1. Asian big cats

Recognizing the disturbing decline of wild tiger numbers, Russia hosted the St Petersburg Tiger Summit in 2010 where 13 tiger range States collectively agree to double the number of tigers in the wild. This is an ambitious, yet achievable target.

The Russian Federation reaffirms its commitment towards the conservation of tigers and other Asian big cats in the wild.

There is much evidence in the Review on Annex 4 of Doc.71.1 of the significant threat to Asian big cats in the wild from trade in their specimens, parts and derivatives. We appreciate India’s consideration of the evidence and best practice in that review in their proposal for draft Decisions in Doc.71.2 (Rev.1) with specific measures that are required for real impact on this issue.

We encourage the adoption of measures, aimed at tackling poaching and reducing demand of Asian big cats’ parts and derivatives.

So we support the measures recommended by India and the Secretariat in draft Decisions and amendments aimed at strengthening of Res.12.5 (Rev. CoP17), and retaining and implementing existing CITES Decision 14.69.

The Russian Federation has offered to host the next Tiger Summit in 2022.

We hope that CITES will be able to be proud at that time of the contribution it has made to eliminate the threat of illegal tiger trade to help achieve the tiger range States to double wild tiger numbers.

2. Proposal to include Woolly Mammoth in Appendix II to CITES

The Russian Federation opposes the proposal by Israel and adheres to the following position.

First, we would like to second the views previously expressed by the Secretariat, which we believe to be the only possible basis for consideration of this issue.

The Convention strictly regulates trade in listed species that are threatened with extinction; may become threatened in order not to endanger further their survival or to avoid utilization incompatible with their survival; and species that are protected in at least one country, which has asked other CITES Parties for assistance in controlling the trade.

Under CITES, trade in extinct species is normally not regulated. For instance, Parties have recognized that fossilized species are not covered by the provisions of the Convention (see Resolution Conf. 11.10 (Rev. CoP15) on Trade in stony corals).

It is our firm conviction that the species Mammuthus primigenius is long extinct and hence is not covered by the scope and the provisions of the Convention.

According to experts, mammoth ivory can be easily differentiated from elephant ivory. Most notably by color (it never is white) and by structure (you can see in cross-section that mammoth cross-hatchings or Schreger lines are different from elephant). The whole elephant tusk is also different from the mammoth tusk: at the elephant tusk, the alveolar cone (the hole in the tusk at its proximal end closest to the skull) is twice as deep and reaches into half the tusk.

Various forensic techniques, including DNA and spectroscopic analysis and radiocarbon dating are also available to reliably distinguish between mammoth and elephant ivory.

To share our experience: in Russia there is a two-step procedure for obtaining permission to export mammoth ivory. First, a user company receives permission to collect mammoth ivory from the Federal Agency for Subsoil Use. Secondly, the Federal Service for the Supervision of Natural Resources Usage issues a permit for the export of ivory or products from it. The package of documents for obtaining an export permit includes the conclusion of an independent expert of the Ministry of Culture of the Russian Federation, who assesses not only the cultural and historical value of the sample, but also the material of which it consists. Thus, each sample of mammoth ivory legally transported across the border is accompanied by an export permit, which states that it is mammoth, not elephant ivory. Obtaining additional CITES approval in this regard seems redundant.

It should also be taken into account that, the genus mammoth (Mammuthus) consists of more than 15 species the woolly mammoth being only one of them.

Based on all this, the Russian Federation considers the inclusion of the woolly mammoth in CITES Appendix II to be inappropriate.

While larger items are particularly easy to differentiate, the theoretical risk of misidentification of elephant ivory as mammoth ivory involves primarily small worked items. We will be happy to consider any statistics on such mislabeling. The current available information on isolated cases leads us to believe that such trade is not in a quantity so as to impact conservation of elephants. That is why we do not consider the proposed actions proportionate with the scale of the risk posed.

In order to help to easily distinguish mammoth and elephant ivory we encourage Parties to utilize the different ivory identification tools posted on the CITES website and to participate in regular capacity building trainings organized by the Secretariat. We are also ready and eager to welcome representatives of Israel and other countries in Russia to share the experience of our scientists and customs officers.

3. Proposal to transfer Saiga antelope from Appendix II to Appendix I to CITES

While acknowledging the issues faced by Mongolia we would like to satate the following.

Due to certain taxonomic and procedural misunderstandings the proposal deals with Saiga tatarica, a species which presently doesn’t live in Mongolia.

According to the classifications of CITES and CMS Saiga tatarica and Mongolian saiga (Saiga borealis) are two separate full species. Now we should be guided only by CITES classification.

Thus changing Saiga tatarica to Saiga spp. (which is the genus of Saiga, including two species) will obviously NOT make the proposal more precise, BUT instead it will extend its scope, which is NOT in accordance with Paragraph 2 of Rule 24 of the Rules of Procedure of the CoP.

The Mongolian side, when putting this issue on the COP-18 CITES agenda, proceeded from the interests of preserving the subspecies of the Mongolian saiga (according to the national classification – Saiga tatarica mongolica). In practice, however, it turned out that, for inclusion in Appendix I, the partners, probably by mistake, proposed the species Saiga tatarica, which, in the framework of the classification adopted by CITES, is not related to Mongolia. According to Russian experts, in order to preserve the species of interest, the Mongolian side should advocate the inclusion of the Saiga borealis species in the CITES strict restrictive list, which would avoid terminological confusion and would not prejudice the sustainable saiga hunting in other countries.

All countries of the modern range of Saiga tatarica (Russia, Kazakhstan, Uzbekistan) object to this proposal. Saiga hunting in these countries is currently prohibited; permits for the cross-border movement of commercial horns are not issued by CITES.

We would also like to reiterate that in Kazakhstan, where large-scale conservation measures at the expense of the state budget yield good results, the number of saigas, despite the mass die-off because of infectious disease, grows and now exceeds 334 thousand individuals. The prospect of sustainable use of this species is considered. It is planned to direct substantial resources to measures for the protection of the species. The closest to this use are two transboundary populations with Russia (Volga-Ural and Betpak-Dala).

The saiga population of the Northwest Caspian Sea, inhabiting only the territory of the Russian Federation, also shows signs of growth and can, in the medium term, reach a level that allows sustainable use.

NONE of the three groups of criteria for placing a species in Appendix I established by resolution Conf. 9.24 (Rev. CoP17) – a small wild population, a restricted area of distribution of the wild population, a marked decline in the population size in the wild – for saigas is met, and different statuses are NOT given to CITES populations.

The main unfavorable factors for the development of the saiga population, including the Mongolian one, are infectious diseases and harsh wintering conditions. Both factors are outside the scope of CITES, and the transfer of the species to Appendix I will not solve the problems associated with them.

Based on the foregoing, the Russian Federation considers the proposal to transfer the saiga to CITES Appendix I to be potentially harmful to the conservation of the species.

Along with the appropriate adjustment of the proposal (replacing the name of the species Saiga tatarica with Saiga borealis), a possible solution seems to be a split-listing. We are also ready to consider other options, for example establishing of a strict export quota while keeping Saiga tatarica in Appendix II.