Sumsaren Lion and Game Reserve
P.O. Box 344
Groot Marico. 2850
North West province
South Africa.
E-mail: gamelodge@sumsaren.co.za
Tel: (27) 83 327 5464
Fax: (27) 86 676 7566
January 16, 2014
The Honorable Daniel Ashe
Director, United States Fish & Wildlife Services
Department of Interior
1849 C Street, NW
Washington, DC 20240
Dear Mr. Ashe,
USFWS possible listing of Lion as “endangered”
As a Lion breeder and keeper of Lions in South Africa (S.A.) please allow me to convey some very relevant information about the captive breeding and hunting of Lions to you and your committee that could have a significant impact on USFWS ultimate decision to “list” or not, the African Lion under the endangered species act (ESA).
It was with particular interest that I have received and read a letter outlining a shortened version of the invitation-only workshop held on Wednesday 26 September 2013 at the head office of USFWS in Arlington, Virginia. The author of the note mentioned that “on a direct question from John
Jackson (Conservation Force) to the Director of FWS if there would be any different consideration given to captive-bred Lions versus wild Lions with regard trophy importation to the U.S. the answer was “No”. “All Lion trophies would be banned from import”. The author continues by stating “it would be pretty obvious why they would do this, as from an enforcement standpoint the
USFWS would have no way to tell that a Lion trophy had originated from a “wild” versus “captive” source”.

This (above) viewpoint regarding the apparent “un-traceability” of a captive bred Lion suggests that you may be lacking information that is highly relevant to this very significant matter currently serving before you. Therefore please allow me to address the above as well as other points which
I believe will and must have a profound impact on the ultimate decision of whether or if so, then how lions may be listed on the ESA.
In this debate regarding status of the African Lion as a species, no doubt much has already been said about the free roaming wild Lion population. Allow me to therefore only focus on the Ranch
Lion as this is my area of expertise.
THE RANCH LION:
THE TRACEABILITY, FINANCIAL and CONSERVATION SIGNIFICANCE TO SOUTH AFRICA.
Ranch Lion’s Traceability. I am of the opinion that the below described process for SA ranch lions would be very similar to the US regulations on hunting a deer. It is my understanding that it is just not possible to simply go out and hunt a deer in Yellowstone National Park for example, and take the trophy to a taxidermist for taxidermy work claiming that the deer has been hunted legally.
Similarly, it would be impossible in SA to take a Lion trophy to any Taxidermist to be worked on or shipping agent without all the supporting documents required to legally hunt a captive bred Ranch
Lion. The application process is a comprehensive one and quite lengthy to ensure that the trophy in question is in fact a captive bred Lion that has been hunted legally and that all the supporting documents are in place to form a complete paper trail.
1: Traceability by means of various SA Government legislations.
a) Keeping and breeding of ranch Lions: Before any person (potential breeder) may keep a lion(s), a comprehensive environmental impact assessment as well as a Management plan must be presented to the state. Once approved, a specific and unique keeping permit number is allocated which must be quoted on all correspondence with the state or client.
No Lion whatsoever can be moved to or from enclosures or anywhere else without a transport permit accompanying the animal at all times. Such transport permit and hunting permit and keeping permit must at all times reflect the unique keeping permit number. b) Hunting destination: Application must be made to the Government to move a lion from the breeding facilities to the hunting destination. All Lion hunting destinations of which there are less than 30 in SA are also a registered Lion hunting Destination and are not allowed to be on the same property where the Lions are kept and bred. Transport permit from breeding facility as well as the hunting permit will again display the keeping and breeding as well as hunting destination permit number and relevant information as in (a) above. Relevant information on the hunting permit (hunting tag) would be Hunters country of origin, passport

no, clients home address, outfitter information, PHs detail, Taxidermist and/or shipping agent information etc. c) Outfitters log book & Professional hunters log book: No person may operate as a hunting outfitter or Professional hunter and therefore take foreign hunters on a hunt if he/she is not registered with the authorities as a hunting outfitter or Professional Hunter. Both these individuals have government log books that must be completed indicating also clients detail, as well as farm where hunt has taken place, Lion was moved from (name) to (name) with permit numbers in place. A carbon copy (not Xerox) of the mentioned log books must be send to Dept of Nature within 7 days of the finished hunt. Only additionally qualified and registered as such “dangerous game” Professional hunters may take a client on a Lion hunt.
d) Taxidermist: No Taxidermist or dip and ship agent or shipping agent may accept any trophies to be processed without all relevant information attached indicating all the clients as well as outfitters and PH’s detail. Taxidermist applies further to the state for a release document before any work may be processed for export. The state will only issue a release document if they can complete the circle by tying up the outfitters and PH log book copy as in (c) above.
2: Traceability by means of Micro Chipping .
The South African Predator Association (SAPA) has already embarked on a program to Micro chip all its members’ Lions; “chip” numbers will form part of the above-mentioned paper trail process. Furthermore, it is already a prerequisite in the Free State Province that all Lions residing in that province must be micro chipped and registered with the relevant Gov.
Department. Lions not chipped and pre registered will have no value and will thus be unsellable.
From all the above it is thus clear that a Ranch Lion that was hunted coming out of a captive breeding program in South Africa is without a doubt traceable and cannot be confused with a free roaming Lion originating from within or outside of South Africa.
Ranch Lion’s FINANCIAL SIGNIFICANCE:
1. Ranching operation: Ranching with Lions is a pure farming operation similar to Farming with Crocodiles, Ostrich, Buffalo and Sable. Farming and thus the producing of Lions for the hunt market is driven by market forces of supply and demand, thus no farmer will hunt his last Lion and have no income for the next year.
2. Absolutely sustainable: Ranch Lions are well looked after and cared for. Ranch lion farming and hunting is highly competitive, thus quality of the trophies is crucial to ensure satisfied clientele. Quality animals require significant investment, thus the long-term marketing strategy is based on supply and demand for sustainable quality export product. Lions are kept in state of the art keeping facilities to ensure a healthy, quality and sellable “product”.
3. Employment vs. unemployment: It is estimated that there are 7,000 captive bred Lions in
South Africa at present. For every 5 Lions the rancher would employ one worker specially

trained to work in and around the Lion enclosures. For every 6 workers there would be a
Lion enclosure manager. In total this would calculate to 1633 employees that worked in and around the enclosures in the captive bred Lion industry. In Africa the Individual’s dependant on a worker are around 10 to 1. This ratio could include wife(s), children, grandparents, siblings and even extended families. This brings the number of people directly affected by the keeping and breeding of Ranch Lions to 16,330 people. Please
Note that I am not dealing here with the greater unemployment impact such as hunting guides and Professional hunters and tour guides and taxidermy staff, fuel usage, rent vehicles, lodging staff etc on the SA economy. At his stage I am merely pointing out the number of people that will be directly affected in South Africa alone. Keeping in mind that we are referring to a country with an already unemployment rate of 40%.
Adding the other mentioned sectors that will be affected; the number of people losing their jobs could easily rise to 40,000.
Of the approximately 7,000 lions currently in captivity throughout SA, Lions are kept and bred for mainly two reasons, being:
1: Tourism: Tourism would be to show Lions and (possible) walk with lions, petting cubs etc.
2: Hunting: Due to the subject matter I am exclusively dealing here with the hunting of Ranch lions and thus the estimated (as best possible) accompanying financial significance. It is estimated that
1,000 Ranch Lions were hunted in SA during 2013. The estimated average price for a male Lion was USD$15,000 and for a female USD$7,000 (vary between outfitters) representing approximately USD$11,000,000 of export revenue coming into SA for export products. This does not include shipping agents, taxidermy, lodge staff, hunting staff, hunting guides, the additional plains game hunted, the meat supply to local communities, PHs and their staff, skinners, trackers, lodging staff, fuel usage, hand crafted curios bought, taxidermy staff, dip and ship agents and their staff, and the shipping agent and its staff. Considering the spin-off industries as quoted above, and additional plains game that will be hunted during the Safari, the monitory value coming into
SA could easily be tripled bringing the estimate to a total of USD$33,000,000. In terms of SA
Rand, this is an enormous amount of desperately needed revenue, export products and jobs, all obtained and provided through a carefully monitored, sustainable industry that is at the same time contributing to conserving wild roaming African Lions.
Ranch Lion’s CONSERVATION SIGNIFICANCE:
Statement by S.A. Government:
“The SOUTH AFRICAN GOVERNMENT recognizes that the breeding of Lions in captivity does not threaten our wild Lion populations or bio-diversity conservation. Government is further of the view that the hunting of such [Ranch] Lions is sustainable ”.

The Professional Hunters Association of South Africa (PHASA) also concur to these positions and has, on their AGM, November 16, 2013 acknowledged that hunting of captive bred Lions will remain part of the South African Hunting Industry.
In addition to the above I want to draw USFWS attention, for consideration in the matter, to a recent court case in South Africa involving the Minister of environmental Affairs v South African
Predator Association (72/10){2010} ZASCA 151
(29 November 2010)……….The Supreme court of appeal stated that:
1: The breeding of Lions in captivity (Ranch Lions) plays no role in the conservation and survival of
Lions as a species.
2: The destruction of captive-bred Lions has no bearing on the survival of Lions as a species;
3: The breeding and hunting of captive-bred Lions (Ranch Lions) does not contribute to biodiversity .
In conclusion of the court’s verdict
:
“The two principal purposes are the management and conservation of South Africa’s diversity and the protection of the species and ecosystems. More specifically, s 57(2) of the act, empowering the minister to prohibit the carrying out of any activity involving a threatened or a protected species provided that he or she may only do so if that activity is of a nature that may negatively impact on the survival of that species. The specific condition for the exercise of a prohibiting power is thus one which serves for the protection of that species…The Minister failed to demonstrate that CAPTIVE - BRED lions…”may negatively impact on the survival of that species”.
I am therefore of the opinion that the above would also be a true reflection of the matter serving before USFWS in so far as the possible listing of the African Lion (without clear distinction as
Ranch Lions) onto the US Endangered Species Act.
Other Points of Conservation Value:
1. Bone trade: If the import of Lion products is indeed banned from entering the US this action would effectively wipe out the captive bred Lion industry in SA. Up to as much as 80% of
Lions hunted in South Africa per year are hunted with American clients. There would thus be hardly any financial incentive left for the South African Rancher/breeder to “ranch” with lions, as the return on investment to ranch with Lions, due to the much smaller market demand, would just not be there. It is furthermore a known fact that there is a demand for
Lion bones just as there is a demand for Rhino horn. The individuals, predominantly from the east, wanting Lion bones, like the ones wanting Rhino horn (for whatever reason) will, irrespective of price, irrespective of legal consequences, irrespective of possible extinction of the species or irrespective of the risks, pay large sums of money to get their hands on
Rhino horn, and to a lesser degree Lion bones. The only Lion bones that will then be available for those individuals that desperately want it will be on the black market, coming out of the wild Lion populations throughout Africa. This will then result in innumerable slaughter of the African Lion for the trading of its bones on the black market and put the
African Lion on the same path to extinction as our Rhino
’s are facing at present.
2. Our Rhinos in SA are been slaughtered because it is currently “illegal” to hunt a rhino.
There are people out there in the world that wants the Rhino’s by-products and they will

pay anything for it. Due to this
“hunting ban” on Rhinos there is currently no incentive to ranch with Rhinos any more and Rhino owners are trying to “on sell” (get rid of) their Rhinos due to the high risk of keeping them and while they can still get something for them. Rhino numbers are declining daily. A Listing of “endangered” for
Lions now by USFWS equates to a ban and will put the African Lion on the same path to destruction.
3. I firmly believe that the hunting of sustainable ranch Lions contribute GREATLY to the survival of the free roaming African Lion. Ranch Lion hunts are in FACT saving a free roaming Lions elsewhere in Africa, ensuring the Lions’ future. The American icon Ted
Turner has proved this concept to work as far back as 2002 and one should ask, are we not trying to please some parties where there is no need for that or are we trying to reinvent the wheel. Allow me to very importantly quote out of the US own back-yard referring to Ted’s Montana grill and the
AMERICAN BISON
. “ At Ted’s we strive to do the right thing for our guests, our people and the planet. This began when our founders pioneered the effort to preserve the American Bison by returning it to the American table. “( it means killing the Bison
)
“They not only saved the species from extinction, they built a restaurant serving Bison on its
Menu.” Ted’s, furthermore, quote ; “in doing this it creates incentives for ranchers to grow their herds.
”
Conservation by utilization:
Here the American Bison project and in particular the Ted Turner restaurant group comes to mind again as the Bison
’s being killed for the 44 Restaurants in 16 states are Mr. Turners private stock and property. It belongs to him and he can ranch (farm) with them as he wishes so long as he
(obviously) does not contravene the animal welfare legislation. For 44 Restaurants, one must kill a substantial amount of Bison per year and this must mean that he is doing it in a sustainable way otherwise ….He will have no stock left for tomorrow and next week and next year.
A fact that must not be overlooked is the killing of Turner’s own, (thousands) of Bison per year has absolutely nothing to do with the only 20, 000 “vulnerable” or “red list of threatened species” that distinguish wild Bison herds. I salute Ted Tu rner for his far sightedness and …very important, his indirect (so often overlooked) contribution, in the process , to the welfare of free roaming
Bison
.
If we now have an understanding and agree that Mr. Turner may sell his own Bison to the market demand that exist and that these actions do not at all impact on any free roaming Bison then
Ladies and Gentleman allow me to sell my sustainable, well cared for Lions to the market demand. Allow me to also “actively grow my herd (pride)” in exactly the same fashion as what
Mr. Turner does with his Bison. Allow me to also “ pioneer the effort to preserve the African
Lion ”. Mr. Turner and I are both supplying a market demand with our own product that we have successfully and sustainable produced ourselves now and for long into the future. The selling of both our products has ABSOLUTELY NOTHING to do with the well being of the Bison in
Yellowstone National park or the Lions in Kruger Park or Zambia or in Botswana. Quite the contrary….every Lion hunted from my stock, might just save the life of a Lion in the wild.

I am therefore of the opinion that an endangered listing of the African Lion that includes SA Ranch
Lion will have massive consequences across the board for the African Lion and its existence elsewhere in Africa.
Bison are been legally killed and this action is saving the species and in fact growing the species.
I urge you therefore to reconsider your possible listing of the Ranch Lion and in assisting you with that decision I would like to personally present USFWS with some additional insight in the matter by way of a scheduled meeting
– should you wish.
A fact finding visit to the South African captive bred Lion industry by your team would also be advisable and once here in SA I can schedule a comprehensive Itinerary that will include
Government departments to familiarize yourself with the processes in place and set your mind at ease regarding the ultimate Conservation of Lions by the utilizing of Ranch Lions.
U.S. Endangered Species Act : I am also aware that the US Endangered species act allows for a section of a species to be classified as a “distinct population segment”. This would effectively mean that USFWS can use “Distinct Population Segment” listings to customize sections of a listed species by rem oving or reducing the Endangered Species Act‘s protection for a part of a listed species such as the “South African Ranch Lion”. In my humble opinion, the use of “ Distinct
Population Segment ” would seem to fit this situation well, and provide for a clear understanding and appropriate terms of management, including hunting, for captive bred Lions originating from and held in SA in terms of the Endangered Species Act and its regulations.
On a lighter note : I want to quote what a fellow breeder has said last month during a Lion discussion with pure academics. After a vocal interaction between parties, he said, “ Why is it that the arm chair academic conservationists living in the city and has made no capital investment of their own or has never stepped into Lions dung, always has the most to say about Lions”.
I have invested millions of $ into the species (my own stock), I step into my Lions dung daily. I invite you and plead with you to listen to the African Lion Rancher that work in the Lions den and step into the Lions dung daily.
Anybody that wants to talk about Bison must talk to Ted Turner; he has made the $ m investment into the species, he has more than academic knowledge, he looks after and cares for his Bison daily. You want to talk about Lions then talk to the African Ranch Lion breeder, he has more than academic knowledge, and he also has Lion dung under his toes.
I thank you for the time and willingness to listen to a Lion Rancher dealing with and caring for
Lions daily.
Sincerely
J.N.J. (Koos) Erasmus
Sumsaren Lion Ranch: South Africa