Written evidence submitted by A1 (AAB008)

  1. Will the Government’s proposals on the export and import of hunting trophies effectively support the conservation of endangered species?


              The government’s proposals on the import and export of trophies will not support the conservation of endangered species.  Rather it will have the opposite effect and will impact on vital conservation funding.  I have outlined my justification below (both on import and export)


              Firstly, there are no “endangered species” that are hunted in the UK. Should any restrictions be placed on the export of deer “trophies” in the UK, it will have a detrimental impact to the overall quality of the UK deer population. Trophy hunting in the UK for export is primarily linked to the six wild species of deer that are present, and deer that form part of deer parks, which are not present in the wild (Pere David, Elds Deer, Sambar etc).  None of the UKs wild deer species are endangered or threatened. 

              Park Deer (such as those at Woburn, Windsor, etc.) have no ability to move from the park, so need to be managed.  The control of deer in Park settings is part of an overall plan to maintain the health and wellbeing of the herd – culling a small number of the older deer is part of the overall plan, and allowing a small number to be shot as “trophies” by visiting tourists provides income to the estate and the local community, whilst completing an activity that needs to be done regardless. 

              The wild deer of the UK are not endangered, and indeed in many parts of England and Scotland are deemed to be pests.  In the UK all deer management activity is part of a controlled cull and management plan.  Cull plans require a cross section of the population of deer to be managed including older “trophy deer”.  Due to large deer numbers in the UK, a ban on “trophy hunting” of deer will only have the effect of not enabling deer to reach maturity, as their primary value will be the value of the meat.  Indeed, through not being able to charge more for a “trophy” deer there will be minimal incentive to allow the wild herds of the UK to grow into mature “trophy” animals.  A good example of this is the wild red deer of East Anglia.  A small number of estates (Euston, Elveden and others) shoot very small numbers of wild stags each year, but those that they do shoot are old, and have had a life where they have passed their genetics on to the herd.  In contrast, landowners that don’t have revenue from the red deer population shoot them as pests, or for venison

              In summary, any proposed export ban would have no benefit to conservation efforts, and indeed would likely have a detrimental impact on the quality of deer in the UK and destine them to pest animals that will be shot on sight.


              It is encouraging that the aim of this consultation is on conservation rather than preservation, as hunting is a crucial component of effective wild animal conservation.  We tend to always look towards Africa and question whether the hunting £/$ makes a difference, but the scope of this consultation implies that it is broader than just African game.

              If we were to take a closer look at the United States, the impact of hunting as part of an overall conservation plan is apparent.  Each game department in the US defines the annual quota that can be hunted, and for some species dictates the size that it must be before it can be shot (namely, the rarest of US species, the big horn sheep – with the condition being that it must be a mature (or “trophy”) animal).  Several game departments insist on online training and familiarisation to ensure that hunters understand how to effectively age animals.  The game departments of the US receive a significant proportion of revenue from hunting licences, and numbers of licences and permits are allocated by the holding capacity of the region.  Often there are limited permits, and hunters will wait 20+ years to draw a coveted permit for the best regions that produce the best quality animals – paying each year to enter the ballot for a permit, until they eventually draw

              In the US it is widely accepted that hunters’ dollars have re-built populations of bison, sheep, elk, and deer.  Yet this proposed legislation could penalise a British hunter wishing to import his elk antlers after paying substantial sums to support the US game departments conservation efforts. 

              The same model applies almost universally around the world, but Western animal right groups and governments don’t seem willing to trust African conservationists, despite numbers of large game (specifically in Southern Africa where there is a buoyant hunting industry), are increasing.  In contrast, counties that have closed hunting have seen animal populations decline mainly due to habitat loss through turning wilderness into agricultural use.  Sadly, most non-hunters will never venture outside of a national park to see the impact that this lack of funding has on local communities, and the game that used to co-exist with them.  Whereas initiatives such as CAMPFIRE in Zimbabwe incentivise local communities to keep land wild, and to tolerate game, and in return they receive a proportion of hunting revenues.


              If any ban on the import of trophies assumes that the killing of certain species will suddenly stop is short-sighted.  In Botswana it has been illegal to shoot lions for trophies for some years, but it is perfectly legal to shoot them if they are predating livestock.  Large predators would be tolerated and indeed encouraged if the farmer had the ability to receive income from strictly controlled sport hunting.

              In Namibia – which has the largest population of black rhino and is the only country to allow sport hunting of small numbers of rhino – old black rhinoceros become aggressive and a danger to younger animals.  They are past breeding age, so are shot to ensure that they don’t wound or kill younger breeding animals.  Prior to a CITES quota being applied to these bulls, they would be shot by the government game department.  In doing so, there would be no revenue brought into the Game Department, whilst still resulting in the rhino being shot – whether by a wealthy foreign hunter, or a government game scout. 

              Any proposed ban would also show a level of ignorance from the UK government in not understanding how precious wildlife resources are managed, and how solutions are put in place to ensure that people and wild game can co-exist outside of national parks. 


2.              Should there be different rules for the trade in animal trophies depending on the setting in which the animal was hunted?




  1. What are the possible unintended consequences of the proposals, for example in relation to animal trophies that pre-date the legislation?







4.              How effective are current measures on the trade in trophies of hunting, including how they support conservation?







5.              What will be the impact of the proposed domestic ban on advertising and offering for sale overseas attractions, activities or experiences that involve the unacceptable treatment of animals?



6.              Who should be responsible for ensuring attractions, activities or experiences overseas do not cause the unacceptable treatment of animals?