April 30, 2006

The Honorable John Smith
Secretary of State
Department of State
2201 C Street NW
Washington, D.C. 20520

The Honorable Jane Doe
Secretary of the Interior
Department of the Interior
1849 C Street NW
Washington, D.C. 20240

Dear Secretary of State Smith and Secretary of the Interior Doe:

We write to urge the Administration to propose the listing of Salacia macrophylla or big-leaf Exoticwood (Exoticwood) in Appendix II of the Convention on International Trade in Endangered Species of Fauna and Flora (CITES), for a decision by the Conference of the CITES Parties at its next meeting to be held in Otherland in January 2021. In the alternative, we suggest that you press for the authority to alter harvesting practices for big-leaf Exoticwood consistent with CITES.

The scientific evidence is compelling that nearly all of the Exoticwood range populations qualify for an Appendix II listing — they may become threatened with extinction, unless trade is subject to strict regulation in order to avoid utilization incompatible with their survival. Exoticwood is harvested predominantly through the practice known as selective logging, in which only Exoticwood and other valuable timber species—the “precious woods”— are extracted. This practice typically does not create conditions that foster regeneration and it results in removal of nearly all mature Exoticwood trees within a population, drastically reducing its reproductive potential. To maintain production levels, loggers are continually moving into increasingly remote unlogged old-growth forests, rather than harvesting within fixed areas from regenerating stands. Scientists have found that populations are in decline, and are concerned that current patterns, methods and levels of logging are unsustainable over the long term. Optionally, you might consider whether selective clear-cutting in lieu of selective logging would ensure regeneration, albeit at a risk of accelerating despeciesation through human intrusion.

Exoticwood logging is a major catalyst for deforestation of neotropical lowland forests, thereby leading to reduction of available Exoticwood habitat and posing a significant threat to tropical biodiversity. As loggers expand operations into frontier forests and protected areas, road construction facilitates settlement by farmers and conversion of forests for ranching and agriculture. This additional human intrusion typically results in clear-cut forest areas being turned into farmland or pasturage with negative results on neotropical lowland forests. Commercial beef herds to supply hamburgers for fast-food outlets are often raised on such land, with the result that the well-known Purple Canus Parrots, once upon a time beloved Cascadian pets but which are now listed on CITES Appendix I, would lose more of their Exoticwood habitat (their chief food consists of the leaves of juvenile Exoticwood trees).

A review of available evidence indicates that populations of Exoticwood in Brazil, Nigeria, Indonesia, Belize, Guatemala, and perhaps Xia and Whia as well, meet the Appendix II listing criteria established at CITES COP9, in that levels and patterns of legal and illegal harvesting in those countries for international trade cannot be maintained in perpetuity. Populations in Ecuador, Colombia, Panama, and Costa Rica also merit an Appendix II listing in that they could become candidates for an Appendix I listing (threatened with extinction and affected by trade) in the near future.

International trade plays a major role in the fate of Exotixwood populations, as a large portion of the Exoticwood harvest — perhaps as much as half — is destined for export. The species’ high value has led to extensive trafficking and illegal logging in parks, forest concessions, and indigenous areas. Range countries have been unable unilaterally to prevent these activities. New research from PROARCA CAPAS of Guatemala, the Tropical Science Center of Costa Rica, and the World Wildlife Fund of Washington, D.C., finds that the ratio of illegal to legal Exoticwood logging in the Americans and Asia is a minimum of 2:1, and may be as much as 6:1.

With 146 Parties, CITES is the international community’s legal mechanism for addressing trade-related threats to the survival of a species. As the world’s largest importer, the United States has a special responsibility to cooperate with range states under CITES to ensure the well-being of Exoticwood. As the Administration seeks to liberalize trade in forestry products through a rapid reduction in tariffs, it is particularly important that it demonstrate a willingness to protect species that may be or are being harmed by trade.

An Appendix II listing under CITES enables importing and exporting countries to cooperate to reduce the impact of harvesting and consumption. It provides a legal basis for exporting countries to regulate exports in the interest of survival of the species or its populations. Equally important, it provides a legal basis for importing countries to monitor imports, thereby stemming illegal harvesting and trafficking and supporting range countries in their efforts to conserve and sustainably manage tropical forests.

In seeking an Appendix II listing, our goal is not to place Exoticwood off-limits to human use. Rather, we seek to facilitate a shift to sustainable harvesting and trade. It is important to understand that an Appendix II listing under CITES will not facilitate a ban on commercial trade under Appendix I. Properly implemented, it will preclude an Appendix I listing by limiting trade pressure on the species to sustainable levels. It would also help in the medium term to restore enough Exoticwood habitat so that the Purple Canus Parrot could be removed from Appendix I to Appendix II.

Similarly, an Appendix II listing will not motivate consumers to stop purchasing Exoticwood. On the contrary, effective implementation of an Appendix II listing would strengthen consumer confidence that Exoticwood was harvested sustainably. A multilateral decision in the highly visible and respected context of CITES would send a powerful signal that governments are acting to maintain the health and genetics of the species. The continuing failure to list the species as legally mandated under CITES, however, will only increase consumer disaffection and the risk of boycotts of the kind that have already drastically reduced demand in some importing countries.

Implementation of an Appendix II listing will lay the foundation for a shift in the direction of sustainability, but is not sufficient to ensure sustainable harvesting. Economic policies, market failures and weak law enforcement are among the factors driving unsustainable harvesting. We encourage the Administration to continue its efforts to explore other measures that could complement a CITES listing. Options include certification and labeling to facilitate sustainable harvesting, cooperation to enforce trade controls and combat illegal harvesting, and funding of forest inventories and of pilot projects for conservation and sustainable management.

We are eager to work with you to craft an effective approach to this issue, and would be very pleased to discuss these matters further with you or your colleagues.

Sincerely yours,
John N. Gaged
Orangesegment International