October 17, 2003

Public Interest Comment on Enhancement-of-Survival Permits for Foreign Species

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Draft Policy for Enhancement-of-Survival Permits for Foreign Species Listed Under The Endangered Species Act


Stated Purpose:

To "provide guidance under which the [FWS] will consider issuance of enhancement-of-survival permits as incentives to encourage conservation."

Summary of RSP Comment:

The Fish and Wildlife Service (FWS) is proposing to change its policy on "enhancement of survival permits" for foreign species listed under the Endangered Species Act (ESA). The new policy would allow for the import of foreign endangered or threatened (T&E) species that are listed under the ESA in limited situations where such action enhances the survival of the species in the wild.

This policy would be a welcome change in FWS policy. One of the problems with the ESA is that it fails to provide good incentives for conservation. Landowners who manage their land in such a way to attract T&E species to their land are rewarded with increased regulation on what they can do with their land.

This draft policy for enhancement-of-survival permits, however, recognizes that proper incentives are needed to protect T&E species. With this policy, the FWS recognizes that one way to increase the conservation of wildlife is to increase the value of the wildlife. This draft policy allows for the hunting and importation of some T&E species, when the hunting or importation is part of a conservation program that provides net benefits to the species. While some people abhor hunting, it generates a lot of revenue that can be used to protect T&E species and their habitat. If we truly care about the plight of T&E species, we should consider all of the possible ways to protect species.

Another important benefit is that the policy can be used to promote greater scientific knowledge developed by the private sector. Because the policy allows for more imports of T&E species to the United States, there will be more demand for the exotic species in the United States. This generates incentives for people here to invest in discovering better and more effective ways to propagate these species. Knowledge generated through these experiments can be used here and abroad to improve the conservation of species.