“Lions Are Now Protected Under the Endangered Species Act,” USFWS – Really?

Stephen Wiggins Article, Uncategorised 26 Comments

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Does the United States Fish and Wildlife Service (USFWS) Director, Dan Ashe’s words and planned actions go far enough?

The USFWS announced (21 December 2015) that:

“In response to the dramatic decline of lion populations in the wild, the U.S. Fish and Wildlife Service (Service) today announced it will list two lion subspecies under the Endangered Species Act (ESA). Panthera leo leo, located in India and western and central Africa, will be listed as endangered, and Panthera leo melanochaita, located in eastern and southern Africa, will be listed as threatened.”

These USFWS listings, under the Endangered Species Act (ESA) will become effective 22 January 2016.

Lion Range Map

African Lion (Panthera leo) Range – USFWS

So, in the USFWS view, the sub-species Panthera leo leo is “Endangered” but Panthera leo melanchaita is only “Threatened.” This latter statement is made in the acknowledgement that the overall Panthera leo population has been in steep decline, worse case 80% since 1980s. The USFWS says:

“The subspecies of P. l. melanochaita likely numbers between 17,000-19,000 and is found across southern and eastern Africa. The Service determined that this subspecies is less vulnerable and is not currently in danger of extinction. However, although lion numbers in southern Africa are increasing overall, there are populations that are declining due to ongoing threats. As a result, the Service finds the subspecies meets the definition of a threatened species under the ESA.”

The USFWS is also basing its “Threatened” judgement on Panthera leo melanchaita on “likely numbers between 17,000-19,000……”- which really says “no one really knows how many, so this is a best/‘likely’ guess we are basing an important judgement upon, with the risk that ‘reality’ could be worse.”

What will need to happen to the Panthera leo melanchaita population for the USFWS to class it and Panthera leo as a whole as ‘Endangered?” Presumably, the USFWS wishes to wait and see a scientific based approach that proves the Panthera leo melanchaita population has reached the same desperate level as Panthera leo leo (‘likely’ 1,400) before taking any ‘haste’ action.

It is also clear that USFWS is not taken in by all the hunting associations and their supporters’ claims, but still wishes to show leniency (complacency?) to the hunting fraternity and support such endeavours that are “well managed.” Well Trophy Hunting of lions is clearly not “well managed” in Zambia and Tanzania (both targeting Panthera leo melanchaita), so does the USFWS plan to immediately ban trophy imports from Zambia and Tanzania? I am not clear at the moment…..….

Indeed, how can Trophy Hunting of lions be “well managed” when hunting quotas continue to be based on “likely” population numbers and guesstimates, with hunting quotas set in cohorts with the hunting operators themselves?

Current reliance on lion range state government estimates of lion population numbers without independent scientific verification should be abandoned” – LionAid, 19 December 2015.

‘Canned’ Hunting

Also, where is the strong stance needed to restore credibility to the hunting industry and USFWS when it comes to protecting African lions and ensuring best practice? Does the USFWS support ‘canned’ hunting and its abhorrent, deceitful animal abuse, because there is no clear statement on the issue of ‘canned’ hunting in Dan Ashe’s 21 December statement, but the subject of inconclusive ‘analysis’ in the USFWS’s governing decision document:

Page 87- 89 USFWS, “Endangered and Threatened Wildlife and Plants; Listing Two Lion Subspecies,” RIN 1018-BA29, 10 December 2015

“Lindsey et al. (2012, p. 21) warn that future efforts to control hunting of captive-bred lions could potentially increase the demand for wild lion trophies and result in excessive harvests.” – Of course, allowing the ‘canned’ industry to flourish and continue to nurture a new cliental – a ‘hunter’ without any ethics that can ‘graduate’ to “harvest” the real, wild thing anyway, appears to have been somewhat ‘overlooked’ by the USFWS with any on-going acceptance of ‘canned’ hunting.

However, we also note that trade in bones of captive lions could stimulate harvest of wild lions to supply a growing bone trade.”

“………..As a result, we do not believe that the captive-lion industry currently contributes to, reduces, or removes threats to the species.

Update, 22 December 2015 – U.S. Fish and Wildlife Service Liz Hoopes:

Let us clarify a little more. We did not explicitly outline a ban on canned hunts, it is just illegal to kill a species listed under the Endangered Species Act. The ESA also regulates imports into the U.S. to make sure that trophies are obtained and permitted legally. We’re protecting the species here in the U.S. and regulating their movement into and around the country. If you have more questions, please let us know.”

Furthermore, at Page 220 “Our Response” USFWS, “Endangered and Threatened Wildlife and Plants; Listing Two Lion Subspecies,” RIN 1018-BA29, 10 December 2015

In analyzing threats to the species, we focused our analysis on threats acting upon wild specimens within the native range of the species, because the goal of the Act is survival and recovery of the species within its native ecosystem. We did not separately analyze “threats” to captive-held specimens because the statutory five factors under section 4 (16 U.S.C. 1533) are not well-suited to consideration of specimens in captivity and captive-held specimens are not eligible for separate consideration for listing. However, we did consider the extent to which specimens held in captivity create, contribute to, reduce, or remove threats to the species. See the Captive Lions and Traditional Use of Lion Parts and Products sections above. Under CITES, captive specimens are still listed the same as their wild counterparts; however, the Convention does allow for different treatment of captive-bred specimens in regard to permitting. As stated earlier, CITES also provides for stricter domestic measures, and the protections afforded to all specimens of the subspecies through listing under the ESA and the 4(d) rule would constitute such a measure.”

So, this USFWS ‘clarification’ on ‘canned’ hunting say Panthera leo trophies obtained from ‘canned’ hunting will be subject to the same USFWS verification process, ensuring the lion source is ‘sustainable conservation:’

USFWS Criteria stated at Page 178 -184 USFWS, “Endangered and Threatened Wildlife and Plants; Listing Two Lion Subspecies,” RIN 1018-BA29, 10 December 2015 – Including the “IUCN Species Survival Commission (SSC) Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives,” Ver. 1.0 (IUCN SSC 2012).

Well, of course ‘canned’ hunting/farming is “sustainable” because the ‘canned’ industry is very good at breeding ‘product.’ But, the ‘canned’ lions and big cats held are not part of any recognisable ‘conservation’ programme. The whole ‘canned’ industry in South Africa was declared to be of no conservation value, but was declared ‘farming’ by the South African Supreme Court of Appeal (SCA November 2010) when the South African Environment Department sought to regulate the ‘canned’ industry (Chris Mercer, of the CACH explains). The ‘canned’ industry in South Africa has been virtually unregulated since.

The question is whether the USFWS will consider ‘canned’ hunting, under IUCN Species Survival Commission (SSC) “Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives,” Net Conservation Benefit” as acceptable because in the USFWS’s opinion ‘canned’ hunting is “reducing the pressure on the target species….,” or ‘canned’ hunting is in contravention of that principle because “…it is also imperative that the program [‘canned’ hunting] is part of a legally recognized governance system that supports conservation.”  Well, ‘canned’ hunting in South Africa is clearly not part of a legally recognized governance system that supports conservation. So on those grounds, the USFWS should not permit the import of trophies derived from the unregulated and unrecognised ‘conservation value’ of the South African ‘canned’ hunting industry.  



Dan Ashe’s 21 December 2015 statement, as Director USFWS does not seem to go far enough. The action it does contain, listing the sub-species Panthera leo leo as “Endangered” is welcome, but long, long overdue – the USFWS’s action is not fully encompassing of the species.

There is no increased protection ‘required’ for Panthera leo melanchaita in Dan’s/USFWS’s opinion at the moment, no recommendation for better science to understand Panthera leo melanchaita plight even, just a best hope based on the “likely” numbers and future outcomes, with a “permitting mechanism to support and strengthen the accountability of conservation programs in other nations.

So the hunting of Panthera leo melanchaita may continue with Dan’s blessing it seems, provided of course the “sport-hunting” is “well managed.”  Dan/USFWS acknowledges that:

During the public comment period the Service [USFWS] found that not all trophy hunting programs are scientifically based or managed in a sustainable way…...”

USFWS “…….will allow for the importation of Panthera leo melanochaita provided they are permitted by the Service as originating from countries with effective lion conservation programmes.”

Where is the USFWS’s current list of “countries with effective lion conservation programs…” and more immediately, those countries that do not have an “effective lion conservation program” in the USFWS’s current view?

Without a USFWS pre-emptive list that has an enduring applicability (say at least three years from 22 January 2016, to give any Trophy Hunted lion population declared ‘unsustainable’ a ‘theoretical’ time to recover), but a rolling ‘apply and see’ policy, this may not (initially) prevent any hunters from taking their trophy lions kills, but will ‘frustrate’ the subsequent dead lion’s trophy imports into the USA if the lions was not sourced from a well managed, sustainable population in the USFWS’s opinion (ie. no Enhancement Permit will be issued, but the lion is already dead, so not exactly enhancing the species’ population). If the hunter has already paid in advance for their kill/trophy, why would the hunter still not take the kill anyway and chance the trophy import either immediately, or at some point in the future if/when allowed if there is no clear, enduring applicability to any USFWS ruling for a given country/source? So, is seems the picture will gradually emerge (and change regularly) with the USFWS’s on-going analysis/decisions on a ‘case-by-case’ basis where trophy imports might be allowed on any given day. Is this USFWS policy/approach likely to deter any Trophy Hunter from killing a lion anyway and thinking about the consequences (and how to circumnavigate them) afterwards? Will such a policy/approach help save the species? In my opinion, a much stronger, clearer approach and ‘message’ is required.

So, the USFWS “list” (where Enhancement Permits might be issued, or not) appears to be a ‘work in progress’ (and will remain a rolling ‘work in progress’) based on long list of specific criteria:

USFWS Criteria stated at Page 178 -184 USFWS, “Endangered and Threatened Wildlife and Plants; Listing Two Lion Subspecies,” RIN 1018-BA29, 10 December 2015 – Including the “IUCN Species Survival Commission (SSC) Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives,” Ver. 1.0 (IUCN SSC 2012).

From the criteria stated, how long will it take the USFWS to form the “list” and hence, enforce it? Why has such a list not been formed already on the mass of past evidence? What is the reason for past in-activity and past acceptance of lion trophies from countries with poorly managed lion conservation?

The fact that the proposed USFWS trophy permits will be required for trophy importation will not stop “well managed,” or indeed ‘poorly managed’ hunting (unless the Noble Hunter relents) and the ‘off-take’ of precious lion numbers.

So, the USFWS plans to ‘manage’ the import of any given dead lion’s trophy. The USFWS will not/cannot directly prevent any lion’s death in another country, but the USFWS could send a much clearer message by banning all lion trophy imports. Of course, the reluctance is due to the “saving of lion habitat” in hunting areas. But at the moment, there is a severe risk of conserving lion habitat in hunting areas, but the unscientific “off-take” of the lion within hunting and protected areas will not save the species. Could the general tourism industry (a much larger income base than Trophy Hunting, see Table 1) in country not take more action to protect habitat?

Table 1 – Trophy Hunting, Tourism Income and Population



Trophy Hunting Revenue(2) (b)

($m USD)



($m USD)

Trophy Hunting Revenue as % of Tourism Revenue
South Africa 51.4 112 9,547 1.2%
Ethiopia 84.3 1.45 522 0.3%
Cameroon 18.9 2.4 159 1.5%
Tanzania 44.9 32.9 1,457 2.3%
Zambia 11.8 7 125 5.6%
Botswana 2.0 25.4 218 11.7%
Namibia 2.1 32.8 517 6.3%
Burkina Faso 15.7 0.8 72 1.1%
Zimbabwe 11.8 20 634 3.2%
242.9 234.75 13,251 1.77%

(a) Based on US Census numbers (2009)

(b) All figures converted to 2011 $ USD

(c) UNWETO (2012)

By the time it’s realised that the decline of Panthera leo melanchaita is still on-going at a shocking rate (and the “likely” population numbers were perhaps very wrong), it might well be too late/pointless for Dan/USFWS to list Panthera leo melanchaita as “Endangered.”

If Panthera leo melanchaita heads to extinction, it will be partly due to the not so well managed, or even ‘managed’  “sports-hunting” and Dan Ashe’s, Service Director, USFWS’s complacency, or indeed, complicity. Or will the USFWS enforce strict rules to all trophy and ‘canned’ hunting and force better management of the species? With 60% of lion trophies historically imported into the USA, could stringent USFWS trophy import restrictions really deter the excessive “off-take” of lions? We will have to wait and see.

Let’s hope the European Union and potential CITES ‘uplist’ proposals to Appendix I for the African lion (including Panthera leo melanchaita) are more forthcoming, based on past evidence, current risk to the species as a whole, plus a perspective based on ‘reality’ and a need for urgent action, not partial action, or indeed inaction.

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