MAINTAIN THE NAMIBIAN IVORY BAN & ELEVATE ELEPHANTS TO Appendix 1

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ATTENTION: HON. MIN. POHAMBA SHIFETA | HON. MIN. SAKEUS EDWARD SHANGHALA

Dear Ministers and Secretary General:

The Legalization of Ivory Trade proposals have been denied at previous CITES conferences, because of the immediate impact the original 1989 placement of elephants as Appendix I had on halting illegal poaching and disrupting the illicit ivory market. Because elephant populations have declined nearly 30% in the past seven years, according to the Great Elephant Census, (GEC), ivory legalization attempts should continue to be denied to prevent the loss of these endemic and iconic African animals for future generations. This body has already determined that as a keystone animal, the loss of elephants on the African continent would irreversibly damage the African environment


Research confirms that ivory legalization  has an almost immediate impact and results in significantly increased poaching. The 2008 sale of ivory led to a dramatic 66% increase in illegally traded ivory. Elephants are considered to be “threatened with extinction” and are therefore have been listed in Appendix I of the Convention since (18/01/1990); except for populations of Botswana, Namibia and Zimbabwe who are listed on Appendix II since (18/09/1997); and South Africa since (Appendix II, 19/07/2000). The listing of these animals on Appendix II has weakened the ban on ivory trade because it has created a tiered system of protection, in contradiction of the convention’s own rules and goals.

Namibia, a country in favour of Appendix II status for elephants and which supports the Legalization of Ivory, refused to take part in the Great Elephant Census (GEC).Although it was afforded the opportunity to have its National Elephants counted for free and subject to the highest international standards by the GEC, it elected not to participate.

Even though Namibia did not participate in the GEC, it claims to have a stable growth of elephants and continues to propose the legalization of the ivory trade to CITES for consideration. This is despite a lack of any objective proof, evidence, or demonstrable and scientifically approved methodology for counting elephant  populations in Namibia. If CITES wishes to seriously consider Namibia’s proposal to reopen the ivory trade, then we respectfully request this body request proof from Namibia of their elephant population numbers.

Additionally, despite the local mitigation efforts and global outcry to protect elephants in Namibia, the Namibian Ministry of Environment and Tourism (“MET”) continues to issue hunting permits for specifically adapted desert elephants (which significantly jeopardizes their continued survival).  Although “Desert Adapted Elephants” are not regarded as a subspecies of Loxodonta Africana, there are various factors that render them unique, such as morphological, behavioural and geographical differences from Savannah elephants, as well as unique habits such as storing water in their throats, longer gestation periods, and longer suckling.8 The true numbers of these Elephants are very low, as confirmed by people living with them, and a proper survey would be advisable as the first step to provide the protection required by such a limited, unique population.9 Because these elephants are not only endemic to Namibia, but substantially contribute to tourist revenues and job creation for local Namibians, they should be temporarily placed by CITES and the MET into a special category of protection with no hunting allowed pending the result of a forensic audit on these elephant populations.

For all of the foregoing, CITES should continue to enforce a ban on the legalization of ivory. Additionally, because elephant populations will continue declining due to climate change, human encroachment and human/ elephant conflict, now more than ever it is critical CITES designate all elephants on Appendix I. To that end we respectfully request that:

1. The Namibian Government be required to perform a comprehensive census count and survey of Namibian Elephants to determine the exact Elephant Population numbers before their request for ivory legalization is considered;

2. this census be done with the oversight of CITES and its partner organizations to ensure a credible and accurate count using internationally approved counting methodology;

3. the Namibian Government and MET revoke and withdraw its proposal for Trade in Ivory and that the Ivory ban remain in place to protect Elephants in Namibia until a census can be completed;

4. the Namibian Government and MET join other African countries and elevate elephants to Appendix I protection;

5. that the Namibian government and MET immediately burn and destroy any existing stockpiles of elephant ivory in solidarity with other African countries who have done the same and to prevent an uptick in illicit black market trade in ivory;

6. CITES elevate elephants to Appendix I and make elephants exempt from Trophy Hunting;

7. Elephants who remain on Appendix II be exempt from Trophy Hunting and trade in their body parts;

8. CITES continue to vote in favor of proposals to elevate elephants to Appendix I protection;

9. CITES reject proposals by certain SADC countries to re-open trade in ivory and other elephant body parts; and,

10. Countries who are trading ivory domestically such as Japan, Canada and the EU end and abolish their domestic ivory trade.

We appreciate your time and attention to the serious matter of protecting African elephants in Namibia for future generations. It is our hope this letter will help further protect elephants and stop the poaching of elephants and end the ivory trade once and for all.

Sincerely,

Protect Elephants In Namibia (PEIN)
Namibian Elephant Coalition  (NEC)


 The mission of both Protect Elephants in Namibia and the Namibian Elephant Coalition is to give voice to the very serious issue of elephant extinction and advocate for all means to save these endemic animals for future generations and we demand that world leaders take action to Protect Elephants and STOP the poaching of elephants and END the trade in ivory.