John Jackson of Conservation Force has developed a list of talking points related to the elephant import situation. This is a must read for anyone who wants to understand the facts on this issue.



  • There has been no “ban” on elephant trophy imports. In April 2014, the U.S. Fish and Wildlife Service (FWS) “suspended” the import of elephant trophies from Zimbabwe due to an asserted lack of information. Zimbabwe’s Parks and Wildlife Management Authority (ZPWMA) responded to two questionnaires from the FWS in April 2014 and December 2014. However, in March 2015, the FWS extended the suspension, finding information was still lacking. At the same time, the March 2015 enhancement finding repeatedly affirmed, “The suspension … could be lifted if additional information on the status and management of elephants in Zimbabwe becomes available…” In May 2015, the FWS sent another information request to ZPWMA. ZPWMA responded in July 2015. The FWS made two additional information requests, to which ZPWMA responded in May and November 2016. The FWS’ November 2017 positive enhancement finding is based on all these responses and thousands of pages of supporting documents, including Zimbabwe’s National Elephant Management Action Plan, 2014 countrywide elephant population surveys, 2014-2016 actual and projected budget data, 2014 and 2015 offtakes and 2016 quota data, 2014-2016 CAMPFIRE data, and much more.
  • Issuing import permits for elephant trophies from Zimbabwe was not a political decision by this Administration. In September 2016, before the election occurred, the FWS had already indicated to ZPWMA that the suspension would be lifted. ZPWMA was told by the Chief of Permits that the FWS needed “only one more piece of information,” a prioritization of the new Elephant Management Plan, before the 2015 negative enhancement finding could be revised. That prioritization was emailed on November 8, 2016, before the election results were in. At the end of 2016, the FWS should have made a positive enhancement finding, but was side-tracked by an influx of thousands of new permit applications due to the listing of rosewood (used extensively in musical instruments and furniture) on the CITES Appendixes, which was decided in October 2016.
  • Similarly, there has been no “ban” on the import of elephant trophies from Zambia. In October 2011, the FWS made a positive enhancement finding to authorize the import of elephant hunting trophies from Zambia. However, in 2013 and 2014, Zambia’s wildlife authority suspended hunting to obtain more information on the country’s wildlife populations. In 2015, the government lifted the hunting suspension and set a conservative quota of 80 elephant. In August 2016, the Chief of Permits sent an email indicating that the FWS had received an April 2015 Non-Detriment and Enhancement Finding from Zambia’s wildlife authority, and the FWS was trying to issue import permits for elephant trophies from Zambia before the CITES Conference of the Parties in September 2016. However, the FWS ran out of time. At the Conference of the Parties, the Chief of Permits indicated that elephant permits from Zambia would likely issue before the end of the year. Again, because of the new requirements for rosewood, that enhancement finding was put on a back burner.



  • In 1900, it was estimated that Zimbabwe had a national population of 4,000 elephant. Since then, the population has grown to over 82,000 (a twenty-fold increase). The current population is double the target national population established in the 1980s, almost 40% larger than in 1992, when the FWS determined to maintain the Endangered Species Act (ESA) “threatened” listing for African elephant, and almost 20% larger than in 1997, when the FWS made a positive enhancement finding for import of elephant trophies from Zimbabwe. Elephant sub-populations in Zimbabwe are generally considered stable or increasing.
  • North-West Matabeleland: This population is estimated at 54,000, and is most dense in Hwange National Park (~45,000 elephant). In 1928, the estimated elephant population in Hwange was 2,000.
  • Sebungwe: This population is estimated at 3,500 and has declined since 2001 due to human population expansion into a previously unsettled area. The human population rapidly expanded from 45,000 in 1950 to over 700,000 in 2013, which explains the decline in the elephant population. Unlike other major elephant ranges in Zimbabwe, the habitat in this area is fragmented.
  • Mid-Zambezi Valley: This population is estimated at approximately 12,000 elephant. That number declined since the 2001 countrywide survey. The decline is due to cross-border poaching and perhaps cross-border movement of elephant during the survey period. Anti-poaching is a major component of the Zambezi Valley/Mana Pools Regional Elephant Management Action Plan, and recently the area has been chosen as a CITES MIKES site with an ongoing project.
  • South-East Lowveld: Most of this population inhabits Gonarezhou National Park, whose population has been growing consistently at 5% per annum over 20 years. This population is estimated at 13,000 elephant between the Park, surrounding communal areas, and nearby private conservancies.



  • Zambia’s elephant population inhabits seven sub-regions covering National Parks and Game Management Areas. According to the 2016 African Elephant Status Report, Zambia’s elephant population is estimated at over 21,000. This is considered stable over the past 25 years, and is stable compared to Zambia’s population in 1992, when the FWS maintained elephant as a “threatened” listed species. However, several population surveys indicating an estimate closer to 30,000 were not included in the 2016 African Elephant Status Report, and Zambia’s wildlife authority estimates the country’s population at over 30,000.



  • Zimbabwe maintains a CITES export quota of 1,000 tusks from 500 bull elephants. A national quota of 500 elephants represents only 0.6% of a population of 82,630 elephant. Hunting offtakes are considerably lower, have a negligible impact on the overall population rate, and have declined in the past three years due to the import suspension.

Average Hunting Offtakes 2010-2013 (% of Total Elephant Population): 228 (0.276%)

2013 Hunting Offtakes (% of Total Elephant Population): 258 (0.312%)

2014 Hunting Offtakes (% of Total Elephant Population): 162 (0.196%)

2015 Hunting Offtakes (% of Total Elephant Population): 075 (0.091%)



  • In 2013 and 2014, Zambia suspended regulated tourist hunting to obtain a better sense of national wildlife population trends. After obtaining this information and reorganizing the wildlife authority, Zambia lifted the suspension in 2015. It set a conservative export quota of 160 tusks from 80 bull elephants. Zambia maintained the quota of 80 elephants in 2016 and 2017. A national quota of 80 elephants represents less than 0.4% of a population of 21,967 elephant. The offtake quota is even lower, and was set at only 30 elephant (0.14% of the population) in 2016. Hunting offtakes are negligible and have no impact on the national population rate.

2015 Hunting Offtakes (% of Total Elephant Population): 03 (0.014%)

2016 Hunting Offtakes (% of Total Elephant Population): 12 (0.055%)



  • Governing Law: The Zimbabwe Parks and Wild Life Act is the governing law for ZPWMA and its programs. The Act created ZPWMA as a parastatal authority apart from the central government and established a separate fund to sustain ZPWMA’s operations. The Act sets heavy penalties for elephant-related offenses. It was amended in 2010 to increase these sentences even more, and now imposes a nine-year minimum sentence for a first offense of elephant poaching. Under the Act, Rural District Councils and other land holders are granted “appropriate authority” to benefit directly from wildlife. Land holders are encouraged to maintain and increase wildlife populations because they retain the benefits of the sustainable use of that wildlife.
  • Elephant Management Plan: Zimbabwe’s elephant management plan was kicked off by the FWS’ elephant trophy import suspension. To develop a new plan, ZPWMA held a year of participatory stakeholder planning workshops, including a preparatory meeting of representatives from CAMPFIRE in November 2014; a national elephant management planning workshop in December 2014; an elephant management planning and anti-poaching workshop in Mana Pools (Zambezi Valley range) in March-April 2015; an elephant management planning workshop in the Sebungwe range in May 2015; and an elephant management planning workshop in the South East Lowveld range in September 2015. This process resulted in the Zimbabwe National Elephant Management Plan (2015-2020), the most up-to-date elephant management plan in Africa. The plan incorporates specific action items, deliverables, deadlines, and responsible parties. The plan identifies strategic objectives and sets targets to reach those objectives. It measures the success of reaching those targets through identifying outputs and Key Performance Indicators. The plan focuses on five major components: Protection and Law Enforcement; Biological Monitoring and Management; Social, Economic, and Cultural Framework; Building Conservation Capacity; and Program Management. The plan also creates the position of dedicated Elephant Coordinator at ZPWMA and establishes a national committee to coordinate and oversee implementation. The national plan is supplemented by four regional management plans that utilize the same framework to address the unique challenges for each major elephant range.


ELEPHANT HUNTING IN ZIMBABWE GENERATES CONSERVATION BENEFITS THAT SATISFY THE ENHANCEMENT” STANDARD: Although hunting offtakes are negligible, elephant hunting fees are substantial and create extensive conservation incentives in Zimbabwe.

  • Habitat: Hunting areas in Zimbabwe cover ~130,000 km² of protected habitat. This area is over four times the size of Zimbabwe’s National Parks (~28,000 km2). Healthy elephant populations require large tracts of habitat; the areas set aside for regulated hunting are therefore essential to the elephant’s continued survival.
  • Management and Enforcement Revenues: Revenues generated from tourist hunting conducted on state lands comprised approximately 20% of ZPWMA’s revenue stream in 2014. Over $6.2 million in trophy fees came from elephant hunts, with $5 million accruing to ZPWMA to reinvest in elephant protection and species management. Over 50% of that revenue came from U.S. clients. Almost 80% of these revenues are allocated for law enforcement in the form of staff costs and patrol provisions. ZPWMA employs 1,500 active field rangers. Put simply, hunting revenues support anti-poaching efforts across Zimbabwe’s elephant range—and this is largely paid for by American elephant hunters.
  • Operator Anti-Poaching: In addition to supporting ZPWMA’s enforcement capacity, hunting operators deploy their own anti-poaching units to police the Safari Areas and fund community scouts in CAMPFIRE Areas. For example, a small sample of 14 operators surveyed by the Safari Operators Association of Zimbabwe spent $957,843 on anti-poaching in 2013 and deployed 245 anti-poaching scouts. One operator, Charlton McCallum Safaris (CMS) in the Dande Safari Area and Mbire Communal Area, spends on average $80,000-$90,000 in anti-poaching costs and rewards. From 2010 to 2016, CMS’ efforts led to an 82% decline in elephant poaching in an important border region. As another example, the Save Valley and Bubye Valley Conservancies together spend over $1 million on anti-poaching each year. These efforts are funded by hunting revenues, and protect stable populations of elephant, increasing lion populations, and the third-largest black rhino population in the world.
  • Regional Anti-Poaching: According to the CITES “Monitoring the Illegal Killing of Elephants” (MIKE) data, poaching in the Southern African countries that depend upon regulated tourist hunting as a conservation tool, including Zimbabwe and Zambia, is lower than anywhere else on the continent and has never reached an unsustainable level. This stands in stark contrast to the West and Central African countries that do not allow tourist hunting.
  • Community Benefits: Zimbabwe’s CAMPFIRE program is the pioneering community-based natural resource management program in Africa. The program allows rural communities to financially benefit from wildlife, thereby incentivizing the use of communal land as wildlife habitat and the protection of wildlife through increased tolerance. An estimated 800,000 households benefit from CAMPFIRE revenues, ~200,000 direct participants and ~600,000 indirect beneficiaries. 90% of CAMPFIRE revenue is generated from regulated hunting, and 70% of this comes from elephant hunting. Thus, prior to the import suspension, elephant hunting generated over $1.6 million per year for CAMPFIRE communities and was reinvested in the construction of classrooms and clinics, installation of water infrastructure and solar powered facilities, purchase of vehicles for anti-poaching support, compensation for destruction of crops or livestock by dangerous game, and other benefits which improve the livelihoods of the rural communities living in CAMPFIRE Areas. These benefits offset the damage caused by game species: from 2010 to 2015, elephant destroyed 7,495 hectares of crop fields in CAMPFIRE communities and claimed the lives of approximately 40 people.



  • Governing Law: The Zambian Wildlife Act No. 14 of 2015 is the primary legislation governing elephant management and protection. This new law consolidated the prior wildlife authority into a government Department of National Parks and Wildlife (DNPW), to address funding concerns and shortfalls experienced by the prior authority. DNPW is made up of a Wildlife Law Enforcement Unit with over 1,250 rangers; a Conservation Unit; an Infrastructure Development Unit; and a Community-Based Natural Resource Management Unit to oversee the development of conservation planning in Game Management Areas.
  • Management and Enforcement Revenues: Between 2010 and 2012, regulated hunting revenues accounted for approximately 32% of the operating budget funding for Zambia’s wildlife authority. With the potential to generate nearly $1 million in elephant hunting fees, in 2015 and 2016, these fees totaled only $150,000, due largely to import restrictions. This amount was divided between DNPW and the Community Resource Boards in Game Management Areas (GMAs). DNPW uses this revenue for ranger salaries and resource protection, as well as management surveys, staff training, and other activities. Approximately 75% of DNPW’s expenditures are for anti-poaching. The Wildlife Law Enforcement Unit conducted over 10,500 anti-poaching patrols in 2015, involving an average of 5,878 staff per quarter and 237,028 patrol days.
  • Habitat: Hunting areas in Zambia (~180,000 km²) provide almost three times the amount of protected habitat as the country’s National Parks (~64,000 km²).
  • Community Benefits: In GMAs, elephant license fees are divided equally between the DNPW and the Community Resource Board. 20% of concession fees also accrue to the Board. In 2015 and 2016, approximately $1.36 million in hunting fees was distributed to the Boards, as well as $10,000 per concession paid by the hunting operator. Under the new Wildlife Law, Boards must dedicate 45% of those funds towards wildlife protection and patrols, 35% to community improvement projects such as construction of schools, clinics, and water infrastructure, and 20% to administrative costs. Written concession agreements among the operators, DNPW, and the Community Resource Boards typically obligate the operator to invest in additional community projects, such as building a classroom and paying the teacher’s salary. According to DNPW’s data, operators in 13 blocks were obligated to invest over $1.1 million in community infrastructure development and $3.4 million in community lease/other payments for the duration of their concession agreements.
  • Game Meat Distributions: Under Zambian law, at least 50% of harvested game meat must be distributed to local communities. A 2015 study found that operators in three GMAs contributed an average of 6,000 kilograms of harvested meat per season. The study estimated that operators across all GMAs could provide ~130 tons of much-needed protein annually. This reduces the incentive for bushmeat poaching in the GMAs, which border and buffer Zambia’s National Parks.
  • Operator Anti-Poaching: Hunting operators’ concession agreements with DNPW and the Community Resource Board identify mandatory anti-poaching obligations and expenditures. These include the payment of scout salaries. At present, 75 Boards employ over 750 wildlife scouts and 79 support personnel, at a monthly cost of $38,800. Operators may maintain their own anti-poaching teams as well. A small sample of four operators spent over $201,000 on anti-poaching in 2015. This anti-poaching support is largely paid for by U.S. hunters, as over half of all hunting clients in Zambia are from the U.S.


Note: Supporting documents for each point are available by contacting Conservation Force, These Talking Points largely rely on the responses of ZPWMA and DNPW to FWS information requests as well as individual hunting operator enhancement reports, reports of the CAMPFIRE Association, and publicly available IUCN documents.




  • There has never been a “ban” on elephant trophy imports from Zimbabwe. The FWS made a negative enhancement finding in April 2014 and “suspended” the import of elephant hunting trophies. However, that finding, and the FWS’ 2015 enhancement finding, each repeatedly stated that the negative conclusion would be reviewed and reversed upon receipt of additional information. (E.g., “The suspension … could be lifted if additional information on the status and management of elephants in Zimbabwe becomes available, including utilization of revenue generated through sport-hunting by U.S. hunters…”) A “ban” suggests a permanent prohibition; a “suspension” is a “temporary abrogation or withholding.” Zimbabwe’s elephant trophy imports were suspended.
  • Lifting the suspension was not a political decision. The decision should have been made in July 2015, when ZPWMA provided extensive additional documentation in response to an FWS questionnaire. The FWS requested “one more piece of information” at the CITES Conference of the Parties in September 2016. That information was emailed to the Chief of Permits in November 2016. No further information was needed, or requested. If the FWS had properly prioritized issuance of elephant import permits—as they told ZPWMA they would at the CITES CoP—the positive enhancement finding would have been made and these permits would have issued before the current Administration took office.
  • The import of elephant trophies from Zimbabwe should not have been suspended in the first place. In April 2014, the FWS announced the suspension based on an asserted “lack of information.” The FWS suspended imports under a negative enhancement finding that it later admitted was incorrect with respect to Zimbabwe’s elephant population estimate, the level of poaching, and more. When the correct estimate is considered, Zimbabwe’s elephant population of almost 83,000 is 16,000 higher (almost 20%) than when the FWS made a positive enhancement finding in 1997. That estimate is double the size of the elephant populations of Namibia and South Africa put together, yet the FWS maintains positive enhancement findings for the import of elephant trophies from Namibia and South Africa. The trophy import suspension was based on a mistaken concern that Zimbabwe’s elephant population had declined. The FWS should have admitted the mistake and reversed the suspension immediately. The failure to do so suggests a political motivation, not a scientific one. In addition, suspending imports without first notifying and consulting Zimbabwe contradicts CITES Res. Conf. 6.7 and the Endangered Species Act, which requires the FWS to “encourage foreign conservation programs.”
  • Zimbabwe’s elephant population is not “the worst managed,” but among the best managed, in Africa. That Zimbabwe maintains a stable population of over 83,000 elephant, despite a despotic government, poor economy, and rapidly growing human population, is a testament to the country’s strong species management. That number is almost 40% higher than in 1992, when the FWS confirmed the “threatened” listing of elephant, and almost 20% higher than in 1997, when the FWS made a positive enhancement finding authorizing the import of elephant trophies from Zimbabwe. This strong management is due in part to ZPWMA being a parastatal separate and separately funded from the central government. It is also due to the commitment of Zimbabwe’s citizens to maintain their elephant populations, notwithstanding the costs—over 40 rural Zimbabweans were killed by elephant from 2010 to 2015. Zimbabwe’s strong species management is also evident in recent IUCN Red List assessments of lion and giraffe, which indicate increasing populations of these species in Zimbabwe. Overall, Zimbabwe is maintaining stable or increasing wildlife populations, which is evidence of strong management.
  • Zimbabwe’s elephant management plan is not “poor” or outdated; it is state-of-the-art and written by one of the world’s foremost elephant experts. The April 2014 suspension of elephant trophy imports was based in part on the fact Zimbabwe’s then-current elephant management plan dated to 1997. Although that plan was adaptively implemented and monitored, it was 17 years old. ZPWMA immediately began the process of developing a brand-new, state-of-the-art elephant management plan. This included a year of stakeholder planning workshops: a preparatory meeting of representatives from Zimbabwe’s community-based natural resources management program, CAMPFIRE, in November 2014; a national elephant management planning workshop in December 2014; an elephant management planning and anti-poaching workshop in Mana Pools (Zambezi Valley) in early April 2015; an elephant management planning workshop in the Sebungwe range in May 2015; and an elephant management planning workshop in the South East Lowveld region in September 2015. Zimbabwe focused on regional planning because the four regions face different management challenges. Each planning workshop produced a regional elephant management plan that was incorporated into the final document, which was drafted by a leading elephant scientist. The process was monitored throughout by the IUCN’s African Elephant Specialist Group. The positive 2017 enhancement finding is largely based on the development and implementation of this excellent new plan.
  • Regulated hunting is not poaching. By definition, “regulated” hunting is regulated and lawful—it is carefully monitored by ZPWMA, offtakes are recorded in a national database, and trophy tusks are marked in accordance with CITES resolutions to note the year of harvest. Moreover, regulated hunting revenues underwrite most anti-poaching expenses in Zimbabwe (and the rest of Southern Africa)—most of the fees paid to government wildlife authorities are used for enforcement, and operator-funded teams patrol concessions and keep poachers out. Finally, revenue-sharing and contributions by hunting operators create conservation incentives for the rural communities most affected by wildlife, which dis-incentivizes poaching. For example, Zimbabwe’s CAMPFIRE communities were receiving over $1.6 million per year in revenues from elephant hunting prior to the import suspension. These funds built clinics and schools, paid teachers’ salaries, drilled boreholes, and so on. Similarly, hunting operators in Zambia are required to share at least 50% of harvested meat with rural communities. Many tons of meat can come from elephant hunts, to reduce the need and tolerance for bushmeat poaching and protect species in addition to elephant.
  • Allowing imports of elephant trophies will not damage the government’s efforts to control ivory trafficking. There is no support for this assertion, because hunting trophies are marked to show that they were lawfully hunted. Moreover, in the Southern African countries that depend upon regulated hunting as a conservation tool, poaching levels are lower than anywhere else in Africa. According to CITES MIKE data, Southern African countries (including Namibia, South Africa, Zambia, and Zimbabwe) have the lowest Proportion of Illegally Killed Elephant (PIKE) rates. PIKE, which is used to assess whether poaching levels are unsustainable, has never risen above the sustainability threshold in Southern Africa. PIKE at Zimbabwe’s MIKE sites is well below the sustainability threshold. According to the evidence, regulated hunting keeps poaching levels low.

Photographic tourism is not a substitute in most hunting areas. Opponents argue that photographic tourism would be a better option than hunting tourism. It is true that photo-tourism is available in some places; for example, some conservancies in Namibia benefit from photographic tourism revenues alone or along with hunting tourism. However, photo-tourism requires infrastructure and scenery, and dense wildlife populations to draw tourists. These features are not available in remote areas of a country without access to airports or other activities, where the wildlife populations are not dense enough to ensure a sighting during a two-hour game drive. And this is the situation in many CAMPFIRE Areas, where photographic tourism was tried and failed. In these areas, without the benefits of hunting, the habitat would be converted to agriculture and livestock. Benefits to the rural community stakeholders are less from photographic tourism than from tourism hunting.

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