ENHANCEMENT PERMITTING DIVISION
For conservation purposes Conservation Force has always been the leader in providing select, pioneering, import permitting services. The purpose has been to enhance the survival and propagation of listed species and to increase their range. Witness our reopening of elephant, African lion, argali, markhor, Canadian wood bison, black rhino, et al. This has been essential for some of the most successful species conservation programs ever devised which in fact secure and grow important populations of the respective species.
Beginning January 1, 2022, Conservation Force has begun supplying permitting services on a broader, fee-paying basis. This is necessary to serve the greater community with the increasing complexity of the permitting process and to cover the almost prohibitive costs in range nations and the USA of establishing and maintaining imports when facing growing regulatory impediments. Conservation Force is accustomed to establishing imports from cradle to grave, that is, from action planning and implementation in foreign countries to administrative appeal of permit denials and undertaking curative work in foreign countries when import permit applications are denied. Because of our long history of conservation projects with hunting operators, we are also equipped to collect the necessary data from operators as well as to smartly direct support to their enhancement efforts. Our costs are three to five thousand Dollars a day or more. The permitting fees are aimed at increasing the management actions that are necessary to reduce the threats to the hunted species and enhance their survival through conservation hunting.
We only do mission related conservation services for programs that are designed to enhance/benefit the survival and propagation of listed game species as well as secure essential habitat. The whole endeavor is about being a force for conservation. The more at risk a species, the greater the role of conservation hunting that enhances its survival. This is done through action programs that identify the species needs and targets the reduction of specific threats.
We are not an import or export broker, taxidermist, freight forwarder, carrier, or other commercial service provider. Neither are we a hunting broker.
Why Does it Take so Long to Get an Import Permit?
Import permits use to be available several years before a hunt and those were granted within 60 to 90 days of filing an application. Now filing before a hunt seems to be a waste to time because the application is not processed until too long after the application. This is because the special regulations and the FWS procedure itself are more demanding. The FWS has changed its entire application processing procedure. It has gone from making a “country-wide” finding for several years and class of hunters in the future for all applicants to having to make its findings one application at a time for each applicant/hunt at the national management level as well as at the operator or hunting area operator level. Conservation Force’s years, relationships and hundreds of projects with operators lends itself to the necessary local area fact finding with those same operators for today’s permitting process.
Incomplete or otherwise incorrectly filed applications adds to the delay for all applicants. Too many applicants and/or their agents have been filing incomplete applications that do not satisfy the newer requirements. Completing an application on its face requires attachment of documentary proof of enhancement for the hunt, one hunt at a time, from the foreign wildlife authorities and expert NGOs. So, Conservation Force developed an Operator Enhancement Questionnaire which the FWS eventually adopted for its own use, but that calls for more information about each operator than ever before. The proper filing of an application is now a team effort that can require months of focused information gathering and remedial work.
The International Affairs section of FWS has also been plagued by Covid and all that it has entailed like loss of staff, difficult recruitment, and training, etc.
Ultimate Validation of Conservation
An enhancement finding today is the ultimate validation of the conservation value of international hunting by the most sophisticated agency of its kind in the world, the FWS Permits Office. Only upon proof of enhancement can you get your permit and be assured of the conservation spin-off and benefits. In a true sense, what Conservation Force does is conservation permitting or enhancement permitting which fits in with our mission.
The completion and filing of the application form with documentary attachments is only the half-of-it. Conservation Force is uniquely engaged from cradle to grave with making hunting a greater tool for conservation including regulatory compliance, budgeted management planning at the national and local level, implementation of recovery action plans, participatory community programs to incentivize and benefit local rural people, and much more. This requires leadership participation at CITES Conferences of the Parties and committee meetings and in the settings of USFWS regulatory policy and procedures. By design the fees charged by Conservation Force for its conservation permitting services go towards the array of costs and budgeted smart projects that underly the issuance of import permits. It does not happen by itself- someone must do the conservation work behind the scenes.
Neither CITES or the U.S. Endangered Species Act provide the recovery programs, recovery funding, planning and management activities for foreign species that they do for domestic species, so it is necessary for Conservation Force, the hunting community at large and the range country authorities to provide those recovery activities. That requires identifying the primary threats to a species and directly reducing those threats such as securing habitat, controlling poaching, providing conservation infrastructure, etc. Those identified benefits are the enhancements that must be documented for issuance of import permits.
What Happens When Applications Are Denied
Under the Administrative Procedures Act, the FWS Permits Office must state its reasons for denial of a permit. Conservation Force is expert at identifying and understanding the rationale, then taking remedial action to correct the deficiency on the form, or, more importantly, in the foreign land. This is how Conservation Force has pioneered new hunting areas and species or reopened hunting after species have been up listed. We dig into the facts, identify the threats to the species and develop hunting programs that strategically reduce those threats. A permit denial is a window that guides us on the remedial action that must be taken to refile or successfully file applications. We long ago mastered this important process. Once the conservation deficiency is corrected the denial can be reconsidered or the application can be refilled. It has long been our objective to identify and remedy the problems until permits are granted.
Connections with Legal Division
If the FWS should fail to follow the law if any, then Conservation Force has a long successful litigation history of getting injunctive and declaratory relief.
When anti-hunting organizations file suit to enjoin trophy imports Conservation Force intervenes and has a long record of defeating those actions.
Likewise, when State Legislatures enact legislation to ban import of trophies, Conservation Force has successfully led filed suit and nullified the illegal legislation. Witness the New Jersey case.
In instances where imported trophies are seized for forfeiture because of any number of innocent owners, technical violations we are experts at filing petitions for remission as well as seeking fair judicial relief.