This is the sample letter provided by David Warther, feel free to use it.
<Insert your name
and address here>
VIA EMAIL:
cade_london@fws.gov
Cade London
Special Assistant, USFWS International Affairs
Advisory Council on Wildlife Trafficking
4401 North Fairfax Drive, Room 110
Arlington, VA 22203
RE: My Comments on the National Strategy for Combating Wildlife
Trafficking & Commercial Ban on Trade in Elephant Ivory and its
implementation by the U.S. Fish and Wildlife Service
Dear Mr. London,
I support the goal of stopping the barbaric and criminal poaching of
elephants in Africa, Asia, or anywhere else in the world. Because of the
important artistic, practical, historical and economic value of ivory, I am
also in favor of preserving the trade of domestic ivory in the United
States. Both goals can be accomplished, and I want to provide the Advisory
Council with information and ideas to make this happen.
<Briefly describe who you are and what your interest is in ivory.>
Current Laws Already Isolate the US Market from Poached Ivory
In the USFWS September 2012 Fact Sheet, U.S. Efforts to Control Illegal
Elephant Ivory Trade and Internal Markets, the Service summarized US laws
already in effect and efforts to stop poaching of Asian and African
elephants. The report described the Service's seizures of illegally
imported ivory between 1989 (the year the ban on African elephant
international trade went into effect) through 2007 and concluded that "we do
not believe that there is a significant illegal ivory trade into this
country." The report further noted that "[t]he U.S. Public and other
international travelers often unwittingly purchase and import ivory products
in to the United States only to have them confiscated at the ports. We hope
to reduce global ivory traffic by informing international travelers of the
domestic and international laws controlling the movement of ivory through
outreach efforts such as this fact sheet."
The Service's conclusions were entirely consistent with independent studies
conducted by international organizations tasked with wild life conservation
and monitoring & fighting illegal ivory trade. Most recently, in the
December 2013 report "Status of African elephant populations and levels of
illegal killing and the illegal trade in ivory: A report to the African
Elephant Summit" by the International Union for Conservation of Nature,
African Elephant Specialist Group, they found that while elephant poaching
in Africa is on the increase, the trend is closely associated with increases
in consumer spending in China, the world's largest consumer of illegal
ivory. On the other hand, the relationship does not hold for ivory markets
in Europe, the USA or Japan, nor for countries know to be transit points in
the ivory trade chain (Malaysia, Philippines, Thailand or Viet Nam). When
further discussing trade routes for poached elephant ivory and showing maps
of those routes with estimates of illegal ivory transferred, the report does
not show any illegal trade involving the United States after 2008.
The United States is not contributing to elephant poaching in any meaningful
way because current laws in the U.S. are working. When the 1989 ban on
exporting and importing African ivory went into place, it allowed the
domestic trade of ivory that was already in the United States ("pre-ban
ivory") to continue. The export limitations discouraged big businesses from
using ivory in products, but small businesses have continued to make,
repair, embellish and trade pre ban ivory along with antique ivory. People
who dealt regularly with ivory were very aware of the regulatory structures,
as reflected the small number of seizures and tiny amounts of illegal ivory
confiscated in the United States in recent years from dealers or businesses.
Also, pricing confirms the stability of ivory trade in the United States.
Domestically, the cost of raw ivory has been around $250 per pound, whereas
in China, where illegal ivory flourishes, ivory can cost as much as $1500
per pound. Given the price discrepancy, it is obvious where illegal
poachers will peddle their ivory.
If not from poachers, where does raw ivory come from in the United States?
There are a variety of sources including a few dealers who carry documented
pre-ban ivory, museums with excess ivory in stock, estate sales of people
who collected ivory, and a small amount from people who legally hunt
elephants on safari with government permission from stable populations and
who fund conservation efforts in African countries. With the ample supply
of ivory already in the U.S., there simply has been no need to risk
smuggling illegal ivory. For this reason, the US has successfully isolated
its domestic market from illegal poaching.
Enormous Costs of Domestic Ivory Ban Outweigh Non-Existent Benefit
Notwithstanding the success the U.S. has had in keeping poached ivory out of
its domestic market, the regulations that USFWS are considering would kill
it.
There are well over 3000 small businesses in the United States that use,
embellish, repair, restore, or provide services involving ivory. Guitar and
banjo repair shops, piano restorers and movers, silversmiths, religious
product dealers, antique dealers, tool & knife makers, gunsmiths, engravers,
jewelers, art galleries, museums - all of these entities will be penalized
by denying them materials for their trade or products that they rely upon
and have nothing to do with elephant poaching in Africa. Galleries and
museums will not be able to charge admission to exhibits containing ivory.
Artisans and craftspeople who have dedicated their lives to ivory carving
will become obsolete or criminals, losing their livelihoods. And that is
just on the business side.
On the consumer side, millions of people who own items that contain ivory
will be severely limited with what they can do with it. Musicians will not
be able to repair or refurbish their instruments. Art collectors, from high
end Nitsuke collectors to people trading collectibles on eBay, will see the
value of their collections plummet to $0. People who lose family members
will have difficulty resolving estates. Cultural and religious items from
statues to rosary beads will become contraband. All of these items made
from ivory taken from elephants that died decades if not generations ago
will drop out of the legal stream of commerce without preventing a single
elephant from dying in Africa.
Worse than that, if regulations are adopted that require paperwork to prove
the age or pedigree of ivory when the government knows full well such
paperwork never existed because it was or is unnecessary to create under
then-existing or current law, people will disrespect the law. If antique
dealers and collectors need to prove items were imported through ports even
though the items came to this country before there were requirements to use
certain ports to import ivory, their cynicism with the government will be
well justified. If regulations are jammed through without giving the
law-abiding people they will punish adequate time to respond or due
consideration of their views, then the people's frustration and anger will
predictably erupt.
Recommendations
Instead of antagonizing law abiding citizens engaged in trade in the United
States, the government should focus its efforts where they belong - on
border enforcement and affecting demand in China. To the extent tourists
carry undocumented ivory across borders, the USFWS should follow its own
counsel from its 2012 Fact Sheet. To the extent the government believes
poaching to be an international crisis as stated in Executive Order 13648,
then the now well-known NSA data monitoring and spying efforts should be
shared with foreign governments to intercept trade routes, capture poachers,
and condemn Asian traders who unscrupulously deal in poached ivory. Those
are far more direct and effective ways of affecting illicit Chinese trade
and saving elephants' lives.
Domestic Ivory Ban Will Increase the Slaughter of Elephants
One final thought. Dr. Daniel Stiles, a world renowned expert on African
elephants and a prominent member of conservation organization, has recently
concluded that the initiatives under consideration in the United States will
dramatically increase elephant poaching instead of decreasing it. Crushing
the domestic market in the United States will make the legal supply of ivory
disappear. As ivory becomes rarer, prices will increase, giving poachers an
even greater incentive to kill elephants for their valuable tusks. It would
be catastrophic to destroy the lives of innocent artisans, ruin the finances
of legitimate businesses, deprive people of lifelong collections, and in the
process reward poachers for slaughtering elephants.
Very truly yours,
<YOUR SIGNATURE>