USFWS Proposed Lion Rule– How Does This Affect Me as a Hunter?

Safari Club International Frequently Asked Questions about
the Recent Fish and Wildlife Service Lion Decision
On October 27, 2014, the United States Fish and Wildlife Service (“FWS”) announced its long-awaited decision about whether the African lion should be listed as an endangered species under the Endangered Species Act (“ESA”).  A summary of its decision and of its potential effects on hunters is provided by Safari Club International (“SCI”) for its members below in a question and answer format.What did the FWS decide?

The FWS decided four things.

First, the FWS decided that the lion is not endangered.  Under the ESA, a species is endangered only if it is on the brink of extinction.  This decision was a defeat for the anti-hunting groups that had petitioned the FWS to list the lion as endangered.

Second, the FWS decided to propose that the lion be listed as threatened.  Under the ESA, a species is threatened if it is not currently on the brink of extinction, but is “likely to become endangered in the foreseeable future.”  SCI disagrees with this decision because the FWS reached this conclusion notwithstanding the fact that 70% of the lion population lives in what are termed “strongholds” in eastern and southern Africa and the protections afforded by the “strongholds” have kept the lion populations in those areas relatively stable for the last three decades.

Third, the FWS decided that lion hunting is “not … a threat to the species at this time,” and that well-managed hunting can provide important conservation benefits for the lion.  According to the FWS, the lion is threatened due to a rapidly increasing human population in Africa, which leads to habitat loss, loss of prey-base, and increased lion-human conflict, usually in the form of killings in retaliation for lion attacks on livestock.

Fourth, the FWS decided to propose what is known as a 4(d) rule for the lion.  The rule, if finalized, “will establish a permitting mechanism to allow importation of sport-hunted African lion trophies into the United States provided that they are established as originating from countries with a scientifically sound management plan for the African lion.”  The implementation of this rule will be of vital concern to hunters, and SCI will vigorously work to modify it to ensure hunters’ ability to import lions from Africa.

How will the FWS’s decision affect lion hunts booked for 2014 or 2015?

The FWS’s decision will not affect those hunts in any way.  The FWS’s decision will affect lion hunts in 2016 and beyond only if the proposed listing as threatened and the proposed 4(d) rule are finalized, which will not occur for at least one year.  SCI and SCIF will provide comments to the FWS on both proposals, and will keep you informed of any developments in the rulemaking.

If finalized, how will the 4(d) rule affect the importation of hunted African lion trophies for 2016 and beyond?

If finalized, the 4(d) rule will require a hunter to have a permit from the FWS before he or she can import a lion trophy into the United States.  The FWS will issue a permit only if the lion is taken from a country that has an “effective lion conservation program,” as determined by the FWS.  The FWS claims that, once it has determined that a country has an effective program, it will be able to process permit applications within 30 to 60 days.  However, based upon the experiences of SCI members with the permit application process for the importation of other species, some skepticism is in order.

Has the FWS identified any countries with “effective lion conservation programs”?

No.  The FWS claims that it currently lacks the information necessary to make any such identifications, although it acknowledges that “many of the range countries have implemented or will implement best management practices.”  “Effective lion conservation programs” will be expected to address: lion population levels and trends, the biological needs of the lion, quotas, management practices, legal protection, local community involvement, and use of hunting fees for conservation.

If hunting is not a threat to the lion, why does the FWS believe a 4(d) rule that regulates the importation of trophies is necessary?

The FWS believes that hunting is a source of significant revenue for the range states, and that by regulating the importation of lion trophies, it will give the range states a strong incentive to develop and maintain “effective lion conservation programs.”  SCI and the American public believe that this ecological imperialism is unnecessary and the FWS should be working within the international treaty system instead of acting unilaterally.

How will the FWS’s adoption of a 4(d) rule affect the importation of trophies from lion populations in South Africa hunting preserves?

As far as can be determined at this point, the 4(d) rule will apply to the importation of trophies from captive lion populations.  However, the FWS specifically states in the proposed rule that the ESA focuses on conservation of lions in their native ecosystems.  SCI is very concerned that FWS will use this rule as an excuse to stop importations from hunting preserves.  SCI will be working to modify the 4(d) rule to make sure that lions imported from hunting preserves are not subject to the ESA permitting process.

Has the FWS required permits for the importation of trophies of other threatened species besides the lion?

Yes.  The FWS requires a permit to import African elephants, leopards, straight-horned markhors, argali and bonteboks.  However, many of these species are permitted under rules that are far more hunter-friendly than the proposed lion rule. SCI will be pushing to modify the lion rule to more closely resemble these other rules.

How can I help as an SCI member?

Donations to the Fighting for Lions Campaign ( will assist SCI in its efforts to develop comments on the FWS’s proposed listing and proposed 4(d) rule that will insure that the decisions are not finalized, or that, if they are, that the 4(d) rule will be workable and properly recognize the conservation efforts of the range states.  SCI will also be working closely with the range states to update and improve their lion conservation programs.

For additional information, please contact Nelson Freeman at


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