Attack on Namibia Black Rhino Conservation Efforts

In January, 2014, the Dallas Safari Club (“DSC”) auctioned off a permit to shoot an old, non-breeding, male black rhinoceros (Diceros bicornis) in the southern African country of Namibia. It was the first time a black rhino permit had been auctioned outside the country. The winning bid was $350,000 by Corey Knowlton of Royse City, Texas, who leads international hunting trips for a Virginia company, The Hunting Consortium. All the proceeds will be donated to a trust fund administered by the Namibian government. Unfortunately, both the DSC and Knowlton, who has now hired full-time security, have received death threats that are being investigated by the FBI. Namibia sold another permit for $200,000 to Michael Luzich, a Las Vegas investment manager, inveterate big game hunter, and NRA supporter who did not attract such attention but has already filled his permit.

Namibia contains 1,800 of the world’s 4,880 black rhinos, which are not really black but vary in color from brown to grey. Extremely aggressive, they have the highest rates of mortal combat for any mammal, 50% for males and 30% for females.

The Namibian Ministry of Environment and Tourism oversees protection of the country’s black rhinos and annually issues three to five hunting permits to fund a conservation program for protection of the critically endangered species. The conservation program includes habitat improvement, rural community development, hiring scouts to monitor the rhinos, and removing the horns (which is ineffective, very expensive, and deprives adults of a weapon to defend their young against predators) in order to reduce their appeal to poachers who can sell the horns for $30,000/pound on the black market.

The animals, which are selected by a committee and approved by the Namibian government, are older males that cannot reproduce. In a letter to the DSC, the Namibian government wrote, “To hunt a black rhino is not taken lightly by Namibia. . . . Only old geriatric bulls, which are marginalized in the population and do not contribute to reproduction, are trophy hunted.” The Namibian government plans to closely monitor the hunting expeditions. Both Knowlton and Luzich have applied for permits from the U.S. Fish and Wildlife Service (“FWS”) that will allow each to import the trophy after a successful hunt. If the permit is denied, the DSC will refund Knowlton’s money and the rhino conservation fund in Namibia will suffer as a result of the FWS decision.

The FWS published on November 6, 2014, in the Federal Register a Notice of Receipt of Applications for Permit (the “Notice”) and has invited the public to comment on several applications, including those of Knowlton and Luzich. The FWS has said that it is paying extra attention to Knowlton’s application because of the rise in poaching, an argument that may have been made because of pressure from anti-hunting groups. The agency also says it is examining how the auction funds will be administered. In short, it is making itself the arbiter of the Namibian government’s conservation program.

The International Fund for Animal Welfare (“IFAW”), an anti-hunting organization, is leading a campaign, which has been joined by many groups, to persuade the FWS to deny the Knowlton and Luzich applications. IFAW contends that it is “a farce” to say that the hunting permits were issued for conservation purposes. It claims that it would be better to promote wildlife viewing and ecotourism by charging people to experience seeing a black rhino in the wild, even though it has been demonstrated that hunting safaris bring in more money. For example, since Kenya banned hunting in 1977, it not only has lost a great deal of money but also most animal species there have declined in number from 40% to 90%. Hunting bans have been ineffective for the purpose of increasing animal numbers because they reduce the value of local animals and local interest in protecting them. In Namibia, where the gross per capita income is estimated by the World Bank to be less than $6,000, its government cannot ignore the opportunity to raise so much money for conservation so quickly.

The IFAW has published on its web site a template e-mail for its followers to send to FWS Director Dan Ashe requesting him to deny the import permits as follows:

I am writing to urge you to deny the requests for import permits for black rhino trophies from Namibia. This would continue a terrible precedent for this and other critically endangered species whose future depends on keeping healthy populations in the wild.

The American people agree that killing an endangered species is unacceptable. A recent poll found that 89 percent of the public said they were opposed to the hunting of rhinos for sport.

With approximately 5,000 remaining in the wild, the black rhinoceros is on the brink of extinction. The U.S. Fish and Wildlife Service has an opportunity to set an example for the world by denying import permits for two rare black rhinos that will have been needlessly killed.

The so-called “recent poll” was conducted by the Beekeeper Group, which has been described inaccurately as “an independent polling company” but is actually a public relations organization serving clients that are looking for grass roots mobilization. It pushes policies or messages by helping clients with advocacy strategies. Beekeeper primarily provides web design, mobile messaging, customer relationship management, and video and animation services. Although Beekeeper often performs “polls” for IFAW, it most definitely is not a polling company. Beekeeper allegedly interviewed 1,000 voters online in September, which sounds more like posing questions to whomever decided to respond, much like the questions we have all seen in little boxes on the side of an Internet page; it hardly deserves to be viewed as scientific polling.

Similarly, the Humane Society International (“HSI”) has the following petition on its web site for people to sign:

I am writing to urge you not to issue the import permits that would allow the import of black rhinoceros trophies from Namibia. This would set a terrible precedent for this and other critically endangered species whose future depends on keeping as many of their kind alive so that they can contribute to the gene pool. Killing in the name of conservation is unacceptable. Conversely, promoting the killing would undermine conservation efforts that are so desperately needed to save the dwindling numbers of black rhinoceroses.

With fewer than 5,000 remaining in the wild, black rhinoceroses are on the brink of extinction. The U.S. Fish and Wildlife Service has an opportunity to set an example for the world by denying the import permits of this critically endangered rhino—and animals that would be killed for nothing more than to decorate hunters’ trophy rooms.

Nevertheless, anti-hunting, alleged conservation, and animal protection organizations are very effective in mobilizing their members who act on emotion instead of science and ignore wildlife biologists’ observations. Over 410,000 persons have “liked” IFAW on Facebook. The FWS is probably being inundated with emails generated by IFAW, HIS, and like-minded groups who are supported by dozens of misguided, ignorant celebrities such as George Clooney, Leonardo DiCaprio, and Bill Clinton.

The hunting and conservation communities need to generate the same kind of support in favor of the two applicants as is being whipped up against them by the anti-hunters who are using conservation as a smokescreen. Approval of the Knowlton and Luzich applications will have a positive effect by providing an additional $550,000 toward black rhino conservation activities. There is no evidence that IFWA, the Humane Society International, or any other anti-hunting organization or individuals have promised to make up Mr. Knowlton’s $350,000 auction bid if FWS denies the permits. Moreover, since Mr. Luzich has already filled his permit, denying the application will not “save” any rhino but rather serve only to penalize him for exercising a legal activity that has been approved by the Namibian government in order to raise money for conservation.

Accordingly, if you wish to help counter the anti-hunting, anti-conservationist backlash, please submit a comment to FWS in support of the two hunters’ applications. Although IFWA has directed its members to email the FWS director, the FWS has stated in the Notice that comments on the applications should be delivered by: (1) e-mail to; (2) fax to (703) 358-2281; or (3) mail to:

Brenda Tapia
U.S. Fish and Wildlife Service
Division of Management Authority
Branch of Permits
5275 Leesburg Pike
Falls Church, VA 22041

You must include in your comment the following identifying information: (1) the date of the Federal Register Notice publication date, which is November 6, 2014; (2) the name of the applicant, i.e., Corey Knowlton or Michael Luzich; and (3) the PRT-number for each applicant, which is PRT-33291B for Mr. Knowlton and PRT-33743B for Mr. Luzich. You need to submit a separate comment for each applicant even if your comments are virtually the same except for the required identifying information.

In order to facilitate your sending a comment, I have drafted the following proposed message that you should feel free to modify or ignore in favor of your own language. However, whatever you may write, be sure that you are polite and not too wordy:

Regarding the Notice of Receipt of Applications for Permit that appeared in the Federal Register on November 6, 2014, I urge you to grant the application of Corey Knowlton, PRT-33291B [for second message, substitute Michael Luzich, PRT-33743B], for a permit to import the sport-hunted trophy of one black rhinoceros taken from the wild in Namibia pursuant to a hunting permit issued to him by the Namibian government.

The American public overwhelmingly supports the legal hunting of any animal. The fact that the black rhinoceros is an endangered species does not prevent it from being hunted for sport. In this case, the hunting permit was issued by the Namibian government for an old, non-breeding, male black rhinoceros that can no longer contribute to the gene pool. Therefore, in the words of the Section 10(a)(2)(B)(iv) of the Endangered Species Act, “the taking will not appreciably reduce the likelihood of the survival and recovery of the species in the wild.”

Further, the application should be granted because the taking of this animal will enhance or benefit wild populations of the species. The Dallas Safari Club, which auctioned off the permit for $350,000, pledged the proceeds to a rhino conservation trust fund in Namibia. If the application is not granted, the $350,000 will have to be returned to Mr. Knowlton. In death, this particular black rhino will help to preserve and increase the species’ numbers. Granting the application will insure that a large amount of money will help fund Namibia’s conservation efforts for insuring survival of the species.

When commenting on the Luzich application, disregard the preceding paragraph and use the following:

Further, the application should be granted because the taking of this animal will enhance or benefit wild populations of the species. Mr. Luzich has already paid the Namibian government $200,000 for a permit, which he has filled, to take an old, male, non-breeding black rhino. Denial of the permit will not save any rhino and only discourage the purchase of other permits, which are rarely issued, and thereby adversely affect conservation funding efforts in Namibia.

If you would like a Word copy of the suggested comments for modification or moving passages into an e-mail, letter, or fax, contact the Conservation Director and it will be provided.

The FWS must receive comments on or before December 8, 2014.