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HUTCHENS FINAL (DO NOT DELETE)4/28/2014 3:01 PMTHE LAW NEVER FORGETS: AN ANALYSIS OF THEELEPHANT POACHING CRISIS, FAILED POLICES, ANDPOTENTIAL SOLUTIONSEMILY HUTCHENS“Elephants are living treasures. Nature’s gardeners. Nature’s greatteachers. Tragically some people don’t give a damn. They prefer thedead treasure to the living one. The ivory. We must challenge this socalled ‘trade’ with all our might and shame on those who wouldcondone it.”1Introduction . 935I. The Initial Ban and the Subsequent Developments in ElephantProtection Law . 937A. CITES .937B. The Fight over a Total Ban on the Ivory Trade.938C. Since the Ban: The Two Approaches towardsMaintaining Elephant Populations .941D. Aftermath of the Upgrade in the African Elephants’Status .943II. Elephant Poaching on the Rise. 944A. The Threat to the Elephant .944B. Who Are the Poachers? .947C. Why Is Poaching on the Rise? .948D. International Reaction .949III. A Case Study of Current Laws . 950A. Fractured Approach among African Nations .950B. Comparison: Botswana vs. Kenya .951C. A Uniform Approach Promulgated by Parties to CITES .954IV. Solutions and Steps that Need to be Taken . 957A. AEAP and Enforcement .957B. AEAP and Sustainable Use .960C. AEAP and Funding .961Conclusion. 9621Virginia McKenna, What the Experts Say, BLOOD IVORY, visited Mar. 10, 2013).

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets935INTRODUCTIONThe African elephant is the largest land-dwelling animal onearth.2 Unlike the Asian elephant, the African elephant develops largeivory tusks. Individuals covet these tusks, usually tusks that are largerand stronger, in order to manufacture and sell goods.3 The only way toacquire elephant tusks is to kill the elephant and then remove the tusks.Thus, poachers must kill elephants to fill the demand for ivory, which inturn has decimated elephant populations at two different junctures inrecent history.In the 1970s and 1980s countries legally traded ivory.4 Africancountries with elephant populations exhausted the resources - includingivory, meat, and skin - provided by elephants. 5 They extracted ivoryfrom dead elephants and traded it6 to other (mostly Asian) countries.7The trade of ivory created a market for ivory and allowed poachers toprofit from their illegal trade. However, the systems created to managethe legal trade of ivory did not provide an effective way to differentiatebetween legally acquired ivory and poached ivory. Ninety percent of theivory traded was obtained illegally.8 Poachers organized and began to useautomatic weapons, which dramatically depleted elephant populations.9They then flooded the market with ivory in turn for a substantial profit.In response to this threat to elephant populations, many countriesenforced unilateral bans on the export and import of ivory in 1988. Themovement began with the United States’ ban on the import of ivoryproducts.10 West Germany and twelve other European countries bannedthe import of ivory as well.11 Kenya banned the export of ivory and234567891011DAVID HARLAND, KILLING GAME: INTERNATIONAL LAW AND THE AFRICAN ELEPHANT 18(1994).The Shrinking Roots of Heaven, U.S. NEWS & WORLD REP., May 22, 1989, at 11. Such productsinclude Japanese seals (hanko), knife handles, and powder for medicine. Id. at 11–12.Michael J. Glennon, Has International Law Failed the Elephant?, 84 AM. J. INT’L L. 1, 3(1990); Sam B. Edwards, III, Legal Trade in African Elephant Ivory: Buy Ivory to Save theElephant?, 7 ANIMAL L., 2001, at 119, 122.David Harland, Jumping on the “Ban” Wagon: Efforts to Save the African Elephant, 14FLETCHER F. WORLD AFF. 284, 286 (1990).Id.See Edwards, supra note 4, at 122. Prior to the ban in 1989 Japan was the largest importer ofivory.Id.Id.Glennon, supra note 4, at 16.Id.

HUTCHENS FINAL (DO NOT DELETE)9364/28/2014 3:01 PMWisconsin International Law Journalimplemented a system intended to stop all illegal poaching of Africanelephants.12 However, not all countries agreed to impose a unilateral ban;Japan and Hong Kong did not ban the import of ivory and South Africaand Zimbabwe refused to stop exporting ivory.13 Nonetheless, in 1989,the Convention on International Trade of Endangered Species of WildFauna and Flora (CITES) imposed a complete, world-wide ban on theivory trade.14Initially, the ban dramatically reduced the incidence of illegalpoaching because it destroyed the market for ivory.15 However, in 1999Zimbabwe, Botswana, and Namibia exported their ivory stores to Asiannations revitalizing the ivory market.16 Poaching started to increaseagain17 and now, in 2013, the African elephant is facing its largestpoaching crisis since the 1989 ban. As the New York Times reported,“Africa is in the midst of an epic elephant slaughter.”18 Conservationgroups note, “poachers are wiping out tens of thousands of elephants ayear, more than at any time in the previous two decades, with theunderground ivory trade becoming increasingly militarized.”19 The newdemand has pushed the value of ivory upwards of 1,000 per kilogram,which makes poaching very profitable.20 Due to the renewed threat toelephants, CITES members commissioned African range states –Africanstates with elephant populations– to develop a plan to combat the crisis.21These range states developed the African Elephant Action Plan (AEAP),which was subsequently adopted by all of the range states; though thestrategies have not been implemented in most of them.12131415161718192021Id.Id. at 16-17Susan J. Keller, Is the International Ban on the Importation of Ivory Saving the AfricanElephant?, 3 COLO. J. INT’L ENVTL. L. & POL’Y 381, 393–95 (1992).Bill Padgett, The African Elephant, Africa, and CITES: The Next Step, 2 IND. J. GLOBAL LEGALSTUD. 529, 540-541 (1994-1995).Scott Hitch, Losing the Elephant Wars: CITES and the “Ivory Ban”, 27 GA. J. INT’L & COMP.L. 167, 170 (1998-1999).Id. at 184.Jeffrey Gettleman, Elephants Dying in Epic Frenzy as ivory Fuels Wars and Profits, NEW YORKTIMES, Sept. 3 2012, available at enzy.html.Id.Id.See Convention on International Trade in Endangered Species and Wild Fauna and Flora[CITES], Fifteenth Meeting of the Conference of the Parties, Doha (Qatar), Mar. 13–25, 15i-68.pdf.

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets937This pressing problem suggests a failure of the current system toprevent elephant poaching and the trade of illegal ivory. Currently, theinternational community is not united against the problem; there aremany different enforcement procedures, penalties, and rules about whatcan be done with elephant resources. Countries must implement a unifiedstrategy to quell the current problem. They need to do more than justadopt the AEAP; they need to effectuate the AEAP through creatinguniformed enforcement mechanisms including shoot-to-kill laws,garnering citizen support through sustainable use programs, andincreasing funding from both the international community andsustainable use programs.In Part I of this note, I discuss the history of CITES and thesubsequent changes to the law and different conservation strategies inAfrican countries through the 1990s. In Part II, I discuss the current risein elephant poaching and the international reaction to the problem. InPart III, I discuss the discrepancies in the laws of Botswana and Kenya aswell as the approach commissioned by CITES and the approach adoptedby the range states– the AEAP. Finally in Part IV, I argue that theAfrican range states need to properly implement the AEAP system,impose harsher enforcement mechanisms, and increase funding throughsustainable use programs and other means in order to combat the currentcrisis.I.THE INITIAL BAN AND THE SUBSEQUENT DEVELOPMENTS INELEPHANT PROTECTION LAWA. CITESIn 1975 ten states ratified CITES to protect wildlife (animals andplants) from exploitation often found in international trade.22 Themember states have since swelled to 175.23 CITES members meetannually to assess situations affecting wildlife and issue reports. Thisconvention sought to protect individual species and plants fromhumans.24 In order to accomplish this goal CITES classified animal222324Padgett, supra note 15, at 529.Joint Press Release, CITES, Experts Report Highest Elephant Poaching and Ivory tp:// elephant poaching ivory smuggling.php.Padgett, supra note 15, at 531.

HUTCHENS FINAL (DO NOT DELETE)9384/28/2014 3:01 PMWisconsin International Law Journalspecies in certain appendices depending on how threatened the speciesis.25 “CITES acts as the ultimate traffic cop, deciding when internationaltrade in certain species, whether the African elephant, jaguar, or exoticbirds, can continue unimpeded, when it must slow, and when it must stopentirely to avoid the tragedy of extinction.”26CITES established three different appendices to categorizeanimal species. The most protected species garnered Appendix I status.Species placed into Appendix I include “all species threatened withextinction which are or may be affected by trade.”27 Placement inAppendix I demands a halt on all trade of that species between memberstates.28 The next level, Appendix II, is the intermediate level. Itincludes “all species which although not necessarily now threatened withextinction may become so unless trade in specimens of such species issubject to strict regulation.”29 Regulated trade of Appendix II species isallowed, however, CITES requires member states to submit quotas ofhow much of an animal resource they are allowed to trade.30 The lastlevel, Appendix III, is the least regulated level. Appendix III statusincludes “all species which any Party identifies as being subject toregulation within its jurisdiction for the purposes of preventing orrestricting exploitation.”31Appendix III demarcation leaves allregulation matters of the species to the individual member states.B. THE FIGHT OVER A TOTAL BAN ON THE IVORY TRADEParties to CITES initially listed elephants in Appendix II. Underthe Appendix II listing, the CITES secretariat implemented a quotasystem in order to try to regulate the amount of ivory member states mayexport. Under this system each country determined its own quota for theamount of raw ivory they could export,32 which they set unreasonably2526272829303132INTERNATIONAL WILDLIFE TRADE: A CITES SOURCEBOOK, at ix (Ginette Hemley ed., 1994).Id.Convention on International Trade in Endangered Species of Wild Fauna and Flora, art. II(1),Mar. 3, 1973, 27 U.S.T. 1087 [hereinafter CITES].Padgett, supra note 15, at 533.CITES, supra note 27, at art. II(2)(a).Id.Id. at art. II(3).UNITED NATIONS ENV’T PROGRAMME, UNEP ENVIRONMENT BRIEF NO. 8, CITES THECONVENTION ON INTERNATIONAL TRADE IN ENDANGERED SPECIES OF WILD FAUNA ANDFLORA, 2, 4–5 (1989).

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets939high at levels their elephant populations could not sustain.33 Countriesmonitored their quotas with an elaborate system that was overseen by theCITES secretariat.34 However, this system failed, as it did not adequatelydistinguish legal from illegal ivory.35 Corruption overran many of thegovernment organizations responsible for monitoring and implementingthe policies.36 Poachers bribed officials in the system and legal andA combination of notillegal ivory became indistinguishable.37“providing adequate measures to combat poaching” and the free trade ofivory perpetuated a market for illegal ivory.38 Therefore, Africanelephant populations decreased dramatically.39In 1988 many countries, including the United States, WestGermany, and Kenya, took notice of this problem and advocated for aworldwide ban of ivory sales.40 These countries implemented unilateralbans on their export and import of ivory and advocated for areclassification of African elephants from Appendix II to Appendix Ispecies.41 The Kenyan government not only banned the killing ofelephants and the sale of ivory, but it also implemented a shoot-to-killpolicy.42 Shoot-to-kill policies allow rangers to shoot poachers on-sight.The Kenyan government would not even sell confiscated ivory or ivorytaken from elephants who died naturally because, as President Moistated, “we believe that this is only fueling the market.”43While some countries supported the ban on ivory trade, othercountries vehemently opposed it. Southern African countries did notwant to ban the sale of ivory outright both because they used theproceeds to fund elephant conservation efforts and because theirpopulations viewed elephants as nuisances.44 Zimbabwe, South Africa,333435363738394041424344Padgett, supra note 15, at 540.Harland, supra note 5, at 294 (citing UNITED NATIONS ENV’T PROGRAMME (UNEP), TheAfrican Elephant, (Nairobi: UNEP, 1989) 33-37).Harland, supra note 5, at 294.Yvonne Fiadjoe, CITES In Africa: An Examination of Domestic Implementation andCompliance, 4 SUSTAINABLE DEV. L. & POL’Y, no.1, 2004, at 38, 40.See id.Harland, supra note 5, at 295.Edwards, supra note 4, at 122.Glennon, supra note 4, at 15–16. This included both exporting governments, such as Kenya, andimporting governments such as the United States and West Germany. Id.Glennon, supra note 4, at 16.Id. at 15.Glennon, supra note 7, at 23 (citing SUNDAY TELEGRAPH (London), July 16, 1989, at 14.).Andrew J. Heimert, How the Elephant Lost his Tusks, 104 YALE L.J. 1473, 1474, 1483 (1995).

HUTCHENS FINAL (DO NOT DELETE)9404/28/2014 3:01 PMWisconsin International Law Journaland Botswana did not support the ban and intended to continue to exportivory to Japan, Hong Kong, and other countries in the Far East.45At the 1989 CITES meeting Kenya proposed changing the statusof African elephants from Appendix II to Appendix I.46 In order to movespecies from Appendix II to Appendix I, the species must satisfy theBerne Criteria.47 The primary criterion is that the “species must becurrently threatened with extinction.”48 The remaining Berne Criteriaallow countries to take other factors into account including economic andpolitical self-interest, ethical positions, and sentimentality.49 Countriesthat opposed the ban – lead by Zimbabwe – noted that, on the whole,African elephant populations were not threatened with extinction, onlythreatened in certain countries.50 Therefore, they argued that upgradingthem to an Appendix I species circumvents the Berne Criteria and thelaws set by this Convention.51Over the protest of Southern African countries, the pro-banlobby won the fight and African elephants were reclassified as anAppendix I species.52 The pro-ban lobby’s argument was strengthenedby the lack of adequate enforcement techniques for the current systemand the unilateral bans that some supporters put in place prior to the 1989meeting.53 However, the final push to gain the requisite backing andmove African elephants from Appendix II to Appendix I listing camefrom the actions of President Moi of Kenya, who set ablaze 3 milliondollars worth of ivory instead of selling it for government revenue.54Despite the apparent win for the pro-ban forces and Africanelephants, some of the member states rejected the ban and invoked45464748495051525354Glennon, supra note 4, at 16–17.See CITES, Seventh Meeting of the Conference of the Parties, Oct. 9–20, 1989, -Prop-26 Loxodonta AT.PDF.Harland, supra note 5, at 294-295CITES, First Meeting of the Conference of the Parties, Nov. 2-6, 1976, Berne, Criteria forAddition of Species and Other Taxa to Appendices I and II and for the Transfer of Species andOther Taxa from Appendix II to Appendix I [hereinafter Berne Criteria], available itch, supra note 16, at 178.Harland, supra note 5, at 294.Id. at 296.CITES, Seventh Meeting of the Conference of the Parties, Oct. 9-20, 1989, Lausanne,Amendments to Appendices I and II of the Convention, available o-Appendices.pdf.Glennon, supra note 4, at 15–16.Padgett, supra note 15, at 540.

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets941reservations.55 Reservations occur when a party in CITES opts out offollowing the policies such as a total ban on the trade of elephants.56 Anyparty to CITES is allowed to claim a reservation with respect to theamendments as long as they notify the secretariat.57 Usually countriestake reservations because of a significant economic interest in the tradeof that species.58 Despite these nations initial use of reservations, theyquickly caved to international pressure and withdrew their reservationsbecause of a decline in the international demand of ivory.59C. SINCE THE BAN: THE TWO APPROACHES TOWARDS MAINTAININGELEPHANT POPULATIONSAfter the move from Appendix II to Appendix I, two differentapproaches emerged towards how best to protect and utilize the elephantpopulation: 1) total ban pure protectionist and 2) sustainable use.60Proponents of the pure protections support “a complete ban on allhunting and cultivation of wildlife resources, and instead focuses onnonconsumptive activities such as tourism.”61 Kenya favored thisapproach towards its elephant population. Kenya fenced in reserves inorder to protect elephants by keeping them away from citizens.62The downside to this approach is it does not allow for revenuesfrom elephant resources, which can be used to fund the preservation ofthe species; instead, it relies primarily on funds from tourism.63 Despitethe downsides, the policies implemented by Kenya allowed theirelephant populations to recover. During the previous two decades (19701989), poachers reduced Kenya’s elephant population from 167,000 to17,000.64 Between 1989 and 2000, following the adoption of a shoot-to55565758596061626364Dennis McAuliffe, Jr., U.N. Conference Bars Ivory Imports, WASH. POST, Oct. 17, 1989, atA13.Padgett, supra note 15, at 536.CITES, art. XV, opened for signature Mar. 3, 1973, 993 U.N.T.S. 14537, available me%20993/volume-993-I-14537-English.pdf.Padgett, supra note 15, at 535.Id.Edwards, supra note 4, at 128–129.Id. at 128.Id. at 128.Id. at 128Kent Messer, Protecting Endangered Species: When are Shoot-on-Sight Policies the OnlyViable Option to Stop Poaching?, 69 ECOLOGICAL ECON. 2334, 2336–37.

HUTCHENS FINAL (DO NOT DELETE)9424/28/2014 3:01 PMWisconsin International Law Journalkill policy and fencing in reserves, Kenya’s elephant population grew to26,000.65Conversely, sustainable use “treat[s] species as resources to beused, rather than merely preserved.”66 As Zimbabwe President RobertMugabe said “we believe a species must pay [its] own way to survive.”67Elephants can be a drain on a country’s resources. The cost ofpreserving elephants can be quite high, which diverts needed funds fromother programs such as social services. Elephants can also be a nuisanceto citizens by taking their water and trampling their crops. Thereforesome African countries, including Botswana, Zimbabwe, and other statesin Southern Africa, want to control their elephant populations and usethem to help pay for their preservation.68 South Africa and Zimbabweemployed culling, the killing of some elephants in order to ensure thatthe population does not grow to unsustainable levels, to maintain theirelephant populations.69 Countries utilize culling to save elephants andtheir habitats.70 Culling also provides elephant resources, such aselephant meat, to the people.71 However, “culling adds to the ivorystockpile, creating pressure for increased trade.”72Sustainable use countries also implement programs that allowcitizens to benefit from elephants. In 1989 Zimbabwe countryimplemented the Communal Areas Management Programme forIndigenous Resources (CAMPFIRE). “CAMPFIRE asks local people tomanage their wildlife resources, on ‘the premise that the wildlife belongsto the person on whose land it is found.’”73 This program gave onepercent of the elephant population to the people, who were allowed toeither kill them and use them for resources or allow them to live. Thisprogram gave citizens a stake in the elephant’s future through economicincentives: a share of the profits from their elephants supports their areasand the rest supports preservation.74 CAMPFIRE, “earned enough fromthe sale of wildlife products (not just elephants) to support its65666768697071727374Id. at 2337.Edwards, supra note 4, at 129.Id.See Id.Padgett, supra note 15, at 543.Id.Id.Hitch, supra note 16, at 189.Heimert, supra note 44, at 1483.See id.

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets943conservation at a level well above the norm and to support its purchasesof otherwise unaffordable social services.”75D. AFTERMATH OF THE UPGRADE IN THE AFRICAN ELEPHANTS’STATUSThe ivory ban squelched the worldwide demand for ivory.Initial data after the 1989 ban showed a sharp decrease in the price ofivory.76 The price of ivory collapsed in most parts of Africa.77 In theCentral Africa Republic, the price of ivory dropped to 65 percent lessthan the price in mid-1989.78 The South Africa government, a countrythat took a reservation on the ban, did not receive a bid on the 1.3 tons ofivory it had stockpiled.79 While the ban made it harder for poachers tosell illegal ivory, it also made it impossible for countries to sell theirstockpiles of ivory.80Throughout the 1990s elephant populations started to recover.81With their recovery, nations that employed sustainable use methods topay for the preservation of elephants wanted to sell their ivory stockpiles.Zimbabwe, Botswana, and Namibia lobbied to have their elephantpopulations moved from Appendix I to Appendix II and to get approvalfor a one time ivory trade with Japan.82 After much debate, the initiativewas passed in 1999.83 This allowed the countries to fuel theirpreservation efforts with the proceeds from the ivory sale. However, thetemporary lift on the complete ban led to renewed poaching as well asthe ineffective enforcement of a trading system and highly weaponizedpoachers who were present before the initial ban.84 . Parties to CITESrelaxed the ban again in 2008 to allow for another one-time sale in ivoryfrom those three countries.857576777879808182838485Id.Jeffery Vail, Halting the Elephant Ivory Trade: A True Test for International Law, 9 WIS. INT’LL.J. 227, 244 (1990-91).Id.Id.Id.Edwards, supra note 4, at 127.Messer, supra note 64, at 2337.Shawn M. Danksy, The CITES “Objective” Listing Criteria: Are They “Objective” Enough toProtect the African Elephant?, 73 TUL. L. REV. 961, 971–972 (1999).Id.Hitch, supra note 15, at 184.Joint Press Release, CITES, supra note 23.

HUTCHENS FINAL (DO NOT DELETE)9444/28/2014 3:01 PMWisconsin International Law JournalAs a result of the changed status allowing some nations toreinstate ivory trade, the international community no longer has a unifiedapproach to the problem and there is a renewed market for ivory. Whilethis allows for demand to continue, it also benefits the economicdevelopment of Southern African countries. However, nations withelephant populations need to actually enforce a uniform plan to bestaddress the problems of elephant conservation.II. ELEPHANT POACHING ON THE RISEA. THE THREAT TO THE ELEPHANTIn the last few years, reports surfaced addressing the renewedelephant poaching crisis in Africa.86 As the Washington Post reported inOctober 2012, “elephant poaching levels are currently at their worst in adecade, and seizures of illegal ivory are at their highest level in years.”87The UN acknowledged the problem in June 2012 stating that poaching isplaguing the African elephant population.88 The UN also reported thatelephant poaching is the highest it has been since 1989 and that theillegal ivory trade has gotten worse.89 The conservationist Ian Craig908687888990See Gettleman, supra note 18; Jethro Mullen and Dayu Zhang, Booming Illegal Ivory TradeTaking Severe Toll on Africa’s Eelephants, Groups Say, CNN, Sept. 5, 2012, available a-ivory-elephant-slaughter/index.html; GayneC. Young, 22 Elephants Shot from Helicopter, Africa Facing its Worst Poaching Spree g-spree-ever; David Braun, Philippines to Prosecute Ivory rs/; Apolinari Tairo, Poaching threatens Africa elephants and tourism, ETURBONEWS,Oct. 4, 2012, available at -africaelephants-and-tourism.Slaughtering Elephants for Ivory, WASH. POST, Oct. 2012, available 736f4ba-0c14-11e2-bb5e-492c0d30bff6 gallery.html#photo 1.Amantha Perera, UN-backed Report Finds that Elephant Poaching Levels are Worst in g/apps/news/story.asp?NewsID 42295&Cr endangered species&Cr1 #.UEpn9KT-9ao; See also Philipp Barth, Elephant Poaching in Africa Continues Unabated, DW (Nov.30, 2012), nues-unabated/a-16419764; AnneLook and William Eagle, Interpol Conducts ‘War’ on Poaching in Africa, VOICE OF AMERICA(Nov. 26, 2012).Id.Ian Craig is a founding member of both Namunyak Wildlife Conservation Trust and II NgwesiGroup Ranch in 1995. As executive Director of the Lewa Wildlife Conservancy, Ian was a

HUTCHENS FINAL (DO NOT DELETE)Vol. 31, No. 44/28/2014 3:01 PMThe Law Never Forgets945noted that poaching is “the worst it’s been in the last 30 years. . . . It’s asteady deterioration, and it’s getting worse.”91In 2010-12, the elephant population took a dramatic hit. Reportsindicate that poachers killed upwards of 20,000 elephants in thoseyears.92 In Kenya, the number of elephants killed every year skyrocketedfrom fifty in 2007 to 300 in 2012.93 In early 2013, Kenya experienced itsworst poaching in three decades, including when armed poachers killed afamily of eleven elephants in one incident.94 This staggering increase inthe level of poaching is occurring throughout Africa.95 Outdoor Lifenewspaper quoted a Ugandan ranger, stating, “it was the worst slaughter[I have] seen in 30 years of fighting poachers.”96 As the below graphindicates, the amount of illegal ivory seized is on the rise.919293949596founding member of the Northern Rangelands Trust. He has spent most his life in northernKenya dealing with the multiple conservation issues there. M. Sanjayan, Kenya Takes DrasticSteps to Save Elephants, CBS NEWS (Nov. 26, 2012), phants/.Id.Look, supra note 88.Barth, supra note 88.Kenya Hunts for Armed Elephant-Poachers: Wildlife Rangers are Searching for Poachers inWhat Officials say is the Worst Elephant Killing in Three Decades, ALJAZEERA (Jan. 8, /2013181422525172.html.Look, supra note 88.Young, supra note 86.

HUTCHENS FINAL (DO NOT DELETE)9464/28/2014 3:01 PMWisconsin International Law Journal97This dramatic increase is worrisome for African nations becauseelephants serve as a valuable resource. The rise in poachers deprives thenations of their elephant population and the money generated from thatpopulation, either by tourism or through programs such as CAMPFIRE.The poaching problem presents another economic resource problem fornations as the demand for funds needed to protect elephants continue toincrease. Ian Craig discussed the Kenyan problem, “it is not a winnablewar in the long term. . . . As a country, we can’t keep putting this level ofresources into the protection of elephants forever.”98 While Craig isspecifically discussing the problems that Kenya faces, this is truethroughout Africa. Craig argues that African elephants produce fundsbeneficial to the nation, and when citizens realize the benefit it is easierto garner support to protect against poaching.99 Craig goes on to explainthat where the benefits from elephant conservation are apparent tocommunities and Kenyans see “money being generated from tourismgoing into education, [and] water projects,” citizens support theconservation of elephants.100 However, where citizens do not recognizethe financial benefit of elephant conservation they do not support the979899100Look, supra note 88.Sanjayan, su

Vol. 31, No. 4 The Law Never Forgets 935 INTRODUCTION The African elephant is the largest land-dwelling animal on earth.2 Unlike the Asian elephant, the African elephant develops large ivory tusks. Individuals covet these tusks, usually tusks that are larger and stronger, in order to manufacture and sell goods.3 The only way to

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