Comment from Holloway, Saundra

To: U.S. Fish and Wildlife Service, Division of Management Authority Docket No: FWS-HQ-IA-2026-0760 Federal Register Citation: 91 FR 25593 ​Target Applications Objections: ​Ross Hammock Ranch Inc (Inglis, FL) — Permit No. PER30264044 ​Ross Hammock Ranch Inc (Inglis, FL) — Permit No. PER30264793 ​The M5 Ranch (Breckenridge, TX) — Permit No. PER30390600 ​The M5 Ranch (Breckenridge, TX) — Permit No. PER30391206 ​Multiple Trophy Applicants (Sport-hunted trophies/import requests) ​Subject: Strong Opposition to the Issuance of Foreign Endangered Species Import and Captive-Bred Wildlife Permits ​To Whom It May Concern, ​I am writing to submit formal testimony strongly opposing the issuance of the foreign endangered species permits requested under Docket No. FWS-HQ-IA-2026-0760, with specific emphasis on the applications listed above filed by private exotic ranching facilities, commercial entities, and sport-hunted trophy import applicants. ​Under Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16\text{ U.S.C. }\S\text{ 1539(a)(1)(A)}), the U.S. Fish and Wildlife Service (the Service) may only issue permits for otherwise prohibited acts if the applicant can definitively demonstrate that the activity will "enhance the propagation or survival of the affected species." The private, commercial, and recreational hunting outfits within this docket fail to meet this strict statutory standard. ​1. Failure to Meet the "Enhancement of Survival" Standard ​The Service must reject applications from private hunting ranches—such as Ross Hammock Ranch Inc. and The M5 Ranch—as well as the Multiple Trophy Applicants seeking sport-hunted imports. ​Commercial Exploitation vs. True Conservation: Utilizing endangered foreign species for private, paid hunting excursions or commercial breeding does not contribute to wild population recovery. ​Lack of Direct Benefit to Wild Populations: Captive propagation on private U.S. lands that serves an insular commercial market does not address the primary threats facing these species in their native habitats, such as poaching and severe habitat fragmentation. Paying a fee to hunt or breed these animals domestically does not inherently translate into a tangible, scientifically validated benefit for wild herds. ​2. Flaws in the "Pay-to-Play" Conservation Model ​Private ranches and trophy applicants frequently argue that a portion of their fees fund international conservation grants. However, the Service should not rely on financial contributions as a substitute for actual biological enhancement. ​There is a profound lack of transparent, verifiable tracking to ensure that funds generated by these private operations directly reach on-the-ground enforcement or habitat restoration in the species' native ranges. ​Allowing wealthy individuals or private entities to bypass ESA protections via financial contributions commodifies endangered wildlife and sets a dangerous regulatory precedent. ​3. Public Interest and Enforcement Concerns ​The ESA is designed to safeguard species from exploitation. Approving permits for trophy imports and private hunting propagation undermines international conservation efforts by signaling that endangered status can be negotiated for recreational or commercial use. Furthermore, monitoring compliance across disparate private facilities places an undue enforcement burden on the Service. ​Conclusion ​Because these private and commercial applicants have failed to provide transparent, peer-reviewed, or quantitative evidence proving that their activities will directly enhance the survival of these species in the wild, the Service must strictly adhere to the mandate of the Endangered Species Act and deny these permit applications. ​Thank you for your time and for considering these comments. ​Sincerely, Saundra Holloway