NGO Letter Urging DENR and PAWB Not to Burn Seized Elephant Tusks

13 June
2013

Hon. Ramon J.P. Paje
Secretary
Department of Environment and Natural Resources

Hon. Theresa Mundita S. Lim
Director
Protected Areas and Wildlife Bureau

Dear Secretary Paje and Director Lim,

We write with urgency to signify our objection to the plan of the Department of
Environment and Natural Resources (DENR) to burn about five tons of confiscated
elephant tusks on June 21, 2013 at the Ninoy Aquino Parks and Wildlife Center
(NAPWC). As per DENR press release dated 9 June 2013, “the seized ivory
tusks will be crushed by a road roller and burned…” “to show to the
whole world that the Philippines will not tolerate illegal wildlife trade.”

At the outset, let us state that we are in full support of the global effort to
stop illegal wildlife trade under the Convention on International Trade in
Endangered Species of Flora and Fauna (CITES) of which the Philippines is a
party to, and that we are one with conservationists in putting an end to elephant
poaching.

However, burning the confiscated tusks goes against the prohibition against the
open burning of municipal solid waste enshrined in two of our major
environmental laws: R.A. 9003, the Ecological Solid Waste Management Act and
R.A. 8749, the Clean Air Act.

Even if the intent is only to conduct “ceremonial burning,” we remain anxious
as this will likely send a confusing message to the general public from the
environmental authorities that open burning is acceptable. A photo showing the
Environment Secretary setting a pile of tusks on fire may be interpreted as a
tacit endorsement that “open burning is okay.”

The “open burning is okay” message that may be generated from such a
“ceremonial burning” will also not serve the objectives of the Integrated
Persistent Organic Pollutants Management Project (IPOPs Project) that the DENR
is implementing with financial assistance from the Global Environment Facility
and the World Bank to assist the country in meeting its obligations under the
Stockholm Convention, specifically with respect to preventing emissions from
the open burning of agricultural and municipal solid waste.

To describe the destruction of the confiscated ivory tusks through a process
that will create and scatter pollutants (or send a wrong message that “open
burning is okay”) as “one of the highlights of the national celebration of June
as Environment Month” is completely ironic and a clear breach of the people’s
right to breathe clean air that the state recognizes and commits to uphold.

In lieu of open burning, we recommend that the seized ivory tusks be simply
crushed and pulverized by a road roller until the tusks are rendered useless to
traders and users to ensure that the same are not returned to illegal trade,
and then buried for composting at an appropriate site within the NAPWC.

The eco-burial site can serve as a lasting memorial to our country’s commitment
to ending illegal wildlife trade and to poaching that is mercilessly killing
the elephants. It will be fitting to install a marker at the site made out of
combined cement and crushed tusks in memory of the murdered elephants.

We thank you very much for considering our proposal not to burn the confiscated
elephant tusks.

Sincerely yours,

Aileen Lucero, EcoWaste Coalition
Roy Alvarez, Alaga Lahat
Jaybee Garganera, Alyansa Tigil Mina