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THE UTILISATION OF WILDLIFE IN TANZANIA: KEY ISSUES AND EXPERIENCES Martin Walsh Cambridge,October 2006 paper prepared for BEES Consulting Group (BCG), Johannesburg (input to A Comparative Study of Commercial Consumptive and Non-Consumptive Utilization Options for Wildlife Consemation Strategies in Kenya, commissioned by the International Fund for Animal Welfare (IFAW), East Africa) Introduction This is not a literature review, but an outline of key issuesand experiences relating to different forms of wildlife utilisation in mainland Tanzania (semi-autonomous Zanzibar has its own wildlife policies and legislation, and will not be discussed further here). The paper focuses on two critical subjects: ongoing debate about the developmentof community wildlife management (CWM) in Tanzania,and increasing concern about the organisationand practice of tourist and other kinds of hunting in the country. It is illustrated with referenceto both academic and project-basedresearch about the SelousGame Reserve and other well-studied cases. First some background information. Tanzaniais famed for its natural landscapes and wildlife, and protectedareas (PAs) of different kinds are estimated to cover more than a quarter of its land surface(Severre2000). Tourism contributesdirectly to more than l5Yo of GDP and is the country's secondmost important source of foreign exchange earnings after agriculture. Game viewing or photographic tourism is by far the most important kind of non-consumptive wildlife utilisation in Tanzania; hunting is the only economically significant form of consumptive utilisation. Two principal kinds of hunting are permitted under license: tourist hunting and resident hunting, the latter being restricted to Tanzaniancitizens and resident foreigners. Subsistence and illegal hunting also occur widely, as does commercial poaching, though this is often said to be less of a problem than it was in the 1970s and 1980s before the nationwide anti- poaching campaign (Operation Uhai) that took place in 1989 (cf. Gordon 1991). Table I below provides basic information on the different categories of PA that are set aside for the conservation and utilisation of wildlife (excluding forest and marine reserves). Ngorongoro Conservation Area forms a special category with its own legislation and governing authority. The 14 National Parks (NPs) ile managed by a government parastatal, TanzaniaNational Parks (TANAPA); all the other areasshown come under the authority of the Wildlife Division $fD) in the Ministry of Natural Resources and Tourism (MNRT). The NPs are designed exclusively for non- consumptive tourism, and the Game Reserves(GRs) for tourist hunting. Different kinds of utilisation and hunting can be authorised in the Game Controlled Areas (GCAs), which are gazettedon village lands. Open Areas (OAs) are village lands which have no conservation stafus, but have been designatedfor tourist or resident hunting by the WD. Wildlife Management Areas (WMAs) are a newly-introduced category of community-managed PA that are expected to take the place of many existing GCAs and OAs.

The Utilisation of Wildlife in Tanzania: Key Issues and Experiences

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A paper by Martin Walsh outlining key issues in wildlife utilisation in mainland Tanzania. Citation: Walsh, M. T. 2006. The Utilisation of Wildlife in Tanzania: Key Issues and Experiences. Paper prepared for A Comparative Study of Commercial Consumptive and Non-Consumptive Utilization Options for Wildlife Conservation Strategies in Kenya. Johannesburg: BEES Consulting Group (BCG), for the International Fund for Animal Welfare (IFAW), East Africa.

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Page 1: The Utilisation of Wildlife in Tanzania: Key Issues and Experiences

THE UTILISATION OF WILDLIFE IN TANZANIA:KEY ISSUES AND EXPERIENCES

Martin WalshCambridge, October 2006

paper prepared for BEES Consulting Group (BCG), Johannesburg(input to A Comparative Study of Commercial Consumptive and Non-Consumptive Utilization Options

for Wildlife Consemation Strategies in Kenya, commissioned by the International Fund for AnimalWelfare (IFAW), East Africa)

Introduction

This is not a literature review, but an outline of key issues and experiences relating todifferent forms of wildlife utilisation in mainland Tanzania (semi-autonomousZanzibar has its own wildlife policies and legislation, and will not be discussedfurther here). The paper focuses on two critical subjects: ongoing debate about thedevelopment of community wildlife management (CWM) in Tanzania, and increasingconcern about the organisation and practice of tourist and other kinds of hunting in thecountry. It is illustrated with reference to both academic and project-based researchabout the Selous Game Reserve and other well-studied cases.

First some background information. Tanzania is famed for its natural landscapes andwildlife, and protected areas (PAs) of different kinds are estimated to cover more thana quarter of its land surface (Severre 2000). Tourism contributes directly to more thanl5Yo of GDP and is the country's second most important source of foreign exchangeearnings after agriculture. Game viewing or photographic tourism is by far the mostimportant kind of non-consumptive wildlife utilisation in Tanzania; hunting is theonly economically significant form of consumptive utilisation. Two principal kindsof hunting are permitted under license: tourist hunting and resident hunting, the latterbeing restricted to Tanzanian citizens and resident foreigners. Subsistence and illegalhunting also occur widely, as does commercial poaching, though this is often said tobe less of a problem than it was in the 1970s and 1980s before the nationwide anti-poaching campaign (Operation Uhai) that took place in 1989 (cf. Gordon 1991).

Table I below provides basic information on the different categories of PA that are setaside for the conservation and utilisation of wildlife (excluding forest and marinereserves). Ngorongoro Conservation Area forms a special category with its ownlegislation and governing authority. The 14 National Parks (NPs) ile managed by agovernment parastatal, TanzaniaNational Parks (TANAPA); all the other areas showncome under the authority of the Wildlife Division $fD) in the Ministry of NaturalResources and Tourism (MNRT). The NPs are designed exclusively for non-consumptive tourism, and the Game Reserves (GRs) for tourist hunting. Differentkinds of utilisation and hunting can be authorised in the Game Controlled Areas(GCAs), which are gazetted on village lands. Open Areas (OAs) are village landswhich have no conservation stafus, but have been designated for tourist or residenthunting by the WD. Wildlife Management Areas (WMAs) are a newly-introducedcategory of community-managed PA that are expected to take the place of manyexisting GCAs and OAs.

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Table 1: Protected Areas and Hunting in Tanzania(based on Severre 20001'2003)

Problems with Community Wildtife Management in Tanzania

For more than a decade, debate about wildlife utilisation in Tanzania has focused onthe pros and cons of CWM as an alternative or supplement to "fortress conservation",the traditional approach to conservation based on the creation of parks and reservesdesigned in part to protect wildlife and game resources from their unauthorised use bylocal people. Colonial Tanganyika was one of the first African countries toexperiment with a form of community-friendly conservation: the NCA was intendedto provide for the coexistence of Maasai pastoralists and wildlife in the wider regionincluding Ngorongoro Crater. Recent research, however, has highlighted theprogressive erosion of Maasai rights in the conservation area (Shivji & Kapinga 1998;Lissu 2000). Meanwhile, a study of the exclusion of Maasai and other local peoplefrom Mkomazi Game Reserve in north-east Tanzania has become one of the mostwidely read sources for the academic critique of "fortress conservation" (Brockington2002). Despite its claim to a long history of actively promoting community-basedwildlife management,Tatuarria is held up as an example of the very opposite.

Category ofProtected (orother) Area

Legal mandate / governmentauthoritv

Villages? Touristhunting?

Residenthunting?

NgorongoroConservation Area(NCA)n: l

Ngorongoro Conservation AreaOrdinance, 1959 / NgorongoroConservation Authoritv Authoritv(NCAA)

yes no no

National Parks(NPs)n:14

National Parks Ordinance,1959 IT anzania National Parks(TANAPA)

no no no

Game Reserves(GRs)n:33

Wildlife Conservation Act 1974 IWildlife Division (WD)

no yes no

Game ControlledAreas (GCAs)n:43

Wildlife Conservation Act, 1974 /Wildlife Division (WD)

yes yes yes

Open Areas (OAs)n:?

Wildlife Conservation Act, 1974 IWildlife Division (WD)

yes yes yes

WildlifeManagementAreas (WMAs)n:0 (only pilotprojects)

Wildlife Conservation Act 1974 &Wildlife Conservation (WildlifeManagement Areas) Regulations,2002 /Wildlife Division (WD)

yes yes yes

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Contemporary community-based approaches in Tanzania date from the late 1980s.Important milestones include the start of donor-funded projects in and aroundSerengeti NP (in 1986) and Selous GR (1988), the beginning of TANAPA's benefit-sharing progftunme (1988), and preparation of the first draft. Policy on WildlifeConservation and Utilisation (1988). The resulting Wildlife Policy of Tanzania waseventually published ten years later, in March 1998 (URT 1998). While calling forthe maintenance of the core PAs - NPs and GRs - the new policy also advocated theestablishment of community-run WMAs, to be managed by Authorised Associations(AAs) representing the communities concerned. This proposal was based on localproject experiences as well as lessons learned from the development of CWM inZatrb:Joia. Zimbabwe and Botswana. It became law at the end of 2002 when the WDpublished its WMA Regulations, supported by explanatory Guidelines (URT 2002a;2002b). Following a workshop in 2001, work was also begun on the preparation ofnew legislation to replace the Wildlife Conservation Act of 1974 (for more details ofthis history see Hartley 1997; Walsh 2000;2001;2003; Goldman 2001;2003; Siege2001; Gardner et a|.2004; Stolla 2005).

Sixteen areas were selected for piloting the new WMA Regulations; these includedCWM initiatives around the Selous and elsewhere in the country that were alreadybeing supported by donor-funded projects (cf. the list in Baldus et a|.2004). Thethree-year pilot period has passed, however, without any of the pilot WMAs satisffingthe new legal procedures and receiving user rights over wildlife resources. Thedevelopment of CWM in Tanzarria through the establishment of community-runWMAs is generally perceived to have stalled, and one donor (USAID) is currentlyfunding a study (by WWF Tanzania) of the WMA pilot process and its problems.Observers have already highlighted a series of difficulties with this process (Goldman2001;2003; Walsh 2003; Baldus et a|.2004; Gardner et aL.2004; Stolla 2004). Hereis one account:

"The WMA Regulations define what WMAs are: "village land set aside for wildlifeconservation" (Section 2.2) which are created according to decisions by the Village Assemblyand Village Council. The WMA Guidelines state that the purpose of WMAs is "to enable thelocal communities living in villages to participate in the protection and utilization of wildliferesources on village land."

The WMA Regulations provide detailed provisions for establishment of the WMAs,which are roughly as follows:

1. The Village Assembly decides to form a WMA based on the recommendations of theVillage Council.

2. The villages forming the WMA on parts of their lands form a community-basedorganisation (CBO), and register it as such with the Ministry of Home Affairs accordingto the provisions of the Societies Ordinance.

3. The villages prepare land use plans which provide for the proposed WMA on theirlands. These land use plans are to be subjected to basic environmental impactassessments.

4. The CBO prepares a general management plan for the WMA, or as an interim measurefor up to five years, a more basic resource management zone plan showing thedesignation of different resource uses in the WMA

5. The CBO can then, following the completion of the above steps, apply to the Director ofWildlife to become an Authorized Association (AA), meaning the CBO has beengranted user rights for wildlife in the WMA.

lf the CBO is granted user rights by the Director (meaning the Director approves the CBOsapplication) and becomes an Authorized Association, then the WMA is gazetted and comes

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into existence. A number of the pilot WMAs, however, have a very important caveat emptorwhich must be added to the above procedures. According to the WMA Regulations, forvillages situated in Game Controlled Areas, the Game Controlled Areas must be transferredto village land status before the WMA can be created [...].

Additional procedures apply for the AA to enter into investment agreements in the WMAs asmay be desirable in order for the community to generate benefits from wildlife throughcommercial activities such as tourism or hunting. lnvestment agreements also are subject toEnvironmental lmpact Assessments and all investments in WMAs must be approved by theDirector of Wildlife.

The WMA Regulations represent a major legal reform in the wildlife sector. The question is:do the WMA Regulations fulfil the goal of the Wildlife Policy of Tanzania to enable localcommunities "to manage wildlife on their land for their own benefit." There are a number ofproblems with the WMA Regulations in terms of their realizing this aim. The proceduralrequirements of the Regulations for communities to form WMAs are daunting and complex ashas been reported by local representatives in many seminars and workshops during the pasttwo years. Some requirements, such as formation of CBOs and development of participatoryland use plans subjected to Environmental lmpact Assessments, may take several years tocomplete. More problematic are those procedural hurdles, particularly the transfer of reservedland in Game Controlled Areas to village lands, for which the way forward is not addressed bythe Regulations. /f is partly because of the complexity of these procedures fhaf as of January,2005, two years after the launching by the Ministry of the WMA Regulations, none of the pilotWMAs have yet been gazefted.

Second, even if communities are able to complete all the procedures and form WMAs, thedegree of authority they receive for management of these areas is limited. All investments inWMAs must be approved by the Director of Wildlife, and liftle influence on hunting blockallocation is granted to local people and instead remains with the Director of Wildlife. Section73.1 ot the WMA Regulations is a problem because it states that benefit sharing will bedetermined by circulars issued by the Ministry from time to time. This means that thecommunities establishing WMAs do not know what proportion of the revenue in the WMAsthey will keep and what proportion will go to the Government. This is a serious problembecause it undermines the potential for WMAs to compete with other forms of land use andfor communities to evaluate the sensibility of forming a WMA in the first place." (Stolla 2005:6-8, spelling and punctuation corrected)

The process laid down for establishing a WMA is far too complex and costly, and isproving difficult for communities to complete even with the help of funds andtechnical assistance provided by bilateral donors and NGOs. To make matters worse,some donors (including DFID) have withdrawn their support from CWM projects inTanzaria following changes in their funding priorities (now brought in line with theMillennium Development Goals and Tanzania's Poverty Reduction Strategy Paper,which has led to reduced assistance to the environment and natural resources sector).It is difficult to see how remote rural communities can satisff the legal requirementsfor registering an AA and gazettinga WMA without this kind of help.

When the WMA process was being developed, critics in Tanzania pointed out thatrather than straightforwardly empowering communities to manage their own wildliferesources, the balance of power remained with govemment, and in particular with theWD and its Director. User rights could have been devolved to communities usingexisting legislation and without all the complications that the new legal frameworkhas brought (Shauri 1999; Goldman 2001; 2003; Shivji 2001). But the currentprogess, which has taken so long to develop, falls way short of the original ideals ofthe proponents of CWM in Tanzania:

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"Rather than embracing active participation, WMAs present new ways in which communitiescan be acted upon. Communities are clearly not to be trusted to completely take over themanagement of a resource as valuable wildlife, and therefore in the end, despite thediscussion of a "transfer of management" of WMAs to local communities, "the State will retainthe overall ownership of wildlife." As one of the many stakeholders, the community is entitledto receive "user rights" to wildlife, provided they follow policy guidelines outlined by the state(the Wildlife Division, within the Ministry of Natural Resources and Tourism). While thisprovision of use rights to wildlife is a radical break from past wiHlife conservation policies inTanzania and a definite positive step towards embracing the community, it falls short ofconstituting active participation. The allocation of use rights by the Minister (who alsomaintains the right to revoke such rights) reflects a top-down distribution of privileges tocommunity members, rather than acflye participation. Even where management rights aretransferred, local communities are not recognized as capable decision-makers. Rather, theyare seen as "subjects of the state," or tools of conservation, that rteed to be "educated,

informed and guided" through standardized training, technical assistance and supervision toproperly manage naturalresources."" (Goldman 2001: 56)

The development of wildlife policy and institutions are everywhere subject to politicalpressures (cf. Gibson 1999), and the evolution of CWM and the WMA process inTat:..z:ania are no exception. International agencies have provided the main impetus forthe promotion of CWM in Tanzania over the past two decades; the resulting changesto policy and practice continue to meet with considerable resistance both within andoutside of government, especially from conservative game officers and residenthunters who are unwilling to pay the extra costs that community ownership of wildlifeentails. Many WD staff remain openly sceptical of CWM, argurng that it is thedonors' and not an indigenous Tanzanian agenda. These arguments have spilled overinto public debate among wildlife professionals and academics in Tanzania, and canbe followed in articles published over the years in the quarterly magazine KakalarcnalTanzania Wildlife, published by the Tanzania Wildlife Protection Fund (TWPF) inWD headquarters (Walsh 2003). Lack of support for CWM and especially its moreradical political consequences played a large part in the creation of a WMA processthat was more complex than it needed to be, and has also undoubtedly contributed tothe subsequent stalling of the process.

The intemational community, meanwhile, has also lost some of its initial enthusiasmfor CWM. Critics include both conservationists who doubt that it can provideeffective protectioq for wildlife, and economists who doubt that it can provide all ofthe social and ecoqomip benefits that are claimed (for these debates see, for example,Barrow et a\.2000;F.:oe et at.2000; Hulme & Murphree 2001; Elliott 2002; Walpole& Thouless 2005). Relatively liule information is available on the impacts of existingCWM initiatives in Tanzani4 and most evaluations have been written by project staffor researchers with a pro-CWM or related agenda. It has also proved difficult toassess impacts given the relative youth of most initiatives and the extent to which theyhave been supported and subsidised with donor funding. The most detailed work todate has been undprtaken in villages in Morogoro District that have bee4 affiliated tothe GTZ-funded Selous Conservation Project (Gillingham 1999; Hahn & Kaggi 2001;Ashley et aL.2002). These and other studies suggest that there is considerable scopefor increasing revenues and livelihood impacts in many pilot WMAs, and that infavoured locations wildlife tourism may provide much better revenues than in lessaccessible areas, where income from tourist and resident hunting has been importantin sustaining CWM (Emerton & Mfunda 1999; Holmern et al. 2002;2004; Walsh2003; Gardner et a|.2004).

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Problems with Hunting in Tanzania

While most debate about wildlife conservation and utilisation in Tanzania has focusedon the pros and cons of CWM, the spotlight has recently been turned on hunting(Nshala 1999; Majamba 2001). Although CWM is compatible with different kinds ofutilisation, it has been strongly resisted by some sections of the hunting community inTat:r;aria, unwilling to cede control and share the benefits of hunting with localcommunities. This resistance and the many problems that beset the towist huntingindustry in Tanzania are examined in a recent report (Baldus & Cauldwell 2004),which I will quote from at length. The following paragraphs are taken from itsexecutive swnmary:

"Tourist hunting in Tanzania has developed over a long period and is now a well establishedindustry and a principle source of income for vast areas of the country. The industry hasdemonstrated an impressive growth in recent years and is an important source of foreignexchange to Tanzania. However very little information is available on the industry and manyaspects are shrouded in secrecy.

The Wildlife Division of the Ministry of Natural Resources and Tourism has developed acommand system of control that favours a select group of hunting outfitters with reducedincome generation and the exclusion of communities who are the legitimate holders of theland upon which hunting takes places. Concessions are leased at rates far below the truemarket value, which represents a massive loss of income to the Wildlife Division (possiblyUS$ 7 million or more). Most of the concessions are leased to local companies that do nothave the capacity to market their hunting opportunities. A system of subleasing mostly toforeigners without any residence status in Tanzania has thus developed. Hunting issubleased at low rates and as a result much of the income that is now generated by theindustry never enters Tanzania and the Tanzania Revenue Authorities are unable to accessmuch of the funds that should be due for taxation. Outfitters are billed for their huntingactivities in a manner that they are shielded from financial risk by the Wildlife Division, and areable to accrue significant amounts of interest (estimated in excess of US$ 1 million) thatshould be going to the Government.

The Wildlife Policy formulated in 1998 describes the development of Wildlife ManagementAreas (WMAs) that are managed by the local communities. Tourist hunting is the landuseoption that will provide the major source of funds for WMAs. However the development ofWMAs is seriously delayed and there is still no effective schedule for sharing of benefits fromtourist hunting with the local communities on whose land hunting takes place. Outfitters arerequired to contribute towards protection and support local communities, but theserequirements are vaguely set in a manner that they cannot be effectively evaluated. As aresult most companies do mere window dressing. There is a general hesitation amongoutfitters to accept the WMA concept and effectively empower local communities. lt ispossible that much of the delay in development of WMAs is the result of negative high-levelinfluence by some hunting outfltters.

There is a general lack of will to improve the tourist hunting industry, and one can onlyspeculate on the reasons why. The lack of will is demonstrated in the following:

o There is a poor level of control. Hunting concession boundaries are not respectedand hunting takes place in areas specifically designated for nonhunting purposes,and hunting is frequently listed as taking place in areas other than where it actuallyhappens, despite direct supervision by Wildlife Division staff.

r Some concessions show extremely high levels of utilisation that are not sustainable,but offtakes are within quota set bythe Wildlife Division.

o Initiatives to effectively computerise the control of hunting and bring greatertransparency have twice been disregarded and a cumbersome manual system of

6

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issuing and checking permits is continued. The number and variety of animals huntedannually is far greater than can be manually evaluated. As a result, hunting quotautilisation is not clear and effective management of quota is not possible with thecurrent system.

o Ecosystem monitoring has fallen into disarray, and once reliable trends in wildlifepopulations are no longer available, yet the Wildlife Division has requested anincreased leopard quota from CITES and announced that it intends to increase theelephant quota. Distrust from the international community is bound to increasewithout effective supporti ng ecological data.

o There is a lack of standards in the private sector. Ethics are not maintained and thereis no internal control or training of professional hunters. Many young inexperiencedhunters are nevertheless authorised as professionals to guide foreign clients.

o A policy and management plan for tourist hunting was developed by the WildlifeDivision in 1995. This was signed and accepted by the Director of Wildlife but hasnever been implemented, possibly because it shows the way for comprehensivereform of the tourist hunting industry which includes introducing competition andincorporating communities as decision-makers with access to significant fundsgenerated from hunting.

The current system of controlling tourist hunting cannot continue much longer. lnternationalpressures will grow and will force change where it is needed. Pressures from within Tanzaniawill also demand change. Pressures from above are already coming from the Vice President'sOffice, while widespread demands among the numerous grassroots communities are building.To retain control, the Wildlife Division needs to be proactive through implementing effectivereform of the tourist hunting industry, but this is only possible if:

1. Effective market-based competition between outfitters is introduced, i.e. outfitters bidcompetitively against each other for concessions;

2. Control of subleasing is implemented, which may come naturally through effectivemarket-based competition;

3. Local communities are the principal decision makers for allocation of concessions andquota setting for hunting on their land, and they receive and manage the fundsgenerated on their land.

All this will be achieved by implementing the Policy and Management Plan for TouristHunting." (Baldus & Cauldwell 2004:4-5)

In the main text of their report, Baldus and Cauldwell elaborate further on theproblems mentioned above:

"A number of problems are known to exist within the tourist hunting industry. Many of theseare explained below. Problems are listed with the intention of encouraging discussion anddeveloping solutions. Responsibility of finding solutions however, rests with the WildlifeDivision.

lnadequate control

There are inadequate control mechanisms applied by the Wildlife Division and as a resultcorruption appears to have become ingrained into the primary means of control of hunting, i.e.game scouts supervising the actual hunt. The differences between the government gamescout salaries and the fees paid by foreign hunting clients is tremendous resulting in asituation where the game scout is easily bribed.. There is little effective control from the game reserve offices. Senior wildlife officials

seldom go on field visits and many hunting persons do not report to the local wildlifeoffices, and total control in most cases is reliant upon a game scout.

. Many outfitters tolerate and even encourage a corrupt practice of clients tipping the gamescout at the start of a hunting safari in return for 'no problem safaris'.

. Overshooting of permits does occur and trophies are discarded in the field, in such casesonly the better trophies being declared and exported.

o Hunting permits do not list the presence of observers and not all outfitters are honestlydeclaring the presence of observers in their hunting camps.

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. Very few wounded animals are declared. Very few hunting clients have proper huntingexperience and many professional hunters lack the necessary skills. Even the best huntersoccasionally lose wounded animals, and something is certainly fishy if outfitters declareless than 10% wounded animals lost. Statistics from the Selous hunting database revealthat a wounding rate of only 1.5% is declared.

P rofe ssion al h u nte rs n of profe ssion al

o Too many professional hunters are simply not competent to hunt big game in Tanzania.This lack of competence ranges from inadequate handling of large calibre firearms,inadequate field experience and ignorance of relevant Tanzanian law. The problem occursbecause there is no certification of competence for professional hunters in Tanzania. Awritten examination is required at present, but the standard of this exam is disgracefullylow and does not do justice to the industry.

. A fundamental problem is that there is nobody or organisation in Tanzania who couldcertify their competence. As a result the Wildlife Division issues only provisionalprofessional hunters licenses. Legally there are no licensed professional hunters inTanzania. Hunting is a dangerous sport and accidents frequently occur where evenexperienced professional hunters are mauled/killed by the animals they hunt. The WildlifeDivision is placing itself in a risky legal situation provisionally authorising persons ofunknown ability to guide high paying foreign tourists.

. Many young South African "professional hunters" are hunting in Tanzania. There isminimal big game hunting in South Africa and these people therefore have to gain theirexperience in Tanzania, yet are provisionally authorised as professionals from the start.

o Professional hunters that are disqualified for bad hunting practices elsewhere in Africa areallowed to guide hunting clients in Tanzania, even with the Wildlife Authorities having fullknowledge of the digressions of such professional hunters elsewhere.

. Some professional hunters have a disregard for the hunting regulations and aredisrespectful to wildlife officials. Evidence for this statement is the corruption of gamescouts and under-sized elephant trophies being shot. lssues are reported and the rogueelements in the industry are known, but appropriate action is seldom taken. Evenprofessional hunters that were barred at some stage from hunting in Tanzania are able torenew their licenses without difficulty.

o lnability of hunters to recognise sexual differences results in many female animals beinghunted mistakenly, particularly with leopard, topi, hartebeest and zebra.

U n de r-sized troph ie s are I eg al i sed

. Elephant trophies that do not meet the minimum standard are provided with the necessaryCITES export documentation.

. A promotional pamphlet produced by the Wildlife Division in 2002 shows a hunter posingwith an under-sized elephant trophy.

. Many other under-sized animals are also being hunted which are detrimental to thedynamics of populations, particularly lion, leopard and buffalo.

Ethical standards not maintained

r A number of hunting outfitters are not adhering to any code of ethics. Examples of ethicalcontraventions are:- Hunting from vehicles and a reluctance to walk- Wounded animals are frequently not followed- Commercial videos that are detrimental to the hunting industry are produced, in whichanimals are incited to charge and there is a blatant disregard of hunting ethics.Commercial photography fees are due but such videos are not declared and fees are thusnot paid.- Charging animals are sometimes shot above permit and/or quota requirements under theguise of 'self protection'- Hunting cats at night with artificial lights and calling of lions using tapes and other artificialmeans

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- Small aircraft are being used to easily locate trophy animals, particularly in areas wherewildlife populations are low and decent trophies are difficult to find.

Quota adjustments

o The Wildlife Division issues additional quotas to outfitters upon request during the huntingseason.

. There are allegations that quota are adjusted for some companies after the huntingseason has ended.

Environmental standards not maintained

o Environmental standards for hunting camps are inadequate, and the existing standardsare not enforced at all.

o In some camps there is an excessive accumulation of litter around hunting camps overmany years.

e Permanent constructions are not permitted but the use of cement in hunting camps iswidespread. Cutting trees for camp clearing and construction gets excessive. Many campsare located in ecologically sensitive sites but with little concern to the environmentalimpact.

Zanzibar not signatory fo C/IES

. Zanzibar wildlife authorities do not consider themselves signatory to CITES and make noattempt to control the export of CITES restricted wildlife products originating from themainland. Many countries are of the opinion that if a product is legally exported, then itmay be legally imported. There is a substantial loophole for the export of many wildlifeproducts without the full set of legal documentation, in particular to countries with laximport regulations.

Decl i n i n g w il dl ife pop u I atio n s

o Wildlife populations are declining in many parts of Tanzania and there is an effectiveshrinkage of many hunting areas as a result of increasing human settlement and due tothe bush meat trade.

Sub/easlng and /oss of revenue

o Subleasing of concessions is widespread. lt is estimated that up to 7oo/o of companiesleasing concessions are subleasing these in various ways. Sub-lessees possibly accountfor approximately 40o/o of the industry's income, yet there are no specific taxation controlson the sub-lessees who are gaining huge profits at the expense of the industry. Manyforeign PHs are bringing clients to sublet concessions, among these are PHs entering asundeclared observers, paying neither observer fees nor PH licenses.

Outfitters shielded from the competitive market

o The Wildlife Division is shielding its selected group of outfitters from natural market forcesresulting in a loss of income to the Tanzanian economy.

Outfitters are influential and manipulate senior government

. Some hunting outfitters are highly influential with the Government and influence the blockallocation processes and are partly responsible for delays in developing and implementingthe WMA concepts.

Sysfem of ad mi nistration

'. The Wildlife Division imposes an inflexible approach to marketing hunting in Tanzania

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o Rigid game fee schedules and a strong emphasis on trophy fees leaves the WildlifeDivision with no option other than to increase quota offtake to generate increased revenue

r lncome generation from the concessions is dependant solely on hunting and is notconducive to the development of other sources of income

o There has never been an inventory of the true value of the hunting concessions.

Lack of desire to improve the industry

. A policy and management plan for tourist hunting [...] was compiled by the WildlifeDivision and accepted in 1995 but has never been implemented. This plan is wellformulated and outlines the way for extensive reform in the industry. Many of the problemslisted above would be addressed through implementing this plan.

. Support has twice been provided for computerisation of the issuing of tourist huntingpermits by the PAWM project and through the Selous Conservation Programme. Neither ofthese initiatives has been maintained and instead an outdated and non-transparent systemof issuing permits is continued.

o The hunting operators association (TAHOA) argue strongly against reform. Influentialmembers of this association were able to convince even the Minister that higher prices forthe operators would force them to over hunt the wildlife resource to survive, which issimply wrong and one can only speculate about the underlying reasons. Experience showsthat the worse the players, the greater is the level of over-utilisation. To improve thesystem, the bad players must be removed!" (Baldus & Cauldwell 2004: 33-36)

This is a serious indictment. The full report provides detailed statistics on touristhunting in the Selous GR" together with summary information on hunting concessionselsewhere in Tanzania. It is estimated that in 2001 gross income from hunting inTaruaria amounted to around US$ 27.6 million, compared to US$ 22 million inZimbabwe, US$ 15 million in Botswana, and US$ 5 million in Namibia. This figurecould clearly have been higher (by US$ 7 million or more according to Baldus andCauldwell). At the same time this represents only a fraction of the income fromtourism, which earned Tatuaria around US$ 725 million in foreign crrrency in 2001.This suggests that even if the hurrting industry in Tanzania is put on a sounder footing,it will only ever provide a small portion of total revenue from different kinds ofwildlife utilisation. At present, though, hunting seems to be causing as much harm (towildlife and prospects for community benefrt) as good, despite the presence of some"ethical" hunting operations in the country.

In the May 2005 issue of ly'ican Indabc, which describes itself as a newsletter "for

hunter-conservationists and all people who are interested in the conservation,management and the sustainable use of Africa's wild natural resources", Baldus andCauldwell used their Tatrzarian experience to call for "a Debate on the Reform ofSafari Hunting". This elicited a number of responses from around the region,including two from Taruaniahighlighting the ways in which community rights to landand wildlife continue to be usurped despite the stated intentions of the Wildlife Policyand the new WMA Regulations (Nelson et al. 2005; Rodgers 2006). Baldus andCauldwell's report and the debate they have initiated does not extend to considerationof resident hunting in Tanzania" which is effectively subsidised by the state (fees aremuch are much lower than for tourist hunting) but suffers from many of the sameproblems of inadequate control, lack of professionalism, and often downrightcomrption. Resident hunters have also resisted the introduction of CWM in differentparts of Tanzania, though in some cases project intervention has forced them to acceptthe new dispensation (for the struggle that took place before the start of theMBOMIPA Project in Iringa see Hartley 1997).

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Conclusion

This brings us back to our earlier discussion about CWM and the stalling of the WMAprocess. Despite considerable backing over the years from the intemationalcommunity, it has taken Tarzaria two decades to reach a somewhat uncertain point inthe development of CWM. The basic problem is both political and economic:govemment has lacked the will to upset those with a vested interest in the status quo,among them its own officers and hunters who are reluctant to give up their controlover wildlife and the proceeds thereof. This is regrettable, because although CWMmay not be the only solution to the problems of conservation and development inwildlife-rich areas, it is surely people's right to exercise a greater degree of ownershipover these resources and their products than has been the case in the colonial andpostcolonial past. Resistance to CWM and related reforms is undoubtedly strongestamong groups who benefit from the misuse of these resources, to the detriment of thenation's wildlife, the people who share their village lands with these animals, and thewider economic good. The Tanzanian experience suggests that similar difhculties arelikely to occur whenever hunting is introduced in a country with comparable levels ofcomrption and problems of governance. While other kinds of wildlife utilisation,tourism included, can also be exploitative, the evidence indicates that hunting isespecially problematic and will prove diffrcult to reform.

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