successful conservation. Americans can support international conservation efforts on other continents, but we do not dictate them to others.

Trophy hunting takes the local community out of the solution almost entirely, as the trophy hunting industry employs almost no locals. In fact, proponents of trophy hunting argue that trophy hunting fees go to help the local community and the conservation of the elephants themselves. But this is actually not happening in countries that allow trophy hunting of elephants. The money that is supposed to go into the local community ends up being siphoned off to bureaucrats and safari clubs.

In many cases, investigations have revealed that the intended beneficiaries of trophy hunting fees never get a penny of the proceeds. This helps explain why elephant populations are declining.

Elephant Populations are Declining in Countries that Support Elephant Hunting

Across Africa, elephant populations have been plummeting in the last 10 years alone. On average, across Africa, the elephant populations are declining by 8% each year. This is partially due to habitat loss, but primarily due to hunting. The reason? The demand for ivory by wealthy foreigners. Even though 98% of all Americans are against the import of ivory into the United States, ultra-wealthy Chinese and ultra-wealthy Americans together form the bulk of the ivory marketplace. As the supply of ivory declines, the value increases. Those who collect and trade ivory understand that as global supplies dwindle, the value of their collection skyrockets.

It is the very people who this law was designed for - ultra-wealthy trophy hunters and ivory collectors - who are the primary cause of elephant declines in the first place.

Laws which Encourage the Trade of Ivory are Indefensible

Because the ivory trade is the primary reason for the rapid decline of elephants throughout Africa, promoting legislation which expands or supports that trade directly contributes to the decline of elephants.

The international trade of ivory was banned in 1989, and that ban was a high point in conservation of elephants, as it helped to shut down global ivory markets and created the hugely successful global perception that owning ivory was illicit and immoral.

Laws which champion the trade of ivory directly subvert the authority of international bans on ivory.

The Claim that Hunting Elephants is an Important Conservation Tactic is False

According to a November 16, 2017 article in the Washington Post:

"...The hunting of elephants brings in very little revenue. A 2017 report by Economists at Large, an economic analysis firm based in Australia, found that in eight African countries, trophy hunting amounted to less than 1 percent of total tourism revenue and 0.03 percent of the countries' total gross national product. A 2015 National Geographic report found that only minimal amounts of revenue from game hunting actually trickled down to the communities managing elephant populations. Government corruption is a big factor in this, with authorities keeping hunting fees for themselves and seizing wildlife lands to profit from hunting and poaching."

The Washington Post then went on to cite data from your own department, showing the positive effects of banning trophies.

How to Pack your Cooler

This chart is a screen capture from the Washington Post.

Trophy Hunting Advocates Misprepesent the Value of Older Males to Herd Health

In a November 18, 2017 article for The Atlantic, author Virginia Morell argues that the trophy hunter advocates' talking point about the older males being of no value to the herd are not supported. A quote from the article:

From a population standpoint, "older male elephants are very important to the health and genetic vitality of a population," said Cynthia Moss, who has led the Amboseli Elephant Research Project in Kenya since 1972. While hunters in the past have used the belief that older males are reproductively senile as an argument for killing them for their ivory, research has revealed that they are in fact an elephant population's primary breeders. "By living to an older age, [older males show that] they have the traits for longevity and good health to pass on to their offspring," Moss said. "Killing these males compromises the next generation of the population."

There are Better Ways for the United States to Support African Elephant Conservation Efforts

There are three proven methods to protecting elephants, and they go hand in hand. To support elephant populations and the African habitats in which they live, Americans should focus on these three alternatives:

1. Efforts that result in the expansion of natural reserves in Subsaharan Africa.

2. wildlife and nature tourism in African countries.

3. Global Solidarity on Efforts to Shut Down the Ivory Trade.

Diverse forms of tourism to African countries that center around the preservation of habitat, landscape and wildlife, such as wildlife viewing, birdwatching, safari tourism, cultural tourism and food and wine tourism are increasing by 10% each year. This number is far more important in terms of sheer tourism revenue.

Other forms of tourism outweigh trophy hunting tourism revenue by leaps and bounds. For example, according to the 2006 Biological Conservation paper, 18,500 hunters visit sub-saharan Africa annually, but 33.8 million non-hunting tourists visit the same region in the same period. Hunting only contributes 0.06% of tourism revenue in sub-saharan Africa.

International Park Reserves Are the Answer

This map sketch roughly shows the historical elephant distribution across Africa. Start with this goal: turn the historical elephant ranges into massive international parks. Focus on the increasing number of African tourists and international tourists who want to learn about the wildlife and culture of these beautiful countries.

Larger park reserves are the real answer to the long-term conservation of elephants and the habitats in which they live. Remember that habitat loss is the other reason elephant populations are declining! Focus on the expanding nature tourism economy, which include African tourists and African businesses which cater to them.

With strict nature corridors, buffers and mixed-use areas, imagine African efforts to return the historical elephant ranges to the highest level of protection possible.

Africa National Park Map

This Map Shows the Protected Regions of Subsaharan Africa

This map, which I pieced together from the ProtectedPlanet data map, shows just how much Subsaharan Africa is protected. Lighter green indicates lower levels of protection. Pure kelly green represents strict nature reserves. Note that there are no strict nature reserves overlapping with elephant habitat.

I have overlaid the color orange to indicate roughly where elephant populations currently exist.

  • Parks are fragmented.
  • There is no solid kelly green overlapping elephant habitat, meaning that the level of protection in these parks is low or incomplete.
  • Reserves often stop at country borders.
  • There are not sufficient corridors that extend throughout these population ranges.

Map of Current Protected Land in Subsaharan Africa

To Save Elephants, Increase Strict Nature Reserves and Connect them, Country to Country.

Strict nature reserves (shown in bright green on the Protected Planet map above), are areas that are protected from everything except the lightest human use. These are the most ideal habitats to protect keystone species like elephants, as well as the habitats in which they live.

Africa's economy is the fastest growing continental economy in the world. It is expected to grow at an annual rate of 6% over the next ten years. In that time, we will begin to see the international infrastructure of the continent begin the solidify. This will be a huge boon to the continent, in many ways, affecting health and security of the human populations of the continent, and encouraging business and leisure tourism throughout the region.

There is no better time than now to build up the size of protected park reserves. As Africa stabilizes and its economy expands, protecting larger spaces and increasing the level of protection of existing spaces will help encourage the flow of tourism. It is in this model that we will see the long-term preservation of elephant habitat.

To Save Elephants, Greg Sheehan's U.S. Fish and Wildlife Service should Smash the World Ivory Trade and Commit to Zero Tolerance for Trading and Importing Ivory

It's simple. The ivory markets of the world are the United States and China. But China recently banned ivory sales, and the markets there are collapsing. Other countries make it very difficult to trade ivory. Why on Earth would the United States even think of making some ivory imports legal?

Due to China's ban, the ivory trade is shifting to the United States, especially Washington D.C. The United States has the power to smash the ivory trade by making ivory truly illegal. But the laws of individual states, and the Fish and Wildlife Service, offer up a bounty of ways for buyers and sellers to get around these regulations.

To fight poachers, whose profits funnel to ISIS and Boko Haram, fight U.S. state laws and the many gray areas passed off by the Fish and Wildlife Service. Ignore any argument from the hunting and gun lobbies that argue for any ivory trade ban exemptions. A simple and complete ban of ivory and any other elephant part in the United States will pay back in spades.

U.S. Fish and Wildlife Service Can Tighten Laws

If you read the U.S. Fish and Wildlife Service website, detailing the many exemptions to outright bans on ivory in the United States, you'll see that it's just too easy to buy ivory here in the United States. Our lax laws on ivory fuels the continued poaching of elephants, threatening the species and increasing the funding of terrorism in Africa.

Map of Current Protected Land in Subsaharan Africa

This demand-side of the declining elephant problem has a simple solution: close all loopholes on trading and importing ivory in the United States, and stiffen the consequences for anyone thinking about buying or selling ivory. If even antique ivory is illegal, importer's can't label their fresh tusks as antiques.

Do outright bans on ivory work? Yes. In August 2014, New York governor Cuomo signed some of the strictest elephant ivory laws in the United States, and the ivory trade there quickly died. As long as the U.S. Fish and Wildlife Service keeps loopholes, the market can find a way. A complete ban on ivory will shut the ivory trade down.

But most states have extremely lax ivory laws, and the internet is becoming the place to sell ivory.

Greg Sheehan, The U.S. Fish and Wildlife Service can Destroy the Internet Trade in Elephant Ivory

Sites like have strict rules about selling ivory online. Lo and behold, you'll be hard-pressed to find anybody selling ivory there.

Let's take a look at how easy it is to buy ivory online in the United States. Gun enthusiasts have been led to believe that buying ivory helps to save elephants. In their various forums, you'll often see them saying that they want to buy ivory to help elephant conservation.

Here is a potential ivory buyer communicating openly with potential sellers. Note how he has been misled by the gun industry to believe that marketplace demand for ivory leads to their conservation. Little does he know that ISIS and Al Qaeda directly benefit from this belief, and elephant herds are vanishing because of this belief.

Selling Ivory Online should be illegal

Where is ivory being sold online? Craigslist, for one, and gun sites for another. Take a look at this gun site -, selling dozens of ivory pieces.

Ivory being sold on

It appears quite easy to sell ivory online. But take a look at the effect of recent bans in the United States. It's much harder to sell ivory, but it can still be done, and they are following loopholes created by the Fish and Wildlife Service.

Selling Elephant Ivory Online should be illegal

Mr. Greg Sheenan, I have made my case that trophy hunting is not really the solution to protecting elephants. I've offered data points, a moral basis for my argument and three alternatives to trophy hunting. Instead of supporting the trophy hunting of elephants, how about this: Ban the selling and buying of ivory outright, and go after internet marketplaces that continue to trade in ivory. The demand side of the solution is to terminate the marketplaces entirely, and the U.S. Department of Fish and Wildlife Service can contribute to that in the United States by closing the gaps.




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