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      ALIVE 
        All Life In a Viable Environment 
        5-18-10-102, Honkomagome, Bunkyo-ku, Tokyo, 113-0021 
        Japan 
        Tel.+81-3-5978-6272  
        Fax..+81-3-5978-6273 
        
        Anti Vivisection Action Network 
        
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                                          A
                                                letter to demand the refusal
                                                of permission of the import of
                                                Borneo elephants. 
                                                                                    
                                          October 6th , 2003 
                                               
                                           
									   
										
                                          Minister of the Economy, Trade and
                                            Industry 
    Mr.Shoichi Nakagawa 
     
    Minister of the Environment 
    Mrs. Yuriko Koike 
     
     
    We have been informed from an international NGO, which is working on protecting
    the wild Asian elephants captured in Sabah, Borneo (Malaysia) and are intended
    for export to Japanese zoos. 
     
    We have serious concerns that the intended ex/import may not be in compliance
    with CITES provisions. We would therefore like to request the Japanese government
    not to permit the importation until after investigating this case. 
     
    1. The import of these elephants will threaten the survival of the species. 
                                           
                                          Asian elephants are listed on Appendix
                                            I of CITES and may only be im/exported
                                            under strict conditions. According
                                            to Article III, paragraph 2a, an
                                            export permit should only be granted
                                            if the export is not detrimental
                                            to the survival of the species. 
                                               
    Borneo elephants have only recently been found to be genetically distinct
    from other Asian elephants subspecies, which have followed an independent
    evolutionary path in an isolated environment.(See attached article) 
     
    Genetic research has found that contrary to the former belief that elephants
    were introduced to Borneo in the 18th century it has now been found that
    elephants are indigenous to Borneo, and have experienced an independent evolutionary
    development for at least 18,000 years. 
     
    The population number of Borneo elephants is estimated to be very low, between
    1,000 to 2,500 animals in total. Their distribution is very limited, fragmented
    and restricted to 5% of the northeast of Borneo only. Moreover, genetic diversity
    is extremely low, making Borneo elephants even more vulnerable. The habitat
    and range of Borneo elephants is rapidly decreasing due to logging operations
    and conversion of forests for plantations. Killing of elephants and the capture
    of live animals are additional threats. 
     
    Therefore we fear that exporting the elephants would be detrimental to the
    survival of this isolated species. 
     
    2. There is no proper facilities in Japan to keep elephants. 
     
    According to Article III, paragraph 3b,the Managing Authority of importing
    country should consider if the facility is suitable for keeping and caring
    about animals. However, there are neither laws for zoos nor the public organizations
    which guide and supervise zoos. 
     
    On the other hand JAZA (Japan Aquarium and Zoo Association) insists that
    it is a social gathering of the zoo industry and clarifies that it dose not
    work on advising and supervising zoos. 
     
    That is why even facilities where it is impossible to keep animals for scientific
    purposes because of their poor condition, can call themselves "zoos".
    Some of them have even been involved in illegal importation. 
     
    Because there is no obligation to follow the standard for facility, it is
    not too much to say that there are only a few zoos where they care about
    animal's biological and habitat needs. 
     
    ALIVE has been working on zoo checks for a long time. As a result we have
    found that most elephants display repetitive behavior because of mental and
    physical stress.(See attached video film) it is obvious that Japan's zoos
    do not offer a proper environment for elephants whose life span is between
    70 years and 80 years. In fact many elephants die earlier than expected. 
     
     
    3.A false definition: "non-commercial purpose" 
     
    According to Article III, paragraph 3c) an import permit must only be granted
    for Appendix I specimens if these are not to be used for primarily commercial
    purposes. 
     
    In Japan animals that are listed to CITES I are allowed under a breeding
    program, purportedly a scientific research by zoos. At this time animals
    are also allowed to be imported for scientific purposes. However, the Managing
    Authority should check if the purpose of this importation can be justified. 
     
    While about 70 Asian elephants are kept in Japan's zoos, no Asian elephants
    have been bred. Because elephants are highly socialized animals, which live
    in a maternal family, simple keeping of male and female animals does not
    cause breeding. 
     
    Moreover, male elephants are rarely kept in captivity because it is hard
    and dangerous to control them in the breeding season. Based on the actual
    situation in Japan, there will never be proper conditions where Asian elephants
    can be bred. Therefore it is a falsehood that they apply for the import under
    a scientific (breeding)purpose. 
     
     
    4. No relation to the conservation of the species 
     
    According to CITES Resolution Conf.5.10 Annex, paragraph e) , "any importation
    for captive breeding purposes must be aimed as a priority at the long term
    protection of the affected species as required in Res. Conf.2.12". 
     
    However, there is only 1 female elephant, which is a presumed "Borneo
    elephant".(born in 1998,probably) It means that it will be more than
    10 years until she can breed. Before her breeding season she will be exhibited.
    As a result the main purpose of this import is to keep them for commercial
    purposes. This point also violates CITES. 
     
    Basically the conservation of Asian elephants should be done in their own
    habitat. Bringing one or two elephants, one of whom will not be mature to
    breed for over ten years, has no relation to the preservation of the species.
    And if successful breeding does occur in captivity, one young elephant, separated
    from his/her local population, will not help in the conservation of the species. 
     
    Wildlife researchers insist that Borneo elephants should be conserved in
    their habitat. And with regard to the Borneo elephant's genetic distinctiveness
    they should be carefully managed separately from other Asian elephants. 
     
    For the above reasons ALIVE would like to demand that the Japanese government
    not permit this import. 
     
    Sincerely, 
                                           
                                          
                                          Fusako Nogami 
    Director of ALIVE 
    All Life In a Viable Environment 
    URL:http://www.alive-net.net/ 
                                           
                                           
                                           
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