John Frederick Walker

Rethinking Ivory: An Exchange with Wasser, et al.

Posted in elephant and ivory news, ivory news by JFW on September 2, 2010

In advance of the 2010 CITES meeting, Samuel Wasser and a number of other prominent elephant researchers published a much-discussed Policy Forum piece (“Elephants, ivory, and trade”) in the March 12 issue of SCIENCE, reproduced on the Save the Elephants site (click here.)

Ivory trade researcher Daniel Stiles and I wrote the following letter, which appeared in the June 25, 2010 issue of SCIENCE (and was reproduced on the Save the Elephants site here, along with a response from Wasser et al.).  Both are given below:

Letters to the Editor
Science Vol 328
June 25, 2010

THE POLICY FORUM BY S. WASSER ET AL. (“Elephants, ivory, and trade,” 12 March, p. 1331) overlooks several points that bear on the issue of whether the Convention on International Trade in Endangered Species (CITES) should allow legal ivory sales. There is no proof that the elephant population is dropping. The two citations given offer no clear evidence. The IUCN Red List categorizes Loxodonta africana as “vulnerable,” below two levels of higher threat, and its population trend is described as “increasing” (1).

We agree with the statement that “most of Africa lacks adequate controls for protection of elephants,” but rather than target legal ivory sales, CITES should take steps to increase anti-poaching and trade enforcement. Legal ivory sales have not been shown to stimulate poaching (2–4), despite widespread media claims that link the two. Focus on this issue takes attention away from other factors that drive illegal killings, such as unregulated domestic markets, ivory demand, corruption, and human-elephant conflict.

Wasser et al. state that “[i]n the absence of data, precautionary principles should be applied.” Yet precautionary principles can be manipulated to suit one’s purposes. The authors assume that a legal trade might lead to irreversible elephant losses. What if the assumption were the opposite—that not allowing trade would lead to increased poaching? This scenario is hardly far-fetched. In the absence of legal supply, ivory demand will inevitably be met by killing elephants illegally. The authors state, accurately, that “oneoff” sales introduce uncertainty into the market place, but they do not acknowledge that there is another way to reduce uncertainty other than having no sales: Allow a regular, annually recurrent sale to settle the markets, reduce prices, and lower motivation to poach and buy illegal ivory.

We believe that both no sales and “oneoff” sales are harmful for elephant conservation and, given suff cient institutional support and political will, a normalized legal ivory trade would save elephant lives.

1Kent, CT 06757, USA. 2Diani Beach, 80401, Kenya.

*To whom correspondence should be addressed. E-mail:

1. The IUCN Red List of Threatened Species, Loxodonta Africana (
2. D. Stiles, Environ. Conserv. 34, 309 (2004).
3. E. Bulte, R. Damania, G. van Kooten, J. Wildlife Manage. 71, 613 (2007).
4. T. Milliken, R. W. Burn, L. Sangalakula, The Elephant Trade Information System (ETIS) and the Illicit Trade in Ivory (CoP15, Doc. 44.1, TRAFFIC, Cambridge, MA, 2009);


WALKER AND STILES ARGUE THAT ELEPHANT populations are not declining. The facts say otherwise. Loxodonta africana numbers have plummeted by more than 50% continent-wide in the past 40 years, a reduction now compounded by increases in range loss, confl ict with humans, and resurgence in poaching (1). Illegal killing from 2000 to 2007 was highest in central Africa (63% of carcasses were illegally killed) followed by eastern (57%), western (33%), and southern Africa (19%) (2). Poaching reduced one of the Democratic Republic of the Congo’s (DRC’s) largest populations of forest elephants by nearly half between 1996 and 2006 (3). Elephant populations in Chad and Central African Republic declined by more than 80% in the past 5 and 20 years, respectively (4, 5). The Selous Game Reserve population in Tanzania has declined by 30% since 2006, amidst escalated poaching (2, 6). Because average tusk size has progressively decreased over the past three decades (7, 8), more elephants must be killed for the same volume of ivory; this has accelerated the trend toward population collapse.

Walker and Stiles next argue that legal trade does not increase illegal trade, and CITES should focus on enforcement instead of targeting legal trade. We disagree. The appeal of the market mechanism for managing wildlife stocks presumes well-functioning institutions with unambiguous ownership of the stocks. Chronic problems such as poaching, corruption, and inadequate regulation and enforcement capacity show that this assumption is false. The problem will be exacerbated if CITES’ promotion of legal trade increases illegal trade by signaling an opening market. The ETIS (9) report to CITES rejected such a relationship for the first one-off ivory sale in 1999 but acknowledged that illegal ivory trade increased substantially in 2009 after the 2008 sale. The Elephant Trade Information System (ETIS) analysis used adjusted amounts of seizures that markedly differed from unadjusted values, incorporated a smoothing technique that blunted peaks and troughs, and excluded a major increase in poaching in DRC during 2004 (10). This obscured a recurring pattern where each proposal for one-off ivory sales appears to have instigated a rise in poaching. Walker and Stiles believe that a regular, legal trade should be established and enforced. We are not suggesting that legal sales will always lead to irreversible losses, but rather that illegal trade currently is too uncontrolled to justify the risk. When the distinction between legal and illegal ivory is uncertain, increasing the legal supply raises the probability that more ivory will be provided through illegal trade. Illegal dealers will see an expanding market due to increased allowable trade, and will endeavor to maintain their share of that market. Moreover, growing demand for ivory will outstrip any potential sustainable legal supply given increasing purchasing power of Asian consumers and limited maximum growth rates of elephant populations, particularly when poaching is already mining populations of progressively younger individuals. If seizures are assumed to represent ≤10% of ivory shipped (11), the average 19,000 kg of annual ivory seizures over the past decade (9) would require 190,000 kg of “legal” ivory sold annually just to meet levels of demand presently supplied through illegal trade.

We contend that any legal trade at this time is an untenable risk that complicates law enforcement and distracts from the need to reduce demand. Although reducing demand is possible, elephants could be seriously depleted in the interim because (i) verified natural mortality and controlled culls are insufficient to meet current demand; (ii) proceeds from ivory sales cannot be guaranteed to return to local communities as incentive for in situ conservation; and (iii) education campaigns are finding it difficult to suppress the growing desire and purchasing power for luxury goods in end-user countries.

Analogous arguments apply to most other trade species, including sharks, blue fin tuna, polar bears, and corals. CITES should therefore reset its priorities, more explicitly apply the precautionary principle, and insist upon open data access and peer review. Only then will it ensure the long-term viability of species and trade.

1University of Washington, Seattle, WA 98195, USA.
2Princeton University, Princeton, NJ 08540, USA.
3ElephantVoices, Sandefjord, 3236, Norway. 4Amboseli
Trust for Elephants, Kenya. 5Tshuapa-Lomami-Lualaba
Project, Kinshasa, Democratic Republic of the Congo.
6University of British Columbia, Vancouver, BC V6T 1Z4,
Canada. 7University of Stirling, Stirling K94LA, UK.

*To whom correspondence should be addressed. E-mail:

References and Notes
1. J. J. Blanc et al., African Elephant Status Report 2007(IUCN, Gland, Switzerland, 2007).
2. CITES, “Monitoring of illegal hunting in elephant range states” (CoP15, Doc. 44.2, 2009); cop/15/doc/E15-44-02.pdf.
3. R. Beyers, thesis, University of British Columbia, Vancouver, BC (2008);
4. P. Bouché et al., Afr. J. Ecol., 10.1111/j.1365-2028.2009.01202.x (23 December 2009).
5. D. Potgieter, N. Taloua, B. Djimet, M. Fay, L. Holm, Dry Season Aerial Total Count, Zakouma National Park, Chad 4–8 March 2009 (Wildlife Conservation Society Technical Report, 2009).
6. CITES, “Report of the Panel regarding the proposal of the United Republic of Tanzania” (CoP15 Doc. 68 A6a);
7. E. J. Millner-Gulland, J. R. Beddington, Proc. R. Soc. London Ser. B 252, 29 (1993).
8. CITES, “Report of the Panel regarding the proposal of Zambia” (CoP15 Doc. 68 A6b);
9. T. Milliken, R. W. Burn, L. Sangalakula, The Elephant Trade Information System (ETIS) and the Illicit Trade in Ivory (CoP15, Doc. 44.1, TRAFFIC, Cambridge, MA, 2009);
10. C. A. Apobo, Rapport sur le Braconnage D’Eléphant et sur le Commerce de l’Ivoire dans et a la Périphérie de la Réserve de Faune à Okapis (RFO) Ituri, RDC (ICCN Report, Wildlife Conservation Society, Democratic Republic of Congo, 2004).
11. S. K. Wasser et al., Conserv. Biol. 22, 1065 (2008).

Stiles and I wrote a follow-up letter which appeared online in SCIENCE on July 16, 2010. It is reproduced below:


The response of S. K. Wasser et al. to our Letter (“Consequences of legal ivory trade,” 25 June 2010, p.1633) is replete with factual errors and misrepresentations.

They state we are incorrect when we held that Africa’s elephant population is not decreasing, changing the time frame from “recent” to “40 years” to make their point. The African Elephant Database and IUCN both indicate a continent-wide increase in recent years (1, 2), despite decreases in the areas Wasser et al. cite.

They assert that market mechanisms will not control illegal trade because of poaching, corruption, etc. We disagree. It is the absence of legal trade that has led to increased poaching. If legal ivory were available at prices seen in the Convention on International Trade in Endangered Species (CITES)–approved southern Africa auctions (3), black market ivory traders would have no buyers, regardless of corruption and weak law enforcement.

The 2009 Elephant Trade Information System (ETIS) report to CITES (4) did not acknowledge “that illegal ivory trade increased substantially in 2009 after the 2008 sale.” What increased was the volume of ivory seized, which we think was due to increased vigilance by the authorities in reaction to the upsurge in publicity associated with the CITES conference and proposed ivory sales by Zambia and Tanzania. Also, as the CITES Secretariat stated: “indications from some recent seizures suggest that some of the ivory may have been poached in the early 2000s. If accurate, this means that it came from elephants that were poached before the most recent legal trade occurred or was even authorized by the Conference of the Parties” (3).

Wasser et al. assert that the ETIS report excluded a major increase in poaching in the Democratic Republic of Congo (DRC) in 2004 that would have revealed a recurring pattern of increased poaching being instigated by one-off legal ivory sales. The DRC report cited referred only to the Okapi Faunal Reserve, which suffers from rampant poaching of all wildlife due to a state of general anarchy. CITES decisions are of little motivational consequence to brigand militias and a lawless army.

They state “that illegal trade currently is too uncontrolled to justify the risk [of allowing legal trade].” Obviously illegal trade is uncontrolled, which is why we argue for a controlled legal trade that will render illegal trade economically unviable.

We do not think that allowing regulated sales of legal ivory will expand the market. It would only expand if demand increased, and demand has been declining almost everywhere since the 1990s (5–9). There appears to be rising demand in China, but no hard data support the contention.

Wasser et al.’s observation that a growing ivory demand in Asia will outstrip the ability of elephant population growth to meet required supply applies to all ivory, not just legal. They assume that only 10% of illegal ivory is seized. The CITES Secretariat stated that it believes the 10% figure often quoted is too low (3). If 90% is getting through, why was no illegal African raw ivory found in recent ivory surveys of Thailand, Vietnam and Japan (10–12)? Also, to derive an ivory demand figure of 190 tons annually from ivory seizures alone is unjustified, and lacks all scientific credibility.

They claim further that “education campaigns are finding it difficult to suppress the growing desire and purchasing power for luxury goods in end-user countries.” This is totally at variance with published peer-reviewed data that ivory demand in the great majority of countries has been falling in response to increased public awareness since 1990 (5–12). Education campaigns do work, and to suggest they do not is harmful to elephant conservation.

Finally, we disagree with Wasser et al. that analogous arguments can be made with most other trade species. In those cases the organism must be killed to trade the product. It is not necessary to illegally kill an elephant to trade its tusks–unless tusks from natural and legally induced mortality are banned from trade.

John Frederick Walker

Kent, CT 06757, USA.

Daniel Stiles

Diani Beach, 80401, Kenya.


1. J. J. Blanc et al., African Elephant Status Report 2007: An Update from the African Elephant Database (No. 33 IUCN/SSC AfESG, Gland, Switzerland, 2007), pp. 22–24.

2. The IUCN Red List of Threatened Species, Loxodonta africana (

3. Monitoring of Illegal Trade in Ivory and other Elephant Specimens, CITES Secretariat, CoP15 Doc. 44.1 (Rev.1);

4. T. Milliken, R. W. Burn, L. Sangalakula, The Elephant Trade Information System (ETIS) and the Illicit Trade in Ivory (CoP15, Doc. 44.1, TRAFFIC, East/Southern Africa, 2009);

5. E. Martin, D. Stiles, The Ivory Markets of Africa (Save the Elephants, London, UK, 2000).

6. E. Martin, D. Stiles, The Ivory Markets of South and South East Asia (Save the Elephants, London, 2002).

7. E. Martin, D. Stiles, The Ivory Markets of East Asia (Save the Elephants, London, 2003).

8. E. Martin, D. Stiles, Ivory Markets of Europe (Care for the Wild International and Save the Elephants, London, 2005).

9. E. Martin, D. Stiles, Ivory Markets in the USA (Care for the Wild International, Kingsfold, UK and Save the Elephants, Nairobi and London, 2008).

10. D. Stiles, An Assessment of the Illegal Ivory Trade in Viet Nam (TRAFFIC Southeast Asia, Petaling Jaya, Selangor, Malaysia, 2008).

11. D. Stiles, The Elephant and Ivory Trade in Thailand (TRAFFIC Southeast Asia, Petaling Jaya, Selangor, Malaysia, 2009).

12. L. Vigne, E. Martin, Pachyderm 47, 46 (2010).

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