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Inter-American Association for Environmental Defense

December 17, 2003

Mr. Steven A. Williams

Director

U.S. Fish and Wildlife Service

Telephone: (202) 208-4717

Fax: (202) 208-6965

Dear Mr. Williams,

As you know, on November 15,  new controls went into effect for big-leaf mahogany (S. macrophylla) under the Convention on International Trade in Endangered Species (CITES).  In light of the listing of this species under Appendix II of the agreement, we are writing to request that the U.S. Fish and Wildlife Service carefully monitor imports of this species, and reject any shipments that do not conform to the requirements of CITES.  Since the United States is the largest importer of Peruvian mahogany, it is imperative that the U.S. government send a clear signal that anything less than full compliance with the law is unacceptable.    

While the government of Peru has taken steps to curb illegal logging, Peruvian mahogany continues to be illegally and unsustainably extracted, endangering biodiversity and the lives of uncontacted indigenous people while undermining the rule of law and feeding a greater web of illegality.  Recent field data, corroborated by various experts on the timber extraction industry in Peru, indicate that Peruvian mahogany consistently fails to meet international standards for sustainable extraction, most notably in the lack of reliable forest inventory systems or management plans, key requirements for the compliance with CITES Appendix II[1].  Though Peru has recently created a system to assess and manage mahogany logged prior to the Appendix II listing,[2] and has started to implement a new forestry law, these regulatory mechanisms have not yet been effectively implemented.  Strict U.S. enforcement of these endangered-species protections will create a key impetus for improvement in logging practices and forestry enforcement, and thus assist Peru in meeting the goals to which it has committed under CITES. 

According to a recent report in the New York Times[3], as much as 90 percent of the 45,000 cubic meters of Peruvian mahogany exported to the U.S. last year may have been extracted illegally.  Logging records, permits, and export licenses are frequently falsified to facilitate the sale of the valuable wood. The Times cites Dr. Fabiola Muñoz, a former top official in Peru’s Ministry of Agriculture, who identifies institutional weakness and lack of technical preparedness among the authorities charged with overseeing the mahogany trade as key points for improvement. 

Although the Peruvian government has now taken critical steps to create the framework necessary for such an industry, enforcement mechanisms still leave much to be desired: internal politics, a lack of sufficient funding, and a culture of informality have proved formidable obstacles on the road to a sustainable future.  Our organizations have urged further cooperation between the Peruvian government and the U.S. State Department in order to forge agreements of technical and logistical cooperation.  This cooperation may soon lead to the creation in Peru of a forest management agency that can effectively monitor timber extraction and the chain of custody while ensuring compliance with CITES trade controls. 

U.S. and Peruvian authorities have confirmed that traffic in illegal mahogany is part of a greater web of illegality[4].  In fact, this was one of the reasons behind the listing of mahogany under the more stringent controls of CITES Appendix II.   In its efforts to support the rule of law across Latin America and the globe, the United States must take decisive action and demonstrate by example that illegal trade in endangered species will be challenged by the most effective and sophisticated law-enforcement mechanisms available.

As Colin Powell pointed out upon introducing the President’s Initiative Against Illegal Logging on July 28:  “Laws without enforcement are but hollow gestures.”  We are hopeful that the USFWS will fulfill the promise of the CITES agreement by actively combating the entrance of noncompliant mahogany into the United States.

Sincerely,

Ari Hershowitz

Director, BioGems Program, Latin America

Natural Resources Defense Council

Atossa Soltani

Executive Director

Amazon Watch

Wm. Carroll Muffett

Director of International Programs

Defenders of Wildlife

Scott Paul

Forest Campaign Coordinator

Greenpeace USA

Anna Cederstav

Program Director

Interamerican Association for Environmental Defense (AIDA)

cc:        John F. Turner,    Assistant Secretary, Bureau of Oceans and International

                                       Environmental and Scientific Affairs, U.S. Department of State

            Jan McAlpine,     Office of Ecology and Terrestrial Conservation, (OES),

                                       U.S. Department of State

            Patrick Cronin,    Assistant Administrator for Policy and Program Coordination,

                                       USAID