Comment from Holloway, Saundra

Date: June 10, 2026 To: U.S. Fish and Wildlife Service, Division of Management Authority Docket No: FWS-HQ-IA-2026-1057 Federal Register Citation: 91 FR 25591 ​Target Applications Objections: ​Tanganyika Wildlife Preserve dba Tanganyika Wildlife Park (Goddard, KS) — Permit No. PER23008706 ​Ox Ranch Investments, LLC (Uvalde, TX) — Permit No. PER24623358 ​Ox Ranch Investments, LLC (Uvalde, TX) — Permit No. PER0039889 ​Acacia Ranch, LLC (Auburn, IN) — Permit No. PER30746146 ​Project Banteng, LLC (Laredo, TX) — Permit No. PER30778775 ​Project Banteng, LLC (Laredo, TX) — Permit No. PER30779073 ​Multiple Trophy Applicants (Sport-hunted trophies/import requests) ​Subject: Strong Opposition to the Issuance of Foreign Endangered Species Import, Captive-Bred Wildlife Registrations, and Take Permits ​To Whom It May Concern, ​I am writing to submit formal testimony strongly opposing the issuance of the foreign endangered species permits and captive-bred wildlife registrations requested under Docket No. FWS-HQ-IA-2026-1057. My opposition is directed specifically at the commercial wildlife entertainment parks, private exotic ranching operations, and individual sport-hunted trophy import applicants designated above. ​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) possesses the narrow authority to grant permits for otherwise prohibited actions only if the applicant demonstrates that the proposed activity "enhances the propagation or survival of the affected species" in the wild. The commercial and recreational entities listed above fail to satisfy this stringent legal baseline. ​1. Exploitation and Commercial Breeding Are Not True Conservation ​The applications submitted by commercial operations and private hunting preserves—such as Ox Ranch Investments, LLC, Project Banteng, LLC, Acacia Ranch, LLC, and Tanganyika Wildlife Preserve—fundamentally conflict with the protective intent of the ESA. ​Insular Commercial Markets: Propagating endangered foreign fauna for private, paid hunting excursions, commercial photo opportunities, or insular domestic breeding networks does not contribute to wild population recovery. ​Failure to Address Wild Threats: These operations do not mitigate the core threats facing these species in their native ranges, such as localized poaching, habitat loss, and fragmented ecological corridors. Breeding endangered exotic animals for domestic commercial utility does not inherently provide a scientifically validated benefit to wild populations. ​2. Flaws in the "Pay-to-Play" Trophy Model ​The inclusion of Multiple Trophy Applicants seeking sport-hunted imports must be rejected. The Service must deny each and every individual application submitted under this collective "Multiple Trophy" umbrella; this objection applies universally to every individual permit request nested within this joint designation. The argument that high fees paid for international trophy hunts find their way back to range-country conservation programs is profoundly flawed. ​There is an ongoing lack of transparent, verifiable tracking mechanisms to guarantee that funds generated by wealthy recreational hunters or private sport-hunting brokers directly finance on-the-ground anti-poaching enforcement or native habitat restoration. ​Sanctioning the import of sport-hunted trophies under the guise of "enhancement" commodifies endangered species, giving a green light to international wildlife exploitation. ​3. Regulatory and Enforcement Precedent ​Approving Captive-Bred Wildlife (CBW) registrations or take permits for private operations and commercial entertainment facilities signals that endangered status is a negotiable regulatory barrier rather than an absolute protection. Furthermore, tracking compliance across disparate, private commercial holdings shifts an unmanageable oversight and enforcement burden onto the Service. ​Conclusion ​Because these commercial, private, and recreational applicants have failed to supply quantitative, peer-reviewed evidence proving that their domestic activities directly enhance the survival of these endangered species in their native wild habitats, the Service must strictly execute its statutory mandate under the Endangered Species Act and deny these permit applications. ​Thank you for your time and for considering these comments. ​Sincerely, Saundra Holloway