BRIEFING DOCUMENT: Sustainable Use, Rural Communities and Livelihoods

SUMMARY OF WORKING DOCUMENTS SUBMITTED TO CITES CoP18

CoP 18 Doc. 11 Review of the Convention (Democratic Republic of Congo, Namibia, South Africa and Zimbabwe)

SUMMARY OF RECOMMENDATIONS

Document 11 does not contain draft Decisions or Resolution text but makes a series of recommendations:

1. Review of the Convention

1. Undertake a comprehensive review of the Convention with the aim of “improving the equitability of the Convention with regards to the role of people and States to be the best protectors of their own wild fauna and flora and the rights of rural communities and indigenous people over their own natural resources which include wild animals and plants”

• Output of the review should includeproposed amendments to Resolutions, Decisions and the Strategic Vision of CITES and/or proposals for a new Protocol and/or an Addendum to the Convention or, as a last resort, proposed amendments to the Convention

• Mandate the Standing Committee (SC) to establish a process to set the scope and TORs of the review

• CITES and the WTO

1. Commission a study on “the inherent contradictions between the GATT and CITES” with the aim of identifying measures to better harmonize the underpinning principles of international trade and conservation and the obligations of the Parties to these two agreements
   1. Request the WTO to provide expertise and other resources to work together with a representative working group to be established by the Standing Committee on the study
   1. Secretariat to develop modalities for the study for consideration by SC at its first meeting after CoP 18

• Regarding review of the Appendices

1. Revisit and prioritise revision of the Appendices to make sure that species and “their geographically separate populations” (especially Appendix I species) are correctly included in the Appendices in compliance with the criteria adopted by the Parties in Resolution Conf. 9.24 (Rev. CoP17) 

• Contract IUCN or other competent body to carry out an urgent and comprehensive review of the listing of species (and/or geographically distinct populations) and report to CoP20 in a manner that would enable the Conference of the Parties to correct inappropriate listings of species in the Appendices in one session

1. Regarding Resources

Request financial assistance from Parties and “cooperating partners.”

POTENTIAL IMPACT

The recommendations in Document 11 would tie CITES up in unnecessary, expensive, time-consuming and impractical reviews and studies aimed at promoting trade and national sovereignty, paralysing the convention and weakening it irrevocably.

• Review of the Convention: the proponents aim to re-shape CITES (through potential amendments to the Convention, and/or Resolutions, Decisions, Strategic vision, a new Protocol or Addendum), seeking to prioritize consumptive use of wildlife and increase the power of individual States (as “the best protectors of their own wild fauna and flora”). The proposal would compromise multilateral decision-making by giving individual Parties veto power over listings and decisions concerning their national populations (the implication from the proposal is that the CoP should not be able to reject a proposal from a country to down-list their own populations. Currently they are forced to accept “unwanted restriction[s] on trade”). The supporting statement suggests that the motivation for the proposed review is to enable governments (and rural communities) to “realise the full economic value of their wildlife resources.” Recognizing the rights of Indigenous peoples, rural and local communities, and supporting community-based conservation initiatives that work is vitally important, but the proponents use this to cover a nationalistic pro-trade agenda. They seek to fundamentally change CITES, taking no account of governance challenges or unpredictable market forces that vary significantly from one species to the next. Their proposals place wildlife and communities dependent on healthy ecosystems at enormous risk.

This proposal promotes greater unilateralism in the conservation of endangered species with less oversight from the international community. This will reinforce the tendency to weaken multilateralism in the establishment of goals and objectives of environmental stewardship at a time when it is most needed. While the Convention preamble recognizes States as the best protectors of their resources, it also recognizes that biodiversity is irreplaceable and “must be protected” and that international cooperation is essential. Document 11 prioritizes national sovereignty over natural resources above all other objectives, which are ignored.

The proposal would create a damaging precedent in international environmental law, and directly contradicts Rio Principle 7, which states that while national sovereignty of natural resources is a recognised principle of international law, it should not be relied on to undermine the spirit of global partnership required to conserve, protect and restore the health and integrity of the Earth’s ecosystem.

• CITES and WTO: the proponents are trying to resurrect an old debate that CITES is incompatible with the GATT (the free trade agreement that is part and parcel of the WTO agreements), and potentially use the GATT to undermine and redefine CITES. This issue has long been settled. Any potential contradiction between GATT and CITES would likely be resolved in favour of CITES since the most recent law prevails and both agreements contain legal provisions that accommodate the other (GATT Article XX and CITES Article XIV) so there is no conflict of law. The absence of any trade disputes based on the inconsistencies alleged in Document 11 speaks for itself.

Document 11 calls for a study of the relationship between CITES and the GATT with the implied objective that it should evaluate how CITES should maximise and enable trade, rather than to conserve threatened species.

The question of relations between CITES and WTO in the context of “sustainable trade” needs to take into account the set of very thorny issues related to production processes and their trace in final products. This is something that will come up when determining if production processes (or harvesting methods) are or not “sustainable”. Trade disputes on the application of Article III of GATT show this is something that the proponents have not taken into account. Disputes on forest products and dolphin protections required of the tuna industry show this road would be plagued by constant disputes. Adjudication will be very cumbersome and expensive.

On its face, GATT appears to have provisions that benefit developing countries, but in practice that is not how the agreement has operated. It has benefited large multinational corporations and their investments. To emulate this model would take CITES down a path of trade liberalization contrary to its objectives and benefit big players in the wildlife trade business.  Such a system would not benefit Indigenous Peoples, rural or local communities. 

• Review of the Appendices: a rapid review by IUCN of all listings would result in complete revision of the Appendices at CoP20. Apart from being unrealistic given that there are 36,000 listed species, the proposed review would be hugely expensive and lead to listings already decided by the CoP being over-turned through an ill-conceived fast-tracked process.

The objective of the proposed review appears to be a way of circumventing the current rules in Resolution Conf. 14.8 (Rev CoP17) on the periodic review of species, which excludes species that were the subject of listing proposals at the 3 previous CoP meetings (i.e. elephants) from review. The proposal’s emphasis on the need to make sure that “geographically separate” populations are correctly included in the Appendices, appears to be a way to re-open CoP decisions on every species. Given recent findings noted above that it takes CITES 12 years to protect species once identified as at risk and that over 271 species identified by the IUCN as threatened by intentional use and which are traded internationally are not protected by CITES (Frank and Wilcove, 2019), Parties should focus on species that are not protected, and how to speed up the listing process, rather than attempting to reopen discussions on listed species.

As phrased, this review is likely to lead to and add to the pattern of split-listing for species as a generalized practice of the Convention. Split-listing is a problematic policy, particularly for migratory species. This is recognized in the recommendation to avoid split-listing in Resolution Conf. 9.24 (Rev. CoP17) in view of the enforcement problems it creates, making it more difficult to combat illegal trafficking.

RECOMMENDED POSITION

Review of the Convention: OPPOSE

Rationale

• These recommendations challenge the integrity of the Convention and the Appendix listings and, given the context of the supporting statement, constitutes in effect an attempt to re-write the Convention, circumvent decisions of the CoP and re-define the objective of CITES to promote “sustainable trade” rather than preventing trade from threatening the continued existence of species in the wild.

If approved, this proposal would weaken CITES, promote unilateralism over multilateralism, and potentially transform it into a forum for promoting trade. The world is facing a biodiversity crisis unprecedented in human history. Around one million species are facing extinction, with direct exploitation, including trade, the second biggest driver (IPBES Global Biodiversity Assessment). CITES is the most effective multilateral tool we have to combat this crisis. Now more than ever we need to strengthen international cooperation and ensure CITES is properly implemented and enforced through good governance, not trade promotion.

The Convention is designed to promote cooperation and protect wild fauna and flora from over-exploitation from trade. Attempting to diminish cooperation, generate conflicts with GATT, and undertake a review designed to prompt numerous split-listing of CITES-species will take CITES in a direction that conflicts with its core objectives.

Underlying the proposal is an implication that a definition of “sustainable use” is needed. However, there is no appreciation of the complexities of such a task. The Convention already has non-detriment findings (NDFs) to determine whether trade proposals threaten a species. And CITES already recognizes the CBD’s Addis Ababa Principles and Guidelines for the Sustainable Use of Biodiversity. Forcing CITES to adopt its own definition would be fraught with pitfalls and undermine the existing synergy between these two Conventions.

The document also fails to consider fundamental governance challenges and market forces, including the existence and relevance of illegal trade and trafficking of wildlife. It assumes that illegal activities would simply disappear if all forms of wildlife become commodities ready for commercial exploitation. The presumption is unrealistic whether you look at it from an economic, legal, or governance perspective.

CITES and WTO: OPPOSE

Rationale

There is no intrinsic contradiction or inconsistency between CITES and WTO. The WTO enables the restriction of trade on environmental grounds under GATT’s Article XX. On the other hand, Article XIV of CITES states that nothing in the Convention affects the provisions or obligations deriving from treaties or agreements on international trade. Thus, both CITES and WTO contain the legal instruments affirming and recognizing their consistency. This has long been recognized and the debate resolved. It is not in the interest of CITES to resurrect it, especially not with the aim of emulating the WTO model, which benefits large multinational corporations and their investments. It would take the convention down a path of trade liberalization contrary to its objectives, benefitting big players in the wildlife trade business. 

Review of the Appendices: OPPOSE

Rationale

The proposal calls for a full-scale review of CITES listings between CoP18 and CoP20 that rejects the current review rules and systems. Apart from being unrealistic, it would re-open CoP decisions on numerous listings and entrench a pattern of split-listing species. Split listings are discouraged under CITES rules because of the enforcement issues they create. As we have seen with elephants, they generate a host of other problems, especially for trans-boundary and migratory species. Given the extinctions predicted by IPBES now is not the time to revisit listings with a view to increasing trade through a fast-tracked ill-conceived process that circumvents CoP decisions and established CITES’ review processes.

CoP18 Doc. 17.1 Engagement of rural communities in the CITES process (Report of the Standing Committee)

SUMMARY OF RECOMMENDATIONS

1. Standing Committee

The CoP is invited to consider whether the Standing Committee should be directed to continue the work on how to engage rural communities in CITES processes and report to the Conference of the Parties at its 19th meeting.

1. Secretariat

Suggests amending Resolution Conf. 16.6 (Rev. CoP17) on CITES and livelihoods by inserting a new sub-paragraph 3. a) i) and ii) [and consequent re-numbering of the existing sub-paragraphs] 

1. taking account of the impact of the measures proposed on rural communities that may be affected by them, when preparing and submitting proposals to amend the Appendices, draft resolutions, draft decisions, and other documents for consideration at meetings of the Conference of Parties and when reviewing such documents submitted by other Parties; 
2. including representatives of rural communities that may be affected by the proposed measures in official national delegations to meetings of the Conference of the Parties. 

POTENTIAL IMPACT

SC proposal on continuing its work: The intersessional WG had a mandate to consider how to effectively engage rural communities in CITES processes. An unrepresentative group was constituted by the Chair Namibia that excluded Observers (other than a hunting organization, Conservation Force). Among the options considered was the establishment of a permanent rural communities’ committee or sub-committee as an official CITES body. However, consensus could not be reached. Continuing the work of the working group or bringing this issue back to SC would be unlikely to resolve the lack of consensus and disagreements concerning a rural communities’ committee.

Secretariat proposal to amend the livelihoods resolution, Resolution Conf. 16.6 (Rev CoP17):

• New paragraph 3 a) i): if adopted, this provision would introduce socio-economic considerations or even impact assessments for every document submitted to CITES conferences. Although Parties’ are given some discretion (through “as appropriate” in the chapeau of para 3), taking account of impacts on rural communities when preparing listing and up-listing proposals could potentially result in proposals being blocked because of the perceived negative impacts on rural livelihoods even though that use may be what is threatening the species. Similarly, taking account of potential impacts on communities in proposals to amend Resolutions and Decisions for consideration at CoP meetings could prevent action under CITES such as trade restrictions to prevent over-exploitation.

• New paragraph 3 a) ii): encouraging the inclusion of representatives of rural communities in national delegations raises questions of equitability among stakeholders. It could also afford some constituencies (those defined or identified as “rural communities”) disproportionate access, disadvantaging vulnerable minorities (such as Indigenous Peoples who may not be considered for inclusion due to their categorisation).

RECOMMENDED POSITION

OPPOSE the renewal of the SC intersessional working group. If it is renewed, insist that it should be representative of all CITES stakeholders, include CITES Observers, and ensure equitable representation from Parties,  rural communities,  Indigenous Peoples, and other stakeholders. Due to the controversy surrounding the discussions on terminology within the working group, and the legal implications of the different terms in some countries (Indigenous Peoples in particular) it is imperative that a common understanding is agreed by the CoP of what constitutes a ‘rural community’.  The accepted and better defined terminology used in other international fora is: local communities and Indigenous Peoples. This is a more inclusive term.

Rationale

• The working group lacked regional balance, excluded Observers (except for a hunting organization), and included relatively more communities from Southern Africa compared with other regions (see below under CoP18 Doc 17.3).

• The group could not come to consensus on how to engage rural communities in CITES. When the report was discussed at the 70^th meeting of the Standing Committee (SC 70) a significant number of Parties opposed the establishment of a formal mechanism for engagement of rural communities, and emphasized that CITES is a treaty between national State Parties, and while input from Observers representing different interest groups, including rural communities, is critical to ensure the best possible outcomes, ultimate decision-making power rests with governments.

• CITES discussions use the term ‘rural communities’ without there being a common understanding of who is included. It has been used by CITES to refer to different categories of stakeholders, such as Indigenous Peoples and local communities, as well as communities with different levels of social and economic power. In reality, rural communities are not homogeneous blocks of population, and not easily defined, raising the fundamental question of how to frame legitimate representation. There can be considerable social, cultural and economic differences among communities sharing a common landscape; power and resources are not distributed equally even within a community. Especially where poverty, food security, and other factors affect community members, economic pressure can weaken local institutions and social tissue and lead to easy manipulation of existing power structures. This inequality creates intractable problems with creating a legitimate or genuine representation model. These issues need to be taken into account to ensure legitimate, equitable and representative engagement of rural communities in CITES based on a common understanding of what constitutes a ‘rural community’.

• Other multilateral environmental agreements (MEAs) provide for engagement from Indigenous Peoples and local communities (IPLC) through official Observer status, allowing them to intervene from the floor and participate in working groups. In addition, the Convention on Biological Diversity (CBD) supports the Indigenous Peoples’ Forum on Biodiversity, while the United Nations Framework Convention on Climate Change (UNFCCC) supports a Local Communities and Indigenous Peoples Platform. However, these are not permanent Committees with decision-making powers as was proposed, but not accepted, in the SC intersessional working group (see below under CoP18 Doc 17.3).

• Under CITES, the Observer process is available for all stakeholders and is already used by organizations representing local communities. CITES should encourage the further engagement of rural communities in coherence with other MEAs, including by encouraging and facilitating the application by representatives for official Observer status and enabling them to exchange views and input more effectively at meetings through an informal forum.

OPPOSE the Secretariat’s proposal (new paragraph 3 a) i)) to amend the livelihoods Resolution to take into account impacts of measures proposed on rural communities that may be affected in all proposals and documents submitted to CoP meetings.

Rationale

• Even though Parties are given some discretion, taking into account socio-economic factors could act as a deterrent and prevent the listing of species negatively impacted by trade, and inhibit actions through resolutions and decisions to protect them. Listing decisions are about species’ survival. They should be based on the scientific and precautionary criteria in Resolution Conf. 9.24 (Rev. CoP17), and made in accordance with the fundamental principles in CITES Article II, which emphasizes the likely impact of trade on species’ conservation status.  

• The Working Group on CITES and Livelihoods set up at SC57 (Geneva, 2008) discussed the scope of a similar proposed amendment to Resolution Conf. 8.3 (Rev. CoP13) on Recognition of the Benefits of the Trade in Wildlife, and a majority of members affirmed their belief that the emphasis of the amendment should be clearly on the implementation of CITES-listing decisions, rather than on the listing of the species itself.[1] It was also emphasized that consideration of the impacts of the implementation of the CITES-listing decisions on the livelihoods of the poor should not be a “backdoor” to discuss the criteria for listing species in CITES. Currently worded, the Secretariat’s proposal would be a backdoor amendment to the criteria for amending the Appendices contained in Resolution Conf. 9.24 (Rev. CoP17).

• If there is to be any amendment to the livelihoods resolution, emphasis should be on considering the impacts of implementation of CITES decisions in coherence with Resolution Conf. 8.3, not the possible impacts of the decisions if adopted (i.e. proposals to amend the Appendices, Resolutions, Decisions, etc.).

AMEND the Secretariat proposal (new paragraph 3 a) ii)) to encourage and facilitate the engagement of rural communities as Observers in CITES.

Rationale

• The Observer process is already available and being used, but needs to be made more accessible to encourage engagement by rural communities.

• The engagement of different stakeholders should be equitable. It is not appropriate for CITES to encourage preferential access to Party delegations for some stakeholders over others (and potentially some communities over others). Countries have different processes for deciding the composition of their delegations, and whether to include non-governmental stakeholders. This is an issue to be decided nationally.

CoP18 Doc. 17.2:  Proposed amendments to Resolution Conf. 4.6 (Rev. CoP17) and Resolution Conf. 9.24 (Rev. CoP17) (Namibia and Zimbabwe)

SUMMARY OF THE RECOMMENDATIONS

1. Amend Resolution Conf. 4.6 (Rev.CoP17) on Submission of draft resolutions, draft decisions and other documents for meetings of the Conference of Parties

Proposed amendment: “AGREES that Parties, when submitting proposals to amend the Appendices, draft resolutions, draft decisions, and other documents for consideration at meetings of the Conference of Parties and when reviewing such documents submitted by other Parties, should take account of the impact of the measure proposed on rural communities that may be affected by them.”

1. Amend Resolution Conf. 9.24 (Rev. CoP17) on Criteria for the amendment of Appendices I and II

Specifically, in Annex 6 (Format for proposals to amend the Appendices) by adding two new sub-paragraphs to paragraph 6 Utilization and Trade and paragraph 10 Consultation: 

• New subparagraph 6.6: Provide information on any involvement of rural communities within the range of the species, in the use of, trade in and management of, the species. 

• New subparagraph to paragraph 10: Provide details of any consultation undertaken to secure comments on the proposal from rural communities living within the range of the species or how the potential impacts of the proposal on rural communities were considered. Comments from rural communities should be from locally recognized institutions representing interests of rural communities living within the range of the species. Comments received from these communities should be provided. Where comments were sought but not received in sufficient time to enable their inclusion in the supporting statement, this should be noted, as well as the date of request.

• Specifies that comments “should be from locally recognized institutions representing interests of rural communities living within the range of the species.”

POTENTIAL IMPACT

• Proposed amendment to Resolution Conf. 4.6 (Rev. CoP17): requiring Parties to take account of impacts on rural communities that may be affected by proposals could act as a deterrent for their submission, and potentially result in the blocking of additional protections for species in listing and up-listing proposals, Resolutions and amendments thereto, and Decisions because of perceived negative impacts on rural livelihoods, even though that use may be what is threatening the species.

• Proposed amendment to Resolution Conf. 9.24 (Rev. CoP17): The amendment is a backdoor to modify the criteria for amending the CITES Appendices. Its added requirement for Parties to provide evidence of consultations carried out with rural communities throughout the species’ range is almost impossible to implement, especially for migratory species with an extensive range across many countries (e.g. elephants and migratory marine species). Socio-economic research will also be required as part of listing proposals on rural communities’ use, trade, and management of the species throughout its range. These proposed additional requirements are likely to serve as a deterrent to the submission of much-needed proposals, especially for wide-ranging species, and potentially lead to the blocking of listing proposals on procedural grounds (insufficient consultations).

RECOMMENDED POSITION

OPPOSE both proposals

Rationale

• Parties have repeatedly agreed that decisions on listing proposals must be based on scientific and precautionary principles in line with the Convention’s objectives and have rejected attempts to include socioeconomic aspects in the listing process; they have decided that these are most appropriately dealt with during implementation at national level.

Resolution Conf. 8.3 (Rev. CoP13) on Recognition of the Benefits of the Trade in Wildlife, amended in 2004 in Bangkok, already “Recognises that implementation of CITES-listing decisions should take into account potential impacts on the livelihoods of the poor.” This emphasis was reaffirmed by the Working Group on CITES and Livelihoods set up at SC 57 in 2008 (as highlighted above).

• While consultation with rural communities at the national level should be encouraged, requiring evidence of consultations with communities living within a species’ range would in effect preclude the submission of proposals for species with a large range across many countries (e.g. elephants). It would also require proponents to consult with rural communities in other range States with not only practical implications but implications for their consultation processes. To maintain the integrity of the Convention and ensure it fulfils its objective – the survival of species through cooperation – the listing criteria must be based on biological and precautionary criteria.

• The proponents have tried to incorporate socioeconomic impact assessments into the listing criteria before, and their attempts were rejected, and should be rejected again. This most recent attempt uses rural communities and livelihoods as a screen for what in effect is an agenda to impede listings in Appendix I and II. Combined with the proposals in Document 11 to review the Convention and the Appendices (of which Namibia and Zimbabwe are co-proponents), they represent an attempt to re-write CITES, change its priorities and reorient it so trade can trump conservation.

• The proposed amendments to Resolution Conf. 9.24 (Rev. CoP17) would introduce an excessively demanding pre-condition for the drafting of listing proposals, and require an enormous commitment of financial and human resources, introducing lengthy time delays into CITES processes and deterring the submission of proposals. This is especially true for wide-ranging migratory species such as elephants and many marine species.   Given it already takes on average of 12 years to protect species once identified as at risk, and that over 271 species identified by the IUCN as threatened by intentional use and which are traded internationally are not protected by CITES, it would be detrimental to add further demanding pre-conditions.   

• The notion of “potential impacts” is not without its own problems. It implies that the effects of a given policy measure (i.e. up-listing) are to be measured in the absence of other policies that could be introduced to compensate for the negative impacts on rural communities. Moreover, this notion requires that these potential impacts are clearly identified and linked to the specific policy measure that is being adopted (causality is a crucial element here). As any lawyer knows, this is a very difficult requirement to fulfil in actual adjudication. When negative impacts are claimed to exist by one of the parties, the other will have to show that these alleged negative impacts are the consequence of other factors or that they are non-existent.  In any event, this opens the door to bringing into the debate questions of agricultural and fiscal policies.

CoP 18 Doc 17.3 Participatory mechanism for rural communities (Botswana, Democratic Republic of Congo, Namibia, South Africa and Zimbabwe) 

SUMMARY OF THE RECOMMENDATIONS

The Conference of the Parties is requested to:

• Endorse the United Nations Declaration on the Rights of Peasants and Other People Working in Rural Area at its 19th meeting, through a specific Resolution

• Establish a Rural Communities Committee whose objective would be to:

• operationalize principles embodied in the Preamble to the Convention as well as Resolution Conf. 8.3 (Rev. CoP13) on recognition of the benefits of trade in wildlife, and Resolution Conf. 16.6 (Rev. CoP17) on CITES and livelihoods and be part of the process to achieve the UN Sustainable Development goals,
• provide advice to the Conference of the Parties and the Secretariat on issues related to wildlife trade, in order to assess also the potential social and economic impact of CITES overall decisions on rural communities 
• carry out activities related to the promotion of community-based programmes aimed at the management, conservation, sustainable use of, and international trade in CITES-listed species
• draft resolutions and decisions for consideration by the Conference of the Parties 

• The Committee would be composed of Parties, “Rural Communities Organizations” that “manage, conserve, use, and trade in CITES-listed species, or species that could be listed on the CITES Appendices in the future”, and “observers from bonafide Non-Governmental Organizations with a proven record of work in the field of community-based conservation”

• Adopt Decisions directing: the Secretariat to prepare costed options for a Rural Communities Committee and a subcommittee of the Standing Committee; and the Standing Committee to consider the Secretariat’s report and make recommendations to CoP19, and consider extending the mandate of the intersessional WG on rural communities to SC 73

POTENTIAL IMPACT

The proposal would afford “Rural Communities Organizations” engaged in wildlife trade disproportionate power in relation to state Parties and other Observers, setting a dangerous precedent and undermining national sovereignty. CITES is a treaty between national State Parties, and while input from Observers representing different interest groups, including rural communities, is critical to ensure the best possible outcomes, the right to submit draft resolutions and decisions for approval by the CoP, as well as ultimate decision-making power rests with governments. Accordingly, all existing CITES Committees include either government representatives or adequately qualified “persons” chosen by the major geographic regions (for Animals and Plants Committees whose role is limited to providing scientific advice and guidance as per Resolution Conf. 11.1).

The proposal focuses not on including Indigenous Peoples and local communities’ voices but specifies the inclusion of only “Rural Communities Organizations” that “manage, conserve, use, and trade in CITES-listed species;” the focus is therefore not on equity but on managing wildlife so that a certain subset of communities can benefit from trade. Thus, community organizations engaged in consumptive use from countries that promote wildlife trade (e.g. in Southern Africa) would be afforded considerable powers, disadvantaging other local community organizations and Indigenous Peoples with different social and cultural values, who do not engage in trade and would presumably be excluded from the proposed committee.

The creation of a permanent Rural Communities Committee substantially increases CITES bureaucracy, and will place further financial and logistical strain on the Secretariat and Parties.

RECOMMENDED POSITION

OPPOSE all recommendations

Rationale

• As discussed above under Potential Impacts, the proposal would afford “Rural Communities Organizations” engaged in wildlife trade disproportionate power in relation to state Parties, other Observers, and other local communities and Indigenous Peoples who don’t engage in trade, setting a dangerous precedent and undermining national sovereignty.

• The UN Declaration on the Rights of Peasants and Other Peoples Working in Rural Areas is a resolution approved by the UN General Assembly designed to address the significant imbalances in agricultural policies worldwide. Efforts to get it approved were spearheaded by La Vía Campesina, a civil society organization that aims to reform agricultural policies in order to truly improve living standards for small-scale farmers and campesinos. La Via Campesina is one of the largest civil society organizations (CSOs) in the world, with more than 300 million members worldwide. The guiding principle of this resolution is indeed the need to reform current agricultural policies, but not as a smokescreen to hide the promotion of wildlife trade.

• The intersessional Working Group established in accordance with Decisions 17.28 to 17.30 to discuss engagement of rural communities in CITES was chaired by Namibia and met in Gigiri, Kenya in February 2018. The membership was not established according to usual procedures (i.e. during a CITES meeting, selecting representatives accredited by CITES). As a result, it lacked regional balance, excluded NGO Observers with the exception of trophy hunting lobby organisation “Conservation Force”,[2] and included a disproportionate number of community organizations from Southern Africa. It provides an example of how mismanaged representation can contaminate deliberations on engaging rural communities.

• Despite its lack of balanced representation, this group could not come to consensus on how to engage rural communities in CITES. There was divergence on the two major options that emerged from discussion for increased engagement of communities in CITES processes:  a permanent CITES advisory body and ensuring participation of Rural Communities in all CITES meetings. 

• When the report was discussed at the 70^th meeting of the Standing Committee (SC 70), a significant number of Parties opposed the establishment of a formal mechanism, emphasizing that CITES is a treaty between national State Parties. While input from Observers representing different interest groups, including rural communities, is critical to ensure the best possible outcomes, ultimate decision-making power rests with governments. The proposal would afford rural communities the power to influence CITES agenda items at the international level in the same way as other permanent bodies (the Animals Committee, Plants Committee and Standing Committee).

• As discussed above (under CoP18 Doc 17.1), CITES bundles ‘rural communities’ under one label, with no common understanding of who is included. It has been used by CITES to include different categories of stakeholders, such as Indigenous Peoples and local communities, as well as communities with different levels of social and economic power. In reality, rural communities are not homogeneous blocks of population, and not easily defined, raising the fundamental question of how to frame legitimate representation. There can be considerable social, cultural and economic differences among communities sharing a common landscape; power and resources are not distributed equally even within a community. Especially where poverty, food security, and other factors affect community members, economic pressure can weaken local institutions and social tissue and lead to easy manipulation of existing power structures. This inequality creates intractable problems with creating a legitimate or genuine representation model. It is important to recall that for this proposal, rural communities are equated with only organizations that “manage, conserve, use, and trade in CITES-listed species”.

• As already stated (under CoP18 Doc 17.1), other multilateral environmental agreements (MEAs) provide for engagement by Indigenous Peoples and local communities (IPLC) through official Observer status, allowing them to intervene from the floor and participate in working groups. The CBD supports the Indigenous Peoples’ Forum on Biodiversity, while the UNFCCC supports a Local Communities and Indigenous Peoples Platform. However, these are not permanent Committees with decision-making powers as was proposed, but not accepted, in the intersessional working group. In addition, it is important to note that the objectives of both the CBD and the UNFCCC are very different from the objectives of CITES. Nevertheless, CITES still affords local communities and Indigenous Peoples the opportunity to participate as Observers.

• The proposal to establish a Rural Communities Committee is yet another backdoor to amending the CITES listing criteria.

CoP 18 Doc 18.1 (Rev. 1) CITES and livelihoods (Report of the Secretariat)

SUMMARY OF THE RECOMMENDATIONS

The Secretariat recognises in this working document that many other CoP 18 working documents (Doc.17.1, Doc.17.2, Doc.17.3, Doc.18.1, Doc.18.2, Doc.18.3 and Doc.19) touch upon “the participation and the livelihoods of rural, local or indigenous communities” and notes the similarities in some of the recommendations. The Secretariat has summarised its recommendations from Docs 17.2, 17.3, 18.2 and 18.3 in Doc 18.1 Rev.1. The Secretariat’s discussion focuses on implementation of CITES-listing decisions and minimizing their impacts on livelihoods and on survival of CITES-listed species in the wild.

The document proposes several recommendations to advance the livelihoods agenda through a series of draft Decisions (18.AA – 18.EE) that focus on continuing the case study work, developing best practices on CITES and livelihoods, sustainable use of wildlife and engagement of rural communities, and potential development of a certification scheme.

• Recommendation 1 (draft Decision 18. AA): Parties are directed to:

• Collate or conduct new case studies on how the involvement in legal and sustainable trade in CITES-listed species of rural communities who live alongside wildlife contributes to the improvement of their livelihoods and the conservation of the species in the wild;
• Engage rural communities to take part in CITES decision-making processes at the national level to better achieve the objectives of the Convention; and
• Where appropriate, incorporate issues related to CITES implementation and livelihoods into national wildlife conservation and socio-economic development plans, as well as in relevant projects being developed for external funding, including funding from the Global Environment Facility (GEF) through the Global Wildlife Programme. 

• Recommendation 2 (draft Decisions 18.BB and 18 CC): the Standing Committee is directed to (in collaboration with the Secretariat)

• Review the report (see draft Decision 18.DD below) on the possibility of using registered marks of certification for products of CITES-listed species produced by rural communities; and
• Monitor the progress made by Parties in implementing the recommendation to engage rural communities in CITES decision-making processes;
• Review the report of the Secretariat on progress made with regard to implementation of the above recommendations to Parties and the recommendations below directed to the Secretariat.

• Recommendation 3 (draft Decisions DD and EE): the Secretariat is directed to

• Support the collation or conduct of new case studies on CITES and livelihoods and assist Parties to present the case studies in appropriate platforms, and in formats and manners that are most effective for targeted audiences;
• Contract a consultant to conduct a review of relevant case studies on CITES and livelihoods, both existing and new, as well as existing guidelines on sustainable use of wildlife and engagement of rural communities, to identify best practices;
• On the basis of the review prepare a Guidance on how to maximize the benefits of trade in CITES-listed species to rural communities and the conservation of the species and facilitate a workshop to review the guidance;
• Evaluate the possibility of using registered marks of certification, existing and new, for products of CITES-listed species produced by rural communities consistent with CITES provisions in order to enhance conservation and livelihood outcomes;
• Organise the production of outreach materials to raise awareness of and promote best practices in CITES implementation and livelihoods including its contribution to the United Nations Sustainable Development Goals (SDGs) and to share them on appropriate platforms
• Report to the SC and CoP19 on progress made with regard to the implementation of Decisions directed to Parties and the Standing Committee and Resolution Conf. 16.6 (Rev. CoP17) on CITES and livelihoods. 

POTENTIAL IMPACT

The recommendations as currently worded betray a bias in favour of use involving trade. The case studies are geared towards showing how wildlife trade improves wellbeing of communities. This is tantamount to writing the conclusions before the studies begin, and excludes studies where trade has led to over-exploitation at the expense of community livelihoods. It does not recognise that the feasibility and impacts of consumptive use and commercial trade vary widely from species to species and fails to provide a frame of reference for objective science-based studies on the impact of wildlife trade or ‘sustainable use’. Any recommendation to carry out studies about the impact of wildlife trade on communities should have as its starting point the need to objectively assess all economic effects of these commercial undertakings. It is impossible to have a pre-selected agenda as a guiding post for the studies.

The second set of recommendations is designed to develop guidance on maximising the benefits of trade in CITES-listed species and consider the development of a certification scheme. But again, a pro-trade outcome is presumed, regardless of the species or geographical location, and the question of whether trade should occur or whether there is a better long term plan for a local community is not asked.

There is a real need for studies on the impacts of wildlife trade on livelihoods. Wildlife trade has different types of impacts, both favourable and unfavourable on livelihoods, wildlife and ecosystems. A pre-designed agenda confining the scope of case studies of how wildlife trade contributes to the “improvement” of livelihoods and the “best practices” for ensuring such contributions is not the right way to move forward. As it stands, this proposal has an inherent pro-trade bias and would have a negative impact.

Evaluating the use of registered certification marks could move CITES towards trade promotion, contrary to its objective to protect species from over-exploitation by trade.

RECOMMENDED POSITION

Support the engagement of rural communities to take part in CITES decision-making processes at the national level to better achieve the objectives of the Convention.

Amend the other recommendations to:  

• Modify the scope of the proposed case studies and collation to include studies where trade has led to over-exploitation at the expense of community livelihoods, and studies on non-consumptive use. Ensure the approach is policy relevant and would generate objective science-based studies on the impacts, both favourable and unfavourable, of wildlife trade and non-consumptive use on rural livelihoods and the species on which they depend. On the basis of the studies, identify best practices and make recommendations on further action to advance the agenda on CITES and livelihoods in a way that will ensure sustainability for both communities and wildlife, taking into account governance challenges. Identify species whose particular characteristics (e.g. birth rates, length of time to reach maturity) render them more amenable to being traded sustainably, bearing in mind the risk of shifting from in situ to ex situ production.
• Until such studies are available as an objective information base, oppose the development of any guidance on how to maximise the benefits of trade, as well as consideration of CITES certification schemes and the incorporation of issues related to CITES and livelihoods into national wildlife conservation and socio-economic development plans.

Rationale

• Policy relevant research is urgently needed on the structure, dynamics and drivers of legal and illegal wildlife trade and their impacts on livelihoods, as well as the impacts of non-consumptive use[3]. In this context, we strongly support the Secretariat’s statement in the Document that:

“Since the ultimate objective of CITES is to ensure the survival of the species in the wild, the survival of the species in the wild must also be the ultimate goal of the work on CITES and livelihoods. It is in the interest of the Convention to engage rural communities so that their efforts to conserve wildlife and ensure their survival in the wild is clearly seen as beneficial for their livelihoods. This recognition and principle should guide the consideration of various issues surrounding livelihoods and rural communities in the CITES context.”

• As discussed above under Potential Impacts, the studies proposed in Doc. 18.1 (Rev. 1) have an inherent bias in favour of trade and would not provide an objective and policy-relevant analysis of the true impact of wildlife trade, including how ex situ production and resulting commercial trade impacts the survival of species in the wild.

• CITES certification has been discussed before and proved controversial. As a result, compromise language was agreed in Resolution Conf. 16.6 (Rev. CoP17) on CITES and livelihoods which “invites” Parties to “explore” the use of registered certification marks consistent with CITES. Evaluating the use of registration marks of certification is potentially a risky move towards trade promotion, especially in the absence of the consideration of compliance costs and in situations where there may be governance challenges to ensuring sustainability.

• There are many kinds of certification schemes. Some provide a guarantee of origin and can be subsumed under the category of “Designation of Origin”. Others pertain to the contents of a product (chemical composition). They are typically disliked by WTO (see Agreement on Technical Barriers to Trade) because they lend themselves to discriminatory measures. WTO is inclined to take methods of production into consideration only when they leave a trace in the chemical or composite features of a particular commodity. When this is not the case, the principle of ‘substantial equivalence’ is applied. Finally, others are related to quality control where particular methods and production processes need to be ascertained (sustainable production processes are particularly relevant in this context). The proposal does not clarify which of these methods are to be considered. Because each trade venture will be different, this is best left for the consideration of stakeholders and government agencies.

• Only a handful of Parties and stakeholders have engaged and only a few case studies have been done. Greater involvement by all CITES stakeholders is necessary. Certainly, more information is required before any kind of certification ideas could or should be explored.

CoP18 Doc 18.2 CITES and Livelihoods (Peru)

SUMMARY OF THE RECOMMENDATIONS

The document proposes several recommendations through a series of draft Decisions to:

• Re-establish the Working Group on CITES and livelihoods with terms of reference to:

• Evaluate the possibility of using registered marks of certification for products of CITES-listed species produced by rural communities
• Analyse the need for and draft a new resolution, or amend an existing resolution, on methods to avoid unintended negative conservation consequences of trade related measures that may result in livelihoods and incentive implications 
• Explore the usefulness of developing an evaluation mechanism to consider the effects of CITES decisions on trade stakeholders, and the potential consequences of those decisions on the effective conservation of species and implementation of CITES
• Provide feedback on guidance developed by a consultant on how to maximize the benefits of trade in CITES-listed species to communities and the conservation of the species

The document also proposes a draft Resolution for an International Day for Livelihoods of Rural Communities.  

POTENTIAL IMPACT

• The suggested draft Decision to evaluate the need for a new Resolution on methods to avoid unintended negative conservation consequences of trade related measures that may result in livelihoods and incentive implications is another way to include socioeconomic factors, and potentially impact assessments, into CITES decisions, akin to including such provisions in Resolutions Conf. 4.6, 9.24 and 16.6 (see discussions above on potential impacts of recommendations in CoP18 Docs 17.1 and 17.2). This proposal does at least incorporate consideration of impacts on conservation of CITES-listed species, but still injects socio-economic considerations into listing and other CITES decisions.

• The proposal for the development of an evaluation mechanism to consider the impacts of CITES decisions on “trade stakeholders” could potentially result in the blocking of proposals because of the negative impacts on commercial traders (and rural livelihoods) even though that use and trade may be what is threatening the species. Moreover, itconflicts with the Convention’s objective to conserve species in the wild.

• The proposal’s allusion to “trade stakeholders” goes beyond the reference to rural communities and livelihoods. This text appears to be aimed at shifting the main focus of discussion under the Convention from legitimate concerns about Indigenous Peoples, rural and local communities to issues of commercial interests. Trade stakeholders can include dealers, brokers, big and small-scale suppliers, moneylenders involved in commercial operations, craftsmen, etc. These groups of people go well beyond a discussion about livelihoods.

• Concerning the recommendation to evaluate the possibility of using registered marks of certification, see discussion above under CoP18 Doc. 18.1).

RECOMMENDED POSITION

OPPOSE the recommendations in the draft Decisions

Rationale

• The proposals promote a pro-trade agenda that assumes trade will benefit wildlife, and considers CITES listing decisions as hampering livelihoods. They take no account of the negative impacts of wildlife trade on communities or the governance challenges involved.

• As with other proposals discussed above, an evaluation mechanism to consider the impacts of CITES decisions on livelihoods could block decisions that restrict trade. In effect, it would be a “backdoor” to changing the criteria for listing species in Resolution Conf. 9.24 (Rev. CoP17) to include socio-economic impact assessment.

• The Review of Significant Trade already addresses implementation of CITES in relation to traded species and seeks to ensure that trade is non-detrimental. In addition, the CITES Livelihoods Handbook, toolkit and guidelines provide materials to help Parties assess impact of implementation of CITES-listing decisions on livelihoods of rural communities.

• Article VI of the Convention already establishes a system of certificates and permits under the provisions of Articles III, IV and V. These certificates and permits are administered by the Management Authorities of export and import countries. The creation of other CITES-sponsored certificates of “sustainable use” will cause more confusion and may even open the door to forgery and misuse of the current certification system.

CoP18 Doc 18.3 CITES and Livelihoods (China)

SUMMARY OF THE RECOMMENDATIONS

Introduce a livelihood analysis as an added requirement in the supporting statement for all listing proposals by revising Resolution Conf. 9.24 (Rev. CoP17): Section C Supporting Statement in Annex 6 on the Format for proposals to amend the Appendices to include:

• Explanation of how and to what extent the proposed listing would impact livelihoods which are beneficial for the conservation of the species in its range States and in the whole trade chain, both the supply side and demand side;

• Explanation of how and to what extent the proposed listing could create the opportunities to divert livelihood from a beneficial one into a way detrimental to the conservation of the species in its range States and in the whole trade chain, both the supply side and demand side; and 

• Explanation of how the proposed listing would impact through livelihoods in the whole trade chain to the conservation of wildlife. If the overall livelihood impact is negative and the listing is still preferred, please articulate what remedy measures would be taken to overcome it after the listing to ensure the long-term survival of the species and the livelihood of people live with it [sic].

POTENTIAL IMPACT

This proposal would require Parties to, when preparing listing proposals, carry out complex assessments of impacts on livelihoods along the whole trade chain,and where they are negative “overall”, to “articulate” compensatory measures. If adopted, it would almost certainly result in blocking listing and up-listing proposals.

The proposal has three separate components, all of which are deeply problematic.  

• First, the proposal to “explain how and to what extent a proposed listing would impact livelihoods which are beneficial for the conservation of the species in range States” would have a detrimental impact on CITES for two important reasons.
  •  First, it would paralyze the listing process as it requires analysing complex phenomena that are extremely difficult to quantify. Thus, the notion of examining “to what extent” a listing proposal affects livelihoods would be a major obstacle to all listing activity.
  • Second, the proposal is contradictory as it implies that the livelihoods that would be affected “are beneficial for the conservation of the species”. The contradiction lies in the fact that if listing a species is deemed to be necessary that is because there is scientific evidence that trade or use of the species is already having a negative effect on the population, and yet the proposal implies that livelihoods are having a beneficial effect on the species. The proposal tries to solve this contradiction by stating that this “explanation” would be required at all stages of the “trade chain”. This just makes things more difficult but does not solve the inherent contradiction between the need for listing and the supposed beneficial effects of livelihoods on the species.

• Second, the proposal to have an explanation on how the listing could create opportunities to divert livelihoods from a beneficial to a detrimental role for the conservation of the species is also inherently contradictory. It assumes that livelihoods are already having a beneficial effect on the species and that the listing may transform these livelihoods in such a way that they would have a detrimental impact on the species. But in that case why would there be a need for a new listing if a species was experiencing the beneficial effects derived from a certain livelihood? Such an analysis would also be difficult if not impossible to perform since wildlife markets are incredibly varied and given those variables it is difficult to predict the reaction to a listing. The proposal calls for the impossible and imposes criteria well beyond the Convention’s remit.

• Third, the proposal to “articulate what remedy measures would be taken to overcome” negative impacts on livelihoods along the whole trade chain stemming from a proposed listing introduces a fundamental shift in CITES’ operations. The proposal not only wants to introduce an extra requirement in the listing process, it introduces the concept that all those along a trade chain that have negatively impacted the conservation status of a species should be compensated, including traders and industry. It also fails to acknowledge the fact that the Addis Ababa Principles and Guidelines on the Sustainable Use of Biodiversity, when defining the underlying conditions for sustainable use, contain the requirement (Section A, paragraph f) that to ameliorate any potential negative long term effects of uses (and by extension of policies restricting uses) it is incumbent on all resource users “to apply precaution in their management decisions”. The need for precaution is not adhered to by the proposal. Finally, the need to articulate remedial measures could potentially result in listing proposals being blocked because of the negative effect on unsustainable use of a particular species. Interminable disputes would arise from discussions on what sufficiency standards would need to be applied for remedial or compensatory measures.

Apart from paralysing listings, the proposal would set a dangerous precedent by introducing the concept of impact assessments and compensation of stakeholders all along the entire “trade” or “value” chain, including business and industry interests. The proposal may be a reaction to pressures on China to close its ivory market, which raised discussions of compensation and was a “top-down” decision rather than “bottom-up” from the CITES Management Authority. It states: “Appendix listing without consideration of livelihood would encourage pressures to close the market in the end of the trade chain, hampering both the sustainable trade and the consumers’ recognition of the role played by the livelihoods in the range states, as well as that by the [sic] themselves in the market”.

RECOMMENDED POSITION

OPPOSE China’s proposal to amend Resolution Conf. 9.24 (Rev. CoP17)

Rationale

• The grounds set out above under Potential Impacts provide a strong rationale for rejecting China’s proposal. It would not only paralyse the listing process by imposing an impossible requirement that sets a dangerous precedent, it would introduce the concept of compensating traders whose profit-making activities jeopardised the species in the first place. CITES Parties have repeatedly agreed that decisions on listing proposals must be based on science and the precautionary principle. As set out above (under CoP18 Docs. 17.1 and 17.2), they should be based on the scientific and precautionary criteria in Resolution Conf. 9.24 (Rev. CoP17), and made in accordance with the fundamental principles in CITES Article II, which emphasizes the likely impact of trade on species’ conservation status.  Previous attempts to include socioeconomic aspects in the listing process were strongly resisted and rejected.

• The China proposal also provides a questionable interpretation of Resolution Conf. 16.6 (Rev. CoP17) on CITES and Livelihoods, stating that it recognizes the potential benefits of legal and sustainable trade to both the conservation of the species and the livelihoods of rural communities that live alongside wildlife. The text in Resolution Conf. 16.6 does not contain a passage that conveys this idea.

CoP18 Doc 19 Food Security and Livelihoods (prepared by the Standing Committee)

SUMMARY OF THE RECOMMENDATIONS

CoP18 is invited to renew Decisions 17.41 to 17.43, which called for:

• Consideration of a stand-alone Resolution on Food security and livelihoods;
• Consideration of a revised Resolution from the proponents of the draft Resolution submitted to CoP17 (Antigua and Barbuda, Côte d’Ivoire and Namibia);
• Consideration by Standing Committee of the work done and to make any recommendations to CoP18. 

Renewing these Decisions would also extend the mandate of the working group, which included:

• A stand-alone Resolution on Food security and livelihoods 
• Incorporate food security issues into existing resolutions
• Make recommendations to CoP18

POTENTIAL IMPACT

The origin of this initiative was CoP17 Doc 17, submitted by Antigua and Barbuda and Namibia (Côte d’Ivoire withdrew from the proposal at the CoP), which introduced a proposal for a draft Resolution on livelihoods and food security that, inter alia, urged Parties to take into account “food and nutrition security, preservation of cultural identity and security of livelihoods when making proposed amendments to the Appendices”. Thus, extending the mandate of the working group would keep alive a process intent on introducing a new criterion in the listing process – yet another way to block listing proposals and undermine the core work of CITES.

It met with strong opposition at CoP17, and failure to reach a consensus led SC69 to establish an inter-sessional working group. There is still no consensus regarding even the mandate of the working group, which is set by the Standing Committee, not the working group participants. Extending the mandate would drag out the issue and waste Committee time given there is no chance of resolution, adding to the burden of the Secretariat and Parties, the multiplication of inter-sessional working groups, and duplicate work (food security is already addressed under the Resolution on CITES and Livelihoods).

RECOMMENDED POSITION

OPPOSE the renewal of these Decisions

SUPPORT the Secretariat’s conclusions that Resolution Conf.16.6 (Rev. CoP17) on CITES and livelihoods comprehensively addresses livelihoods and community concerns, including the issue of food security.

SUPPORT the Secretariat’s conclusion that, given this initiative met with considerable opposition at CoP17, and again at SC69 and SC 70, and that the opposing views of Parties and stakeholders are likely to remain as divergent and fundamental at CoP18, we do not see any prospect that further discussions will lead to agreement.

Rationale

• CITES inherently promotes food security, and livelihoods are already comprehensively addressed in Resolution Conf. 16.6 (Rev. CoP17). The initiative does not add any value, neither would attempts to resurrect the concept of a stand-alone resolution as initially proposed in CoP17 Doc. 17. Rather, it would prolong a process whose underlying motivation is to impede listing proposals and undermine CITES.

• The Standing Committee at SC69 already clearly rejected the consideration of a stand-alone resolution. Not only did the draft resolution submitted to CoP17 attempt to add a new criterion for amending the Appendices (“issues relating to food and nutrition security, preservation of cultural identity and security of livelihoods”), setting a dangerous precedent (see under CoP18 Doc. 17.1, 17.2 and 18.3), it instructed the Secretariat to increase information exchange with FAO on these issues. It would only be one step further to require assessments by FAO of how all listing proposals address these issues.  

• The original proponents of the draft Resolution failed to craft a revised Resolution (per Decision 17.42) and should not be given a second opportunity to do so.

• The proposal draws CITES into issues far beyond its mandate and competence that are being addressed in other fora. The notion of “food security” is not in itself a technical concept and has many implications. There is currently a heated debate on the advantages and disadvantages of using this notion of ‘food security’ instead of the more comprehensive notion of ‘food sovereignty’. Food security according to the United Nations implies that a given population has at its disposal sufficient, safe and nutritious food to meet their dietary needs. Food sovereignty is defined as a right of peoples to have adequate food and at the same time decide on the production technologies and the agricultural output mix required. This concept was first introduced in the International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD), an intergovernmental effort under the auspices of the World Bank, UNEP, WHO and FAO. It is a much more ambitious concept as it encompasses economic and environmental considerations. The main difference between these two notions is that “food security” can be met if the economic means to obtain food are obtained, regardless of social or environmental considerations. Thus, the replacement of food production by cash crops may lead to food security, but not necessarily in a manner that is both socially responsible and environmentally sustainable.

In the context of the objectives of CITES and of domestic wildlife conservation policies, it is clear that ‘food security’ entails a rather limited perspective. The concept of ‘food sovereignty’, on the other hand, requires dovetailing agricultural and environmental policies in order to attain its objectives. Proposals related to the notion of ‘food security’ should be rejected as they offer a very limited perspective on the complex issues related to livelihoods, economic well-being and environmental stewardship.

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[1] CoP 16 Inf 21

[2] Parties: 1 Argentina, 2 Botswana, 2 Brazil, 2 Cameroon, 1 Canada, 2 China, 2 DRC, 1 Ethiopia, 1 EU, 2 India, 2 Kenya, 2 Namibia, 1 Nigeria, 2 Peru, 3 South Africa, 2 Uganda, 2 Tanzania, 2 Zimbabwe; Rural communities: 1 Antigua Barbuda, 1 Canada, 2 Colombia, 1 DRC, 2 India, 2 Kenya, 2 Namibia, 1 Nepal, 2 Spain, 1 Tanzania, 1 Zambia, 2 Zimbabwe)

[3] Noting the recent (June 2019) release by Space for Giants of Building a wildlife economy: Working Paper 1: Developing nature-based tourism in Africa’s state protected areas https://spaceforgiants.org/wp-content/uploads/2019/06/Building-Africas-Wildlife-Economy-Space-for-Giants-Working-Paper-1.pdf