On November 28, 2017 The World Bank posted an article titled: Act now to save wildlife: 5 actions that make a difference. The 5 actions suggested by The World Bank are:

  1. Engage with the conservation community.
  2. Visit a national park to support the wildlife economy, promote sustainable tourism and be touched and captivated by nature.
  3. Reduce demand for illegal wildlife parts and products by not purchasing products made from these items—as our partner WildAid says: “When the buying stops, the killing can too.”
  4. Commit to learning more about the risks to wildlife and their habitats and reducing your carbon footprint to keep forests, wildlife and oceans healthy and intact.
  5. Use the power of your network to inspire others to act by spreading the word about the issues facing different species and communicating the gravity and urgency of the situation.

While Nature Needs More supports these recommendations, none are new. If it was the 1970s then maybe these would be enough, but it is not. So, we would like to suggest some alternatives actions for 2018. These 5 range from ‘fixing the basics’ of the current system (Actions 1, 2, 3 and 4) to a total transformation (Action 5).

5 (Alternative) Actions That Can Make a Difference To Wildlife in 2018

In the run up the 4th Illegal Wildlife Trade Conference, being held in London on the 10 and 11 October 2018, Nature Needs More would like to propose some actions that could be considered in designing the agenda from the perspective of ‘Fixing The Basics’ of the current system.

Action 1: Review & Upgrade the CITES Trade Database/Trade Permit System     

Certainly, we at Nature Needs More have lost count of the number of people who are concerned about the CITES Trade Database/Trade Permit System and the number of times we have heard representatives from global conservation bodies say “Yes, we know it is not great, but it is all we have”. This statement would be OK if the system had just some minor flaws, but that doesn’t appear to be the case.

Nature Needs More was very happy to support the work of Donalea Patman OAM of For the Love Of Wildlife and Fiona Gordon of Gordon Consulting, New Zealand as they lead the charge to close the domestic trade for rhino horn and elephant ivory in Australia and New Zealand respectively. In facilitating a conservation lab in August 2017, to help with the design of the #NoDomesticTrade campaign strategy, the information collected included details of the amount of ‘legal’ elephant ivory exported from the UK to Australia. From a global trade perspective, this was interesting information because it was about collecting information about the wildlife trade between two countries that would be considered relatively non-corrupt, being the UK and Australia. The key findings included:

A) In many instances the CITES permits contain next to no information about the item, no photographs, no provenance and not even quantity/weight or volume; the statement of 1 unit can mean anything. Given that the statement of ‘1 carved item’ in the main contains no supporting evidence, there was no way of knowing the size of the object. It could mean the carved item could be:

 This or  This

B) Import and export permit records between countries didn’t match and so is was impossible to calibrate, for example: Between 2010 and 2016:
i) The number of Elephantidae specimens exported from the UK to Australia amounted to 2298 ‘units’
ii) In the same timeframe the number of Elephantidae specimens recorded as imported in to Australia from the UK equalled 1 ‘unit’
iii) A mismatch of 2297 units. How are you supposed to calibrate and monitor trade here?

C) We were told also that:
i) Imports from CITES non-signatory countries don’t require a permit at all – “Given there is no export permit required, therefore there is no import permit or check” (stated by Customs Official).
ii) “Given the limited resources we have, if a wildlife item is leaving the country, it is considered not our problem” (stated by Customs Official).

When these finding were discussed with the local CITES representative, the response was: “You don’t really need an import permit, it is up to the exporting country to do the due diligence on the country to where the item is being sent.” How does this make the findings better? It doesn’t prove that there is a way of checking if the exports from the UK to Australia arrived here as the designated destination country. How does this statement about the exporting country doing the due diligence square with the customs statement: “If it is leaving the country, it is considered not our problem.”

In summary: The system appears antiquated, not transparent, not consistent and not fit for purpose. Better systems are readily available, for example what can CITES learn from the international system for monitoring the trade in explosives and ammunitions, which we would hope would be more watertight.

Action 2: Review & Update, where required, the CITES Signatory System

There have been a number of articles in recent years highlighting that CITES is a ‘toothless regulator’, because it relies entirely on the willingness and ability of national governments to implement and enforce its regulations.

In reality, there are countries that are:
i) Not signatories
ii) Signatories, but have weak domestic wildlife laws for prosecution purposes, and,
iii) Signatories that have, on paper at least, strong laws and significant sentencing and fines for breaking wildlife trafficking laws, but don’t enforce them.

In relation to point (iii), again it is good to look at Australia. In theory, Australian legislation can result in prosecutions of up to 10 years in prison or 1,000 penalty units, which translates to AU$180,000 fines. On paper quite substantial.


There is clear evidence that rhino horn and ivory are coming in to Australia illegally:

  1. There were 25 seizures of ‘suspected’ rhino horn between 2010 and 2016
  2. There were 411 seizures of ‘suspected’ ivory between 2010 and 2016

We must note the reason that the word ‘suspected’ is highlighted is that none of the seized items underwent testing (DNA or Carbon Dating). While the laws are great on paper, of the 436-items seized, there was no testing, and therefore no prosecutions, fines or jail time resulted from any of these seizures. Now we know that you might be thinking, well 436 items between 2010 and 2016 is not much. We were told: “Optimistically 4% of seaport cargo is checked” (Ex-Customs Official). If this is the case, actual seizures could underestimate the scale of import by factor 25 or more. There has been mixed information about what has been seized in 2017, but if we take the minimum number quoted for ivory items seized in Australia so far in 2017 it is 300. As for the testing, we were told by one institution that had developed such test procedures “We can test what is seized, but no government wants to pay”.

We acknowledge that creating an international regulator is difficult, so the first step should be to create a ‘Signatory Scorecard’ where an independent global auditor examines the national implementations and enforcement of CITES regulations on a regular basis and publishes a scorecard for each signatory country.

A brief aside:

In relation to the enforcement costs (such as DNA testing or carbon dating), who should pay? From an elephant ivory and rhino horn perspective the industries that benefit from keeping trade open are the auction rooms and antiques industry (and possibly also the Asian medicine industry in the case of rhino horn) and their customers.

Auction houses Sotheby’s & Christies acknowledge they use the CITES permit system and that they support better enforcement efforts, stiffer legislation and increased penalties. What they don’t acknowledge is that they make NO contribution to the costs of creating the systems or for monitoring/policing this trade in elephant ivory or rhino horn, when it is, in the main, for their benefit.

At the time of creating this blog, there is work underway to ‘fully cost’ a system for effectively monitoring the trade of elephant ivory and rhino horn in Australia should a full domestic ban not be implemented. People who we have spoken to, as a part of this campaign, believe that the auction houses and antiques industry members (and their customers), who want to keep this trade, should cover the true costs of monitoring, policing and prosecutions. This could be via an annual fee to cover the costs, that is paid by any auction room and antique business who want to continue to sell elephant ivory and rhino horn. It is up to these businesses to decide if they would pass the additional costs on to their clients.

Action 3: Make Each Individual Conservation Organisation Explicitly Declare What They Mean by ‘We Support Sustainable Use’

‘Sustainable Use’ has become a catch-all phrase to justify the trade in wildlife and is usually linked to the fact that in the vast majority of cases local communities around protected wildlife zones don’t receive or derive benefits from their presence (other than the usually very small number of jobs created inside the protected zone).

Many large/specialist conservation organisations use the catch all phrase “In principle, we support sustainable use”, without ever explaining what this explicitly means for them in relation to either the species or protected zone they are working with. This practice is deceiving, as what can be classed as sustainable use under the current ‘free for all’ definition are practices such as:

  1. Eco-tourism
  2. Trophy-Hunting
  3. Canned Hunting
  4. Cub petting, walking with lions safaris
  5. Farming (e.g. rhino for their horns)
  6. Local consumption (meat hunting, egg harvesting etc.)
  7. Selling animals to state owned and private zoos
  8. And many more

Some of these so-called sustainable uses are abhorrent to most people who support conservation, such as the breeding of captive lions for cub petting and (later) canned hunting. Yet the conservation organisations do not have to declare their specific stance on any of these ‘uses’. As a result, donors and supporters make assumptions about an organisation that may not match reality and thus act against their own interest.

Maybe the most recently publicised example of this is in relation to WildCRU, which came to fame and received significant donations after the hunting of Cecil the lion. As the linked article states, WildCRU has sat on the fence in relation to their public stance on lion hunting. The article also asks the question: Did Oxford University researchers sanction hunting of Cecil the lion and his son, Xanda? At least implicitly?

At the heart of this lack of transparency, in relation to the different forms of sustainable use, are usually conflicts of interest based on research, projects and funding arrangements. Some governments and international funding bodies may explicitly state that the receiving organisations must support sustainable use and for many it is an unspoken rule.

We believe that to help private donors make decisions on donations conservation organisations need to be made to declare both those conflicts of interest and publicly state their stance on the different forms of ‘sustainable use’, such as:

  1. Yes, we support/oppose/can’t comment on XX (trophy hunting, rhino horn trade etc) and we must highlight that we need to obtain our licence to operate to do our research in the country from a government that supports XX (e.g. trophy hunting, rhino horn trade etc)
  2. Yes, we support/oppose/can’t comment on XX (trophy hunting, rhino horn trade etc) and we must highlight that we receive funding and run projects on behalf of the government that supports XX (e.g. trophy hunting, rhino horn trade etc)
  3. Yes, we support/oppose/can’t comment on the specific sustainable uses for this species, but we must also highlight that we receive over X% of our funding from funding bodies that promote the sustainable use model.
  4. Yes, we support/oppose/can’t comment on a legalisation of trade in XX (e.g. rhino horn trade), but we must clarify that it is not within our organisational mandate to do research on the viability or risks of a legalised, legal trade in XX (e.g. rhino horn trade).

Action 4: Invest in a Professional Development Program for the Global Conservation Sector

The last 5 years of researching the conservation sector, particularly the areas dealing with trade, has been eye opening. I first mentioned my observations of the sector in a March 2015 blog: Conservation vs. Wildlife Traffickers. Who do you think will win the war in wildlife crime? From the blog: Based on my observations I would estimate that less than 5% of people who are working, thinking, donating and caring about wildlife are thinking strategically about problem solving some imminent and critical issues.

The conservation sector might be stereotypically described as looking like ‘analytical, process (rather than results) driven, arrogant, nit-picky academics’ while the wildlife traffickers could be described as looking more like ‘market savvy, intuitive, ruthless, nimble entrepreneurs’. The traffickers have realised how comparably safe it is to get rich from dealing in wildlife. As a result, they are now moving beyond simply exploiting the existing demand for animal products such as rhino horn and ivory and are creating new ‘products’ and new demand.

So, I go back to the question, does the conservation sector have the skills to respond? If not, how quickly can it catch up? In the time since that March 2015 blog, I haven’t seen much evolution in the sector, which is why I wrote the April 2017 blog: Want To Know Why Conservation Is Failing? Read On….

If significant numbers of people in the sector continue to have limited strategic ability, preferring to stick to a tactical/academic approach, they will continue to miss the point, the agendas, the politics and the power plays and will remain marginalised and ineffective in saving the natural world from the effects of unconstrained growth. Yes, they will be seen as experts in their field, they will do and publish research, but they won’t be doing what they set out to do when they first heard the ‘calling’ to save wildlife and protect the natural world.

Currently the sector doesn’t have the strategic mindset and skills to effect positive change for the natural world. Unless there is a significant commitment to developing employees, the conservation sector will stay be stuck in an old paradigm and not able to effect change based on the current need and context in the natural world. This primarily means learning how to think strategically, learning how to deal with a fast-evolving context and learning about human behaviour from social sciences.

Conservation is about individual and collective human behaviour within a context of neoliberal capitalism. The current crop of conservationists come from an era when the belief that conservation is primarily about biology and ecology had some validity. Since the mid-nineties legal and illegal trade has exploded and habitat destruction has become the primary conservation issue. Hence the skills and mindset of the conservation sector has to change to think primarily about human behaviour and our economic and non-economic relationship with nature; and the agendas associated with this.

Action 5: It is time to ask the question, should a conservation body and not trade body be the primary facilitator governing the natural world?  

It is amazing how many people believe CITES primary terms of reference are about ‘conservation’ when they are about ‘trade’; when you clarify this, a large percentage of people who are concerned about the demise of wildlife and the natural work are genuinely shocked. And potentially, rightly so: Are they shocked because indeed this fact is shocking?

This can be looked at from 2 levels. In the first instance, many people who care about what is happening the world’s flora and fauna can’t relate at all to a system where a ‘trade body’ is the primary facilitator of these critical issues. What ‘rubs salt in to open wounds’ on this is the fact that:

i) CITES was set up in 1973, so the system has had 45 years to make a difference.
ii) Over nearly the exact same time frame (from 1970), WWF published the Living Planet Index (LPI) as an indicator of the state of global biological diversity, based on trends in vertebrate populations of species from around the world.
iii) It then began publishing The Living Planet Report summarising the findings of the LPI and the 2016 report highlighted that animal populations plummeted by 58% between 1970 and 2012, with losses on track to reach 67% by 2020.

So, CITES and the Living Plant Index have pretty much run side-by-side, with only 3 years difference in the launch dates. After 45 years the world is on track to lose two-thirds of wild animals by 2020, it is hardly a ringing endorsement of the current strategy! We have to ask the questions: If a conservation body, rather then a trade body had been the primary regulator over this time frame, would they have acted sooner to curb these losses? 

Principle 15 of the 1992 Rio Declaration sets out a Precautionary Approach “where there are threats of serious or irreversible damage, lack of scientific certainty shall not be used as a reason for postponing cost-effective measure to prevent environments degradation” There has been little evidence that the current facilitators are considering enacting the ‘Precautionary Approach’. If a conservation body, not a trade body had been the primary regulator, would they have pushed for the Principle 15 to be enacted sooner? It would be interesting to consider this question.

The second perspective on CITES is that there are a growing number of players who want to reduce regulation and trade restrictions. They would like it to be easier to trade in wildlife and they are similarly looking at and highlighting the flaws in the CITES trade and signatory system. They have the opposite objective, but also say the system hasn’t worked, so let’s make it easier to trade. In a situation like this pretending that ‘all is fine and it is business as usual’ is a recipe for disaster, as we have seen recently with the Brexit referendum and the election of Trump in the US. When people lose trust in the system the custodians of the system need to acknowledge its flaws, remind people of the history and plot ways forward that fix what is broken, whilst doing battle with those who just want a ‘bonfire of regulations’ and a ‘free for all’ trade.

There is currently precious little evidence that the custodians of CITES can see the writing on the wall. They remain ignorant to how easy it is to dismantle a system once power shifts, no matter how established and entrenched such a system may be. CITES needs to evolve to address higher pressure on populations and vastly expanded trade volumes. It needs to evolve to withstand pressures from ‘pro-trade at any cost’ advocates and those who want to further commoditise nature to make money.

In conclusion

The so-called “actions to save wildlife” proposed by the world bank are delusional, as they imply that individuals taking action in relation to their own and their friends’ behaviour is all that is needed to make a difference. In reality, collective action and fixing broken systems is primarily needed and only collective action can make a difference given the forces of unrestrained trade and growth we are up against. In the run up to the 4th Illegal Wildlife Trade Conference, to be held in London on the 10 and 11 October 2018, Nature Needs More would like to propose that some or all of these 5 actions should be considered for the agenda. In particular, the first two actions outlined above would make an immediate difference to both the legal and illegal wildlife trade. We sincerely hope that conservation organisations and conservation minded individuals and groups will join forces to address a system that appears to be no longer fit for purpose. The 5 actions proposed would go a long way towards turning the tide.

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