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(such as recovery planning and section 7 consulting) do not apply to these foreign 

 species. This means that the only significant effect of listing these species under the 

 ESA is to automatically prohibit the non-commercial importation of hunting trophies 

 or commercial forms of trade. 



As indicated by the diplomatic protest letter, the imposition of these prohibitions 

 amounts to a trade ban. The way that the listing and permit provisions of the ESA 

 have been administered, these trade bans have been imposed without consultation 

 with African wildlife managers and without regard to their impact on Africans or on 

 the conservation of the wildlife itself In other words, the ESA has been administered 

 in a way that interferes with uses of the species that are beneficial to local economies 

 and that provide incentives for conservation. 



Perhaps the worst thing about this improper administration of the ESA is that there 

 is no conservation excuse for it. Almost all of the same species are also regulated by 

 the treaty known by its acronym of CITES (Convention on International Trade in 

 Endangered Species of Wild Faima and Flora). Under CITES, it has been recognized 

 by the best conservationists in the world that the use of wildlife often leads to 

 incentives for conserving the wildlife. CITES allows the non-commercial 

 transportation of hunting trophies, for example, even for endangered species. This 

 recognizes that the number and type of animals taken by international hunters has no 

 biological impact on the species and often turns the species from a financial sink-hole 

 into an economic resource. For some species, such as the leopard, the Nile crocodile, 

 the cheetah and the elephant, quotas are set to assure that this is so. But the U.S., 

 using the ESA, has consistently denied its markets to even these beneficial uses. 



At the last CITES meeting, for example, the 128 countries that are parties to the treaty 

 unanimously adopted a resolution calling on all countries to honor the quotas. Yet the 

 U.S. still will not allow the import of cheetah trophies from the three countries with 

 CITES quotas, or trophies of elephants from Cameroon and Ethiopia, leopards from 

 Mozambique, or crocodiles from ten different countries. 



1 have attached to my testimony a detailed chronology showing the depressing twelve- 

 year history of mismanagement of the crocodile issue by U.S. bureaucrats. During 

 that time, CITES has approved the exportation of crocodiles from eleven African 

 nations, but the U.S. has only managed to allow importation of himting trophies from 

 one of those countries, and it took five years to do that! The record is far worse in 



