All Life In a Viable Environment
5-18-10-102, Honkomagome, Bunkyo-ku, Tokyo, 113-0021
Anti Vivisection Action Network
letter to demand the refusal
of permission of the import of
October 6th , 2003
Minister of the Economy, Trade and
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
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
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.
Director of ALIVE
All Life In a Viable Environment