GGT'S RECOMMENDATIONSON THE AMENDMENT PROPOSALSFOR CONSIDERATION AT THE FIFTEENTH MEETING
OF THE CONFERENCE OF THE PARTIES TO CITES(Doha, 2010)

GLOBAL GUARDIAN TRUST

No.
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Canis lupus
wolf
Lynx rufus
bobcatUrsus maritimus
polar bear
Loxodonta africana
African elephant
Loxodonta africana
African elephant
Loxodonta africana
African elephantAnas oustaleti
Mariana mallard
Crocodylus moreleti
Morelet's crocodile
Crocodylus niloticus
Nile crocodile
Uromastyx ornate
ornate spiny-tailed lizard
Ctenosaura bakeri etc.
Utila iguana, etc.
Ctenosaura palearis
spiny-tailed iguana
Agalychnis spp.
treefrogs
Neurergus kaiseri
Kaiser's spotted newt
Sphyma lewini etc. scalloped hammerhead, etc.
Carcharhinus longimanus
oceanic whitetip
Lamna nasus
porbeagle
Squalus acanthias
spiny dogfish
Thunnus thynnus
Atlantic bluefin tuna
Dynastes satanas
Satanas beetle

Species

Amendment
annotation
II → 0II → I
I → II
I → II
annotation
I→0
I → II
I → II
III → I
0 → II
0 → II
0 → II
0→I
0 → II
0 → II
0 → II
0 → II
0→I
0 → IISUMMARY OF THE RECOMMENDATIONS
Recommendation
Yes
Yes
No
Yes
Yes
No
No
No
Yes
No
No
Yes
Yes
No
No
No
No
No
No
No

21
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27
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Corallidae spp.
red corals, etc.
Operculicarya decaryijahiby sp.
Operculicarya hyphaenoides
jabihy sp.
Operculicarya pachypus
jabihy sp.
plants taxa in App. II
plantsZygosicyos pubescens
toboryZygosicyos tripartitus
betoboky
Euphorbia misera
cliff spurge
Aniba rosaeodora
Brazilian rosewood
Senna meridionalis
tarabyOrchidaceae spp. in App. I
orchids
Beccariophoenix madagascariensis
maroalaDypsis decaryi
laafa
Adenia firingalavensis
lokoranga
Adenia olaboensis
vahisasety
Adenia subsessilofolia
katakata
Orothamnus zeyheri
marsh rose
Protea odorata
Swartland sugarbush
Cyphostemma elephantopus
lazampasika
Cyphostemma lazalaza
Cyphostemma montagnacii
lazamobohitra
Bulnesia sarmientoi
holy wood

0 → II
0 → II
0 → II
0 → II
annotation
0 → II
0 → II
II → 00 → II
0 → II
annotation
annotation
annotation
0 → II
0 → II
0 → II
II → 0II → 00 → II
0 → II
0 → II
III → II
No
No
No
No
Yes
No
No
Yes
No
No
Yes
Yes
Yes
No
No
No
Yes
Yes
No
No
No
No

RECOMMENDATIONS
Prop.1. Addition of an annotation to the species Canis lupus listed in Appendix
I and II reading: "Excludes the domesticated form and the dingo which
are referenced as Canis lupus familiaris and Canis lupus dingo."(Switzerland)
Recent studies revealed that dogs are the domesticated form of wolves Canis
lupus and their origin date back to more than 30,000 years ago. Dingos were
derived from dogs. Since a dog and dingo do not belong to wild fauna, it is clearthat they are not subject to CITES. Also, the proposal is submitted on behalf of
the Animals Committee. The proposal should be accepted.
Prop.2. Deletion of bobcats Lynx rufus from Appendix II (USA)The bobcat occurs in Canada, USA and Mexico. The populations are stable orincreasing despite the bobcat is harvested for its pelt. The bobcat does not meet
the Appendix II listing criteria. Hunting is well regulated by individual States.
There is no need to keep the species listed in Appendix II. The proposal shouldbe accepted.
Prop.3. Transfer of polar bears Ursus maritimus from Appendix II to Appendix I(USA)
The USA insists that the polar bear meets Appendix I criteria in terms of amarked decline in the population size, inferred based on a decrease in area andquality of habitat. Deterioration of habitat, i.e., loss of sea ice, is caused by global
warming. It should be pointed out that although the US has emitted a large
volume of greenhouse effect gases, it seceded from Kyoto Protocol. It seems
likely that the US delegates its responsibility to Inuits who have used polar bearon a sustainable basis for subsistence purposes. Compared to the population
size, international trade volume is small. We agree with Canada thatinternational trade is not a threat and a trade ban might have a negative impact
on conservation. The proposal should be rejected.
Prop.4. Transfer of Tanzania population of African elephant Loxodonta
africana from Appendix I to Appendix II (Tanzania)
We welcome this proposal from a conservation point of view. The supportingstatement is well documented and very persuasive. Tanzania is one of the sevencountries which submitted proposals in 1989 to transfer the African elephantfrom Appendix II to Appendix I. Since then, the elephant population of Tanzania

1has increased from 55,000 (1989) to 136,753 (2006). Tanzania's effort andcommitment to conservation are greatly commendable. Tanzania wishes to tradeivories and other products to further enhance its conservation effort. Countries
with a success story should not be punished by the existence of countries with afailure record. For the benefit of African elephants and local people, the proposal
should be accepted.
Prop.5. Transfer of Zambia population of African elephants Loxodonta africanafrom Appendix I to Appendix II (Zambia)
The situation is similar to that of Tanzania. At the eighth meeting (Kyoto, 1992),
Zambia was opposed to the downlisting proposals submitted by other southern
African countries. However, as a country of LIRDP and other famous projects,
Zambia has made every effort improving the management of elephant and otherwildlife. Most of the ivories Zambia intends to trade are from natural mortality andproblem animal control. The proceeds will be used for wildlife conservation anddevelopment of local communities. Involvement of local communities is
extremely important because conflict with elephants will become increasingly
high as the elephant population grows. Zambia submitted a similar proposal
eight years ago for consideration at CoP 12 (Santiago, 2002). The Conference of
the Parties rejected the proposal, having a detrimental impact on elephants andpeople. This time, the proposal needs to be accepted.
Prop.6. Amendment of annotation to the African elephant Loxodonta africana
populations of Botswana, Namibia, South Africa and Zimbabwe(Kenya, Ghana, Liberia, Mali, Sierra Leone, Togo, Congo and Rwanda)

We are appalled to see that this type of proposal has repeatedly been submitted.
India and Kenya submitted similar proposals at CoP 11 and CoP 12. Again,
Kenya and Mali submitted a similar proposal at CoP 14. As usual, the present
proposal aims at 20 years moratorium on trade in ivories for all African range
states whether they are listed in Appendix I or Appendix II. The adoption of this
proposal will have extremely negative impacts on all the range states which arepromoting elephant conservation through sustainable management. The
proponents of the proposal need to compensate a loss of revenues which could
otherwise be used for conservation and community development. The proposal
contains a lot of unsubstantiated allegations and its descriptions are highly
speculative. For example, the proponent estimated 20,000 ﾐ 30,000 elephants
have been poached annually based on the mere speculation that authorities
seize 10 - 15% of illegal shipments of ivory (at CoP 14 proposal, it was 15%).
This means CITES does not work at all. If this is the case, CITES itself needs tobe abolished. In addition, it should be pointed out that the adoption of the
proposal will affect all range States significantly but the proposal is poorly

2documented and superficial in its description. It is strongly recommended thatthe proposal be rejected.
Prop.7. Deletion of Mariana mallard Anas oustaleti from Appendix I(Switzerland)
The proposal was submitted at the request of the Animals Committee which
agreed at its 24th meeting that a proposal to delete this taxon would be submitted
at CoP15 because it is extinct. It is extremely difficult to confirm the species is
extinct in the wild. It seems that extensive surveys were carried out for an
appropriate time period after the last individual was observed in 1979. It may be"possibly extinct". However, we see no urgent need to delist the taxon from
Appendix I and as such, the proposal should be withdrawn or otherwise
rejected.
Prop.8. Transfer of Morelet's crocodile Crocodylus moreleti from Appendix I toAppendix II with a zero quota for wild specimens (Mexico)Morelet's crocodile is distributed in Mexico, Belize and Guatemala. It is clear thatthe species does not meet the Appendix I listing criteria. In Mexico, three captive
breeding facilities have been registered with the CITES Secretariat inaccordance with Resolution Conf. 12.10 and it is easy to register new facilities.
Mexico could therefore trade in the specimens without transferring to Appendix
II. In practice, there is no difference between CITES registration and Appendix II
listing with a zero quota for wild specimens. We see no rationale behind this
proposal and as such, the proposal should be rejected. From a conservation
point of view, "ranching" is preferable to captive breeding. Mexico should
resubmit a downlisting proposal at CoP 16 subject to ranching.
Prop.9. Transfer of the Egyptian population of Nile crocodile Crocodylus
niloticus from Appendix I to Appendix II (Egypt)
It is not clear if the proposal was submitted as an ordinary proposal or subject toranching. If the latter is the case, the proposal should have been submitted 330
days before CoP. It is unlikely that it was submitted 330 days before. Therefore,
the proposal needs to be assessed against the provisions of Resolution Conf.
9.24. From the supporting statement, it seems the population does not meet the
Appendix I listing criteria. Also, there is a conflict between crocodiles and local
fishermen. The Nile crocodile populations of 12 countries are listed in Appendix II
and two other countries have captive breeding operations registered with the
CITES Secretariat. It is obvious that the Nile crocodile as a whole does not meet
the Appendix I criteria. One way Egypt could pursue is to transfer it to Appendix
II with a zero quota at CoP 15 and resubmit a new proposal for consideration at

3

CoP 16. With this condition, the proposal should be accepted.
Prop.10. Transfer of ornate spiny-tailed lizard Uromastyx ornate from
Appendix III to Appendix I (Israel)
There is uncertainty with regard to some aspects including taxonomy, population
size and trade volume. According to the supporting statement, Israeli populationis legally protected and its habitat is within a nature reserve. It is difficult tounderstand for a developed country like Israel to fail to protect the species. Israelneeds to make every effort to enhance its enforcement activities. As pointed out,
there may be illegal trade in the species. It is recommended for Israel to ask the
Secretariat to issue a Notification informing Israeli population is fully protected
together with information on the conservation and legal status in other range
states. Under the circumstance, we are of the opinion that it is premature to list
the species in Appendix I and as such, the proposal should be rejected.
Prop.11. Inclusion of Utila iguana Ctenosaura bakeri, Roatan spiny-tailed
iguana C. oedirhina and paleate spiny-tailed iguana C. melanostema
in Appendix II (Honduras)
The supporting statement is not presented in the format provided in Resolution
Conf. 9.24. As such, it is difficult to assess the appropriateness of listing inAppendix II. Therefore, the proposal should be rejected. However, based on theavailable information, it is clear that the species certainly meet the Appendix II
listing criteria. All these species are classified as Critically Endangered by IUCN.
It is recommended that Honduras submit a proposal in line with the format given
in Resolution Conf. 9.24 for consideration at CoP 16. In the meantime, Honduras
may wish to unilaterally list these three species in Appendix III. In order to list the
species in Appendix III, laws or regulations to protect the species need to be inplace. It is not clear from the supporting statement.
Prop.12. Inclusion of Guatemalan spiny-tailed iguana Ctenosaura palearis in
Appendix II (Guatemala)Compared to the previous one, this proposal is well documented. The species isendemic to Guatemala with a small population estimated to be 2,500 to 5,000.
Its distribution is restricted to Montagua Valley. It seems that the specimens areillegally traded with US and EU. The species meets the Appendix II criteria. The
proposal should be accepted. Although the species is protected, the species isused internally. Guatemala needs to enhance its enforcement effort. Without
such an effort, Appendix II listing would not much have positive impacts on thestatus of the species.

4Prop.13. Inclusion of treefrogs in the genus Agalychnis in Appendix II(Honduras, Mexico)
The genus Agalychnis comprises five different species of tree frogs. Treefrogs
are being traded for pets mainly in US and EU. Different from the statement
made in the proposal, Agalychnis callidryas may not meet the Appendix II criteria
because it is widely distributed and its population is large. On the other hand, A.
moreletii and A. annae meet the criteria. Morphologically, they are similar one
another. Although the proposal should be accepted, Mexico and other range
states should note that Appendix II listing is not sufficient to achieve theirconservation goal because a main threat to these species is deforestation.
Prop.14. Inclusion of Kaiser's spotted newt Neurergus kaiseri in Appendix I(Iran)The species is endemic to Iran and known to occur in restricted areas on Zagros
Mountains. The species is protected by Iranian law. The proposal is to include all
populations on Zagros Mountains in Appendix I. This means that otherpopulations yet to be found are not subject to CITES and this may be used byunscrupulous pet traders as a loophole. Iran should withdraw or the proposal
should be rejected. It is recommended that immediately after CoP, Iran list the
species as a whole in Appendix III. Iran should then resubmit a new proposal tolist the species either in Appendix I or Appendix II.
Prop.15. Inclusion of scalloped hammerhead shark Sphyma lewini and othersin Appendix II (Palau, USA)
Sphyma lewini occurs throughout temperate and tropical seas. The proponents
suggest that Sphyma lewini be listed in accordance with Criterion A in Annex 2aof Resolution Conf. 9.24 and other four species with Criterion A in Annex 2b.
Nevertheless, the supporting statement mentions that few populationassessments are available globally for S. lewini. Although the proponent saysthat estimates of trends in abundance of S. lewini are available for this species(Annex 2), the table shown as Annex 2 is for Sphyma spp. complex. In addition,
there is no firm agreement among Parties concerning 'introduction from the sea'.
According to the draft decision (see CoP15 Doc. 27) which was agreed to by theStanding Committee, it is recommended that a working group be establishedintersesssionally and the Standing Committee report back its consideration to
CoP 16 which will take place in two to three years. It is premature to list the
species in Appendix II and as such, the proposal should be rejected.

5Prop.16. Inclusion of oceanic whitetip shark Carcharhinus longimanus in
Appendix II (Palau, USA)The species is widely distributed in subtropical and tropical seas. According to
the proposal, there are no stock assessments available for this species and assuch, relative population size is unknown. It should be pointed out that there isno firm agreement among Parties concerning 'introduction from the sea'. This
fact will cause a problem, in particular because the species is highly pelagic.
According to the draft decision (see CoP15 Doc. 27) which was agreed to by theStanding Committee, it is recommended that a working group be establishedintersesssionally and the Standing Committee report back its consideration to
CoP 16 which will take place in two to three years. It is premature to list the
species in Appendix II and as such, the proposal should be rejected.
Prop.17. Inclusion of porbeagle Lamna nasus in Appendix II (Sweden)
A similar proposal was rejected at the previous CoP. With regard to marine fish
species subject to large-scale commercial fisheries, there are many problems
which have yet to be solved. For example, the proponent recognizes a difficultyin implementation, suggesting 18 months delay in the entry into effect. In
addition, there is no firm agreement among Parties concerning 'introduction fromthe sea'. According to the draft decision (see CoP15 Doc. 27) which was agreed
to by the Standing Committee, it is recommended that a working group be
established intersesssionally and the Standing Committee report back its
consideration to CoP 16 which will take place after 18 months period. Normally,a meeting of CoP takes place every two to three years. This means that
Appendix II listing will come into effect without agreeable definition of'introduction from the sea'. Furthermore, EU States consume this shark for its
meat and a 'look-alike' problem need to be addressed. Recently, there has beenmuch progress in terms of porbeagle management. The supporting statement
indicates that quota management has been in place in Canada since 2002, in
the US since 1999, in New Zealand since 2004 and in EU since 2008. Thus, it isexpected that porbeagle stock will recover. There seems little co-ordination
between environment departments and fisheries departments within EU
countries. Instead of listing the species in Appendix II, CITES Management
Authorities should discuss with their own fisheries counterparts within their own
governments with a view to establishing good management practices including a
National Plan of Action for sharks. The proposal should be rejected.

6Prop.18. Inclusion of spiny dogfish Squalus acanthias in Appendix II(Germany)
A similar proposal was rejected at the previous CoP. It seems that some stocks
have been depleted, but the species as a whole is extremely large in numbers.
Clearly the species does not meet the Appendix II listing criteria. As is the casewith porbeagle, there are many problems which have yet to be solved. For
example, the proponent recognizes a difficulty in implementation, suggesting 18
months delay in the entry into effect. In addition, there is no firm agreement
among Parties concerning 'introduction from the sea'. According to the draft
decision (see CoP15 Doc. 27) which was agreed to by the Standing Committee,
it is recommended that a working group be established intersesssionally and theStanding Committee report back its consideration to CoP 16 which will takeplace after 18 months period. Normally, a meeting of CoP takes place every two
to three years. This means that Appendix II listing will come into effect withoutagreeable definition of 'introduction from the sea'. Furthermore, EU States
consume this shark for its meat and a 'look-alike' problem need to be addressed.
There seems little co-ordination between environment departments and fisheries
departments within EU countries. Instead of listing the species in Appendix II,
CITES Management Authorities should discuss with their own fisheries
counterparts within their own governments with a view to establishing goodmanagement practices including a National Plan of Action for sharks. The
proposal should be rejected.
Prop.19. Inclusion of Atlantic bluefin tuna Thunnus tynnus in Appendix I(Monaco)The proposal aims to list all populations of Atlantic bluefin tuna in Appendix I andprohibit international trade in this highly commercial fish. As explained previously,
there are many problems which must be solved before commercial fish species
being listed in CITES Appendices. These need to be addressed very carefully. A
look-alike problem is one of them. The proponent clearly mentioned that thelisting of the species could pose implementation difficulties with regard to
confusion with similar species. In addition to such problems, listing bluefin tunain Appendix I will make the situation more complicated. While it is prohibited forfishers to catch tunas on the high sea and bring back to their countries,'international' trade within EU is permitted without any restriction. This will be
exploited as a loophole. Unscrupulous fishermen may go to the border of thehigh sea and EEZ or beyond the border, catch tunas and bring them back to EU
states declaring tunas are caught within EU waters. Monaco submitted this
proposal together with a draft Resolution suggesting a downlisting mechanism.
This draft Resolution reminds us of the so-called Somali amendment when the
proposals to transfer the African elephant to Appendix I were discussed at CoP7
in 1989. Even with that kind of Resolution, we have witnessed that once

7

transferred to Appendix I, it is extremely difficult to transfer back to Appendix II.
At its recent meeting, ICCAT took many positive approaches. ICCAT is anorganization comprising 47 countries and EU, 46 of which are CITES Parties.
Adoption of the proposal means the governments are opposed to themselves.
ICCAT need to be provided with a grace period so that the recent decision canbe in place without importing the issue from ICCAT to CITES. Under thecircumstances, the proposal should be rejected. In the meantime, ICCAT isrequested to take the issue very seriously.
Prop.20. Inclusion of Satanas beetle Dynastes satanas in Appendix II (Bolivia)
The species is endemic to Bolivia. Little is known of the status of the species
including population size, population trend and trade volume. Therefore, it is
impossible to infer or project that the regulation of trade in the species isnecessary to avoid it becoming eligible for inclusion in Appendix I in the near
future. A major threat to the species is deforestation. It is unknown to what extent
international trade contributes to the status of the species. It is recommended
that the proposal be rejected. However, the species is protected under Bolivian
regulations. Yet, there are many incidents illegally exported from Bolivia. Bolivia
may wish to list the species in Appendix III.
Prop.21. Inclusion of all coral species in the family Coralliidae in Appendix II(Sweden, USA)
A similar proposal was rejected at the previous CoP. The species occur widelyfrom tropical through subtropical to temperate seas. But only fragmented data
are available on overall population status. We do not believe that the harvest of
specimens from the wild is reducing the wild population to a level at which its
survival might be threatened by continued harvesting or other influences. Basedon catch statistics, the proponents stress that seven species meet the decline
criteria. It should be pointed out that landings are influenced by many factors anddo not reflect the actual trend of coral population. Under the circumstances, theproposal should be rejected.
Prop.22. Inclusion of jabihy sp. Operculicarya decaryi in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. The number of thespecimens exported has recently increased. However, it seems that export of thespecies is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.

8Prop.23. Inclusion of jabihy sp. Operculicarya hyphaenoides in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. The number of thespecimens exported has recently increased. However, it seems that export of thespecies is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.24. Inclusion of jabihy sp. Operculicarya pachypus in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. The number of thespecimens exported has recently increased. However, it seems that export of thespecies is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.25. Replacement of annotations #1 and #4 with the new annotation forplant taxa listed in Appendix II (Mexico, USA)The proposal is of technical nature and was submitted on behalf of the Plants
Committee. The Plants Committee was directed by Decision 14.130 to prepare a
proposal on annotations for consideration at the 15th meeting of CoP. The
proposal should be accepted.
Prop.26. I n c l u s i o n o f t o b o r y Z y g o s i c y o s p u b e s c e n s i n A p p e n d i x I I(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. It seems that export ofthe species is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.27. Inclusion of betoboky Zygosicyos tripartitus in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on

9population. The species is not protected nor managed. The number of thespecimens exported has recently increased. It seems that export of the species
is subject to authorization by the Management Authority. If Madagascar isconcerned about the export volume, it should establish an export quota. The
proposal should be rejected.
Prop.28. Deletion of cliff spurge Euphorbia misera from Appendix II (Mexico,
USA)
The species was first listed in Appendix II in 1975. Since then, there have been
few international trade in the species. International trade does not affect thestatus of the species. The species is well protected in Mexico and the US. The
proposal should be accepted.
Prop.29. Inclusion of Brazilian rosewood Aniba rosaeodora in Appendix II(Brazil)Brazilian rosewoods have been exploited for its oil. The quantity exported from
Brazil has steadily decreased for three decades. However, little is known of thestatus of the species including population size and population trend. Therefore, it
is impossible to judge if the species meet the Appendix II listing criteria.
According to the supporting statement, there is a discrepancy between
authorized timber and amounts of oil exported suggesting a large volume ofillegal trade. Being able to obtain export data means that exports are subject toinspection by the authority. Therefore, this problem can be solved within Brazil
without listing the species in Appendix II. The proposal should be rejected.
Prop.30. Inclusion of taraby Senna meridionalis in Appendix II (Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. It seems that export ofthe species is subject to authorization by the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.31. Replacement of annotation with the new annotation for Orchidaceae
in Appendix I (USA)The proposal is of technical nature. At the Plants Committee meeting held lastyear, the US suggested the annotation should be replaced with clearer
annotation and this suggestion was supported by the Plants Committee. The
proposal should be accepted.

10Prop.32. Inclusion of the seeds of maroala Beccariophoenix madagascariensis
in Appendix II (Madagascar)
The species is already listed in Appendix II but seeds and others are exemptedfrom CITES control. The proposal is to amend the annotation. Although theproposal is poorly documented, Madagascar's intention is understandable. The
proposal should be accepted.
Prop.33. Inclusion of the seeds of laafa Dypsis decaryi in Appendix II(Madagascar).
The species is already listed in Appendix II but seeds and others are exemptedfrom CITES control. The proposal is to amend the annotation. Although theproposal is poorly documented, Madagascar's intention is understandable. The
proposal should be accepted.
Prop.34. Inclusion of lokoranga Adenia firingalavensis in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. Some of the habitats are protected in nature reserves. But in others,
the species is not protected nor managed. It seems that export of the species issubject to the authorization of the Management Authority. If Madagascar isconcerned about the export volume, it should establish an export quota. The
proposal should be rejected.
Prop.35. In c l u s i o n of vahisaset y Adenia ola b o e n si s i n Ap p e n d i x II
(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. Some populations are protected in a national park. But in others, thespecies is not protected nor managed. It seems that export of the species issubject to the authorization of the Management Authority. If Madagascar isconcerned about the export volume, it should establish an export quota. The
proposal should be rejected.
Prop.36. Inclusion of katakata Adenia subsessilifolia in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. Some of the habitats are protected in nature reserves. But in others,

11the species is not protected nor managed. It seems that export of the species issubject to the authorization of the Management Authority. If Madagascar isconcerned about the export volume, it should establish an export quota. The
proposal should be rejected.
Prop.37. Deletion of marsh rose Orothamnus zeyheri from Appendix II (South
Africa)The species is endemic to South Africa. The population size is small but the
species is distributed within a protected area and well protected. The species
was first listed in Appendix I in 1975 and was transferred to Appendix II in 1997.
Since 1981, no trade in the species has been recorded. There is no need tocontinue to list the species in CITES Appendices. Therefore, the proposal shouldbe accepted.
Prop.38. Deletion of Swartland sugarbush Protea odorata from Appendix II(South Africa)
The species is endemic to South Africa. The population size is extremely small.
The species was first listed in Appendix I in 1975 and was transferred toAppendix II in 1997. Since 1975, no trade in the species has been recorded.
There is no need to continue to list the species in CITES Appendices. Therefore,
the proposal should be accepted.
Prop.39. Inclusion of lazampasika Cyphostemma elephantopus in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. It seems that export ofthe species is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.40. Inclusion of laza Cyphostemma laza in Appendix II (Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. The number of thespecimens exported has recently increased. It seems that export of the species
is subject to the authorization of the Management Authority. If Madagascar isconcerned about the export volume, it should establish an export quota. The
proposal should be rejected.

12Prop.41. Inclusion of lazamobohitra Cyphostemma montagnacii in Appendix II(Madagascar)
The proposal is very poorly documented. Little quantitative data are provided on
population. The species is not protected nor managed. It seems that export ofthe species is subject to the authorization of the Management Authority. If
Madagascar is concerned about the export volume, it should establish an export
quota. The proposal should be rejected.
Prop.42. Inclusion of holy wood Bulnesia sarmientoi in Appendix II (Argentina)
The species is listed in Appendix III. Little is known of species status andpopulation trend. According to the supporting statement, there are no current
quantitative population data. The proponent states that it is important to carry out
population studies to obtain greater knowledge of the species status. Under thecircumstances, it is impossible to assess if the species meets the Appendix II
criteria. As the species is already subject to CITES regulation, we see no need tolist in Appendix II. Practically, Appendix II listing is identical to Appendix III listing.
The proponent says that the inclusion of the species in Appendix III has
increased provincial controls. Appendix III listing is working. The proposal should
be rejected.

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