The Ministry of Fisheries, Forestry and the Environment

[Richprins]

[Lisbeth]

Review of policies on matters of Elephant, Lion, Leopard and Rhinoceros Management

BY DEPARTMENT OF ENVIRONMENTAL AFFAIRS - APRIL

TERMS OF REFERENCE FOR THE HIGH-LEVEL PANEL OF EXPERTS FOR THE REVIEW OF POLICIES, LEGISLATION AND PRACTICES ON MATTERS OF ELEPHANT, LION, LEOPARD AND RHINOCEROS MANAGEMENT, BREEDING, HUNTING, TRADE AND HANDLING.

FOCUS AREAS FOR THE PANEL OF EXPERTS

PART A: ELEPHANTS

Elephants are iconic species in the South African conservation landscape. They play a significant role in creating and maintaining ecosystems that allow or influence persistence of other species. Elephants are amongst the most magnificent but also problematic members of South Africa’s wildlife population. They provide several economic opportunities, such as ecotourism, however, elephants are amongst some of the key species impacted by high levels of poaching and wildlife trafficking.

The panel of experts will assess and provide policy positions on the following:

- Keeping of elephants in captivity: genesis of keeping elephants in captivity in South Africa, methods, size of captive facilities, handling of elephants in breeding facilities, legal requirements, tourism, interactions and exploitation of tourists, zoos and related activities, as well as associated compliance and enforcement protocols and measures
- Hunting of elephants: should hunting of elephants be permissible and what are the legal requirements and conditions for such
- Population management: population control including culling and contraceptives, intercountry translocations
- Trade in elephant ivory: Ivory export, Trade or no trade, Mechanisms of the trade, Determination of the quota
- Ivory stockpiling: Options for stockpiling or not stockpiling, what are the costs and value for keeping ivory stockpiles to conservation
- Management of stockpiles: How is it standardised, traceability, marking and reporting in elephant ivory
- Impact and benefits: How does the variety of management practices like captive keeping, trading in elephant ivory contribute value to conservation in South Africa.
- Handling and Well-being: Practices, standards and guidelines for permitting facilities that contribute to conservation objectives

PART B: RHINOCEROS

In 2014, the Minister of Environmental Affairs, appointed a Strategic Task Team referred to as a Committee of Inquiry (Committee of Inquiry in terms of Treasury Regulations) to assist the Department of Environmental Affairs (DEA) with preparations for CITES CoP 17 on rhino matters considering that both these species are impacted by high levels of poaching and illegal wildlife trafficking. Discussions relating to legal and illegal trade involving specimens of rhinoceros species is ongoing in the context of the Convention of Trade in endangered Species of Fauna and Flora.

Through a process of stakeholder consultation, scenario planning, analysis of case studies and various workstream documents as well as a decision-tree analysis process, the Committee identified five key areas that require interventions. These interventions were needed to address wildlife crime and enhance government’s ability to conserve rhino species in their natural habitat, as well as enhancing opportunities to realise benefits associated with conservation. The Committee was strongly of the view that these interventions are essential for an effective response to rhino poaching irrespective of whether (or not) South Africa seeks to trade in rhino horn.

The five key interventions for rhino included:

- Enforcement: law enforcement (including anti-trafficking and anti-poaching), significant improvements in intelligence capabilities, understanding of a full value chain approach of illicit networks (led by SAPS), and enhance provincial anti-poaching capacities.
- Community Empowerment: strengthen governance in communities surrounding protected areas with elephants
- Demand Management: describe a detailed view on data required to inform policy, and actionable initiatives for more result oriented communication to different stakeholders
- Management of Rhino populations: outline processes to develop and share best practices to optimise birth rates
- Responsive Legislation: develop an enabling and responsive legislative environment In the light of the above the Panel of Experts is tasked to evaluate the outcomes of the Committee of Inquiry and make recommendations relating to:
- The status of the implementation of the rhino lab initiatives as per Committee of Inquiry outcomes Review and provide advice on the submission of the Rhino related trade proposals to the next coming CITES COP
- Review and advise on management of rhino horn stockpiles and related specimens
- Explore and assess the feasibility of establishing government Central System Database for rhino horn stockpile
- Advise on the possible conservation, socio- economic and political implications of live exports of rhino to countries outside the range states (political economy)
- Analysis of the demand management dynamics of consumer countries
- Develop the Lobby/Advocacy strategy for rhino horn trade in different key areas including, but not limited to:
- Review the current status quo for the domestic trade in rhino horn and assessment of its relationship with illicit trade in rhino horns
- Review current legislation and processes on domestic rhino horn and provide recommendations on the domestic rhino horn trade.
- Identification of new or additional interventions required to create an enabling environment to create an effective rhino horn trade

The panel of experts will assess and provide policy positions on the following:

- Keeping of rhinoceros in captivity: genesis of rhino farming in South Africa, farming and breeding methods, handling of rhino, legal requirements for management of privately owned rhino, tourism, interactions and exploitation of tourists, zoos and related activities, as well as associated compliance and enforcement protocols and measures
- Hunting of rhino: should hunting of rhino be permissible and what are legal requirements and conditions for such
- Population management: metapopulation management and rhino range states translocations
- Trade in rhino and rhino horn: rhino horn export, domestic trade or no trade, mechanisms of the trade, live sales and exports
- Rhino horn stockpiling: options for stockpiling or not of rhino horn, costs and value of keeping rhino horn stockpiles to conservation
- Management of stockpiles: standardization, traceability, DNA profiling, rhino horn markings and reporting
- Impact and benefits: how do the various management practices and trade in rhino horn contribute to conservation in South Africa?
- Handling and Well-being: practices, standards and guidelines for permitting facilities that contribute to conservation objectives

PART C: LEOPARDS

Leopards (Panthera pardus) have a long lifespan with low reproductive rates. They are tolerant of a wide range of habitats and climatic conditions, including mountains, bushveld, woodlands, desert and semi-desert and forests. However, like most felids, leopards are relatively poor dispersers and the degree of connectivity between populations, within and outside of South Africa, is unknown. Although more resilient than many other large carnivores, leopards are still sensitive to human disturbance and have been eradicated from at least 37% of their historic African range.

Approximately 20% (248,770 km2) of South Africa comprises suitable leopard habitat, although much of this is highly fragmented due to agricultural development, persecution and human encroachment. Today leopards are found in the remote mountainous regions of the Western Cape, parts of North-West, Limpopo, Mpumalanga, KwaZulu-Natal, the Eastern Cape, and the semi-desert areas of the Northern Cape bordering on Botswana. There is no rigorous estimate for the size of the South African leopard population, nor reliable estimates of leopard population trends at national or provincial scales.

In addition to habitat loss, key documented threats to leopards include: excessive off-takes (legal and illegal) of putative damage-causing-animals (DCAs); poorly managed trophy hunting; the illegal trade in leopard skins for cultural and religious attire; incidental; snaring; and the unethical radio-collaring of leopards for research and tourism. However, the relative severity of these threats and their impact on the national or provincial leopard populations remain unknown. Trophy hunting (practiced to maximize economic returns) and legal DCA control (practiced to minimize economic losses) are formally though often poorly managed, while other forms of harvest are illegal and therefore unregulated.

There are almost no reliable estimates for the extent of illegal off -take of leopards, though data from a few intensive studies in South Africa suggest that levels of illegal off-take exceed levels of legal off-take. Most leopard trophy hunting occurs on private land. Harvest of leopards is not managed consistently throughout the country; some provinces implement effective controls, others do not. Legal off-takes are poorly documented in many provinces. There is an urgent need for a coordinated national strategy which provides standardized guidelines to all provinces for the management of leopards.

The panel of experts will assess and provide policy positions on the following:

- Hunting of leopards: rationale and basis for hunting or no hunting, determination of the quotas and associated conditions, hunting standards, methods of hunting
- Trade in Leopard skins: trade or no trade, mechanisms of the trade, determination of quotas
- Demand management: dynamics of domestic and international demand, demand for leopard products (skins, claws, teeth), legislative and legal regime for demand management
- Impact and benefits: how do various management practices and trade in leopard specimens benefit conservation in South Africa?

PART D: LIONS

South Africa is home to a lion population of just over 10,000 lions, with close to 3000 lions in the wild and approximately 7000 lions in captive bred facilities. The wild lion is stable and growing owing to abundance of prey, disease management and successful conservation strategies. The captive bred lion population has grown significantly over the years due to favourable market conditions for trophy hunting and trade in lion bones. However, captive lion breeding, trophy hunting and trade in lion specimens present some contentions between the lion trade industry and animal welfare or rights groups and have negatively impacted South Africa’s tourism industry. These contentions draw attention to the policy and legislative position of the South African Government on lion management. While provincial governments are permit issuing authorities for restricted activities and trade matters pertaining to lions, the National Department of Environmental Affairs is the national CITES focal point whose role is mainly liaison and coordination with CITES authorities of the trading or consumer countries.

The implications of public sentiments on South Africa’s handling of the above matters of contention have escalated into an international discourse that necessitates a national dialogue. The department, therefore, seeks to get more insight into the management of lions and trade in lion bone in South Africa.

The panel of experts will assess and provide policy positions on the following:

- Breeding of lions in captivity: genesis of captive breeding of lions in South Africa, methods, size of breeding facilities, euthanasia of lions in captivity, handling of lions in breeding facilities, legal requirements, tourism, interactions and exploitation of tourists, petting zoos and related activities, as well as associated compliance and enforcement protocols and measure
- Hunting of captive bred lions: hunting rationale in captive breeding facilities, conditions for hunting of captive bred lions, size of hunting farms, release periods of lions for hunting and legal requirements for hunting captive bred lions
- Trade in lion bones and Leopard skins: lion bone trade or no trade, mechanisms of the trade, determination of the quota
- Stockpiling: options for stockpiling or not stockpiling lion bone, what is the value in keeping lion bone skeletons and related products to conservation?
- Management of stockpiles: standardization, traceability, DNA profiling, lion bone marking and reporting
- Impact and benefits: how do various management practices like captive breeding, trade in lion bones and other specimens contribute to conservation in South Africa?
- Handling and Well-being: practices, standards and guidelines for permitting facilities that contribute to conservation objectives.

[Lisbeth]

Is the environment minister captured by vested interests?

Opinionista • Don Pinnock • 29 April 2020

Everything a costly high-level panel appointed by the Department of Environmental Affairs is tasked to find out about wildlife is already known... so what’s going on?

Millions of rand are being spent by the Minister of Environment, Barbara Creecy, on a high-level panel to advise her on issues regarding lions, elephants, rhinos and leopards. But the scientific advice she’s requesting already exists.

Creecy is an intelligent, competent minister able to do her homework. So why is she ignoring this and wasting taxpayers’ money on an apparently superfluous exercise? Is the panel simply to inform her in her new position, or was it created to get the answers wanted by those pushing for the commercialisation of wildlife? If so, who are they?

It seems necessary to ask whether the minister is being held to ransom by the wildlife industry or by members of her department? If they’re members of her department, then her staff needs an urgent shakeup. If the initiative is hers, then we have a bias problem. Here’s why.

Terms of reference for the panel were belatedly released on 22 April, months after its formation and then only to those NGOs requesting extension of time to make submissions. They’re so restrictively worded that they predetermine an outcome being pushed by only the wildlife trade and hunting fraternity.

The criteria for panel members required that they have “experience in sustainable utilisation” – essentially in the “use” and not conservation or welfare of wild animals. This calls into question any semblance of impartiality and clearly indicates the direction the panel is expected to follow.

In her selection of the Committee of Inquiry into a Possible Trade in Rhino Horn in 2015, even the previous environmental minister, Edna Molewa, (an avowed proponent of sustainable use) and Creecy’s predecessor, never created such a blatantly biased panel.

There’s an admirable number of traditional leaders on the panel, but not a single mention of community issues in the terms of reference.

What are they there for? Simply to give legitimacy to the decisions of a panel focused on the narrow interests of a group of affluent breeders, traders and hunters?

It’s necessary to inquire if Creecy is knowingly party to developments that would rip SA’s already tattered conservation reputation even further through her department’s continued support of canned lion breeding and its attempts to reopen ivory trade and restart the elephant culling debate. Because this is precisely the door opened by the new terms of reference and composition of the panel.

Culling of elephants risks massive international opprobrium – witness the storm raised by Botswana’s opening of elephant hunting and the suggestion that culled elephants could be used for pet food. Are her advisers not aware of this?

So what do the panel’s terms of reference say?

Elephants

The terms expect the panel of experts to assess and provide policy positions on elephants, yet of 25 members it has only two elephant experts – Rob Slotow and Karen Trendler. Requirements include debate and direction on:

- Keeping of elephants in captivity.
- Hunting of elephants: “Should hunting of elephants be permissible and what are the legal requirements and conditions for such?”
- Population management, including culling, contraceptives and inter-country translocations.
- Trade in elephant ivory, including “mechanisms of the trade, determination of the quota”.
- Ivory stockpiling: “What is the value for keeping ivory stockpiles to conservation?”
- How the variety of management practices like captive keeping, and trading in elephant ivory contribute value to conservation.

But wait! We’ve been through all this before. In 2007, at the invitation of the then minister of environmental affairs, it took around 70 experts to produce a 620-page book covering all these aspects, which led to the norms and standards. Has the current minister read this? She certainly should before starting the process all over again.

It gets worse. For an indecently long time, the minister has had on her desk for signature The National Norms and Standards for the Management of Elephants in South Africa, which are the result of three years’ work by not only DEFF but also all interested parties. These norms and standards are excellent and answer most of the questions posed in the panel’s new terms of reference.

So why doesn’t she just sign that document? Is she seeking to circumvent yet another scientific process? Why?

In addition, DEFF is currently in the process of preparing a National Elephant Plan with input from stakeholders and following due process which should answer any questions not covered in the norms and standards.

The 2007 revised norms and standards specifically exclude the capture of elephants from the wild to prevent new elephants being added to the existing captive population. CITES regulations also preclude trade in live elephants.

This subject was exhaustively examined at a conference in 2019 held in Hermanus which included elephant experts from around the world. DEFF was invited but declined to attend. Most of the answers to the questions now being asked anew by DEFF can be found from the outcomes of that conference. But clearly the department did not like them and now seeks to justify its own actions with the support of a small group with vested interests.

The same year, a series of workshops on elephant policy was held in Hluhluwe-iMfolozi National Park as well as a Conservation Symposium in St Ives, KwaZulu-Natal. The symposium and workshops set out an extensive elephant policy programme answering most of what the panel is now tasked to re-explore.

The panel will serve only to reopen a debate on the hunting of elephants in the face of international disgust at this practice. Most of this hunting takes place in the Associated Private Nature Reserves (APNR) alongside Kruger Park which has its own protocols. There, national assets are permitted to move from Kruger Park to be shot in order to fund the leisure lifestyles of a group of mainly white landowners with scant benefit to bordering communities. Would a panel of mainly game breeders and hunters ever question this?

Culling is another issue to be reopened by the panel. Between 1967 and 1997, 14,629 elephants were culled in South Africa, mainly in Kruger, to maintain the population at an arbitrary level of 7,000. This had no foundation in science. Culling was stopped and a successful policy of closing down water holes was adopted to control elephant numbers.

In 2014 the park’s large-animal ecologist, Dr Sam Ferreira, said there would be no further culling in the park. He said managing the effects of elephants was not about controlling populations but letting natural processes influence where elephants spend time and what they do when they are in particular places. Kruger’s Elephant Management Plan confirmed that.

So why are we now opening up deliberations about culling? Has the minister not read that report? Instead, she’s paying 25 people an estimated R5- to 6-million to duplicate existing work already done by more qualified people. This at a time when the South African economy is on its knees and the costs of Covid-19 are astronomical. And when the answers she’s apparently seeking are already on the table.

Rhinos

Rhinos are under massive threat from poaching and their protection, particularly in Kruger Park, is costing millions of rand and the lives of rangers. The only way to stop the poaching is to reduce demand in China and Vietnam. Adding the possibility of legal rhino horn simply fans the trade and acts as a cover for illegal horn.

However, the panel is not tasked with this problem, but instead, among other things, to “identify new or additional interventions required to create an enabling environment to create an effective rhino horn trade”.

DEFF has already legalised domestic trade in rhino horn, despite an international ban on this trade by CITES. The panel’s task is not to bring South Africa into line with the UN body, but instead to “review and provide advice on the submission of the Rhino related trade proposals to the next coming CITES COP”.

In other words, to try, yet again, to get international horn trade legalised.

Significantly, there are no rhino experts on the panel unless one considers hunters and breeders to be experts.

Lions

In 2018, following a two-day colloquium into the captive lion breeding industry, the Parliamentary Committee on Environmental Affairs recommended that the industry be closed down. This was confirmed by a resolution of the National Assembly. It found that the conservation value of predator breeding was zero and was undermining the country’s tourism brand value.

It noted that, although captive lion breeding for hunting is currently lawful, this did not make it ethically, morally or socially acceptable – especially the manner in which hunted animals are raised and released for hunting.

It also considered SA’s export of lion bones and expressed concern over the health and safety posed by zoonosis – the transmission of disease from wild animals to humans (as with Covid-19).

The task of the high-level panel, however, is not to consolidate the parliamentary instruction on lion breeding or canned hunting, but to “get more insight into the management of lions and trade in lion bone in South Africa”.

It will open the debate afresh as though it has not already been extensively dealt with by Parliament. It is tasked to explore “the genesis of captive breeding of lions in South Africa, methods, size of breeding facilities, euthanasia of lions in captivity, handling of lions in breeding facilities, legal requirements, tourism, interactions and exploitation of tourists, petting zoos and related activities, as well as associated compliance and enforcement protocols and measure”.

It will also re-explore “the hunting rationale in captive breeding facilities, conditions for hunting of captive-bred lions, size of hunting farms, release periods of lions for hunting and legal requirements for hunting captive-bred lions”.

This does not sound like a recipe for closing down captive-bred lion facilities and canned hunting, as per Parliament’s instruction.

Is the minister aware of the 2015 Biodiversity Management Plan for Lions published jointly by CSIR and gazetted into law, specifically to address issues of lion management?

Once again, there are neither lion nor leopard experts on this panel apart from breeders, hunters or supporters of trade. Nor are there any illegal wildlife trade experts or monitoring groups able to advise on the effect and risks of opening legal trade on illegal trade.

The reopening of all these debates about wildlife in the face of solid, scientific guidelines by a large range of wildlife specialists and scientists and parliamentary instructions suggests the existing guidelines and science have not gone in the direction of a lobby group who appear to have considerable influence over DEFF.

Is the department “captured”? Who stands to gain from the commercialisation of wildlife? Why are we wasting money on a panel with terms of reference and composition that virtually guarantees an outcome in favour of a wealthy, privileged group of breeders and hunters?

A letter to DEFF from the Wildlife Animal Protection Forum of South Africa signed by 22 environmentalists and scientists lists the above concerns and concludes that the panel runs the risk of being institutionally biased.

“A candidate with vested interests in the continuation of captive predator breeding or captive-origin lion hunting,” they write, “appears unlikely to uphold the parliamentary resolution to put an end to these practices.

“Similarly, those with a vested interest in trading in rhino horn or ivory or trophy hunting may unduly influence the deliberations of the panel to secure an outcome on which their direct and/or future revenue depends.

“Given the urgent nature of the matters to be reviewed, the qualifications, skills, commitment to the Constitution and freedom from institutional bias among this panel should be beyond reproach. This may not have been achieved.”

The apparent duplication of effort and expense is so extreme it should warrant investigation by the auditor-general as possible wasteful and fruitless expenditure and, in the public interest, by the public protector. DM

[Lisbeth]

Very instructive, worrying and poses a lot of questions

[Lisbeth]

Wildlife experts spurn invite to serve on environmental panel, indicating bias and co-option

By Don Pinnock• 15 July 2020


A rescued male lion in his enclosure at the Lions Rock Big Cat Santuary, Warden, South Africa. (Photo: EPA-EFE / Kim Ludbrook)

Three people have declined to serve on a government panel. That’s not exactly news. But, given who they are and the panel on to which they were invited, their refusal has exposed major fault lines in South Africa’s treatment of wild animals.

The high-level panel was set up by the Minister of Environmental Affairs, Barbara Creecy to review the policies, legislation and management regarding the breeding, hunting, trade and general handling of elephants, lions, rhinos and leopards. It was appointed in 2019 and has to report to Creecy by November 2020. Members were required to sign a confidentiality undertaking – it’s deliberations are secret.

Shortly after the panel was formed, fault lines began to appear, soon to open into an almost unbridgeable canyon of dislike and distrust. The first shots were from conservationists claiming that the panel was hopelessly biased in its composition.

There are some traditional leaders on the panel, a few biltong farmers, several scientists and (initially) one animal welfare specialist. But most members are either hunters, game farmers and advocates of international wildlife trade. There are no vets, epidemiologists, climate change experts or ecotourism representatives.

Although supposedly serving in their personal capacities, some panel members have publicly proclaimed that they represent their organisations.

How, it was asked, could they possibly come to conclusions that could, for example, close down captive breeding or canned hunting of wildlife and vote against the export of ivory, rhino horn, lion bones or live animals? Who on the panel would propose non-consumptive alternatives or could understand the long-term effects of inbreeding or zoonotic transfer of disease?

Through the panel’s wall of secrecy have filtered whispers of acrimony and personal attacks on dissenting voices. “Greenies” are not tolerated. The only welfare specialist, Karen Trendler, resigned citing “personal reasons”.

The former head of Sanparks, Mavuso Msimang who was the panel’s chair, resigned for health reasons. A progressive environmental lawyer, Aadila Agjee, was selected but never served and was not replaced. The NSPCA, a central animal welfare organisation, was promised representation, then not initially invited (more on this later).

The panel called for external submissions as part of public consultation and received 70 – a considerable number for such processes. However, given the panel’s tight deadlines and the Covid-19 epidemic, it is unlikely that there will be any actual public consultation.

A government adviser let slip that the panel will only see “thumbnail sketches” of the presentations prepared by him. Then – out of the blue and after nearly half a year and something of a media storm around the panel’s composition – a progressive environmental lawyer, the acting CEO of the NSPCA and a respected elephant specialist were sent a “letter of appointment” by Creecy. They declined for reasons which follow.

In inviting them halfway through the process, had the minister realised she’d overplayed her hand in the panel’s lopsided composition and was now trying to rescue its credibility? It’s hard to say. A preliminary report had already been submitted to the minister by the time these appointments were proposed.

Their replies refusing appointment were instructive and came close to suggesting attempted co-option and the panel’s inevitable foregone conclusions.

Cormac Cullinan, the environmental lawyer, wrote: “In my view, the terms of reference and the composition of the panel do not reflect an even-handed approach and make it inevitable that the panel will advise you to intensify the commercial use of wildlife and wildlife body parts.

“The recent publication of the regulations on trade in rhino horn make it crystal clear that the Department is committed to promoting a legal trade in rhino horn. And the Department’s reluctance to give effect to the Parliamentary Portfolio Committee’s resolution (subsequently adopted as a resolution of the National Assembly) about phasing out the lion farming industry has been evident for some time.

“In my view the composition and terms of reference of the panel mean that it will not function as a credible or effective means of charting a coherent policy direction that takes account of animal wellbeing and the critical importance of conserving wildlife and ecosystems within the context of a global collapse of species.”

He said he believed that the panel’s recommendations would legitimise measures that will harm global efforts to conserve iconic species, entrench the idea that these animals are commodities, facilitate a small minority to benefit financially from wildlife and support the development of policies based on sustainable use.

Audrey Delsink, who heads Humane Society International-Africa’s wildlife division, refused the appointment, saying there was a “substantial imbalance of representatives favouring the consumptive use framework of these animals – many of whom have direct financial interests in the outcome of the panel’s work”.

The panel’s Terms of Reference, she said, “make no provision for engaged discussions regarding how animal cruelty is implicit in captive breeding, trade and hunting of these species, nor how alternative ways of generating social and economic development from our unique biodiversity could be explored and adopted”.

She added that the terms “have no meaningful conservation value” and “did not make allowance for the reasonable and required reconsideration of current policy”.

Este Kotze, the deputy CEO of the NSPCA, says the organisation was invited on to the panel a few weeks previously (having been ignored earlier), but that its national council did not wish her to serve. The invitation was rejected, she said, “for reasons I cannot discuss”.

The World Wildlife Fund for Nature (WWF), however, accepted the late invitation and will be represented by Theressa Franz, a former employee of the Environment Department who is now head of the WWF’s environmental programmes unit.

The debate about South Africa’s treatment of its wild animals – the core of its tourist industry – is clearly deeply polarised. On the one side are trophy hunters, canned lion operations, intensive commercial breeders of rhinos, lions and other game, the national and international organisations they belong to, pro-trade academics and senior officials in the Department of Forestry, Fisheries and Environment.

On the other side are conservation NGOs, environmental lawyers, owners of private game reserves, ecologists and wildlife tourism operators who support non-consumptive use of wildlife. Also onside are local and international organisations that support ecological sustainability and abhor cruelty and the trade of wild creatures and animal parts. On canned lion hunting and welfare, their views have received the backing of the Constitutional Court, High Court and Parliament’s Environment Portfolio Committee.

At the heart of the great divide between users and protectors of wildlife is the notion of sustainable use. Game farmers and hunters employ the term to describe their operations, which are essentially using wild animals as the raw material with which to accrue income. It’s a business term and about the bottom line.

For breeders of beautiful specimens, long-standing biltong farmers and traditional hunters for the pot that’s perfectly understandable. Why not, it’s their livelihood?

The problem is that, in many cases, using wild species commercially for petting farms, hunting and the lion bone trade has resulted in sordid conditions, with animals kept in small, overcrowded cages. Predators are bred to survive excessive tourist handling and then used for canned hunts, their bones sold for fake tiger wine. Animals are shot to be hung on walls as trophies. Sustainable use (read commodification), can wear a very cruel and ugly face.

To better understand the argument of those who reject “sustainable use”, a position the high-level panel is sure to embrace, let’s widen the frame. There’s no doubt that excessive and unchecked consumption of wildlife on Earth is accelerating biodiversity loss.

A report by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services released in 2019 found that up to a million species were threatened with extinction and that direct exploitation for trade was the second biggest threat to species survival after habitat loss.

It noted that, in the last century, the global biomass of wild mammals fell by 82% and the overall abundance of naturally present terrestrial species declined by 23%.

Could farming wild animals be a hedge against this loss? A report into sustainable use by the NGO Nature Needs More released in June 2020 doesn’t think so. It says that, in the light of the Biodiversity report, “sustainable use” is “just a convenient story to keep us from questioning the reality of unsustainable over-exploitation of wildlife”.

The term “cannot withstand scrutiny. It’s as elegant in language as it is ineffective in preventing disaster,” exploiting our fondness for wishful thinking over having to make hard choices.

“The notion of sustainable use,” says the report, “was designed to disguise the prioritisation of growth and unlimited exploitation over biodiversity preservation and social justice outcomes.” It calls this magical thinking: Hoping that saying the right words will change reality.

Wildlife farming operations, the report notes, are just large-scale for-profit businesses that both satisfy existing demand and create new demand through marketing. The existence of supply of “farmed” products creates a taste for “wild” products to allow “luxury” consumers to differentiate. It’s an incentive for illegal harvesting.

Well, maybe game farming and hunting brings revenue into the country and creates job opportunities? To assess community benefits, the first question that needs to be asked is where the profits go? The answer, says the report, is that they go to those who hold the requisite private property rights – the shareholders of the businesses involved in wildlife trade, hunting and the landowners or owners of wildlife in the case of farming.

In hunting, the profits are generally made in wealthy countries where the hunts are booked. It’s estimated that only 3% gets back to communities or households where the hunting takes place.

These are issues the high-level panel should be grappling with in charting a path for wildlife management in South Africa. But its composition and terms of reference, according to its critics, suggests that sustainable use is a given, not worthy of debate or alternatives and that decisions will be made how best to operate in terms of its assumptions.

However, several people on the panel might well give thought to the implications. Among them are a number of traditional leaders whose people derive little benefit from game farming and hunting in ways other than as labourers. Many of the wild animals under discussion are also sacred to many cultures and totemic to chieftainship.

Biltong farmers, a mainstay of the venison market, are also being tarred with the same brush as canned hunting operations to their detriment.

Claims that wildlife farming supports conservation is evidently a non-starter – very few captive animals can be reintegrated into the wild. No peer-reviewed studies have documented the successful reintegration of captive-bred predators.

A further problem is that on farms, wild animals are often treated with antibiotics that lower their resistance to illnesses they would normally repel in the wild. They also become habituated to humans to their detriment and never learn essential wild skills of hunting or avoidance of predators.

So where does that leave us? The government clearly fully supports sustainable use – even President Cyril Ramaphosa owns a game farm, Phala Phala. In 2019, 32 wild animals were listed under the Animal Improvement Act, rendering them essentially farm animals. A further 98, including rhinos, hippos, elephants and crocodiles, are presently under consideration for listing under the Meat Safety Act, which deals with slaughter conditions and food safety. South Africa is clearly committed to the use of wild animals for revenue generation among those wealthy enough to farm them.

So the battle for the soul of sustainability continues and the question remains: Is the high-level panel a serious think-tank or a rubber stamp? As its report is likely to be secret and may never see public debate, it’s possible we’ll never know. DM

[Richprins]

Why should one decline an invitation to speak one's mind just because one thinks the majority may not agree?

It is tough in the real world vs social media...

[Lisbeth]

It was bound to end like this

Not accepting is a sign of protest against a decision that is already taken. In this case against the unfair selection of the panel members.

This is very dangerous for the future of SA tourism and above all the brand "South Africa". A large amount of money and goodwill involved.

[Richprins]

Remember our reps went to the SANParks meetings even though we knew it was a done deal and the dice were loaded?

[Lisbeth]

That was an open meeting with the presence of the media

[RogerFraser]

Statement by Minister Creecy: Release of report of high-level panel

02 May 2021

https://www.environment.gov.za/speeches ... t_pretoria



Honourable Chair of the Portfolio Committee on Forestry, Fisheries and the Environment, Mr Fikile Xasa, and other members of the Portfoilo Committee

Chairperson of the High-Level Panel, Ms Pam Yako

Esteemed Members of the Panel

Director General of the Department Ms Nomfundo Tshabalala

DDG Shonisani Munzhedzi and your team

Honoured Guests

Members of the Media



I have today, 2 May 2021, released the report of the High-Level Panel that was appointed to review policies, regulatory measures, practices and policy positions that are related to hunting, trade, captive keeping, management and handling of elephant, lion, leopard and rhinoceros.

The appointment of the Panel through the hosting in August 2018, of a Colloquium on Captive Lion Breeding by the then Portfolio Committee on Environmental Affairs. This was attended by a range of national and international organisations who gave evidence to the Committee. According to the report of the Portfolio Committee, which was later adopted by Parliament, there was a predominant view that the captive lion breeding industry did not contribute to conservation and was doing damage to South Africa’s conservation and tourism reputation.

The Portfolio Committee, therefore, requested the department, as a matter of urgency, to initiate a policy and legislative review with a view to putting an end to this practice. Given that there were a number of other burning issues related to other iconic species such as rhino (escalating poaching, rhino horn trade), elephant (ivory trade), and leopard (threats such as illegal offtake of damage causing leopards, poorly managed trophy hunting, trade in leopard skin for religious and traditional use) the department decided to include these in the terms of reference of the Panel in order to get a holistic view of the pertinent issues.

I established the High Level Panel on 10 October 2019, in terms of S.3A of the National Environmental Management Act 107 of 1998 (NEMA). The Panel was chaired by Ms Pamela Yako, and comprised 25 members from a range of backgrounds and areas of expertise.

Despite the obstacles placed in the way of the Panel’s work by the Covid 19 pandemic, it has gone about its task in a thorough and professional manner, and was able to put in place a comprehensive program of stakeholder consultations, during which all interested parties were given an opportunity to make written submissions and to present their case to the Panel. The Panel even managed to conduct a series of face-to-face consultations in between the first and second waves of Covid-19 in 5 provinces with the leadership of those communities living adjacent to protected areas which carry the iconic species under consideration. It concluded its work on 15 December last year, and submitted a report of almost 600 pages to me a few days later. The report was subsequently presented in Cabinet and approved for release and implementation.

I wish to thank the Panel for the work that it has done in producing a comprehensive and credible report with a set of recommendations which address the difficult issues facing the sector.

I am greatly impressed by the depth of work undertaken, and the level of detail presented in the report. It contains a comprehensive situation analysis; a review of the extensive work of previous panels and processes; and it addresses a number of contextual issues necessary to advance coherence in policy, legislation, regulation and its implementation across spheres of government and management authorities.

Throughout the report, the focus is on providing policy certainty and reducing bureaucracy and red tape. Perhaps most admirable that the panel recognised that resolution of the issues required a bigger-picture framing, a re-imagining if you will.

It is in this context that the Panel envisages “Secured, restored, and rewilded natural landscapes with thriving populations of elephant, lion, rhino, and leopard, as indicators for a vibrant, responsible, inclusive, transformed, and sustainable wildlife sector”.

This vision is aligned with the Strategic Plan 2024 of the Department, and the Impact Statement within that Strategy: “A prosperous and equitable society living in harmony with our natural resources”. Besides providing specific interventions to resolve key issues in the sector, the report also provides for a re-conceptualised wildlife sector, that will provide a new deal for people and wildlife in South Africa.

The report contains a clear vision, with 18 goals and 60 recommendations. I must say it is remarkable that a group of people with different views on the management of these iconic species was able to achieve consensus on all recommendations, except those recommendations that deal with captive lion and rhino breeding. In terms of captive lion and captive rhino breeding, where there were majority and minority recommendations, and having applied my mind, we will be adopting the majority recommendations on these issues.

In adopting the report’s recommendations, it is important to indicate what the key outcomes for the country will include:

• The development of a shared vision for the sector;

• Improved policy and legislative coherence, which will provide certainty and a stable base for growth and development;

• Better balancing our economic, social, cultural and natural heritage needs, including re-imagining the role of protected areas, both state and others, in contributing to ecologically sustainable rural development;

• Placing communities living with wildlife at the centre of our thinking so we focus on enhancing human-wildlife co-existence, and transformative approaches to access and benefit sharing for communities living on the edges of protected areas;

• A renewed focus on transforming the ownership and management of the commercial wildlife economy particularly in the eco-toursim and authentic hunting sectors;

• The ending of certain inhumane and irresponsible practices that greatly harm the reputation of South Africa and the position of South Africa as a leader in conservation; and finally,

• Contributing to ensuring Africa’s coherence and unity in relation to conservation; sustainable use and management of these species;

We will be taking forward the recommendations to develop a Policy on Biodiversity Conservation and Sustainable use and adopt a One Welfare approach for wildlife.

There are key recommendations to reposition and reorganise protected areas, simplify and make more effective legislative and administrative processes, as well as to improve cooperative governance. The Department will initiate discussions to resolve these.

Transformation of the sector will be prioritised, in terms of improved inclusion of marginalised groups, especially communities living with or adjacent to these species, and in the role and influence of traditional leaders and healers in the wildlife sector.

In terms of captive rhino, the Panel makes clear recommendations as to how partnership with private owners of rhino can lead to strong conservation outcomes for the species, while enhancing potential benefit streams. We have accepted that the country adopt the recommended positions on ivory and rhino horn trade, such that we will not be making proposals to CITES for further trade in these derivatives until certain conditions have been met. On the rhino these are based on the Commission of Enquiry’s report Option 3 as approved by Cabinet and the Rhino Action Plan and the development of a global consensus for legal international trade in rhino in the interest of rhino conservation. As South Africa protects the largest component of the global rhino population, we intend to play a global leadership role in this. For elephants, although we hold a relatively small portion of the population, South Africa wants to play a key role to bring African consensus on ivory trade in the interest of ivory trade on elephant.

We will be initiating a participatory process, with recognition of the important role and contribution by private owners, including some major ecotourism-based rhino populations, to rhino conservation, to find win-win solutions to safeguard rhino conservation and broaden and deepen the bio-economy associated with rhino.

The Panel identified that the captive lion industry poses risks to the sustainability of wild lion conservation resulting from the negative impact on ecotourism which funds lion conservation and conservation more broadly, the negative impact on the authentic wild hunting industry, and the risk that trade in lion parts poses to stimulating poaching and illegal trade. The panel recommends that South Africa does not captive -breed lions, keep lions in captivity, or use captive lions or their derivatives commercially. I have requested the department to action this accordingly and ensure that the necessary consultation in implementation is conducted.

It is important to stress that the recommendations are not against the hunting industry. Preventing the hunting of captive lions is in the interests of the authentic wild hunting industry, and will boost the hunting economy and our international reputation, and the jobs that this creates.

Now that these recommendations are approved for implementation, they will result in a step change, with the consequent benefits to our standing and reputation. Key to this is transforming the sector, reinvigorating the biodiversity economy through a focus on Big Five-based ecotourism and authentic hunting of wild specimens. We will be partnering with the Department of Tourism to achieve this. In addition, mechanisms to improve benefit flows to restituted communities, as well as novel approaches to land-use planning, can enhance rural socio-economic development based on the wildlife economy.

The report provides specific direction as to how my Department can support the Department of Agriculture, Land Reform and Rural Development in ensuring the welfare and wellbeing of wildlife, which will enhance our reputation and stimulate tourism.

We will, therefore, be working closely with this Department and other departments in this regard. In relation to enhancing our international reputation, an engagement with SADC partners and the African range states of these species and the leadership of the Department of International Relations and Cooperation will be required. A multi-sectoral approach to implementing the recommendations is therefore imperative.

In summary, I believe that the report provides a platform for not only achieving policy clarity, but also for the development of a New Deal for people and wildlife in South Africa. Implementation of the recommendations will greatly transform the practices within the wildlife industry, enhance conservation of our environment and these species, invigorate the rural economies where the species occur or can be introduced, and empower traditional practices, leadership, and healers. Finally, implementing these recommendations will result in both protection and enhancement of South Africa’s international reputation, repositioning the country as an even more competitive destination of choice for ecotourism and responsible hunting.

As indicated in the report, there have been a range of processes over the years that have not been properly implemented, and have resulted in the compromised position that the sector is in. This time I intend that we will act differently. I have instructed the Department, to develop an implementation plan for the recommendations.

Work has already begun, on a draft Policy Position that covers the key policy implications of the recommendations, which will shortly be published for public participation. The Department is also initiating a process to develop a draft White Paper on Biodiversity Conservation and Sustainable Use for consultation. The more administrative processes required by the recommendations are all being taken up by the Department, and I have emphasised to the Department the need for full consultation with both the public, as well as with colleagues in government.

Apart from releasing the report of the Panel today, we are also putting in place a programme of stakeholder feedback sessions to give feedback on the findings and recommendations to those stakeholders who made submissions, and also to those with an interest in the Panel’s work. We will also conduct the required public participation processes in respect of the implementation of some of the Panel’s recommendations.

In order to assist me in the communication of the Panel’s recommendations and in the development of an implementation plan I have extended the term of the Chairperson of the Panel, and a small number of other Panel members, largely the drafting team.

Let me conclude by thanking all those organisations and individuals who assisted the Panel in its work by making submissions and providing the much-needed information and analysis on the areas under review. Your time an effort have resulted in a substantial body of work that will guide us in policy implementation for many years to come.

I thank you.


Kindly find link to the HLP report link on the website: Ministerial high-Level Panel report

For media inquiries contact:
Albi Modise
Cell: 083 490 2871

Report File Here :

2020-12-22_high-levelpanel_report.pdf

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