The Elephant Protection Association submitted the following comment to the Massachusetts Joint Committe on Environment, Natural Resources and Agriculture in anticipation of the hearing scheduled for October 3, 2017. Links to authorities are provided at the end of the submission.
Dear Members of the Committee:
The Elephant Protection Association has offered written opposition to past attempts at Massachusetts ivory bans bills. The circumstances surrounding current bills are not much different from past attempts. Citations to past submissions are available at elephantprotection.org/Massachusetts171003 or upon request, and I will be available for questions at the upcoming hearing scheduled for October 3.
Key points for this committee to consider:
The Federal Ivory Ban, which currently criminalizes importing any ivory that is or could be related to African Elephant poaching, has been in place since July 2016 and is being enforced. The Federal Ban was implemented after considering more than a million comments received over three years. Unlike the proposed Massachusetts Ivory Ban, the Federal ban:
- Does not ban mammoth or mastodon ivory, stating clearly that commercial trade of these forms of ivory in the United States pose no threat to African elephants
- Does not impose weight or percentage limits on antique ivory
- Includes a de minimis exception for items that are not antique
- Makes it a crime to bring poached African elephant ivory into Massachusetts
Because Massachusetts does not have its own population of wild elephants roaming the Commonwealth, an intrastate ivory ban is nothing more than divisive virtue signaling at great expense to the Commonwealth, its heritage, and its people who own, sell or produce items that incorporate ivory obtained decades or generations ago that have nothing to do with elephant poaching in Africa.
From a conservation perspective, ivory bans do more to hurt than help African elephants. After years of hysterical propaganda over the imminent extinction of elephants and rhinos, key facts remain true:
1. African Elephants are not listed as an endangered species. Physical counts of elephants conducted in 2015 show that there are 400,000 to 500,000 wild elephants roaming in Africa, notwithstanding gross exaggerations about the numbers of elephants killed by poachers in the last 7-8 years.
2. There are enormous geographical discrepancies in Africa between local elephant populations. The elephant populations at greatest risk of elimination are located in countries where all commercial use of elephants has been illegal for a long time. In Southern African countries, where hunting and limited trade are regulated and legal, elephant populations have flourished to numbers greater than the local habitats can naturally support. It is the growth of populations in Southern Africa that accounts for the vast majority of African elephants and the best protection for elephants against extinction.
3. In countries with fragile elephant populations, they are slaughtered for more than just ivory. Many are butchered to provide meat for people who do not have access to other forms of protein. Others are killed because they are nuisances – they consume vast quantities of food and water and cause substantial property damage, while they do not provide any legal commercial benefit to the communities who host them. Without any economic incentives to invest in elephant populations, local communities passively allow poachers to eliminate them as pests.
4. The plight of White Rhinos is directly on point, since this bill also bans trade in rhino horn. Northern White Rhinos are effectively extinct – only 3 related and old rhinos are still alive. Southern White Rhinos, who at one point were down to 20 animals, now number over 20,000 animals and are not even considered threatened in Africa. The only difference between these species – the countries in which the rhinos lived. The Northern White Rhinos lived in countries where all commercial trade was banned. The Southern White Rhinos live in countries where private land owners were encouraged to keep these animals on their property, greatly expanding their range land and resources to protect and grow White Rhino herds. The greatest threat to White Rhinos today is rhino horn bans that are stripping White Rhinos of value to land owners and causing private land owners to surrender White Rhinos back to the states who cannot afford to support or protect them on public land. (See IUCN Redlist Assessment at http://www.iucnredlist.org/details/4185/0)
Global ivory and rhino horn bans only make existing problems in troubled African nations worse. They do not provide incentives for countries to invest in elephant populations to help them recover and grow. Instead, they strip hope that there will be any sustainable use of elephants or rhinos to offset their considerable costs. Ivory and rhino horn bans such as what this committee is considering fail to offer any solutions other than delusional suggestions of foreign tourism in remote, dangerous and inhospitable places in Africa.
For the good of the Commonwealth and elephants in Africa, please do not allow these bills to advance out of this committee.
Below are attachments that serve as authority for the comments made above.
What Can I Do With My Ivory FWS FAQ 171001.pdf
IUCN Redlist White Rhino Assessment.pdf
15Nov15 Email To Joint Environment Committee.pdf
EPA Comment to Judiciary 16 Oct 2015.pdf
Atch1_E-SC65-42-01 CITES Elephant Poaching Report 2014.pdf
Atch4_Draft Envtl Assessment FWS-HQ-IA-2013-0091-0002.pdf
Atch6_Ivory Market - FINAL.pdf
Attachment 8 - https://www.rusi.org/publications/occasionalpapers/ref:O56003613E4FFA/