Thank you to the Elephant Protection newsletter for providing this analysis- 
First, we need to continue the fight against state ivory bans.  Among the good things to come out of this rule is the fact that our opposition forced FWS to take a year or more to address the multitude of flaws with this policy, and they had to create exemptions that give ivory owners a little breathing space to survive.  We need to fiercely protect that space, and wherever possible, prevent states from enacting legislation that will further muddy the waters.  So far we have prevented ivory bans in all states except New Jersey, New York, California, Washington and Hawaii.  That’s a pretty good record when you consider about half of the country had pending legislation in one form or another over the past two years.  Ironically, the federal ban gives us another tool to stop states from wasting resources on a state-level ban.
Second, we need to continue to engage politicians.  An administration that truly cares about private property rights and genuine wildlife conservation can reverse this rule. NGOs will continue to fundraise off of crises they create and then divert some of those proceeds to politicians in order to keep their revenue streams flowing.  This ivory ban is corrupt in every sense of the word.  If the people profiting from this go unchallenged, then they will continue to exploit and expand upon the falsehoods and misconceptions that enable their behavior.
Third, there is litigation.  The agency has taken final action, and the matter is unquestionably ripe.  NGOs and the federal government have dared people to sue them, knowing that litigation will be a long and expensive process.  The Ivory Education Institute took up that challenge with California’s ivory ban, and that process is playing out.  Now it remains to be seen whether people will organize to fund a pre-emptive attack on the regulation, or whether individuals who are singled out for prosecution will bear the burden of defending themselves.
I know most people receiving this e-mail are primarily concerned with ivory and not with larger political battles about animal rights and wildlife conservation policy.  You either want to protect the value of a collection about which you are passionate and that you've spent years acquiring, or you have a business or life-long skill you've developed that the government is taking from you.  Very few of you are political or have a desire to engage in politics.
I share my perspective with you because I started off like you – a guy who was trying to help a friend with a problem the government threatened to create that seemed unreasonable.  In the 2 and a half years I’ve been involved, I have come to appreciate the ominous threat that corrupt NGOs working with unrestrained government can do both to personal property rights and wildlife conservation.  Before one can solve a problem, one must understand its cause and scope.  This ban on ivory and rhino horn is the sharp end of a political wedge for greater federal and international government control of land use and private property. I hope by sharing my perspective I have helped you understand why it is so important to continue to fight against people who are at best misguided and at worst corrupt.  I am grateful to everyone who has supported our little group in this big fight, and I look forward to hearing back from those of you who are determined to reverse this injustice.
Sincerely,
Rob Mitchell
So Where Do We Go From Here?
Thank you to the Elephant Protection newsletter for providing this analysis-
First, we need to continue the fight against state ivory bans. Among the good things to come out of this rule is the fact that our opposition forced FWS to take a year or more to address the multitude of flaws with this policy, and they had to create exemptions that give ivory owners a little breathing space to survive. We need to fiercely protect that space, and wherever possible, prevent states from enacting legislation that will further muddy the waters. So far we have prevented ivory bans in all states except New Jersey, New York, California, Washington and Hawaii. That’s a pretty good record when you consider about half of the country had pending legislation in one form or another over the past two years. Ironically, the federal ban gives us another tool to stop states from wasting resources on a state-level ban.
Second, we need to continue to engage politicians. An administration that truly cares about private property rights and genuine wildlife conservation can reverse this rule. NGOs will continue to fundraise off of crises they create and then divert some of those proceeds to politicians in order to keep their revenue streams flowing. This ivory ban is corrupt in every sense of the word. If the people profiting from this go unchallenged, then they will continue to exploit and expand upon the falsehoods and misconceptions that enable their behavior.
Third, there is litigation. The agency has taken final action, and the matter is unquestionably ripe. NGOs and the federal government have dared people to sue them, knowing that litigation will be a long and expensive process. The Ivory Education Institute took up that challenge with California’s ivory ban, and that process is playing out. Now it remains to be seen whether people will organize to fund a pre-emptive attack on the regulation, or whether individuals who are singled out for prosecution will bear the burden of defending themselves.
I know most people receiving this e-mail are primarily concerned with ivory and not with larger political battles about animal rights and wildlife conservation policy. You either want to protect the value of a collection about which you are passionate and that you've spent years acquiring, or you have a business or life-long skill you've developed that the government is taking from you. Very few of you are political or have a desire to engage in politics.
I share my perspective with you because I started off like you – a guy who was trying to help a friend with a problem the government threatened to create that seemed unreasonable. In the 2 and a half years I’ve been involved, I have come to appreciate the ominous threat that corrupt NGOs working with unrestrained government can do both to personal property rights and wildlife conservation. Before one can solve a problem, one must understand its cause and scope. This ban on ivory and rhino horn is the sharp end of a political wedge for greater federal and international government control of land use and private property. I hope by sharing my perspective I have helped you understand why it is so important to continue to fight against people who are at best misguided and at worst corrupt. I am grateful to everyone who has supported our little group in this big fight, and I look forward to hearing back from those of you who are determined to reverse this injustice.
Sincerely,
Rob Mitchell
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