Comment on FR Doc # 2012-19071

Dear Sir/Madam, I would like to comment on this proposal in my capacity as Chair of the IUCN Sustainable Use and Livelihoods Specialist Group (SULi). This IUCN Specialist Group is one of the few cross-Commissional IUCN Specialist Groups, established under the auspices of both the SSC (IUCN Species Survival Commission) and the CEESP (IUCN Commission on Environmental, Economic and Social Policy). This reflects the increasing recognition within IUCN that conservation and sustainable use are intimately bound up both with each other and with the livelihoods of people. These insights are also fundamental to policy developments within the Convention on Biological Diversity (CBD) and the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). With reference to your points 4(a)(b)(d)(e) and 5, I attach a copy of the recently concluded IUCN SSC Guiding Principles for Trophy Hunting as a Tool to Generate Conservation Incentives. This document highlights the potential for well-managed trophy hunting to generate local benefits and support for conservation, reduce human-wildlife conflict, and raise revenue to enable critical management activities such as enforcement and research. It further (see Annex) describes trophy hunting of straight-horned markhor in the Torghar Valley as a case example of the positive impacts that such hunting programmes can have in terms of local benefits, attitudes toward wildlife, local management and enforcement capacity and institutions, and consequent population recovery. Key references are included. The locally-led conservation efforts at Torghar provide a outstanding example of robust and effective management leading to conservation success. A situation of rampant overexploitation has been transformed into a high-value, low-impact harvest, with strong local support for conservation efforts and robust management institutions. This situation strongly warrants recognition by this downlisting.