DRAFT STATEMENT ON E.S.H BY THE S.L.C.S

DRAFT STATEMENT ON ELEPHANT SPORT HUNTING BY THE SOUTH LUANGWA CONSERVATION SOCIETY
The purpose of this document is a reaction to the recent proposals made by the
Zambian Wildlife Authority (ZAWA), to open up Elephant Sport Hunting (ESH) in
the country, reversing a ban that was placed on this activity in 1982. This statement
will seek to
• Prove that this decision is not based on sound wildlife management
principles.
• Suggest alternative methods of
o Promoting elephant conservation.
o Reducing Human/Elephant Conflict (HEC) and increasing the
benefits of elephant ownership to the local community.
o Increasing revenue from the wildlife estate.

BACKGROUND
ZAWA has produced a document entitled “Draft Guidelines for Elephant Sport
Hunting (ESH)”. (Appendix I)
This document describes a fundamental change in ZAWA policy, and sets out the
basic guidelines on which they will base a new means of generating revenue by the
re-opening of elephant on Trophy Hunting License in Zambia.
SECTION 1 Quota Licensing and Hunting
• Stipulates that ESH will not include problem animals shot on control but
that should such animals occur in a GMA designated for ESH, at the right
time of year and be of desired trophy size the Professional Hunter (PH)
may shoot them if it is convenient.
• Four GMA’s are indicated (Upper Lupande, Lower Lupande, Rufunsa and
Chiawa) and the hunting concessionaire in each of these areas will be
allocated 50% of the quota at the ‘current fees for elephant stipulated in
the current Statutory Instrument’.
• The remaining 50% of the quota will be auctioned (with the Legal License
Fee as a reserve price) to hunters from concessions with no quota and the
successful applicants will be permitted to hunt elephant in the GMAs listed
above.
The assumptions made in the above statements are that
o ESH quotas will in effect be in addition to the considerable number of
animals killed on control each year and will not be restricted in any way to
‘problem animals’.
o The “Quota” is a figure derived from sound data on the national elephant
population, based on accepted monitoring and management practices.
o At some time in the last two years an SI has been passed by GRZ
reinstating elephant as a trophy animal and setting a License Fee.
o Animals of the desired trophy size exist in the GMAs designated for ESH.
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SECTION 1 Ownership, Export and Disposal of Remains Procedures
• Outlines the procedures by which ivory from trophy animals shall be
measured, details recorded on a ‘special form’ and surrendered to the
nearest Area Management Unit. Having been recorded in the local Ivory
Register it will be sent on to Chilanga (within 7 days) where it will be
marked in accordance with CITES requirements.
• The ivory will then be entered in the Special Register at Chilanga.
• At the time of export the hunter will be issued with a certificate of
ownership.
• ZAWA shall assist in the acquisition of an Import Permit from the
importing country.
• When the trophy leaves one of the four designated international airport
exit points the ivory will be compared with the details listed on the original
‘special form’ that was filled in (in the field after the animal was killed).
The assumptions made in the above statements are that
o Zambia has made application to CITES for the consideration of a noncommercial
ivory export quota.
o That the targeted importing country (USA) will agree, after taking
advise from CITES, to issue non-commercial ivory import licences for
the trophies arising from ESH.
o There has been a revolutionary change in the control of ivory stock at
Chilanga since the findings of the Panel of Experts who made an
assessment in 2002 and found a deplorable level of record keeping.
(CoP12 Doc 66 Annex 4- p8)
o The Authorities represented at the points of export are qualified to
verify the authenticity and identity of the trophy against records.
o That the original document recorded in the field still exists at the time
of export.
SECTION 1 Benefit Sharing and Conservation
• An elephant account will be set up and audited.
• 50% of proceeds from ESH will remain with ZAWA and 50% will be
disbursed to the local community in the relevant GMA at the end of the
hunting season.
• Not less than 50% of the meat shall remain with the local community
in the GMA.
The assumptions made in the above statements are that
o ‘Proceeds’ means statutory Licence Fees or possibly the value
achieved by auction.
o Not more than 50% of the meat will remain the property of the hunting
client or hunting company or ZAWA.
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In addition to the above information the Director General (ZAWA) has been minuted
in a stakeholders meeting (19/09/04) as stating that.
• The total national quota for ESH shall be 20 (Twenty) animals. These
shall be allocated
o 6 Upper Lupande
o 6 Lower Lupande
o 4 Chiawa
o 4 Rufunsa
• The Licence Fee that it is hoped will be achieved is USD$10,000 per
animal.
• There is to be no differentiation between male and female animals in
price, since this would be gender insensitive.
• No minimum or maximum trophy sizes have been set.
• The figure represents less than 0.75% of the national population and as
such requires no special permission from CITES for hunting to take
place.
• The export of non-commercial ivory, as trophies does not require
CITES approval.
• The importation of non-commercial ivory, as trophies, into the hunting
client’s country does not require CITES approval, merely an import
license from the receiving country.
ZAWA Policy and Elephant Management.
ZAWA’s VISION
To achieve excellence in wildlife estate management by developing innovative
approaches and partnerships that encompass best practice, with complete
transparency and integrity.
ZAWA’s MISSION STATEMENT
To contribute to the preservation of Zambia’s national heritage, ecosystems and
biodiversity for present and future generations through the careful conservation of
Zambia’s wildlife.
We shall use these core statements as a baseline policy for ZAWA’s activities.
As a last point of reference of ZAWA’s Elephant management policy we shall refer to
the document Prop.12.9 Considerations for Proposals for Amendment of Appendices I
and II (Appendix II) which was submitted to CITES in 2002. This document reflected
a change in Zambia’s elephant policy and was an attempt to gain permission from
CITES to
a) trade in raw ivory under a quota of 17 tonnes of whole tusks owned by
the ZAWA obtained from management operations;
b) live sales under special circumstances.
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The reasons given for this proposal can be assumed to be the same reasons for Zambia
now attempting to reinstate ESH, as since 2002 there has been no amelioration, in the
conditions affecting the following three factors which dictate elephant policy
i. Elephant population Monitoring and Management.
ii. HEC and Local communities in elephant areas.
iii. ZAWA Revenue Generation
If these three factors are assumed to be the same key, driving forces which have
caused ZAWA to reach the pro-ESH decision, we have a useful response in the
“Report of the Panel of Experts on the African Elephant on the review of the Proposal
submitted by Zambia to transfer its national population of Loxodonta Africana from
Appendix I to Appendix II “(CoP12 Doc.66 Annex 4) (Appendix III). There have
been no significant changes in conditions i-iii since the findings of this Panel and
CITES’ subsequent rejection, of Prop 12.9.
Let us examine the claims made by ZAWA to justify Prop 12.9 and the findings of
the Panel of Experts in response. We will then examine these same claims under
current conditions.
i) Elephant Population Monitoring and Management.
The following claims were made with regard to the elephant population and its
monitoring and management.
a) POPULATION MONITORING
ZAWA CLAIMS
-“The national elephant surveys conducted between 1992 and 1996 estimate a
national population between 22,000 and 25,000 animals. From the early 1990’s the
numbers have stabilized and shown trends of increasing”
-The following Table 1.0 was produced
Area 1992 1994 1996
1.0 LUANGWA VALLEY 9605 15469 16550
2.0 KAFUE SYSTEM 10263 4792 4980
3.0 LOWER ZAMBEZI SYSTEM 359 32 218
4.0 OTHER AREAS 2240 7 770
TOTAL NATIONAL ESTIMATE 22467 21000 22518
-“However, elephant population has stabilized. The stability in population could be
the only possible gain (of the ivory ban) though population structure is skewed in
favour or sub-adults and juveniles. A sure indicator for growing population.”
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PANEL’S RESPONSE
-“Since…..1998, Zambia’s own capability to monitor its elephant population has been
virtually non-existent”
-Due to resource limitations, no national surveys were conducted after 1996.
However, for the two largest (and therefore most important) subpopulations in the
country, i.e. those in the Luangwa Valley and the Kafue Region…..(the results) were
made available for inspection by the panel.”
-“…since the mid-1990’s, the population for the Luangwa Valley has remained more
or less stable, between 10,000 and 14,000 animals.”
-Other findings are shown below.
Kafue Region. 1992……….10,263
1997………..5200
2001………..4000
* representing a reduction in the population of 61%
-“…the national elephant population may have slowly declined from 20-33,000
animals in the early 1990’s, to 16,000-29,000 in the late 1990’s, to 12,000-25,000 in
2002.”
-“Although the current level of ivory offtake from natural mortalities and control
work is low, and therefore sustainable, the fact that the overall population is not
increasing (and could be decreasing) suggests that there is an important illegal offtake
that accounts for a substantial amount of the ivory that could in theory be produced by
a population of this size. The panel estimates that this accounts for some 800 animals
a year”
-“In view of these factors, it must be concluded that the overall level of offtake is not
sustainable”
CURRENT SITUATION
Assuming the population has remained stable at the maximum estimate of 25,000
animals since 2002 until the current time and that the growth rate is 4%pa, a Zambia
is still losing animals at a rate of 1000 per year.
The stockpile of ivory in storage at ZAWA HQ in 2002 was recorded as 17,713.96
kgs with an average tusk weight of 4.23kg. Assuming two tusks per animal this
represents 2094 animals, accumulated in ten years (1992-2002). This figure represents
209.4 animals per year accounted for, which leaves 790.6 animals unaccounted for
and the result of illegal offtake.
Using the same rationale the stockpile of ivory now in storage is estimated by ZAWA
to be over 20,000kgs which means that a minimum of 2,286.04 kgs has been
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accumulated in two years. This represents 135 animals per year accounted for by
ZAWA.
Given the expected increase of 1000 animals per year it appears that illegal offtake,
estimated using the same methods as the Panel of Experts is still running at around
800 (865) animals per year, which must still be considered as “not sustainable”.
b) LAW ENFORCEMENT.
ZAWA CLAIMS
-“Introduction of stringent penalties for illegal use of elephant and its products”
-“In enforcing the law, ZAWA has adopted a zero tolerance policy to all incidences of
poaching, violation of the wildlife Act is prosecuted to the fullest extent of the law
including the confiscation of any equipment used in the commission of the offence.”
-“In the last decade (1992-2002) poaching for ivory in Zambia’s Protected Areas
appears to have decreased considerably. Between 1980 and 1990 there were more
reported incidences compared to the last decade. Although statistics mat not be
readily available, field reports and aerial observations indicate a reduction in poaching
trends”
-“The decline in poaching for ivory incidences can be attributed to the improved
strategies and effective law enforcement operations in the Area Management Units.”
-With reference to the adoption of the Monitoring of the Illegal Killing of Elephants
(MIKE) programme it was stated in 2002 that
“The programme is now well established in South Luangwa National Park and is
expected to include surrounding GMAs soon”
-The following “Record of elephants killed by poachers in the last nine years.” Was
submitted to CITES
Year 1994 1995 1996 1997 1998 2000 2001 2002
Number killed by poachers 27 22 18 18 16 16 13 0
PANEL’S RESPONSE
-“Effectively, for a period of almost 10 months in 2000, there was virtually no law
enforcement in the majority of Zambia’s conservation areas.”
-“…during the above 10 month transition period, it was estimated that 156 elephants
were killed in an area of about 2,560km2 in the central Kafue alone.” (Jachmann
2000)
-“The current situation suggests that there has been a drastic decline in the
effectiveness of anti-poaching activities”
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-“The consequence of these actions has been a substantial increase in the level of
poaching of all species.”
-“…the Panel concluded that the current anti-poaching measures were not effective.”
-“The Zambian Wildlife Authority is currently investigating the role of Zambian
nationals and ivory sourced within Zambia relating to the recent seizure of 6.5 tonnes
in Singapore. There have been seven arrests to date including an unspecified number
of ZAWA staff members.”
-“It is quite clear that the current anti-poaching measures are not effective”
CURRENT SITUATION
The figures submitted to CITES as national elephant poaching statistics bear no
resemblance to actual figures recorded by Area Management Units and NGO’s as
demonstrated in the table below which indicates poached elephants in the South
Luangwa National Park and bordering Upper and Lower Lupande GMAs.
2000 2001 2002 2003 2004
ZAWA report to CITES
National animals2002
16 13 0 - -
Aerial Count of
elephant carcasses
SLNP/Lupande GMAs
- - 71 - -
SLAMU reported to
ZAWA 2003
SLNP/Lupande GMAs
46 22 22 15
SLAMU records 2004
corroborated by SLCS
SLNP/Lupande GMAs
- - - - 35
The figures for 2002 would suggest that ZAWA’s Proposal to CITES to have the
national elephant population down-listed to Appendix II may not have been based on
figures compiled with complete transparency and integrity.
Following the June 2002 Singapore seizure spearheaded by the Environmental
Investigation Agency and reported in the ‘Back in Business’ report and the EIA
newsletter ‘The Investigator’ (Issue 10 Winter 2002) netted 6.5 tonnes of illegal ivory
representing (at the same average tusk weight we have used thus far) 768 animals.
Some of this ivory was marked with ZAWA identification numbers strongly
suggesting that it originated from the ‘secure’ stockpile held at Chilanga. This,
coupled with the fact that not a single member of ZAWA’s personnel who were
implicated in the investigation was prosecuted or even relieved of duty since that
time, once again raises the question of complete transparency and integrity in
ZAWA’s practices.
The last column of the above table gives figures for poached elephants in the SLNP
and Lupande GMA’s for 2004 (up to 03/10/04). These records derive from SLAMU
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and have been checked against the reports made and held by the SLCS and found to
have no significant differences.
They detail, in many cases with GPS co-ordinates, 35 incidents of elephant poaching
so far this year. If poaching continues at this rate we will, by the end of the year have
equalled the poaching rate of 2002 (46 animals) a period when “there was virtually no
law enforcement in the majority of Zambia’s conservation areas.”
This is a clear indication that despite increased patrol activities and a massive
expenditure, the effectiveness of ZAWA’s law enforcement program in the Area
Management Units has not improved.
In the population estimates for SLNP and Lupande GMAs (aerial census 2002
ZAWA/WWF/SARPO) the following were recorded
• Elephant Bulls
o Lower Lupande…………………..47
o Upper Lupande…………………...26
o SLNP……………………………..190
TOTAL…………...263
• Elephant Cows
o Upper & Lower Lupande…………902
o SLNP……………………………...4268
TOTAL……………5170
These figures represent a discrete sample for a particular time, and are not significant
in themselves but suggest the following
• The population is roughly skewed in favour of female animals.
• The number of bulls at any one time in the Lupande GMA’s is a very small
percentage of the total population.
• Since ESH quotas do no specify sex, age or trophy size and the likely targets
will be old males with significant ivory, the actual quota of 12 animals for
Lupande GMA’s represents an unacceptably high percentage of the number of
bull elephants that might be expected to occur in the GMA’s at any time.
The following concerns regarding elephant populations and behaviour have also been
raised by various stakeholders.
1. Professional hunters themselves have expressed the opinion that the
population has not sufficiently recovered from the recent high levels of illegal
offtake, nor are there sufficient if any trophy animals in the population to
warrant the reinstatement of ESH (Appendix III Statement from Luawata
Conservation)
2. Personal communications with tourism operators throughout the
SLNP/Lupande GMA range suggest that bull elephants with even entry level
trophy ivory are absent or scarce across most of the SLNP and surrounding
GMA’s.
3. Behavioural evidence suggests that older bulls in a population perform an
important disciplinary role with younger animals and that the absence of older
bulls could lead to higher rates of delinquency, crop raiding and HEC in the
SLNP and GMA’s.
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4. Hunting in the GMA’s will cause elephants to move away from the riverine
area and into areas that are less efficiently patrolled placing them under threat
from illegal hunters. This will reduce the population of bull elephants to a
much greater degree than the removal of a relatively low number under ESH.
The above concerns cannot be supported by any known scientific data but are
nonetheless relevant since this is the very data that should be made use of by
ZAWA in order “To achieve excellence in wildlife estate management by
developing innovative approaches and partnerships that encompass best
practice.”
The fact that the decision to reinstate ESH is not based on a scientific data means
that it has no justification on the following grounds.
• The actual size of the population is not known (viability).
• The carrying capacities for the area designated for ESH are not known.
(sustainability)
• The illegal offtake from the population is not known.(sustainability)
• The illegal offtake from the population is not controlled.(sustainability)
• There is insufficient data on the occurrence of ESH trophy animals.
• There is no data on the effects of removing such animals on the population
as a whole or on the behaviour of the remaining animals, especially with
reference to a negative impact on HEC.
Given the above we can discount the ESH Proposal as a scientific imperative or an
example of excellence in wildlife estate management or best practice.
The proposal must now be examined for validity on the remaining grounds.
ii) HEC and Local communities in elephant areas
iii) ZAWA Revenue Generation.
ii) HEC and Local Communities in Elephant Areas.
Using Prop.12.9 Considerations for Proposals for Amendment of Appendices I and II
(Appendix II) once more as the last point of reference.
ZAWA CLAIMS
-“Elephants….must return demonstrable tangible economic benefits to landowners or
communities sharing habitat with them”
-“Their (resource-poor local communities) primary concern is to fight the injustice
that elephants inflict on them in the destruction of their livelihood by loss of crops and
human life”.
-“The funds would be used to develop strategies to protect crops in the elephant range
areas.”
-“A changed perception about elephants would enable the community to tolerate and
accept to coexist with them.”
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-“Communities are distanced from gaining tangible economic benefits from the
animals”
-“It is these same people (rural households) whom should make their lands safe for
elephants while accepting their dangers and risks of living with these large and
sometimes destructive animals”
-“the contributions from the utilization of a species that is known for its devastating
effects were long overdue”
-“The policy statement expresses the government’s intention to regulate use of
elephant by such means and measures that will ensure its long-term survival, by
providing for human benefit particularly to local communities, and enjoyment of the
elephant by the public in such a manner and by such means as will not deplete their
populations but leave them for the enjoyment and benefit of future generations.”
PANEL’S RESPONSE
-“Currently local communities often regard elephants as pests that should be
destroyed, at least in the territories of the communities, especially when their crops
and lives are put at risk. ZAWA has indicated that some of the money from the sale of
the ivory stockpile would be paid to the local communities. This would help to
improve the tolerance of elephants by demonstrating that they have a financial value.”
CURRENT SITUATION
The SLCS agrees with all the statements made by ZAWA in their 2002 Proposal and
with the response of the Panel of Experts. However it is not supported that the only
way to achieve the objective of “A changed perception about elephants” or to improve
the tolerance of elephants” within local communities is through ESH.
ZAWA was established under the 1998 Act, with responsibility for national parks,
ecosystems, biodiversity and GMAs. In particular, it is responsible for the following
• In partnership with local communities, to share the responsibilities of
management in GMAs
• To encourage general development in National Parks,
GMAs…including the development of facilities in accordance with
management plans
• To enhance the economic and social well-being of local communities
in GMAs
• To prepare and implement management plans for National Parks,
GMAs… in consultation with local communities
• In partnership with communities, to grant hunting concessions to
hunting outfitters and photographic tour operators in GMAs
• To assist and advise the CRBs
• To pay out money - to a CRB, from license and concessions fees
obtained, and according to regulations issued by the Minister
• ZAWA may delegate any of its functions to the CRB
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In 2003 hunting revenue to ZAWA from Lower Lupande GMA amounted to a total of
around USD $156,000. The community was supposed to be given 40% of this
revenue as described in the Act (see above). However they have not been given any
part of the concession revenue and the share of Game Licence fees that the Kakumbi
CRB received amounted to a mere USD$ 8,000 which gave a figure of some USD
$2.50 per household.
Nationally CRB’s are involved in litigation with ZAWA to redress what they feel has
been a misinterpretation of the Wildlife Act. This situation is a poor example of
“partnerships that encompass best practice, with complete transparency and
integrity”
ZAWA’s ESH proposal under the same conditions would nett Kakumbi CRB some
USD $30,000 which if distributed in the same way would represent less than USD
$10 per household as a one off annual payment. This figure cannot realistically be
expected to support any of ZAWA’s claims (above) with regard to “changed
perspectives” “tolerance” and “coexistence”. Any payoff, especially such a negligible
one, will do nothing to change the feeling within the community that “the only good
elephant, is a dead elephant”(pers com) and will undermine years of work and
millions of dollars spent in the education and sensitizing of local communities to
conservation issues. In brokering the consumptive use of the communities’ keystone
species for such a pitifully small return ZAWA is failing completely to address the
real issue of sustainable poverty alleviation as funds will still be insufficient to
“develop strategies to protect crops in the elephant range areas”
However there is hope that such strategies will continue to be investigated by ZAWA,
NGO’s and the Community and that donor funding encouraged by non-consumptive
community based trends will affect a long term solution.
The following observations have been made by Mike Jones a technical consultant
who has been working with ZAWA in Lupande
“I am currently working with WWF on HEC in Lupande using chilli-based
methods. So far the results are mostly positive and we will be doubling our input over
the next growing season. In our efforts, we have two major problems to cope with:
1) Many of the villagers would prefer elephants to be shot because (a) they are afraid
of elephants, with good reason (4 deaths this year alone); and
(b)they need animal protein which is in short supply in Lupande because of the Tsetse
Fly.
2) If chilli-based or other methods are to provide a permanent solution to HEC, they
have to be adopted by the villagers and implemented by the villagers. We have to be
careful not to give them the solution, but to lead them to the point where they discover
and implement the solution themselves This approach takes time but it will pay off in
the end.
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Donors of all kinds are showing a lot of interest in HEC and it seems to me that we
need to find a way of coordinating and focusing that interest in Lupande. HEC can
then be tackled, not just in terms of keeping elephants out of crops, or shooting
elephants, but as a way of engaging villagers in economic activity that is financed
from tourism based sources. The primary need for most people in Lupande is food
and jobs and conservation efforts have to address those needs if wildlife is to be
conserved.
I am also working with WWF on land use planning and personally find the arguments
for changing land use from sport hunting to photo-safari along the Luangwa quite
compelling. Unfortunately land use in Lupande is a highly complex and political
affair so this too is a slow process. What I initially envisaged as a simple technical
exercise is likely to take a long time as the conflicting interests of Chiefs, District
Council and ZAWA, not to mention hunters, tour operators and everyone else, are
reconciled.”
ZAWA’s stated aim ‘to facilitate the active participation of local communities in the
management of the wildlife estate’ should look at long term solutions to empower
local communities and convey the responsibility of ownership of natural resources
such as elephant. This will ultimately be achieved by the formation of joint-venture
conservancies which place resource ownership firmly in the hands of the community
and give wildlife usage and ownership rights to such joint-ventures, and which
therefore will naturally conserve wildlife. This long term partnership of communities
and investors could ultimately lead to the GMA’s being independently funded through
tourism, hunting and game ranching and represents the sustainable road to poverty
alleviation. Sadly this will require ZAWA to relinquish some of its control over the
GMA’s, a situation which they have anticipated in the Wildlife Act and are dealing
with, but are ultimately reluctant to accept as evidenced by the comments of the
Director General (19/09/04 Mfuwe)
-The DG stated that the whole GMA is a government game farm and the locals get
their meat from hunting and proceeds from hunting. There is no way a game farm
run by any other party could be allowed in a GMA
Despite this opinion there exists a ZAWA Draft Policy on Private Wildlife Estates
(May 2003)
This draft policy on PWEs is presently under discussion, and, provided ZAWA is able
to consult the private sector and Game Producers Association of Zambia (GPAZ)–
and most importantly the Chiefdoms, the CRBs, the Investment Centre and other
Ministries, a progressive policy could be in place to encourage investment in the
development of conservancies and privately-owned game ranches. The document is
summarized below:
i) General points:
• The importance of PWEs is recognized in the war against rural poverty
• ZAWA will support PWE establishment and will provide the animals
for restocking at a fee.
• ZAWA wish to enter into partnerships with PWEs, communities and
the private sector
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ii) Private estate classification
• Game ranches: fenced, private, not greater than 5 000 ha
• Communal –Private Conservancy: joint venture, fenced, not greater
than 30 000 ha.
• Communal Wildlife Conservancy: community owned, fenced or not,
not greater than 50 000 ha.
iii) Some of the guidelines suggested for PWE applications are:
• Application for a PWE to be made to ZAWA on the prescribed form
• Detailed business plans must be submitted
• Approval of a PWE will be given only after a feasibility study &
inspection
• ZAWA will co-ordinate PWE development with the other Ministries
and stakeholders
iv) PWE restrictions
• Restrictions on the placement of fences in relation to rivers
• Where existing properties are too close to rivers, and unable after an
ecological study (ES) to alter the boundary, ZAWA will not delegate
ownership, but instead will award ‘user rights’; and will set an off-take
quota
• All PWEs must be fenced unless an environmental study (ES) suggests
it is not in the biodiversity interest
• ZAWA will ensure that PWEs have management plans that provide
off-take restrictions and quotas
• Professional hunters and capturers require to be registered with ZAWA
• Only a percentage of live capture are to be allowed for export
• No medium to large scale PWE will be allowed within 10km of built
up area (i.e. a town)
• Export is prohibited in endemic species e.g. Kafue & black lechwe
• Various restrictions are suggested on the import, care and release of
species, most of them following international regulations (CITES and
IATA etc)
v) PWE conditions
• Private operators to submit annual returns to ZAWA not later than 15
Feb. of every year.
• Transfer of ownership to be with the approval of ZAWA, but only after
a game inventory is taken
• A change of land-use requires ZAWA’s approval
• CITES regulations to be followed
vi) ZAWA delegation of responsibilities
• Ecological studies & supervision of game capture may be delegated to
an agent
Thus a framework is already under construction which in a relatively short time, could
offer real poverty alleviation and ownership benefits to local communities on a
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sustainable basis. It is ZAWA’s reluctance to accept the community’s customary
rights which necessitates such drastic, financially inadequate, short term measures as
ESH. Which CRB struggling to get off the ground under the current climate that
exists in most rural, wildlife areas would refuse the chance to earn a few thousand
dollars? It is irresponsible of ZAWA to support such limited, short term rewards at the
higher cost of long term sustainable alternatives.
iii) ZAWA Revenue generation.
ZAWA CLAIMS
-“No licensed hunting would be permitted in the immediate future. Any hunting
allowable would be for the purpose of management operations only”
-“elephants are of high value and manifest themselves with high costs. They should
correspondingly be of high benefit to landowners especially local communities.”
-“Currently, ZAWA’s capacity to continue managing the wildlife estate, effectively is
constrained by financial resources.”
-“Zambia’s Tourism is mainly wildlife based. Elephants along with other big game,
make up the main attraction that mostly interest tourists.”
-“The policy statement expresses the government’s intention to regulate use of
elephant by such means and measures that will ensure its long-term survival, by
providing for human benefit particularly to local communities, and enjoyment of the
elephant by the public in such a manner and by such means as will not deplete their
populations but leave them for the enjoyment and benefit of future generations.”
PANEL’S RESPONSE
-“ZAWA does not have the financial means to manage its wildlife resource, which
includes effective law enforcement and monitoring.
-“there is no indication that Zambia is interested in any form of consumptive
utilization of elephants either in the short or in the long term.”
-“The financial resources of ZAWA are extremely limited and consequently it is not
able to carry out its mandate. It has to rely heavily on donor support and support from
local communities in the Game Management Areas. Any major income for ZAWA
will improve its ability to fulfil its role”
CURRENT SITUATION
There can be no doubt that ZAWA is engaged in a difficult and ambitious undertaking
and that the aim to be self sufficient create tremendous financial pressures.
Using the SLNP/Lupande GMA’s as an example once more we note the following.
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Over the last two decades in the SLAMU area the tourism sector and ZAWA have
engaged in an ongoing and hitherto unresolved debate over tourism vs. hunting as the
key revenue earners. It cannot be denied that in the SLNP GMA’s tourism does not
generate direct funds for ZAWA that are passed on to the community, however
earnings from Park Entry, Drive Levies and Lease Fees in 2003 comprised virtually
all of the 71% of the budget requirements for SLAMU which were generated in the
area and which funded all SLAMU’s management activities both inside the SLNP and
the GMA’s.
Earnings of K4 065 billion (71%) arose from tourism and other sources in SLAMU
while NORAD provided K1 668 billion (29%) in form of revenue grant and GRZ
failed to provide the promised support of K984 million. This gave the total figure
earned by SLAMU of K5 733 billion which was spent on all activities including
Ecosystem Monitoring and Management
Law Enforcement
CBNRM
Infrastructure
Equipment and Vehicles
Procurement and Distribution
Stores Management
Commercial and Tourism Development
Personnel and Administration
These facts serve to reinforce findings made and submitted to CITES in 1994
(Coppinger J. updated Mwanza.I 2000/2001Appendix IV) that Photographic Safaris
generate far more income per square kilometre (USD $ 39,866/sq km) and are thus of
more benefit to the inhabitants of that range, than Hunting Safaris (USD $ 88/sq km).
This is illustrated by the fact that the ZAWA revenue from a handful of operators in
the SLNP in 2003 provided almost 71% of the budget for management of not only the
SLNP but the 4,500 sq km of the Lupande GMA’s.
The potential revenue that may be generated for ZAWA from ESH in the Lupande
GMA’s is USD $60,000. This figure represents some 7% of the operational
expenditure of SLAMU for 2003.
Tourism revenue to ZAWA in the same year generated some USD $900,000. It would
be in the interests of everyone if revenue from tourism could be increased by $60,000.
Park Entry figures for International tourists in 2003 show a revenue of USD $453,595
which represents 22,680 Park entries at $20pp. Plans to increase the Park Entry fee for
internationals from $20 to $30 for 2005 have been unveiled. At the 2003 levels of
entry this would realise USD $680,400 an increase of some 50% in Park Entry
revenue and representing 27% of 2003 SLAMU expenditure. This represents a major
increase in revenue for ZAWA and makes sound economic sense.
The potential negative impact on tourism in Zambia from the introduction of ESH can
only be guessed at. However in the SLNP/Lupande GMA’s if we take 2003 figures
for revenue from tourism at $900,000 and increase the Park Entry Figure to $30pp
then the figure of $60,000 for ESH represents around 5% of the projected revenue
from tourist. This effectively means that if one out of every twenty people planning to
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visit the SLNP changes their mind because of ZAWA’s decision to conduct ESH, the
financial benefit to SLAMU of the scheme will be lost entirely.
There are numerous alternatives to assist ZAWA’s cash flow problem. These include
• Revitalising existing and underutilized tourism sites in the Parks and GMA’s.
• Opening up new areas of the Park and GMA’s for tourism (the latter on a
Community Based system)
• Restructuring resident hunting licence fees so that they represent realistic
meat/trophy value but are still affordable to the relatively affluent Zambian
residents who utilise them (this is not aimed at district or chiefdom quotas for
actual GMA residents who should continue to benefit from subsidised
licences).
• Restructuring international trophy licence fees making more abundant plains
game species more attractive to foreign hunters and more competitively priced
in the sub-region and by introducing a sliding scale for certain animals to be
made available on supplementary licences at a reduced price
o e.g Allow a second buffalo or hippo to be taken at 20% lower than the
first. This would generate significant extra revenue at little cost to
populations of animals such as hippo where culling is planned anyway.
• Reduce ZAWA’s expenditure in the GMA by adopting Private Wildlife Estate
Policy and encouraging community led private sector partnerships in wildlife
management and sustainable utilization projects. If ZAWA is not spending
money on infrastructure and management of large areas of the GMA then it
does not have the critical imperative to earn money from these areas at high
cost to its international conservation credibility and reputation. Adopting such
strategies would encourage huge donor support.
• Consult more openly, seek and take notice of stakeholders’ advice in the areas
of operation. This would ensure that available funds are spent more wisely.
o e.g Current plans to spend USD $5.6 Million on roads in SLNP only
one of which is justified for law-enforcement purposes. The other two
will fail to generate significant revenue for SLAMU in terms of
increased tourism, will contribute significantly to poaching and will
cause degradation and disturbance to areas of the Park which are
already generating proven income for ZAWA, thus overall having a
negative impact whilst spending the equivalent of some 40 years worth
of revenue from ESH.
CONCLUSIONS
ZAWA’s VISION
To achieve excellence in wildlife estate management by developing innovative
approaches and partnerships that encompass best practice, with complete
transparency and integrity.
With reference to the above and with consideration of the following factors
o Promoting elephant conservation.
o Reducing Human/Elephant Conflict (HEC) and increasing the
benefits of elephant ownership to the local community.
o Increasing revenue from the wildlife estate.
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The SLCS observes that
1) ZAWA’s ESH Proposal is made without the benefit of sufficient scientific
data on the national elephant population.
2) That the management of this population and the control of factors such as
illegal hunting are not adequate to justify further offtake from the population.
3) That the benefits in revenue to ZAWA do not justify such a radical change in
policy on elephant conservation nor the damage this will do to Zambia’s
image in the wider donor, conservation and eco-tourism communities.
4) That the benefits in revenue to local communities are insufficient to offer any
real poverty alleviation, hunger relief, compensation for or reduction in
Human/Elephant conflicts and that a more far sighted strategy is desirable.
5) That the negative impact on non consumptive eco-tourism which currently is a
significant source of both ZAWA and GRZ’s revenue, and the possible loss of
earnings associated with this, have not been adequately considered.
6) That the proposal is designed to circumvent CITES conditions and is
damaging to Zambia’s status as a signatory to CITES. There is concern that
this may actually jeopardise any long term hopes of ever being able to utilize
the national population or any ivory or other wildlife products generated from
it even under legally sanctioned and controlled practices.
7) That the proposal seeks to use the needs of the community to promote a
scheme which will have only minor short term, tangible benefits to them
instead of encouraging strategies which might empower the local communities
at a the possible cost to ZAWA of surrendering their own perceived ownership
of the wildlife estate.
8) That the proposal does not consider the actual ESH market and has proven the
occurrence of sufficient trophy animals to ensure a successful marketable
product. This will damage Zambia’s image as a hunting destination.
9) That the resource is being sold too cheaply and that the revenue generated will
not be justified by the benefits to ZAWA or the local communities or negative
impact on tourism and national image.
10) ZAWA has a poor track record in revenue sharing with local communities and
whilst this situation still exists it is unwise to enter into further arrangements,
especially over such a valuable resource.
11) Other avenues of revenue generation for both ZAWA and the communities
have not yet been exhaustively pursued.
12) There is nothing to suggest that ESH in Zambia does indeed represent best
practice or excellence in wildlife estate management.
CONCLUSION
i) The ESH Proposal cannot be justified as an elephant population management tool.
ii) The ESH Proposal will not provide local communities in elephant areas sufficient
revenue to implement long term solutions to poverty or food shortage, nor will
HEC be reduced.
iii) The ESH Proposal will not result in significant ZAWA revenue and thus will
not contribute to elephant conservation management programs
ESH will merely act as a temporary placebo for ZAWA to placate local communities
and defer the real issue of the ownership and preservation of the wildlife estate
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DEFINITIONS AND ABBREVIATIONS
Biodiversity Biological diversity: the variations in biological
organisms at ecosystem, species and gene level
Customary Authority Chiefdom
Ecosystem A dynamic complex of plants, animal and microorganism
communities an their non-living environment
interacting as a functional unit
Game Commonly hunted animal species
Natural resources Land and its biological resources: the soils, the
vegetation and the fauna…
Strategy A set of chosen actions to support the achievement of a
specified development goal
CBNRM Community Based Natural Resources Management
CRB Community Resource Board declared under the Zambia
Wildlife Act of 1998 No. 12 Part 3 (6)
CITES Convention on the International Trade in Endangered
Species of Fauna and Flora
EIA Environmental Investigation Agency
ESH Elephant Sport Hunting
GMA Game Management Areas declared under the Zambia
Wildlife Act No. 12 Part 5 of 1998
GPAZ Game Producers Association of Zambia
GRZ Government of the Republic of Zambia
HEC Human/Elephant Conflict
MIKE Monitoring of the Illegal Killing of Elephants
NGO Non Government Organization
PWEs Private Wildlife Estates
SLAMU South Luangwa Area Management Unit
SLCS South Luangwa Conservation Society
ZAWA Zambia Wildlife Authority
Appendices
Appendix I Draft Guidelines for Elephant Sport Hunting (ESH). (ZAWA)
Appendix II Prop.12.9 Considerations for Proposals for Amendment of Appendices
I and II (ZAWA)
Appendix III Report of the Panel of Experts on the African Elephant on the review
of the Proposal submitted by Zambia to transfer its national population
of Loxodonta Africana from Appendix I to Appendix II “(CoP12
Doc.66 Annex 4)
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Appendix IV Statement from Luawata Conservation on proposed ESH
I have been asked my opinion on the proposal to re-open an elephant hunting quota in
Lupande GMA.
I am a working Professional Hunter with over 30 years experience in the field. I have
an intimate knowledge of the Luangwa Valley where I have spent most of my life. In
the 70's I hunted elephant in Zambia, Congo (then Zaire) and the Sudan and I can
truthfully claim to be the most experienced (legal) elephant hunting guide in Zambia
today.
Thanks to ZAWA's conservation efforts it has been encouraging to observe the
recovery of the elephant population since the decimation of the 80's. This is
particularly true over the last three or four years, where the increase seems to have
been most noticeable.
However, there are very few adult bulls and absolutely no old bulls who are carrying
any significant ivory.
It is my opinion that it is premature to allow the few bulls that there are to be hunted,
particularly at this critical time in their recovery. Until such time as there is sound
scientific evidence that the population has returned to an acceptable mature male to
female ratio, I feel it would be irresponsible to encourage any further offtake of an
already imbalanced population.
Sincerely,
Adrian Carr
Appendix V Game Viewing Safaris-Their Potential and Relationship to Safari
Hunting with Insights from Lumimba. (Coppinger J. updated
Mwanza.I 2000/2001)
Additional References
Chipuna Conservancy Handbook
JOINT-VENTURE CONSERVANCY DEVELOPMENT FOR CHIEFDOMS
(Chipuna Group: ProjectsAfrica & Gamefields International)
The Investigator’ (Issue 10 Winter 2002)
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