Letter to minister singh on moratoriumDocument Transcript
To the Honourable Minister of the Environment and Water Resources, Mr. Ganga Singh.
Dear Minister Singh,
In recent weeks there has been much talk that you are considering the implementation of an
extended moratorium that would make it illegal for anyone to hunt within state lands anywhere in
Trinidad & Tobago.
We have decided that, despite previously indicating our support for such an initiative, we no longer
feel that implementation of a moratorium is the correct strategy for wildlife conservation and
management in Trinidad & Tobago at this time.
It is our hope that through this letter, we are able to persuade you to exercise patience and
constraint whilst considering the question: what will the actual, ‘real-world’ outcomes - both good
ones and the not so good ones - of taking such an extreme, unilateral measure?
Environmental and scientific stakeholders claim that an undeniable benefit of the moratorium is that
it would allow scientists to conduct a comprehensive wildlife assessment. We agree that this is
positive however, the hunting season has in the past allowed for wildlife assessment through the
licensing process as evidenced by the data incorporated in the Fourth National Report of Trinidad and
Tobago on the Convention on Biodiversity (Cropper Foundation 2010). A moratorium would only
provide data for the time period of the ban. In our opinion, what is really required is regular data
which not only looks at the impact of hunting on wildlife but other negative impacts. Legal hunting
only occurs for 5 months of the year and as such, the other 7 months could be maximised by
establishing a regular regimen of wildlife surveying which looks at all important impacts on wildlife
We believe that the moratorium will not address the biggest threat to wildlife which is loss of
ecosystem integrity caused by stressors such as:
● fragmentation and removal of forest habitats for housing/urbanisation, quarrying,
industrialization and agriculture
● pollution and concretisation of rivers, etc.
Loss of ecosystem integrity has had some very direct and severe consequences, the most pressing
including the loss of healthy habitats for wildlife, resulting in reductions in the abundance and
distribution of species on both islands, as well as a higher vulnerability of certain species to
extirpation (Cropper Foundation 2010). More importantly, we feel that wildlife not only need time to
live, they also need habitat, safety and food. Our agricultural lands used to help somewhat by
offering some grazing and foraging opportunities for wildlife. CSO from 2000 indicate that
agricultural holdings are being converted to housing or some other form of commercial
development. It is a known fact that smaller areas of land can only hold smaller numbers of wildlife
organisms. Therefore, if a moratorium on hunting is to be implemented, a ban on forest removal and
agricultural land conversion should also be pursued. Without these green spaces and resources,
wildlife will never thrive.
Another positive of the moratorium is that it may result in an increase in wildlife populations. We
feel that the moratorium will trigger a drastic increase in wildlife prices which could actually
encourage more poaching. We are basing this on the experiences of other countries after
implementing similar measures: in South Africa, “tighter regulation of the South African rhino
market, including the domestic moratorium on horn sales and restrictions on pseudo hunts, caused a
sudden supply constriction during 2008. The imposition of these measures was swiftly followed by a
sharp rise in poaching incidences that has continued ever since” (Michael ‘t Sas-Rolfes 2013). This is a
very important consideration in the argument against the moratorium than for it.
We wish to urge the honourable minister to consider that this action would not be welcomed by a
significant section of our society that currently enjoys ‘the hunt’ whether it is for sport, for
recreation, or to supplement the ability to feed the family . The admins of Trini Eco Warriors do not
hunt ourselves, and even though some of us cannot understand the attraction to the hunt, we
recognise that for some it represents a family tradition, and for others it’s an opportunity to spend
time with friends. For an increasing number of people, hunting represents the ability to occasionally
supplement their store-bought food.
As you no doubt know, the last attempt to implement a nationwide hunting ban was in the late
1980’s. You would also be aware that the then line minister abandoned the plan when it became clear
that members of the Hunter’s Associations had sought legal council and indicated their intent to
challenge the decision in the courts. No doubt there were other factors that contributed to it’s
failure, but what is apparent is that we seem to be determined to repeat history.
In fact following numerous discussions, we question the government’s ability to enforce a ban. The
perception is that the current team of 14 game wardens and 200 honourary wardens is not sufficient
to regulate hunting and control poaching. We think it is unreasonaable and unrealistic to expect
honourary game wardens, who are basically volunteers that the ministry is not legally responsible
for, to have to actively engage in this type of high-risk law enforcement setting. They would have to
stop poachers and trap setters in the forests who are often armed and potentially dangerous.
There is the feeling that if the Ministry is struggling to enforce current hunting laws outside of the
hunting season, then how will they be able to do it during a moratorium? If this moratorium is not
properly enforced, the resulting high price of wild meat could provide the incentive for greater
poaching and a possible extinction vortex scenario, similar to what is being experienced elsewhere.
Trini Eco Warriors recognises that there are responsible law abiding citizens that like to hunt, and
many of these sport hunters have indicated publicly that they are also conservationists at heart. We
wish to state that we support working to preserve their continued responsible usage of our wildlife
resources. We urge legitimate sport hunting enthusiasts to seek to develop strategies to improve
their image. Reforestation projects, Adopting-a-River and self-policing are all ways they could be
working to demonstrate their willingness to become part of the solution.
For the record, we do not support exploitative practices such as commercial hunting and the use of
modern technology that puts wildlife at an unfair disadvantage. (Night vision, semi/fully automatic
We would like to make some recommendations or suggestions which can be tried before we resort to
a complete ban on hunting. These are:
a. T&T has one of the world’s longest hunting seasons; surely it could be worthwhile for the
minister to consider shortening it, say by two months?
b. And what about considering the use of shortened but overlapping hunting restrictions, for
example; a ban on the use of guns during the first half of the season and then a ban on
hunting with dogs for the other half. If they’re overlapped, then sport hunters that like to
run dogs and shoot at the same time have a short period when it’s permitted. Once
adjustments are made in the regulations, and rigorously enforced, we believe that wildlife
assessment projects could take place during the off-season. This way the interests of both
prevailing mindsets will be respected and accommodated.
c. We would like to see a commitment from our leaders to provide the resources and
training necessary, inclusive of a suitable workers medical and life insurance program, for
the officers that enforce our environmental protection laws that were designed to protect
wildlife without the need to resort to measures as drastic as moratoriums.
d. Wildlife farming is also one possible solution to the wildlife conservation and
management issue. Since the areas required for wildlife to survive naturally are
diminishing. You’re ministry should encourage wildlife farming activities for key wild meat
e. Can a moratorium be assigned to one area alone? Then, different areas can be assigned
moratoriums systematically, thereby allowing for wildlife assessment and replenishment
over a given period of time.
f. Stop all future development above the 100m contour line and ensure via enforcement,
that this rule is adhered to. This is the most important aspect of wildlife conservation and
until this is done, wildlife will continue to be threatened.
g. Many hunters claim that they are conservationists at heart. Many are into forestry and are
familiar with the balance of nature. The ministry should be working with hunting groups to
start reforestation programs since they are often out in the forests for long period of
times. They also know the species on which the various wildlife feed. They can also easily
provide their own seed/seedling stock since they are in the forest already. This is a limited
effort, minimal resource program but may require some form of incentive for
h. Trinidad & Tobago has seven prohibited zones. These are environmentally sensitive areas
that were granted special protection under an amendment to the Forests Act by a previous
Right now members of the public that are found within these areas are supposed to be
fined $20,000 if they do not have a permit from either the Forestry Division or the Wildlife
Three of these sites are marine in their nature, which leaves four zones that are on the
island of Trinidad alone. It seems logical that in order to begin the process of nationwide
enforcement that these four sites (Aripo Savanna, Bush Bush Sanctuary (Nariva), Caroni
Swamp and the Trinity Hills) should be the focus of intensive enforcement efforts
spearheaded by your ministry.
This could possibly involve an amnesty period during which persons currently residing
within the boundaries of these zones can be relocated with dignity. This should be
followed by a concerted drive by the enforcing agencies to ensure that the COWA
regulations are strictly upheld within.
We believe these suggestions should be considered for all new strategies or regulations coming out
of your office.
We also would be interested to know, if the moratorium was to be implemented and the ban on wild
meat imports were to be lifted, will any and everybody be allowed to import, or will a select group of
individual’s to be licenced to import wild meat?
As it is already understood that the wild meat market in T&T is worth a lot of money, and that in
many circles the person that is able to control and supply wild meat (especially out of season) is
highly compensated. We would like to know;
If licensing is the proposed direction, would the licensing process be open and transparent?
In conclusion, we would like to reaffirm that any major change to the current modus will affect large,
well-organised and motivated groups of stakeholders and as such, the Ministry should strive to
incorporate the interest of each of them whenever a significant change in policy is under
Anyone reading this that would like to learn more about people’s thoughts on the moratorium as
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