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1. Two Million Tusks report The sample size of auction houses used in the Ivory: The Grey Area report published by Two Million Tusks is far too small to attach any significance to the survey’s findings.

2. Representative views

The replies to the DEFRA consultation were a very small percentage of the population, at the most 2%, and should not be allowed, at this level, to influence legislation.

3. Corruption Most of the countries where ivory poaching takes place are in the top 10 countries of the Corruption Perceptions Index published each year by Transparency International. This includes corruption at a governmental level. Although efforts have been made by the Chinese government to prevent ivory imports, there continues to be a black market.

4. Supply and demand for ivory I quote Enrico Di Minin, research fellow in conservation science at the University of Helsinki, and Douglas MacMillan, professor of biodiversity economics at the Durrell Institute of Conservation and Ecology, University of Kent (The Guardian, October 1, 2016):

“The 1989 UN ban on international ivory trading was supposed to protect elephants. The result has been counterproductive because restricting supply in a time of increasing wealth in Asia has driven up prices, dramatically increasing incentives and rewards for poachers.”

“What is also needed on this issue, sadly lacking, is common sense

5. Sale value of ivory One must consider ivory’s weight, set against the current value of ivory in the Chinese market of about $1500 per pound. The weight of most antique ivory is trivial and would not therefore be of interest.

6. Compensation Millions of pounds were paid in compensation to gun owners after the Firearms (Amendment) Act 1997 banned all hand guns. Nothing has been offered to owners of ivory in the case of the forthcoming legislation. This is not fair and may not be legal.

7. Dating ivory Even though there is only one way to know with certainty that an ivory artefact pre-dates 1947, through radiocarbon dating, there is a wealth of illustrated literature published before 1947 to draw on to distinguish what should be legal within the framework of CITES legislation.

The levels of complexity of carving of most 18th and 19th century articles is testament to their age, without recourse to radiocarbon dating. By all means, ban the sale of ivory billiard balls and hairbrushes.

In conclusion: Ravula and Alexandra conclude that strength, resolve and commitment are needed on this issue. What is also needed, but sadly lacking, is common sense.

Fletcher Wallis