Federal Issue Brief

 Listing All Chimpanzees as Endangered (August 8, 2013)


​​FR Doc No: FWS-R9-ES-2010-0086; FWS Proposed Rule: Endangered and Threatened Wildlife and Plants; Listing All Chimpanzees as Endangered (August 8, 2013)

​​Brief Description:

The U.S. Fish and Wildlife Service (FWS) proposes to list all chimpanzees (Pan troglodytes) as endangered under the Endangered Species Act (ESA) of 1973, as amended.  The agency is taking this action in response to a petition to list the entire species, whether in the wild or in captivity, as endangered under the Act. The proposal constitutes the FWS 12-month finding on the petition and announces its finding that listing all chimpanzees as endangered is warranted.​

​Excerpts from AVMA Response:

The AVMA recognizes that the U.S. is a member of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and that the FWS has been designated under the ESA to carry out the provisions of CITES, which includes the Resolution Conf. 13.4 (Rev. CoP16), “Conservation of and trade in great apes,” that urges all member countries to “limit the international use of great apes to nationally approved zoological institutions, educational centres, rescue centres and captive-breeding centres in accordance with CITES .”

The current split-listing provides a mechanism by which the illicit wildlife trade can market young wild-caught chimpanzees because they are physically indistinguishable from legally obtained and owned captive chimpanzees of the same age.  The AVMA is aware, as stated in the proposed rule, that some poachers target mother chimpanzees with young so that they can sell the killed mothers for parts and meat and the orphaned chimpanzees as pets or for other purposes.  Eliminating the split-listing should simplify and enhance ESA enforcement efforts, which in turn will help to further curtail illicit trade and thereby provide additional protection to the wild chimpanzee populations.

The AVMA is an advocate for animals and their health and welfare and is concerned about the possible extinction of many animal species, including chimpanzees.  In addition to recognizing vulnerabilities of the remaining chimpanzee populations, the critical need for protecting these animals, and their representation of an important gene pool of great value to conservation efforts, the Association is a member of the Multinational Species Coalition, which supports the Great Ape Conservation Fund as well as other Multinational Species Conservation Fund programs.  The AVMA has concerns about animal welfare, husbandry, infectious diseases, and public health and safety relative to ownership of wild animal species such as chimpanzees.  

While the AVMA recognizes that some individuals and organizations may be negatively impacted by the proposed rule if enacted, we also see the regulatory change as a critical and not lightly taken step in protecting the endangered wild populations that continue to decline.  Although the AVMA supports the proposed rule for this reason, we are gravely concerned for the future health and welfare of the chimpanzees presently maintained in captivity by those who, for whatever reason, will be unable to keep them under the proposed regulatory changes.  

Because zoological parks generally do not accept pet chimpanzees and most of the captive chimpanzees impacted will likely never be fit to return to the wild, the AVMA understands that accredited sanctuaries specifically permitted by the FWS to house chimpanzees would be their primary legal destination under the proposed regulatory change.  Unfortunately, many of these facilities may already be at or near capacity, and additional space, facilities, personnel, and funds will be required by sanctuaries if the proposed rule is enacted.  Furthermore, pre-existing behavioral traits or health conditions of some of the animals in question may pose dangers to themselves or other chimpanzees currently living at those facilities.

To ensure the welfare of chimpanzees retired to sanctuaries is protected, AVMA believes it important that oversight through third-party inspections of housing, handling and management is assured.

With technological advances and alternative models, the need for chimpanzees in research has greatly reduced.  But if research is needed, the AVMA understands that such is (50 CFR 17.32) and would continue to be (50 CFR 17.22) subject to consideration and potential permitting by the Director of the FWS if deemed appropriate.

Activities that substantially compromise animal welfare should be prohibited.  ​Such activities include handling and contact by the general public of animals that are ill, of unknown health status, or that are of a vulnerable age such as neonatal to juvenile non-human primates.

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