Lion Landscapes’ Contribution to the Call for Evidence, Animals Abroad Bill

By Amy Dickman and Alayne Cotterill, joint CEOs, Lion Landscapes

Short summary of contribution

Here, we provide a contribution to the Call for Evidence for the Animals Abroad Bill, based on our scientific knowledge and first-hand conservation expertise. This is written by the joint CEOs of Lion Landscapes, a UK charity working on community conservation across multiple lion landscapes in Kenya, Tanzania, and Zambia. We have over 40 years of field conservation experience between us, as well as relevant advanced degrees, including PhDs. Our contribution focus primarily on lions, but the points made relate to many other species as well. As this exceeds 3000 words, our contribution covers the following points, providing evidence for each point raised (often using hyperlinks to the relevant studies):

• We highlight that for effective conservation, the key threats to biodiversity must be identified and addressed. According to the IUCN Red List, current trophy hunting is not a major threat for any species, so the attention on this threat is misleading and draws attention away from other pressing conservation concerns

• Using IUCN Red List data for monitored lion populations, and published data from various African countries, we highlight that the presence of trophy hunting does NOT mean that wildlife populations are declining, and that banning or restricting trophy hunting does not mean they will increase

• We use scientific data to show that while poorly managed trophy hunting can negatively impact some populations, well managed trophy hunting can have a positive impact, even on endangered species. We also link to evidence that regulations can be effective at reducing the pressure on hunted species

• We present studies showing the benefits that are delivered through trophy hunting at present, including habitat conservation, the maintenance of species range, protection against the specific, major threat of land conversion, and provision of livelihood benefits. We present a summary of community benefits from trophy hunting from a recent report, and highlight the importance of listening to affected local communities and not undermining their rights and livelihoods

• We discuss the challenges of finding adequate, scalable, viable alternatives to replace trophy hunting, and some of the problems associated with increasing photo-tourist numbers

• We present suggestions for different rules for animals hunted in different settings, with a focus on trying to incentivise habitat conservation and discourage ‘canned’ hunting

• We outline significant unintended consequences likely from import bans, especially in terms of the risk of indiscriminate killing, with major negative impacts on animal welfare and conservation. We also highlight a recent poll showing that the UK public would not be supportive of trophy hunting bans (including import bans) which led to those consequences

• We state that we do not believe that the current measures on controlling trade in trophies are effective for supporting conservation, and make suggestions for how they could be improved. However, we stress that the current controls would be better than damaging import bans if those are imposed without due consideration for unintended consequences.

1. Will the Government’s proposals on the export and import of hunting trophies effectively support the conservation of endangered species?

No, for many reasons as outlined below.

1a. For effective support of conservation, the key threats to biodiversity must be identified and addressed

Despite all the media attention, IUCN Red List data shows that current trophy hunting is NOT a major threat to any species at a range-wide scale. To effectively support conservation, it would be far more impactful to take action that addresses major threats to wildlife. Data on conservation status and key threats (from the IUCN Red List) are compiled below, for the African species most commonly discussed in this debate. It is clear that trophy hunting is not a major threat to any of them – and by conserving habitat and prey, and contributing towards anti-poaching activities, it can actually help reduce those major threats. Therefore, extreme caution should be taken before imposing restrictions which could harm the economic viability of this land use, particularly without any viable, scalable and funded alternatives ready.

Figure 1. Population trends and major threats to some of the most-discussed African species in the trophy hunting debate.

This current focus on trophy hunting is misleading to the public, and risks detracting attention (and possibly funding) from far more pressing issues such as habitat loss and conflict. It is actually those issues – and working out how conservation can be used to drive local development – that should be the focus of the UK Government and other interested stakeholders. People may suggest that tackling ANY threat is a good step, but that is only positive if in doing so we don’t inadvertently increase larger threats such as conflict, bushmeat snaring and habitat loss, which is the very risk outlined by many conservation scientists and the IUCN with regard to trophy hunting bans, including import bans.

1b. The presence of trophy hunting does NOT mean that wildlife populations are declining – and banning or restricting trophy hunting does not mean they will increase

Using data on monitored lion population trends between 1993 and 2014 in the 2016 IUCN Red List. 38 of these lion populations were in non-hunting areas, and of those, 22 (58%) were declining (Figure 2). Only 7 populations examined were in trophy hunting areas, and of those, only 1 (14%) was declining. This is not to say that trophy hunting does not negatively impact some lion populations – especially where poorly managed and in concert with other threats, as outlined in the section below – but it demonstrates that having trophy hunting in an area is not in itself an indication of threat, just as the absence of trophy hunting does not mean populations are safe.

Figure 2. Data on lion population changes from 1993 – 2014 from 2016 IUCN Red Data List for the African lion.

This trend is not unique to lions: Kenya is a famous example of a country which banned trophy hunting (in 1977) and far from seeing well-conserved wildlife, a study has shown that its wildlife numbers have plummeted since then.

Figure 3. Trends in wildlife and livestock numbers documented in Kenya between 1977-1980 and 2011-2013, showing the precipitous decline in wildlife & concomitant increase in livestock.

While there are multiple causes for these declines, the lack of local incentives to maintain wildlife is a key aspect. This is highlighted in the study when it compares wildlife trends in Kenya to those in several other sub-Saharan African countries which used sustainable use, including trophy hunting, as part of their wildlife management. In those countries, there was evidence of increased wildlife numbers and concurrent declines in livestock numbers.

Figure 4. Indicators of wildlife population increase and concurrent declines in livestock numbers in Namibia, Zimbabwe, South Africa and Zambia but substantial increase in livestock numbers and concurrent declines in wildlife numbers in Kenya (references can be found here.

1c. While poorly-regulated trophy hunting can have a damaging local impact on populations, well-regulated trophy hunting can have a positive impact, even for species like lions. The costs and benefits should be assessed at a site level, not at a species or country level

Poorly regulated trophy hunting can undoubtedly have damaging impacts on populations, especially in concert with other threats. However, trophy hunting is not necessarily damaging to a population if it is well regulated, and can have positive impacts. One key example is Bubye Valley Conservancy (Figure 5), where lions were reintroduced around 20 years ago, and now number around 500 individuals (see case study 4 in the IUCN Briefing Document), with well-regulated trophy hunting used as a key management tool. This demonstrates that trophy hunting can be a useful conservation tool.

Figure 5. Lion population in Bubye Valley Conservancy, which uses well-regulated trophy hunting to fund its wildlife conservation activities.

At a wider scale, the IUCN Red List data shows that wild lion populations are only increasing in two countries, Namibia and Zimbabwe, both of which use trophy hunting (including of lions) as part of their sustainable wildlife management. Because trophy hunting can be positive or negative depending on how it is managed, as suggest that decisions on imports are made on a case-by-case basis rather than imposed at the species or country level.

The same holds true for several other species, including both black and white rhino, as outlined in the IUCN Briefing Paper for Decision-Makers.

Figure 6. Data on rhino population trends, from the IUCN Briefing Paper for Decision-Makers.

Furthermore, in many places (including around Hwange, one of the examples of poor management of lion trophy hunting above), there have been recent changes in policy since those papers were published. Short-term moratoria, reduction of quotas and the adoption or adaptive age-based quotas have all reduced the risk posed by trophy hunting. There is scientific evidence of the effectiveness of such measures in reducing pressure on hunted species, so it is these kinds of approaches which should be tried first, before import bans.

1d. Trophy hunting areas have clear and well-evidenced conservation and livelihood benefits, so care should be taken not to imperil those benefits through bans (including import bans)

It is often questioned whether there is any evidence for conservation benefits from trophy hunting. Here, we provide evidence for clear conservation benefits in terms of protecting habitats and also maintaining species within those areas. While good management of trophy hunting is clearly necessary for effective conservation of the hunted species, it is important to note that some of these key benefits – e.g. habitat protection – still often occur even in those places where the hunting regulations may not be optimal.

(i) Habitat protection

Given that land use change has been identified by IPBES as the main driver of biodiversity decline, we believe that this is the major benefit of trophy hunting, certainly for lions. 11 lion range countries currently allow legal trophy hunting of this species, though this is a dynamic situation. Trophy hunting areas have the same key conservation benefit as National Parks – large-scale habitat protection, and hunting areas cover large extents of remaining range (Figure 7). Our current draft analysis of remaining lion range indicates that the area where lion trophy hunting of lions is legal is ~712,000km2, equal to around 42% of wild African lion range. This exceeds the area of remaining range covered by National Parks (~450,000km2).

Figure 7. Map showing (in blue) from 2019, showing the extent of remaining lion range covered by areas where trophy hunting was legal, compared to the extent covered by National Parks (in green). Note that this was before Botswana lifted its ban on trophy hunting.

Trophy hunting is a particularly significant land use in those countries with the largest remaining extent of lion range (Figure 8), such as Tanzania, Botswana and Mozambique.

Figure 8. Significance of trophy hunting as a land use in remaining lion range countries, though now Botswana has made trophy hunting legal again.

The habitat protection extends far beyond lions, and across Africa, areas conserved under trophy hunting exceed the areas conserved under National Parks. Therefore, decisions which affect that land use should not be taken lightly. Furthermore, the conservation benefit of that habitat protection appears clear: in a recent study assessing how well countries were doing to protect large mammals, the majority of the top 10 countries (including the top 3) use trophy hunting as part of their wildlife management.

The particular significance of trophy hunting as a land use in key wildlife range countries underlines the importance of not imperiling this land through knee-jerk policy reactions. Unfortunately, much of this hunting area is unlikely to be suitable for economically viable photo-tourism, and proven alternatives do not yet exist at the scale required. Researching those alternatives in concert with local stakeholders, and funding them, should be a top priority if the Government wants to play a positive role in moving towards effective wildlife conservation without trophy hunting.

(ii) Maintenance of species range

People often assume that hunting areas are mismanaged and devoid of wildlife, but our recent data analysis for Tanzania (paper in prep), shows that these areas are very important for biodiversity. Considering 18 large mammal species for which sufficient range data are available, the data showed that a mean of 44.4% of the species’ country range was found within hunting PAs, compared to 18.5% in non-hunting PAs and 37.2% in completely non-protected areas (Figure 9). Hunting PAs were the most important area category for 61% of the species considered. We have not yet been able to examine wildlife densities in these areas, but it is clear that hunting areas play a key role in large species conservation in Tanzania (and many other countries) so decisions that affect these areas should be taken very seriously.

Figure 9. Data from Tyrrell et al. (in prep) showing the significance of trophy hunting areas for large mammals in Tanzania.

(iii) Protection against land conversion

Land conversion is the major threat driving biodiversity decline at a global scale. When examining habitat loss across three land uses (National Parks, trophy hunting areas and other areas), Tyrrell et al. (see case study) showed that within Tanzania, habitat loss was lowest in strongly protected non-hunting areas (National Parks), followed by strongly protected hunting areas (Game Reserves). Importantly, as many hunting areas are becoming vacant – partly in response to increasing international pressure – they also found that habitat conversion was higher in vacant blocks than in actively hunted blocks, demonstrating a likely positive impact of anti-poaching activities in managed hunting blocks. This also highlights the major risk of likely unintended consequences in areas where hunting ceases without viable alternatives implemented at the same time.

The map below from Tanzania (Figure 10) clearly demonstrates the value of hunting areas in helping protect against the key threat of habitat conversion (in this case agricultural land conversion). Given that land conversion is so much more significant than trophy hunting in terms of threats to lions, and is such a major threat to biodiversity overall, losing the protective effects of trophy hunting areas is a major risk.

Figure 10. Map from Tanzania from 2019, showing National Parks in dark green and areas where trophy hunting was permitted in light green. The red shows land conversion, demonstrating the clear protective benefit of hunting areas against land conversion. Some of the Selous Game Reserve has now been gazetted as Nyerere National Park.

(iv) Provision of livelihood benefits

Just as with photo-tourism, trophy hunting can provide important local jobs, income and other benefits. There is an erroneous figure commonly used by anti-hunting groups, suggesting that local people only receive 3% of trophy hunting income. Although (again just as with photo-tourism), in many places the amount of benefit reaching local people should be higher, the current income is nonetheless locally significant in many areas. A recent comprehensive assessment from the African Leadership University School of Wildlife Conservation documents the important community benefits which emerge from trophy hunting in many African countries. When trophy hunting was banned in Botswana, there were multiple, varied and well-documented negative impacts on local communities. Elsewhere, scientific analyses have shown that both photo-tourism and trophy hunting revenue combined are currently crucial to many community conservancies in Namibia, with trophy hunting also generating important benefits in the form of meat. Representatives of millions of rural Africans have vociferously spoken out against Western-led campaigns to ban trophy hunting and deprive them of their livelihood options, and the right to sustainably and legally utilise their wildlife. Such campaigns have been accused by community leaders in southern Africa of representing a ‘colonial mindset’, and that should be a major concern for the UK Government in considering any course of action.

Figure 11. Table showing community benefits from trophy hunting in multiple African countries

To summarise, while both National Parks and hunting areas often have issues (e.g. lack of funding, mismanagement, declining wildlife populations), but in both cases the key conservation benefit is the incentive to maintain habitat for wildlife, protect species and prevent land conversion. This is done by generating a wildlife-based income stream, which can also provide substantial benefits for local people, and is often part of their key right to sustainably use their natural resources.

These are very valuable benefits and should not be discounted in the case of trophy hunting areas just because people dislike the activity. It is vital that policy-makers recognise these benefits and work to ensure that they are replaced if action is taken to reduce the economic viability of trophy hunting.

1e. Reducing the economic viability of trophy hunting areas without providing a better alternative is likely to be very damaging for wildlife and people, and yet there are no proven alternatives ready at the scale needed

Peer-reviewed research has demonstrated that lions do best in well-funded photographic areas, and do least well in protected areas which have neither photographic tourism nor trophy hunting. Therefore, the optimal scenario from a lion conservation point of view would be to convert the area to well-funded photographic tourism. However, unfortunately the vast majority of Africa’s existing protected areas, including photographic areas, are severely underfunded. Given that range state Governments are already under severe financial pressure, reducing the income from hunters and asking Governments increase funding for conservation areas appears both unjust and unlikely to happen.

Therefore, it is imperative – as stressed by the IUCN – that fully funded, viable and sustainable alternatives be ready before measures are taken to limit trophy hunting. Many people assume that trophy hunting revenue could simply be replaced by photographic tourism, but in most current trophy hunting areas, photographic tourism is unlikely to be financially viable due to issues such as insecurity, disease risks, naturally low-density wildlife populations and unattractive habitat. The evidence from the hunting moratorium in Botswana demonstrated that it is very hard to adequately replace trophy hunting revenue with photographic tourism revenue, with the ban leading to increases in human-wildlife conflict, poaching and damaging local livelihoods.

Even where viable, photographic tourism often relies on many more tourists than trophy hunters, as the per-capita hunter revenue is often higher. This is exemplified by Timbavati Game Reserve (Figure 12), which reported that 21 hunters generated 30% of their revenue in 2018, while 24,000 tourists generated 51%. Given the huge resource use of tens of thousands of tourists in terms of greenhouse gas emissions, water etc, then a lot of care should be taken to replace low numbers of hunters with many more tourists. This should be of particular concern given the UK’s stated concerns over climate change, and their key role in COP 26.

Figure 12. Breakdown of revenue and numbers of people for each revenue stream in Timbavati

Some potential alternative funding mechanisms exist, including carbon and biodiversity payments, but none of them are proven at the scale needed or have realistic funding streams secured. The key is to ensure that whatever alternatives are in place, they ensure that revenue is directly linked to conserving viable populations of wildlife and its habitat, and that the benefits to the local communities are at least equal to what they are receiving under trophy hunting. Alternative mechanisms should also ideally not rely on vastly increased numbers of users, as that will have unintended consequences in terms of carbon emissions, water use, infrastructure needs etc. Identifying and investing in suitable alternatives long-term at meaningful scales and in cooperation with local stakeholders should be a priority if the UK Government is keen to replace trophy hunting with alternative mechanisms for wildlife conservation.

2. Should there be different rules for the trade in animal trophies depending on the setting in which the animal was hunted?

Yes, as the aim should be to discourage practices like canned hunting (which have little or no conservation benefit), and to allow trophy hunting as a form of wildlife management where it delivers conservation and livelihood gains. Regarding specific conservation-relevant rules for UK imports for lions (our focal species), this was a point that was outlined in a recent report to the UK Government, which recommended:

Those specific rules (e.g. the degree of habitat required to be meaningful) would vary by species, but we believe that stricter rules should be imposed ensuring that benefits to conservation and livelihoods are shown, and reducing the likelihood of canned or captive-bred hunting trophies being imported (although the term canned hunting needs better definition).

3. What are the possible unintended consequences of the proposals, for example in relation to animal trophies that pre-date the legislation?

As outlined above, and explained in the scientific literature, there are very substantial possible unintended consequences of proposals which ban trophy hunting (or imports) without finding and funding viable alternatives to secure wildlife habitat and replace revenue to local communities.

Another unintended consequence is that despite its focus on ‘following the science’ during the COVID-19 pandemic, the UK Government is not taking decisions based on the best available evidence, and listening to recommendations from respected authorities, which in this case would be the IUCN. In their 2016 Briefing Paper for Policy-Makers, IUCN makes the following recommendations to policy-makers, regarding decisions that could restrict or end trophy hunting programmes (including import bans):

To our knowledge none of these steps have been taken with the current proposals, so it is imperative that they are taken before import bans are imposed.

These proposals also risk betraying the public’s faith in the Government to take the right steps to protect and conserve wildlife. We understand (and in fact share) that particularly for iconic species like lions, there is widespread revulsion amongst the UK public towards trophy hunting. However, we also assume that most of the UK public hate other forms of lion killing, e.g. poisoning and snaring, at least as much, particularly as many of those indiscriminate killings involve pregnant females, lionesses with dependent cubs, and the cubs themselves (Figure 13).

Figure 13. Lion cubs killed in conflict: such images and events are likely to be just as appalling to the general public as trophy hunting deaths, and should be considered in any action taken.

While people often stress the ethical and moral dimensions of this debate (which are important considerations), we strongly believe that it is not ethical or moral to stop one kind of killing, only to increase another kind of killing which is often worse both in terms of animal welfare and conservation. In fact, a very recent (September 2021) Survation poll of the UK public revealed that less than half (42%) of the respondents would support bans on trophy hunting which increase overall threats to wildlife (Figure 14). Even fewer (only 39%) would be supportive of a ban which negatively impacted marginalised communities. The poll also showed that only 64% of people polled would want a trophy hunting ban even if it decreased overall threats to wildlife: far less than the ‘86% support’ which has been widely reported, based on an anti-hunting lobby group’s poll.

Figure 14. Data from a recent Survation poll on the views of the UK public towards trophy hunting bans (described as including import bans) which have different likely outcomes.

Unfortunately, negative impacts for both conservation and communities are extremely likely to be the case at the moment (with no better alternatives secured for trophy hunting areas), so would not be respecting the will of the British people. They have often been told by campaign groups that bans or import bans on hunting trophies would positively impact conservation, with no apparent evidence to back up that statement. If the UK Government has reliable evidence suggesting that the conservation, animal welfare and local livelihood impacts could actually be negative (e.g. through this call for evidence) then it should not act in a way which goes against that will to protect and conserve wildlife.

Currently, most of the wildlife deaths that occur when wildlife loses economic value happen deep in the bush and are never seen on social media, so the public is largely unaware of them. However, reports suggest that these kinds of lion killings, particularly from conflict and snaring, probably outweigh those from trophy hunting by around five to ten-fold and in some cases it can be much more.

As one example, one of our study sites is in southern Tanzania, in one of the most important areas left for wild lions (one of only five populations left with >1000 lions). There, we work on village land where there has traditionally been no economic value of lions through photo tourism or trophy hunting. The level of lion killing (and killing of other wildlife) was staggering – in 2011, we had reports of over 25 lions and other large carnivores killed, mainly due to conflict with people. This equated to over 50 lions killed per 1000km2 - 100 times higher than the normal recommended limit of 0.5 lions per 1000km2 if this had been a trophy hunting area (Figure 15). Furthermore, half these killings involved females (often pregnant or lactating), which is known to be particularly damaging in terms of conservation impacts on a population: far more so than removing older males.

Figure 15. Some of the many killings on village land, where lions and other wildlife had no economic value. It is imperative not to reduce trophy hunting deaths only to increase these deaths. Note the heavily pregnant female (top left) and lactating female (bottom left): many of these indiscriminate killings involve reproductively active females, which is known to be particularly damaging in terms of population impacts.

All too often, the debate appears binary, as if it is between trophy hunting deaths and safe lions. Unfortunately, if viable alternatives are not in place, then the likelihood is that when trophy hunting ceases, other threats such as snaring for bushmeat, conflict-related killings and habitat conversion increase, actually increasing the number of wildlife deaths. In addition, these tend to be particularly horrible deaths from both a welfare and conservation standpoint, as they affect many species and often involve killing reproductively active females and younger males.

Therefore, both from the perspectives of what the UK public want, the conservation risks and the animal welfare concerns, it is imperative to consider the very real likelihood that decreasing economic viability of trophy hunting without better options ready will lead to huge increases in other forms of killing. Given the rightful concern amongst the UK public for animal welfare – one which the Rt Hon George Eustice MP highlights in the Action Plan for Animal Welfare – then these likely impacts should be very carefully considered.

4. How effective are current measures on the trade in trophies of hunting, including how they support conservation?

We don’t believe the current measures are effective enough in supporting the conservation of wild species, both the hunted ones and wider biodiversity. One of the major issues here is that one of the major conservation benefits of trophy hunting is the protection of habitats, and currently, as far as we are aware, that does not seem to be recognised under the JNCC criteria for trophy imports. The lack of inclusion of that criteria means that trophies can be imported from captive-bred or ‘canned’ operations, with very little real conservation impact in terms of habitat protection. Canned hunting (albeit a poorly defined term) is also one of those areas where the UK public (in my opinion rightly) feel most revulsion at the practice.

Therefore, as described in the section above, the criteria should be revised to ensure that conservation benefit is mainly centred around how much habitat is protected, rather than the population increasing (which can easily be produced in a captive situation, and which may not be happening in a hunting area due to external threats which are nothing to do with trophy hunting). Furthermore, the criteria have to be reasonable and based on the best available science, rather than unreasonable expectations, e.g. making it a requirement to have rising lion populations in an area - this is not even being delivered in most National Parks so the expectations should be equivalent. The major risk of criteria that are unreasonable is that they would likely lead to a reduction in imports, reduced economic viability and a likelihood of land conversion and biodiversity loss, in the common situation where there is no better wildlife-based land use available. Ideally, we would like to see revised import criteria where decisions were based primarily on metrics such as habitat protection and meaningful community engagement, at the same level that are expected from other protected areas.

However, given the major threats for both conservation and livelihoods, keeping the current regulations would be better than imposing poorly-considered trophy hunting bans or import bans.

5. What will be the impact of the proposed domestic ban on advertising and offering for sale overseas attractions, activities or experiences that involve the unacceptable treatment of animals?

This is beyond the scope of our expertise and we would defer to animal welfare organisations and other experts for input here.

6. Who should be responsible for ensuring attractions, activities or experiences overseas do not cause the unacceptable treatment of animals?

This is beyond the scope of our expertise and we would defer to animal welfare organisations and other experts for input here.

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