I promised a follow up the other night in my piece on the FWS Ivory Ban. National Geographic Channel recently aired a special, “Warlords of Ivory”, where Investigative Journalist Bryan Christy examines the elephant poaching situation in Africa and track the movement of an artificial tusk with a gps transmitter as it enters the black-market pipeline and makes its way to China, the destination for the exponential majority of illicit ivory trade.
The complete video is on YouTube but is a blatant pirate upload of a complete show and isn’t even close to gray-area fair use. However there is a 6 minute trailer below the jump and is worth a look. Tense moments when he is arrested in Daar es Salaam, Tanzania and accused of ivory smuggling himself.
Please contact the US Fish and Wildlife Service and ask them to reconsider the proposed rule change regarding interstate sales of legal ivory. Additionally or alternatively, please contact your Representatives and Senators and ask that they co-sponsor and support the African Elephant Conservation and Legal Ivory Possession Bill.
Click here (and again on the check-box to specify this specific issue) and leave a polite comment to the FWS. Encourage them to reconsider the ivory rule change, citing this piece from Dr. Daniel Stiles as support for the notion that the proposed ban would be an unnecessary burden for legal US ivory owners while wasting resources that could better be used to to curtail the ivory trade to China and other East Asian countries.
If you don’t feel like composing an original letter, copy and paste the following form letter (this is less effective than original writing):
“Fish and Wildlife Service (“Service”) Proposed Rule: Endangered and Threatened Wildlife and Plants: African Elephant (Loxodonta africana) Rule; revisions to rule 4(d) for the African Elephant MUST BE WITHDRAWN. The proposed rule in its present form is in violation of the Administrative Procedure Act (“APA”) (Pub. L. 79-404, 60 Stat. 237) and the Federal Data Quality Act (aka Information Quality Act) (“DQA”/”IQA”) (Pub. L. 106-554, § 515). The APA is violated, because the Service’s proposed rule is “arbitrary and capricious, an abuse of discretion or otherwise not in accordance with law” (5 U.S.C. 706(2)(A)). Specifically, the Service has not articulated a reasonable basis supported by reliable and accurate data for its decision to promulgate this rule. The DQA/IQA is violated, because the data upon which the Service has based its decision to promulgate this rule, is either entirely nonexistent or in the alternative, has been seriously misconstrued. One glaring example of serious misconstruction of data by the Service in justifying the promulgation of this rule, are the misreported findings of the studies conducted by Dr. Daniel Stiles, as noted in his comment submitted August 24, 2015 (See Stiles’s Comment, ID: FWS-HQ-IA-2013-0091-0415 http://www.regulations.gov/#!documentDetail;D=FWS-HQ-IA-2013-0091-0415).
The more promising avenue is to contact your congresscritters and ask them to co-Sponsor the African Elephant Conservation and Legal Ivory Possession Act of 2015 (H.R. 697 or S.1769 respectively).
You can locate your Representatives and Senators contact information at https://www.usa.gov/elected-officials.