by Randy Gibbs
Nov 22, 2017

Good Morning Mr. Secretary Zinke,  and Deputy Director Sheehan

On behalf of the Professional Hunters Association of Zambia (PHAZ) we fully support you in your decision to allow the import of legally hunted lion and elephant from the Republic of Zambia for the calendar years of 2016,2017 and 2018.

We are fully aware that this decision was derived at, from your good offices, after many years of fact finding and enhancement findings on the role of safari hunting in the crucial conservation of lion and elephant here in Zambia. Therefore good sirs i again extend our full support to your decision in allowing imports that we all know will provide the very funds, as paid by your american hunters, to ensure the survival of the many animals that remain. After a carefully selected trophy animal is legally and ethically hunted within the borders of Zambia and as per the laws of our country and the ethics set out not only by our association but by all professional hunters worldwide, that trophy should be allowed import into the USA.

Our association, although sovereign, is a part of something much bigger than ourselves in the form of the Safari Club International, The Operators and Professional Hunters of Africa (OPHA), Conservation Force (CF) and many more - where we all strive to ensure our members adhere and follow the most professional conduct when on safari, Not only Sirs are our members Professional Hunters but they are Professional Conservationists in the truest sense of form. 

They are out there in the field monitoring the game, providing immediate service to anti poaching and have a deep love of not only the fauna but also the flora and the continued well being of all those creatures and plants.

Therefore your recent announcement of the allowing of trophy imports into the United States of America (USA) was a much heralded victory for us in the conservation of the remaining wildlife in our country, Zambia.

Unfortunately the anti-conservationists used some key words like, trophy and Sport hunting and emotional video footage to place your President in a difficult situation - hence his message to put your scientific and fact based decision on 'hold'. This type of situation is not uncommon here in our third world countries, so really it comes as no shock to us, however like all courses of action that follow this type of situation, it now comes the responsibility of your good office Mr Secretary, ably supported by your FWS department, and our associations support to you - that you kindly explain the science and the facts behind your conclusion to the highest office in your country.

I am very confident Mr Secretary that once you have explained this and provided the data and facts that the FWS have collected over the past years it will undoubtedly and irrevocably prove that funds paid by american hunters directly lead to the conservation and well being of not only the precious wildlife in Zambia but also the community living with in the area and the entire bio diversity of that area as well.

All too often these anti - conservationists have grouped together illegal (poaching) and legal hunting in the same category - you Sirs are no fools to this very bad misconception - we (you and us) are promoting the legal off take and ethical manner in which it is done for the betterment and sustainability of the wildlife, this is basic management and conservation, they are however grouping us with the illegal trade, that we know and are fighting every day, that is decimating our flora and fauna here in Zambia.

Furthermore as evidence to support our support of your office in this matter, the following points and facts gathered can be raised, all extracts from other papers we have presented on this,

Regulated hunting is not illegal - it is provided for in the Wildlife Act of 2015, there are permits and payments that have to be met prior to a safari even commencing, once these are met the safari is deemed legal as per the laws of the republic of Zambia. there is a huge difference between a legal safari and an illegal act against wildlife - we are and have only ever promoted the legal and ethical hunting of licensed game here in Zambia.


  • There has been no “ban” on the import of elephant trophies from Zambia.  In October 2011, the FWS made a positive enhancement finding to authorize the import of regulated elephant hunting trophies from Zambia.  However, 2013 and 2014, Zambia’s wildlife authority suspended hunting to obtain more current wildlife population information.  In 2015, Zambia’s government lifted the hunting suspension, and set a conservative quota of 80 elephant.  In August 2016, the Chief of Permits sent an email indicating that the FWS was trying to issue import permits for elephant trophies from Zambia before the CITES Conference of the Parties in September 2016, based on an April 2015 Non-Detriment and Enhancement Finding the FWS received from Zambia’s wildlife authority.  However, the FWS ran out of time.  At the Conference of the Parties, the Chief of Permits indicated that elephant permits from Zambia would likely issue before the end of the year.  Again, because of the new rosewood permits, that enhancement finding was put on a back burner.


  • Zambia’s elephant population inhabits seven sub-regions covering National Parks and Game Management Areas.  According to the 2016 African Elephant Status Report, Zambia’s elephant population is estimated at over 21,000.  This is generally considered stable over the past 25 years, and is stable compared to Zambia’s population in 1992, when the FWS determined to maintain elephant as “threatened” listed.  However, several population surveys indicating an estimate closer to 30,000 were not included in the 2016 African Elephant Status Report, and Zambia’s wildlife authority estimates the country’s population at more than 30,000.


In 2013 and 2014, Zambia suspended regulated tourist hunting to obtain a better sense of national wildlife population trends.  In 2015, Zambia set a conservative export quota of 160 tusks from 80 bull elephants.  Zambia maintained the quota of 80 elephants in 2016 and 2017.  A national quota of 80 elephants represents less than 0.4% of a population of 21,967 elephant.  Actual hunting off takes are negligible and have no impact on the national population rate.

2015 Hunting Off takes (% of Total Elephant Population): 03 (0.014%)

2016 Hunting Off takes (% of Total Elephant Population): 12 (0.055%)


  • Governing Law: The Zambian Wildlife Act No. 14 of 2015 is the guiding legislation for elephant protection and management.  This cutting-edge law consolidated the prior wildlife authority into a government Department of National Parks and Wildlife (DNPW), to address the funding concerns and shortfalls experienced by the prior authority.  DNPW is made up of a Wildlife Law Enforcement Unit with over 1,250 rangers; a Conservation Unit; an Infrastructure Development Unit; and a Community-Based Natural Resource Management Unit to oversee the development of conservation planning in Game Management Areas.
  • Management and Enforcement Revenues: Between 2010 and 2012, regulated hunting revenues accounted for approximately 32% of the operating budget funding for Zambia’s wildlife authority.  With a potential to generate nearly $1 million in elephant hunting fees, in 2015 and 2016, these fees totaled only $150,000, due mainly to import restrictions.  This amount was divided between DNPW and the Community Resource Boards in Game Management Areas (GMA).  DNPW uses this revenue for range salaries and resource protection, as well as management surveys, staff training, and other activities.  Approximately 75% of DNPW’s expenditures are for anti-poaching, and Zambia’s Wildlife Law Enforcement Unit conducted over 10,500 anti-poaching patrols in 2015, involving an average of 5,878 staff per quarter and 237,028 patrol days.
  • Habitat: Hunting areas in Zambia (~180,000 km²) provide almost three times the amount of protected habitat compared to the country’s National Parks (~64,000 km²). 
  • Community Benefits: In GMAs, elephant license fees are divided equally between the DNPW and the GMA’s Community Resource Board, and 20% of concession fees also accrue to the Board.  In 2015 and 2016, approximately $1.36 million in hunting fees was distributed to the Boards, as well as $10,000 per concession paid by the hunting operator.  Under the new Wildlife Law, Boards must invest those funds as follows: 45% towards wildlife protection and patrols, 35% towards community improvement projects such as construction of schools, clinics, and water infrastructure, and 20% towards administrative costs.  Written concession agreements between the operators, DNPW, and the community Boards usually obligate the concessionaire to make further communities investments, such as constructing a classroom and paying a teacher’s salary.  Operators in 13 blocks were obligated to spend over $1.1 million in community infrastructure development and 3.4 million in community lease and other payments for the duration of their leases.
  • Game Meat Distributions: Moreover, under Zambian law, at least 50% of harvested game meat must be donated and distributed to local communities.  A 2015 study found that operators in three GMAs contributed an average of 6,000 kilograms of harvested meat per season, and estimated that operators across all GMAs could provide ~130 tons of much-needed protein annually.  This reduces the incentive for bush meat poaching in these areas bordering and buffering Zambia’s National Parks. 
  • Operator Anti-Poaching: Hunting operators’ concession agreements with DNPW and the Community Resource Board identify mandatory anti-poaching obligations and expenditures.  At present, 75 Boards employ over 750 wildlife scouts and 79 support personnel, at a monthly cost of over $38,800.  Those scouts are paid for by revenues from tourist hunting.  A small sample of four operators spent over $201,000 on anti-poaching in 2015, to fund community scouts and fund and equip their own operator anti-poaching teams.  This anti-poaching support is largely paid for by U.S. hunters, as over half of all hunting clients in Zambia are from the U.S.
  • Photographic tourism is not a substitute in most hunting areas.  Opponents argue that photographic tourism would be a better option than hunting.  It is true that photo-tourism is available in some places; for example, some conservancies in Namibia benefit from photographic tourism revenues alone or a mixture of photo- and hunting tourism.  But photo-tourism requires decent infrastructure and scenery, and dense enough wildlife populations to draw tourists.  These may not be available in remote areas of a country without access to airports or other activities, and where the wildlife populations are not yet dense enough to ensure a sighting on a two-hour game drive, Zambia does yet have the infrastructure for these to operate in more remote areas, therefore all photographic is currently only present around the little infrastructure we do have.

Once again be rest assured you have our support, together in the fight to conserve Zambian wildlife, we thank you very much Mr. Secretary for your tremendous effort already displayed to help us and we ask for your continuing support, having visited your great country we are well aware of how much land you set aside for parks and hunting and we are no strangers to the remarkable story of not only the whitetail and waterfowl in the US but all your fora and fauna, we too can make such a difference in Zambia for the future generations, if given a chance.

Best Regards

Gavin Robinson


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