Statement #2 during the comment period ending Sept 28, 2015
This law will take our property that was purchased legally using our hard earned dollars and remove it’s value on the open market. This law will open up the whole country to a black market of dealers seeking to take advantage of the loss and fear that the average law-abiding citizen will have when this goes into effect. Creating a new class of criminals from people who trade otherwise legal ivory. This law will make those same citizens criminals when they try to recoup the loss of their properties value. And to what end? To be “politically correct”, even if it makes no good sense. I demand that you with draw these rule changes immediately. These rule changes do nothing to help the living elephants, and only hurt the American people.

Stopping our legitimate use, and trade in ivory that has existed here in the US for a minimum of 25 years, and much of it 100 years and older will not help the elephant. Since when do we outlaw a legal item because a few bad people counterfeit it or smuggle it in and pass it off as legitimate? That is the reason you are giving for the need for these rule changes. This is an illogical response to a problem (poaching) that doesn’t exist in this country. The government should instead focus resources on stopping poachers in Africa and prosecuting criminals who smuggle ivory to Asia if it wants to stop elephant poaching. Not punishing law-abiding citizens. CITES data shows that hundreds of tons of illegal ivory flows to China and Asia, but almost none of it comes to the United States. Your own press release of 2012 stated as much. Conveniently this press release has been removed. Even Dan Stiles, an expert FWS relied upon in the Proposed Rule Change, submitted a comment pointing out how FWS has misrepresented his research.
Most of the elephant populations are appendix 2- not appendix 1, as per CITES listing
CITES listing: Appendix I (18/01/1990),
except populations of Botswana, (50,000 in the DRY season) http://www.botswana.co.za/Botswana_Wildlife_Behaviour-travel/elephants-of-botswana.html
Namibia (10,000) http://etoshanationalpark.co.za/fauna-flora/wildlife/desert-elephants/
and Zimbabwe (Appendix II, 18/09/1997) (97,000) http://www.bloomberg.com/news/articles/2015-02-18/zimbabwe-elephant-population-dwindles-amid-threat-from-poachers
In July, wildlife officials in Zimbabwe requested the U.S. reverse a ban on ivory imports it implemented a year ago citing concerns about the sustainability of the country’s elephant population. Zimbabwe’s elephant-hunting industry generates $14 million a year and helps control the population of 97,500 species that trample over trees and farmers’ fields, according to the country’s Parks and Wildlife Management Authority.
and South Africa (Appendix II, 19/07/2000) Where elephant populations hve exploded. Southern Africa continues to hold the lion’s share of Africa’s elephants, https://cmsdata.iucn.org/downloads/african_elephant_summit_background_document_2013_en.pdf Holding close to 55% of the known elephants on the continent. Possibly 250,000. http://www.npr.org/templates/story/story.php?storyId=200104722
While most of the news about elephants out of Africa concerns poaching and falling numbers, South Africa has the opposite problem. Its elephant populations have grown greater than the country can manage.
Botswana, Tanzania and Zimbabwe account for over half of the 420,000-650,000 elephants, as per Elephants in the Dust. 8 of the 38 range African range states were seeking to reopen trade in raw ivory and herds south of the Zambezi R. are large and well managed. Poaching has fallen consistently each of the last 4 years. ( CITES) China and Thailand are the 2 major end users with the US not even making the list. More than poaching, loss of habitat and range is the long term threat to survival.
PIKE levels show overall sustainability has gone up in the last 5 of 7 years.
All this evidence works against FWS and these changes making them illogical, illegal and unnecessary. So again I demand FWS withdraw the proposed rule change entirely .1jz-8lb8-92dj
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