by John J. Jackson III, Chairman, Conservation Force
The FWS has finally posted the new application forms for import permits. This means the prior forms can no longer be used. The FWS has done away with the special form for elephant trophy imports. Elephant have been merged in the general form for all species requiring proof of enhancement (or non-detriment). As we explained in an earlier Bulletin, the questions on the new forms differ somewhat from the prior versions.
Hunters will typically use four forms. First, form number 3-200-19 is only for leopard trophies (from all countries) and white rhino trophies from Namibia. The FWS uses a special form for these two species that are processed by different staff, because no enhancement findings are required for their import.
Almost all other trophies, including elephant, lion and CITES Appendix I-listed species, will go on form 3-200-20. The title of this form is “IMPORT OF SPORT-HUNTED TROPHIES (Appendix I of CITES and/or ESA).” The same form may be used for more than one species if hunted on the same trip as long as they are being imported together.
Although there are different forms, the basic structure and questions are the same. The first page of each looks like the prior versions. It requests the hunter’s name, phone, email and address. However, the FWS no longer requests social security numbers. The FWS also no longer asks if the applicant has received a prior import permit and its number, which will save applicants from digging out old files.
On the subsequent pages, the order of questions on the new forms has changed from the prior versions. The forms no longer begin by asking about the trophy. Instead, they ask for additional mailing instructions, who to contact with questions, and if the hunter has been convicted of certain wildlife-related offenses. In questions 4 through 6, the permit finally requests the species’ name, location and dates of the hunt, and current location of the trophy if already hunted. Thankfully, the forms no longer ask which parts will be imported.
The forms request three new pieces of information about the hunt: (1) the name of the hunting operator or PH; (2) a copy “of any applicable foreign government permits or licenses that were required to remove this animal from the wild (if you have not hunted yet and do not currently hold any such permits or licenses, please indicate so)”; and (3) enhancement information.
Given the FWS’ new procedure of evaluating enhancement permit-by-permit, the following new questions may have greater importance for application approval:
- Do you have any information regarding the population status or trend data on the species hunted?
- In order to hunt, you likely paid for licenses or trophy fees. What were those fees, and do you have any information on how those funds were used by either the landowner, community, or government?
- Do you have information on other funding activities that are being carried out, or were carried out, by the safari outfitter, professional hunter, concession holder, or land owner that provide a conservation benefit to the species being hunted/species hunted?
Consider talking to the operator or PH about their knowledge of the species’ population trend in their area, and their contributions to habitat security, anti-poaching and community investment (as applicable) prior to the hunt. Applicants should include whatever information they have. Conservation Force will also help obtain this information from wildlife management authorities, landowners/operators/PHs and community conservation programs.
The final question on the forms is the same certification statement as appeared in the prior versions. As in the past, be sure to sign the application form twice: once on the first page and a second time at the very end.
The new forms are accessed at www.fws.gov/forms/display.cfm?number1=200. We recommend using only these new forms going forward, as the prior versions have technically expired.
|3-200-19||Leopard, White Rhino from Namibia|
|3-200-20||ESA and CITES Appendix I (Elephant, lion, markhor, wood bison, etc.)|