Comment on the USFWS Submission

Re – Draft Environmental Assessment and Economic Analysis Revisions of the African Elephant Rule under Section 4(d) of the United States Endangered Species Act (50 CFR 17.40(e)).

November 2022.
Prepared by: U.S. Fish and Wildlife Service International Affairs Program Division of Management Authority

This response, from The True Green Alliance (South Africa), is addressed to:
The President,
The Professional Hunters Association of South Africa (PHASA)
Mr Ben Heystek

Dear Sir,

MR BARRY YORK (VICE-PRESIDENT OF PHASA) asked me to respond to this appeal for information, from the US Fish and Wildlife Service, on behalf of PHASA.

I am very happy to do that. Indeed, I am honoured to think that Mr York has that much faith in my knowledge of African Elephant management matters to represent PHASA in this important matter. A great deal of this FWS report deals with the USF&WS’s administration of its own Endangered Species Act (ESA).

The subjects covered in this regard, therefore, are best left unanswered and set aside for the attention of the US Fish & Wild Life Service itself. I have to say, however, that I am pleasantly surprised that the service is now (so it seems) contemplating the commercial sale of live elephants to, from and within the United States.

I am also pleasantly surprised to see that the service is now openly discussing the importance of ‘populations’ as opposed to just ‘species’ in their narrative. This, too, is a great change and improvement and I have to say that I wish CITES, in this respect, would take a leaf out of the USFWS’s book. CITES has been greatly remiss in this regard throughout its life-span (i.e. since 1975).

But I am not going to discuss any of these subjects now. Nevertheless, I note them!

I see this request, therefore, as a great opportunity for me (for PHASA) to place critical and important comment-on-record with the USFWS about elephant management in southern Africa, in general. And I want that record to include discussion about those important facets of the USFWS’s perceptions, regarding the principles and practices of wildlife management, especially elephant management, that clash with my own perceptions and understandings about these subjects.

I say this in all humility because, if the USFWS and African wildlife management associations, such as PHASA and SUCo-SA (The Sustainable Use Coalition of Southern Africa), are to amicably, responsibly, productively and jointly address ourselves to the wildlife management issues that concern us all, we need to have a common understanding about how we should address ourselves to the science of wildlife management.

Both the USFWS and CITES tend to address themselves to the management of ‘SPECIES’ whilst ignoring the realities and importance of ‘POPULATIONS’. In this regard I must point out that nobody can manage a ‘SPECIES’ at the species level. One can only manage a species at the population level. This being the case, the concept of ‘ENDANGERED SPECIES’ in the wildlife management equation becomes invalid. Ipso facto, the American Endangered Species Act, and the articles of CITES, are based on a fallacy.

My apologies! But my perceptions about the truths inherent in the entire wildlife management scenario tell me that this is so.

I don’t want to ‘teach granny how to suck eggs’ but it would be easier for me to explain myself in this riddle if I offer you my own full interpretations, foundations upwards, from the outset.

I accept the definition of a SPECIES as being a group of animals that share the same physical and behavioural characteristics and which, when they breed, produce fertile off-spring with the same physical and behavioural characteristics.

I accept the definition of a POPULATION as being a group of animals of the same species the individuals of which interact with each other on a daily basis and which breed only with other animals in the same group.

I am advised that the African elephant exists in some 150 different populations and that these populations are spread across the continent, south of the Sahara, from Ethiopia in the north to the Cape of Good Hope in the South; and from the Atlantic Ocean in the west to the Indian Ocean in the east.

The habitats in which these 150 elephant populations exist vary in character from high montane rain forests to low coastal grass plains, from savannah grasslands to thick thorn scrub and deciduous woodlands and from swamplands to deserts. No habitat is the same as any other. And their respective rainfalls, which make them all VERY different, vary from 100 inches a year to a mere ten. So their environmental circumstances are all very different.

I consider the definition of ELEPHANT CARRYING CAPACITY to be: ‘The maximum number of elephants that a habitat can sustainably carry – and ‘sustainably carry’ means ‘without the elephants causing permanent damage to the vegetation’.

Each habitat’s capacity to sustainably carry elephants varies according to its biological and environmental circumstances.

One habitat, for example, may be able to sustainably carry one elephant per two square miles of territory at a certain time in its history. Another during that same period of time might comfortably carry twice that number.
In the first instance, at that particular time in the elephant’s history, the habitat’s sustainable elephant carrying capacity can be ‘pegged’ at ONE ELEPHANT PER TWO SQUARE MILES.

But, because most elephant populations have the capacity to double their numbers every ten years, the sizes of elephant populations tend to grow larger all the time. And the bigger the elephant population becomes the less likely will its number be ‘sustainable’. So pegging elephant carrying capacities at a certain number is not good elephant management practice. Change is happening all the time.

When a habitat is thus forced to feed more elephants than its vegetation can sustainably carry, because of a large annual elephant population incremental breeding rate, the habitat will degrade. And if no elephant population-control management action is applied to such an expanding and excessive elephant population, the habitat will, every year, progress a little further along the road towards becoming a desert.

This is what has been happening to elephant populations and their habitats throughout south-central Africa for the last 70 years and that state of affairs has now become critical.

Indeed, MOST southern African elephant sanctuaries are well advanced in their progress towards becoming deserts.

Ron Thomson explaining what a ring barked tree is – see his movie from 6 minutes to about 10 minutes – click on image to see movie.

Some examples:

1. Kruger National Park in South Africa.
Size: 8 000 sq. miles
Sustainable National Park Elephant Carrying Capacity (c.1955) = 3 500 (+/- 500). This equates to one elephant per two square miles or one elephant per five square kilometers.

This figure may be much less today than it was in 1955/60 due to c.65 years of extra and chronic habitat abuse by far too many elephants.

Estimated (guessed ?) current elephant population size: no less than 34 000 (according to the KNP scientists). If this is correct, then Kruger is carrying circa 30 000 too many elephants.

A possible different elephant population size estimate suggests that the real population size for elephants in Kruger National Park is somewhere between 40 000 and 60 000.

This conclusion was determined from scientific calculations derived from the average culling-era incremental rate figure of 7.5 percent. (1967 to 1994. ref Dr. Ian Whyte).

Throughout the 27 years of the culling era the elephant population was consistently reduced to 7000 animals every year.

And Note: a calculated incremental rate of just 7.2% gives an elephant population a doubling time of ten years.
Mathematically, the post-culling period (1994 to 2023) covers 29 years (c.3 decades) and the elephant population size in 1994 was 7 000. When this known-size population is doubled three times in the following 3 decades, the numbers equate as follows: 7000 x 2 = 14 000 (2004); 14 000 x 2 = 28 000 (2014); 28 000 x 2 = 56 000 (2024).

So the actual size of the Kruger National Park elephant population could be as high as 56 000 today, or higher. It is because of these kinds of simple discrepancy, and an apparent lack of any kind of feelings of responsibility by the staff at Kruger, that the ‘people who care about the proper management of Kruger National Park’ have become highly skeptical about the bona-fides of the SANParks authority.

Current Elephant habitat damage considerations: All the big top-canopy trees in the national park (those with canopies bigger than 15 meters) that were present prior to 1960, have been reduced in number by more than 95 percent. This is an estimate glibly suggested by the Kruger National Park scientists in the early years of the new millennium! If this is correct, breeding sites for big eagles have already been almost totally extinguished: Martial Eagle, Tawny Eagle, Bateleur Eagle, Brown Snake-Eagle, four species of vultures and others.

Breeding sites for the iconic Ground Hornbill have almost disappeared, too. Habitats for Roan Antelope, Sable Antelope, Lichtensteins Hartebeest, common Bushbuck and other mammalian species like Bush Babies and monkeys, arboreal snakes and other reptiles, have been very badly damaged, causing serious declines in all these species’ numbers.

Why (?) because of the fact that the park has been carrying excessive numbers of elephants for more than three decades. And it is arguable that hundreds of small avian and insect species have been equally badly affected.

None of these listed species and many others whose continued existence inside Kruger National Park is threatened, have any chance of survival outside the national park. Why? Because two million rural people, and counting, closely occupy all the wildlife habitats that exist outside the boundaries of the national park.

There is, therefore, no place other than inside the park, where these species will be able to survive into posterity. If they disappear from the Kruger National Park landscape, therefore, they will have been rendered extinct. And now most of their habitats and breeding sites have been destroyed!

Maintaining excessive elephant populations in every national park in southern Africa, therefore, which is the real situation that applies today, will destroy all southern Africa’s biological diversities. That fact is something that few people outside Africa really understand; don’t know about; don’t think about; and/or seemingly, don’t care about, either.

2. Hwange National Park in Zimbabwe
Size: 5 000 sq miles.
Estimated Sustainable National Park Elephant Carrying Capacity (1960) = 2 500 = One elephant per two square miles or one elephant per five square kilometers.
Actual elephant population size, in 1960, was 3 500 (1000 too many).

Top canopy tree damage in Hwange (1960) was already then very extensive and the extinction process of several dominant tree species was very apparent.

The current estimated elephant population is 50 000 (20 times above the estimated sustainable elephant carrying capacity). Some scientists (those who don’t want to be associated in the public eye with elephant population reduction management) claim that the Hwange elephant population is ONLY 35 000.

This, in fact, just may be so! But these scientists don’t seem at all perturbed by the fact that 35 000 is ONLY 14 times greater than the estimated 1960 elephant carrying capacity figure. So, what their point is in reciting this opinion I don’t know? It is a ludicrous point of view!

Current elephant habitat damage and biological diversity damage considerations in Hwange are much the same as those that I have just recorded for Kruger National Park.

3. Gonarezhou National Park in Zimbabwe.
Size: 2000 square miles.
Estimated Sustainable National Park Elephant Carrying Capacity (1960) = 1000. This equates to one elephant per two square miles or one elephant per five square kilometers.

This is the same for both Hwange and Kruger National Parks.
Personal note: I, personally, led the elephant population reduction exercise in the Gonarezhou in 1971 and 1972 when the population was reduced from 5000 elephants to 2 500.

It was not enough. We should have reduced the number to 1000 and kept it at that reduced number, permanently, by way of annual culling. But, in those days, we did not have the understanding about elephant management that we have today!

The population reduction exercise that we conducted in the Gonarezhou in 1971/72 was, actually, the first proper ‘population reduction exercise’ ever carried out in Africa.

Its only fault was that we did not have our carrying capacity numbers right. Elephant culling operations there have been aplenty but never before had a proper population reduction exercise been attempted.

Because I recommend that elephant population reduction should the management strategy applied in both the next Kruger and Hwange elephant management programmes, and throughout the KAZA TFCA in Botswana, it would be appropriate to mention how the Gonarezhou elephant population reduction exercise was implemented and what was achieved in the process.

The Gonarezhou exercise was conducted in two parts: one a month-long-exercise during the dry season of 1971 and another one with exactly the same dimensions in 1972. Both exercises allowed us to reduce the elephant population from 5000 to 2500 inside 1 x 2 months.

We had a three-man-shooting-team comprising government game rangers who were highly experienced elephant hunters. They were armed with military 7,62 mm, NATO, self-loading-rifles equipped with magazines carrying 20 rounds each.

And we approached the big breeding herds from three different sides.
Shooting commenced when we saw that one of the elephants had seen us and that it realized that the herd was being surrounded. And that elephant was the first one to be dispatched.

Thereafter, at literally point blank range, simultaneously, we shot every elephant in the herd. All shots were clean brain shots. No elephants were wounded. No elephants escaped the slaughter. Every elephant in every herd was accounted for.
The shooting was very slick!

Often we were able to eliminate groups of between 30 and 50 animals at one go, and the shooting time to accomplish that fete was, regularly, just 60 seconds or less. And we rarely used all 20 rounds in our respective rifle magazines.
We operated every day and killed, on average, 41.6 elephants per day.

The piled-up dead elephants were pulled apart using tractors and chains. This facilitated the numbering, measuring, dissecting and processing of each carcass.

Each carcass was given an individual number and the herd that it was a part of, was awarded a letter of the alphabet. So, on its record sheet, an individual animal would be given an identifying number such as, for example, G-13. And all its biological data was recorded on a table of information on one sheet of paper under that reference number.

All biopsies were conducted in the field not in an abattoir. Indeed we proved that abattoirs are not necessary when conducting even a very large population reduction exercise on elephants.

Biopsy information included:

• The sex of the individual

• Its bottom jaw intact

• Its shoulder height

• Its calculated weight

• Its two tusk weights and measurements

• The weight of its one kidney together with the weight of the fat-cap on the kidney’s crest. This was used to obtain each animal’s condition index.

• A testical slice, taken from every young male animal in the herd and preserved in formalin. This was used to determine when young bull elephants started to produce viable sperm.

• The results of an ovary inspection from every pubertal female in the herd. This was to determine when the young females started to ovulate. Ovulation was easy to confirm because when an ovum was released from the ovary into the uterus, before being fertilized, it was replaced in the ovary with a ‘yellow body’ (a corpus luteum) that was easy to detect.

• The uterus in every mature female was cut out and split open along its length and along both its arms. The internal lining of the uterus was then scraped clean and examined for uterine scarring. Every time a cow elephant fell pregnant the fertilized ovum attached itself to a virgin place on the uterus wall and there it grew into a new calf. The placenta that grew out of that ovum developed into an umbilical cord. And after the calf had been born, at the umbilical-cord-attachment-site it left an indelible broad scar across the uterus wall. And by counting the scars it was possible to tell how many calves each adult cow had given birth to during her life-time.

• A number of elephant hearts were collected and checked for multiple sclerosis scarring. Samples were collected and preserved from those hearts that showed damage.

• Body organs were checked for disease and internal parasites. Samples were collected.

• Skins were checked for external parasites. Samples of everything were collected.

• Tusks were punch-stamped with the elephant’s serial number. They were recovered from the carcass, washed, scraped clean, weighed and stored.

• The bottom jaw of every elephant killed was collected and boiled clean of all flesh. They were immediately tagged with the elephant’s serial number which was stamped onto a thin metal plate. The condition of the animal’s dentition was examined and – in the months ahead – its age was accurately determined.

• Finally, the front head-panel skin and the skin of the trunk was removed in one piece.

• The ears were removed separately – skinned and salted.

• Finally, the animal carcasses were skinned in panels; top front leg; middle-body panel; and top back leg. And all the edible meat on the upper side of the body was removed.

• The carcass was then turned over and the skin was removed in panels from what had been the bottom side of the carcass, and the bottom carcass meat was removed.

• All the guts and the bones were then shoveled into a giant eight feet deep and
25- 30 feet long common grave (excavated with a large front-end-loader); and, when full, it was covered over with the excavated soil. The reason for the burial was to avoid the possibility of anthrax (a transmittable disease that was endemic in nearby Kruger National Park) being introduced to the Gonarezhou via vultures.

These procedures were repeated every day of every week that the population reduction programme was in operation. It was, to say the least, a HUGE job that required a whole cohort of research biologists and their well trained assistants, a fleet of heavy duty vehicles and tractors, a large front-end loader; and an army of labourers to carry out all the manual tasks that were necessary.

The hides were striped clean of flesh, heavily impregnated with crushed salt, and stacked in the shade of giant tarpaulin tents. It was discovered that the value of the elephant hide was infinitely greater than the value of the ivory that was collected.

The meat was machine-cut into two-inch square strips all some 12 to 15 inches long. And after an hour or two of ‘pickling’ in salt, the pieces were laid out on (hundreds of yards long) chicken-wire table-frames to dry out in the hot sun. It was cured inside a period of three days, bagged, and sent out of the national park for sale as human rations to mining companies and farmers. Our elephant meat product was a very palatable, wholesome and inexpensive source of meat protein. THIS was the way the country’s indigenous people cured their own meat. So, it was very well received.

The elephant bulls, which are a whole lot more skittish and more difficult to hunt than the cow herds, were treated differently. Each of the three hunter-game-rangers in our programme hunted down the big bulls, individually, or in small groups, using standard heavy caliber big game hunting weapons. And we tried to match the number of adult bulls we shot in this manner, with the number of adult cows that we had removed from the breeding herds.

After 1972, the Gonarezhou’s elephant population (which was at that time doubling its number every ten years) recovered very quickly. And it was necessary to conduct a similar population reduction exercise on these same elephants in 1982.
There was also a major die off of elephants (and other game) in the Gonarezhou during a very severe drought in 1992. Since then this game reserve’s elephants have been left unmanaged. And today the Gonarezhou elephants number 14 000 which is fourteen times the game reserve’s estimated elephant carrying capacity!

I would like readers to imagine what happens to the habitats in a very arid game reserve like the Gonarezhou, which is currently continuously carrying an elephant population that is 14 times, and more, the size of its sustainable elephant carrying capacity!

With my kind regards,

Ron Thomson CEO – The True Green Alliance of South Africa.




Ron Thomson

I am NOT a ‘trophy hunter’ - and never have been. I am not involved in the trophy hunting safari business. I am also not a game rancher. But I have ‘administratively controlled’ professional hunters and safari outfitters in my capacity as a government game warden. I am an 80 year old ex-game warden with 60 years of continuous experience in hands-on wildlife management, and national park management, in Africa (1959 to 2019). In breakdown, I have 24 years experience in the management of national parks in Rhodesia/Zimbabwe - and in the management of the wild animal populations that lived inside those national parks; one year as the Chief Nature Conservation of the Ciskei in South Africa; three years as Director of the Bophuthatswana National Parks Board in South Africa; and I worked for three years as a professional hunter in the South African Great Karoo (taking foreign hunters on quests for plains game trophies). I discovered, however, that professional hunting was not my forte. I worked as an investigative wildlife journalist for 30 years in South Africa. I have written fifteen books and hundreds of magazine articles on the subject of wildlife management and big game hunting in Africa. Five of my books are university-level text books on wildlife management. I am a university-trained ecologist; was a member of the Institute of Biology (London) for 20 years; and was a registered chartered biologist for the European Union for 20 years. I have VAST experience in the “management hunting” of elephants, buffaloes, lions, leopards and hippos (as part of my official national park work in the control of problem animals); and I pioneered the capture of black rhino in Zimbabwe’s Zambezi Valley (1964 - 1970). My university thesis was entitled: “The Factors Affecting the Survival and Distribution of Black Rhinos in Rhodesia”. Look at my personal website if you want any further details about my experience:

Ron Thomson has 271 posts and counting. See all posts by Ron Thomson

One thought on “Comment on the USFWS Submission

  • Excellent submission but you left out Botswana where the populations are not only permanently devastating the environment but are encroaching densely populated settlements!


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