STATEMENT TO THE ADVISORY COUNCIL

Dear Advisory Committee,

I stand against a total ban of all ivory sales in the US. As called for in the Presidential Executive Order I ask that the recommendations continue to allow for “legal and legitimate commerce”. The ivory market in the US is stable and /or declining, and the seizure records indicate that a high proportion of the seizures made were personal effects lacking the correct paperwork, not the “blood tusks “ spoken about in the media. The Elephant Trade Information System (ETIS) analysis indicated that the amount of ivory (by weight) seized annually has not increased in recent years. WE are not the consumers of the poached ivory.

Therefore banning ivory sales within the US will do nothing to save the remaining world population of elephants. CITES MIKE report (Monitoring the Illegal Killing of Elephants) September 2013 report, page 64 analysis states “Africa’s elephant populations are managed sustainably” and that in 2013 the quota for permits for legal elephants was 1350 animals. There is legal trade that can be monitored with DNA testing and permitting. Enforcing and policing a ban would use funds that should be used to support the ban on imports already in effect I fully support the CITES rules, closing international borders to elephant ivory trade, a law already in effect that should be fully supported and enforced.

I stand against a total ban of all ivory commerce within our United States borders, a decision that would be an enforcement nightmare. Like prohibition it will cause a new wave of illicit commerce where a legitimate one now exists. Museums, antique dealers, collectors, artisans and individual citizens have invested in a legal and valuable material. Sanctioned trade in ivory that is legal (culled and pre-ban) and comes from unthreatened sources (mammoth, boar, warthog, antique and recycled products) can pose no possible threat to elephant herds in the wild. I believe our mutual goals are the same and a solution can be reached. Please keep the focus where it belongs. To increase the elephant population the killing must be stopped in Africa and at its borders.

Respectfully Submitted,

To The Advisory Committee on
Wildlife Trafficking:

I stand against a total ban of all ivory sales in the US.

As called for in the Presidential Executive Order I ask that the recommendations continue to allow for “legal and legitimate commerce”.

The ivory market in the US is stable and /or declining, and the seizure records indicate that a high proportion of the seizures made were personal effects lacking the correct paperwork, not the “blood tusks ” spoken about in the media. The Elephant Trade Information System (ETIS) analysis indicated that the amount of ivory (by weight) seized annually has not increased in recent years. WE are not the consumers of the poached ivory. Therefore banning ivory sale~ within the US will do nothing to save the remaining world population of elephants.

CITES MIKE report (Monitoring the Illegal Killing of Elephants) September 2013 report, page 64 analysis states “Africa’s elephant populations are managed sustainably” and that in 2013 the quota for permits for legal elephants was 1350 animals. There is legal trade that can be monitored with DNA testing and permitting. Enforcing and policing a ban would use funds that should be used to support the ban on imports already in effect.

I fully support the CITES rules, closing international borders to elephant ivory trade, a law already in effect that should be fully supported and enforced. I stand against a total ban of all ivory commerce within our United States borders, a decision that would be an enforcement nightmare. Like prohibition it will cause a new wave of illicit commerce where a legitimate one now exists. Museums, antique dealers, collectors, artisans and individual citizens have invested in a legal and valuable material. Sanctioned trade in ivory that is legal (culled and pre-ban) and comes from unthreatened sources (mammoth, boar, warthog, antique and recycled products) can pose no possible threat to elephant herds in the wild.

I believe our mutual goals are the same and a solution can be reached. Please keep the focus where it belongs. To increase the elephant population the killing must be stopped in Africa and at its borders.

Respectfully Submitted,
Frank C. Gaetje

STATEMENT TO THE ADVISORY COUNCIL

While I strongly support conservation of elephants in the wild and recognize that to do so we need strict regulations regarding trade in raw material and finished goods containing ivory, I am strongly opposed to a ban of all sales of vintage and antique items containing ivory which was harvested prior to its inclusion on Appendix I of the CITES Treaty.

My business Gruhn Guitars Incorporated in Nashville, Tennessee has been in business for 44 years specializing in vintage guitars, banjos, and mandolins. We do not sell new instruments containing ivory, however, we cannot retroactively change the content of vintage musical instruments. Numerous fretted instruments, especially those made prior to World War II have ivory nuts and saddles and the vast majority of vintage violin bows have ivory tips. Ivory was also used for inlay material and binding on some instruments many years ago and was also a common component for rings on flutes and other vintage woodwind instruments. Unlike edible items which are consumed, high quality musical instruments can last for centuries and vintage examples are highly prized and valuable. These musical instruments are part of our cultural heritage and deserve to be preserved. Trade in vintage musical instruments has been an honorable profession for centuries.

I fully agree that trade in ivory should be regulated, but criminalizing all trade in vintage musical instruments and other historically significant antiques containing ivory would be harmful to our cultural heritage, extremely harmful to legitimate dealers, and do nothing to preserve living elephants or their environment.

George Gruhn
Gruhn Guitars
Nashville Tennessee

STATEMENT TO THE ADVISORY COUNCIL ON WILDLIFE TRAFFICKING

Members of the International Ivory Society have long abhorred the barbarity, greed, and criminality of poachers who jeopardize the existence of endangered ivory-bearing animal herds in any habitat anywhere in the world. By the same token, ivory collectors support the trade in tusks and teeth that have been taken in approved hunts, held in storage, extracted from archaeological sites, produced by natural causes, arisen from planned culls, or recycled from previous uses. We strongly believe that objects made from or with ivory, before 1975 as well as afterwards from legal sources, and now held in millions of private and public collections, have important artistic, practical, and decorative value to all societies.

But our membership has also been bothered by the apparently misinformed and occasionally counter-productive restrictions proposed to or instituted by government agencies on behalf of endangered species. The current ground swell of interest in enforcing a total ban on the trade and movement of what is blithely termed “vanity” ivory — but apparently exempts tusks taken in hunting expeditions — is one such misguided effort. The fact that the proposed ban would be imposed only until African elephant herds are returned to their 1990 levels is a transparent attempt to seem moderate while in fact being monolithic. No one who understands the changes in population and land use practices in Africa over the last 25 years, and appreciates the economic changes in Asia since 2008, believes that this goal will ever be attained.

We urge the Presidential Task Force on Combating Wildlife Trafficking to recommend that trade in legal ivory continue. This material, properly and reasonably identified, can pose no possible threat to current herds. Any moratorium on the trade of controlled ivory objects will, in fact, have the opposite effect: Instead of stopping the elephant kills, it will greatly increase the value of existing ivory stocks to the point that criminal gangs will hire all the poachers they can find to reap the enormous profits that will ensue. The blood of future dead elephants will not be on the hands of the collectors, dealers, artisans, and curators, but on the hands of all of those who cannot accept the history of Prohibition, appreciate the current failure of the War on Drugs, or understand the immutable law of economics that demand determines both price and supply.

Every scrap of an ivory tusk has long found a practical, artistic, or decorative use — from billiard balls to blouse buttons, from piano keys to religious emblems, from furniture inlays to personal ornaments, from stethoscopes to statuary, from musical instruments to microscopes. Do not destroy our legitimate interest in understanding, preserving, and appreciating the beauty of objects made from and with ivory in the false hope that it will somehow protect elephants. Let us use modern technology — as well as the stocks of archaeological ivory, antique and recycled ivory, boar, warthog and legally harvested elephant ivory —to change the current marketplace for ivory. Let us use our brains, not bravado, to protect the environment.

Submitted by
Godfrey Harris
Principal Representative, Political Action Network
International Ivory Society

STATEMENT TO THE ADVISORY COUNCIL

The trade in ivory, and the devastating impact it has had an is having on elephant populations is abhorrent. I support efforts that will protect elephant populations around the world. Stopping the trade of antique ivory and items, such as musical instruments, that have been made with appointments of ivory will not, however, serve that purpose. It will make trade in legally acquired impossible by legitimate dealers and will thus expand an underground economy that will care little about the difference between ivory that is old and that which is not. In addition, such a ban will undermine efforts to stop the illegal slaughter of elephants for their ivory and undermine respect for both the intent and the application of the law.

The enforcement procedures would have to be either selective or Draconian– that is intrusive and very costly. So the end result of the domestic ban on ivory trade would very likely be a loss of control and protection rather than an increase. The end result of this would, I believe, be antithetical to the goals of preservation. This is not an easy task for anyone to accomplish. It is clear to me that we have a responsibility to protect the species upon this earth. How we do so effectively is a matter of great concern.

I believe that it would be far better to enlist the aid of people who deal in antique ivory in the effort than to create an underground economy which ignores both the law and its intent. I am a guitar dealer, but very little of what I sell has any ivory. I would not personally be injured by such a ban. I am, however, very concerned that elephant populations be protected and I’m convinced that permitting illegal trade in antique ivory can heighten awareness of the issue. We’ve seen with prohibition of alcohol and drugs that total bans do not work well. Alcohol consumption went up during prohibition and the use of drugs has continued to spiral upward. These have both been unintended consequences of what seem to be solid, moral, and ethical public policy decisions. I trust that any decision made with regard to the trade in ivory will not follow these disastrous examples.

Yours truly,
Jay Pilzer,
New Hope Guitar Traders,
www.guildguy.com
(931) 433-1955

STATEMENT TO THE ADVISORY COUNCIL

Dear Sirs, I was not present at your December 16 public hearings and the information on the development of your recommendations concerning ways to combat trafficking in elephant ivory has been passed to me second hand. As I understand it, a possible recommendation may take the form of a sweeping ban on all forms of ivory commerce that would also include ancient walrus ivory and fossil mammoth ivory, this being purposed to eliminate loop holes and leaks in any ivory trade which may indirectly adversely affect and promote illegal elephant ivory trafficking.

As an artist who only deals with fossil ivory I will limit my comments to any proposal affecting them. Under the 1971 Alaskan Native Claims Settlement Act (ANCSA) there are already legislative provisions which allow the native tribes to harvest walrus ivory, carve and scrimshaw and sell it. They also do this with mammoth ivory. The tribes also collect and sell ancient walrus ivory shards and mammoth ivory collected on tribal lands and have ivory cooperatives which the sales help support the native communities.

Any congressional legislation that would make a clean sweep banning all commerce related to ivory would contradict ANSCA which is already law. Any EXCEPTIONS under ANSCA would still result in a LEAK in ivory commerce and therefore refutes the argument for a complete ban to close loopholes, if proposed. I do not believe that the USFWS will endorse any recommendation changing ANSCA nor do I believe that congress will move to amend ANSCA. The Alaskan natives provide a legal form of ancient ivory to artists and craftsmen in the lower 48 States. Many of these artists like myself firmly believe that use of ancient fossil ivory is an alternative which lessens demands for elephant ivory products and does not perpetuate illegal trafficking.

Thank you,
Dave Stanbrough
Prineville, Oregon

STATEMENT TO THE ADVISORY COUNCIL ON WILDLIFE TRAFFICKING

The minutes are not posted of the 16 December meeting and I only have second hand accounts of what was recommended. I will restrict my comments to elephants and ivory trade, as I have heard that the government is considering a total domestic trade ban. I carried out an ivory trade survey of the USA in 2006-7 so have more than average knowledge of the situation (http://danstiles.org/publications/ivory/16.2008%20USA%20copy.pdf). I assisted on an ABC Frontline ivory story and published an article this year on illegal ivory in New York City (http://danstiles.org/publications/ivory/34.NH%20NY%20ivory.pdf). I have also investigated ivory in many African, Asian (including China) and European countries.

The problem of elephant poaching is complex, but I’ll cut to the essentials.

An ivory trade ban within the U.S. is a bad idea:

1. Only new poached ivory entering the U.S. threatens elephants. Ivory already in the U.S. has no effect on poaching. So how much poached ivory now enters the U.S. legally?

Answer- Raw commercial ivory and worked ivory less than 100 years old are already illegal to import. So we are talking only about antique ivory. Fewer than 1,700 ivory antiques were imported in 2012. Experience shows most of these are small pieces weighing about a pound each on average. Say 10% are fakes – probably a high estimate, as it is reputable firms that deal in antiques (99% from Europe, none from Asia, according to the CITES Trade Database).

So to prevent ~170 fake antiques from being sold in the USA a year, weighing about 170 pounds (if that) total, or about 8 elephant deaths (one poached elephant = ~22 lbs ivory, according to CITES), hundreds, if not thousands, of American ivory collectors, museums, dealers, etc. are to be deprived and, in some cases, suffer financial loss.

Many more elephants are killed by American sport hunters a year. If you want to save more elephants, ban the import of trophy tusks.

An unknown quantity of illegal ivory is smuggled in every year, much of it labeled as mammoth or bone. A total ban will not affect this and trying to control it at the outlet level will require huge manpower, as currently.

2. A U.S. domestic ivory ban will invite multiple lawsuits that will cost millions and most likely result in an injunction postponing implementation of the law anyway, wasting time and resources that could better be directed towards doing something effective to help elephants.

3. A ban in the U.S. is a futile gesture – it will not reduce poaching in Africa because:

• Ivory speculators in Asia are buying and hoarding poached tusks in expectation they will rise in value as stockpiles and elephant numbers decrease; they are the ones stimulating the poaching, fulfilling their own prophecy as elephant numbers diminish. A U.S. ivory ban does nothing to address this cause.
• Ivory demand is already quite low in the U.S. and PR campaigns can drive it lower, more cost-effective than a total ban, which will drive ivory trade underground.

4. Related to 3, a ban will encourage the creation of an underground ivory black market, promoting corruption and criminal networks, increasing law enforcement costs, as has happened in African countries that have banned ivory sales. At least now, ivory outlets in the U.S. are easy to find and monitor.

5. Banning ivory commerce would be like banning the trade in books because they are made partly of endangered trees. These are both cultural items that express ideas, beauty, spirituality, human experience and so on. To save certain tree species or the elephant are we to ban books and crafted ivory?

6. Most important of all, there are much more effective ways of reducing elephant poaching than a ban in the U.S., which would entail the U.S. working in cooperation with ivory producing and consuming countries to devise a system of using only legal ivory humanely sourced from natural elephant mortality and legal elephant control measures. This would provide a long-lasting solution to poaching for ivory.

What is the better alternative to a total ban?

1. Legalize international supply of raw ivory to China to replace poached ivory with legal ivory. Take international raw ivory trade out of the hands of criminals and put it into the hands of CITES and government regulation.

2. Reduce incentives for ivory dealers and factories to buy illegal raw ivory from poachers and smugglers. They include:

• Rregular supply of legal ivory
• Prices lower than poached ivory
• High risk and penalties with poached ivory

3. Reduce consumer demand among Chinese people through a combination of market forces and social advertising to create stigma associated with buying new ivory.

• High price for finished pieces, partly achieved through a levy used to finance the CITES administration of legal tusk sales – ‘conservation tax’
• High prices also achieved by using ivory only for high quality, artistic pieces. Ban the use of elephant ivory for non-artistic items, such as name seals, cigarette holders, jewelry (except small pieces made from carving waste), etc.
• Advertising that links the purchasing of illegal ivory from unregistered sources with the slaughter of elephants. Consumers must be aware that buying ivory from registered outlets does not harm elephants. “Brand” the legal ivory, stigmatize the illegal.
• Use social media to reinforce the advertising message. Weibo is microblogging in China, like Twitter. There are many. Tencent is China’s FB and is bigger. The Chinese government and local NGOs and citizens can fill social media with anti-ivory chatter to lower demand.

Having a legal regulated trade where legal supply meets demand will be significantly preferable to the current unregulated, illegal system where demand is met by poached tusks. The key is convincing mainly Chinese ivory factories to buy only legal raw ivory. If that can be achieved, elephant poaching will drop considerably.

Some misconceptions

The 2008 CITES ivory auction did not stimulate ivory demand and the current poaching crisis.

• The only place in the world where demand went up was in the richer, eastern China cities. (In poorer Fuzhou, demand was lower than earlier, as it was in Japan, Thailand and Vietnam. Why didn’t the auction raise demand in those places?)
• Ivory demand was rising in China years before 2008, as it was for all luxury commodities, in tandem with increased wealth in China. It increased more with the global financial crisis as investors switched from stocks and property to art – ivory, jade, paintings, all went up at the same time.
• Chinese ivory consumers were completely unaware of the CITES auctions, so how could they have spurred Chinese to rush to ivory shops?

What really caused the poaching spike, which started in 2009 according to a recent joint CITES/IUCN/TRAFFIC report?

• CITES and TRAFFIC worked with China for years to encourage them to establish strict ivory controls, which they did, with the understanding legal raw ivory would be made available to satisfy domestic demand. China has the strictest controls of any country on Earth.
• China expected to receive a small but steady flow of legal ivory from Africa via CITES-supervised auctions after the 2008 auction. They would control demand by raising the price of ivory, which they did. Ivory consumer demand has fallen now in China.
• When the pro-ban lobby succeeded in gaining a 9-year moratorium on further CITES ivory auctions in exchange for not opposing the 2008 auction, China felt betrayed. With no legal ivory for at least a decade, factories realized they would have to resort to poached ivory. So word went out to Africa, poaching on.
• Speculators began to realize that with countries destroying their ivory stockpiles and with elephants being wiped out, ivory would only increase in value. They began buying to hoard. This hoarding of ivory on top of ivory being bought by factories has resulted in an elephant holocaust.

Sincerely,
Daniel Stiles, Ph.D.
Member, IUCN/SSC African Elephant Specialist Group