I disagree on one of your points … just from a tactical standpoint and thinking out loud. I do not think it was or will be “dumb” to go it yourself on the permits. Make reps first. If you know they are not currently, nor for the foreseeable future, able to come back to the US; why not roll the dice on something that you didn’t believe you had any chance of getting back anyways? Clearly, they aren’t every likely to show up but what’s a couple hundred bucks across an elephant hunt if I catch a massively awesome outlier.
I'm not sure I understand your point.
There are several permits in question for an American. CITES international approval. Export approval from the African nation. Lastly, USFWS special permit or endangered species permit. The latter is the one for which they have taken years to act and then only under actual litigation by Conservation Force and DSC.
You have two options on when to apply for the USFWS permit. 1.) Before you hunt, 2.) After you hunt. The before you hunt is a non-starter because you cannot gain approval for a 2022 hunt if they grant the approval in 2176. So you will be applying post-hunt.
Then to the options of "how" to apply post-hunt.
A.) You can write up your own 50-100 page documentation in your own words. The USFWS would relish this because when they say "no, denied" your journey comes to an end.
B.) You can hire a law firm, Conservation Force, to write up your application. The USFWS sees that your lawyers are handling the permit and they don't F-around, have already won in court, and they are using already accepted intake forms, biological diversity studies, and they will adjudicate any inconsistencies raised by USFWS as CF is representing the super-majority of all applicants and they know what passes legal muster.
Preceding all these decisions, you need to be very savvy on whom you select as your operator and PH. They better have a long track record in that area to demonstrate local investment and they better be willing to open their books to show revenue and expenses. Most operations cannot or will not do either of these things. It seems clear from the success mentioned that
@Tokoloshe Safaris does this. So does Mapassa safaris. They also are not connected to "Politically Exposed Persons" which is technical speak for corrupt politicians that show up on sanctions lists. Who owns the concession matters and most operators won't even tell you that little detail.