Animal Farm

Stephen Wiggins Article 2 Comments

Banner image courtesy of Mpora – “Rare white lions are considered particularly valuable among trophy hunters, and so are intensively bred – often with detrimental consequences for the gene pool. Photo: Anonymous

The following article is written in conjunction with Voice4Lions.


Why would South Africa’s game breeding industry (the “industry”) seek the listing of wild species, such as lions, under a regime – namely, the Republic of South Africa’s Animal Improvement Act (AIA,) 1998? The AIA allows such game breeders to genetically manipulate listed species, under the pretence that such actions are undertaken to “To provide for the breeding, identification and utilisation of genetically superior animals in order to improve the production and performance of animals in the interest of the Republic“ – whatever that means.

The AIA permits “animal breeders’ societies” (ie. the membership of “breeders’ societies” remains wide open – reference “Definitions“) to manipulate breeding outcomes and hence seek to breed genetically distinct sub-species:

The same method used by humans to domesticate aurochs into docile cows, the grey wolf into the many breeds of dogs and produce “golden” impala – “By the stroke of a legislative pen, a list of iconic and in some cases endangered wild animals can now be manipulated as farming stock. What happens next is anyone’s guess,” Don Pinnock, The Daily Maverick, 16 October 2019

This listing of “Lion” under the AIA took place in May 2019 (plus 24 specific indigenous and six non-indigenous game species, amongst others, lechwe, white and black rhinoceros, cheetah, giraffe and a number of non-indigenous deer species, plus 12 game species which included black wildebeest, blue wildebeest, blue duiker, bontebok, gemsbok, impala, oribi, red hartebeest, roan, sable, springbok and tsessebe).

The species added to the AIA Table 7 was at the behest of Minster Senzeni Zokwana (Department of Agriculture, Forestry and Fisheries (DAFF)) as notified in Gazette 42464, 17 May 2019, Amendment to AIA, Table 7. However, no public consultation took place, as mandated within the AIA, Paragraph 2(2):

In the case of a new kind of animal or a new breed of such kind of animal to be imported into or to be bred in the Republic, the Minister shall make such declaration after considering the request, taking the international law into consideration and after considering comments received in response to an invitation by the registrar to interested persons to comment on a proposed declaration that had been published in the Gazette at least 30 days prior to such declaration

Since when has the public, or animal welfare NGOs not been deemed “interested persons?

As a past precedent, “Game Policy” was put to public consultation in Notice 874, Vol. 493 Gazette 28994, 7 July 2006. So why was adding new kinds of animals/breeds to the AIA Table 7 not put to public consultation? There is clearly scope for a legal challenge to be made for the lack of public consultation for the DAFF’s AIA amendments made in May 2019.

Genetic Confusion

The creation of ‘new’ genetically diverse sub-species would no doubt “create confusion in the implementation of CITES and other laws creating an opportunity for laundering.”

So, could it be, for example, that the industry is seeking to create lions (Panthera leo – African lion) as a new, big boned sub-species for example (ie. ‘Panthera leo villam’ – ‘Farm’ African lion), that can be promoted as genetically distinguished from the sub-species taxonomy Panthera leo leo, or Panthera leo melanchaita….?

The African lion is listed by the International Union for Conservation of Nature (IUCN) Red List as “Vulnerable” and hence the industry could seek to circumvent ‘pesky’ restrictions on specific taxonomy, as imposed by Convention on International Trade in Endangered Fauna and Flora (CITES) and importing signatories by creating a new, farmed sub-species. This then opens up the prospect of unrestricted lion bone trade exports of ‘Panthera leo villam’ unhindered by CITES oversight/export reporting and any CITES imposed quota restrictions.

Update: “The game ranchers’ industry is also pushing to have farmed wild animals listed with a new and separate CITES purpose code, which may come up at CoP19” – “Reclassification of 33 wild mammal species under the Animal Improvement Act,” The Coalition, 30 October 2019

It should be noted that genetic modification of farmed game species is nothing new – for example, Lumarie game breeder’s USP (unique selling proposition) is offering rare, genetically mutated examples for trophy hunters to lust after, be that a white antelope, black giraffe or black impala (all command significant order of magnitude higher returns for Lumarie’s owners Jacque and Carolien come game auction time return on investment).

According to Jacque, it’s a bit like growing flowers and a desire to develop unique colours (or in another analogy Jacque proffers, a need for a different dress (?)). In Jacque’s game breeding/hunting world the same ‘fashion’ applies to animals it seems. “No,” according to Jacque, producing ‘designer’ animals is not about playing God, it’s all about taking nature’s rich palette of colours and using it (or some such self-justifying wisdom Jacque espouses).

The same industry ‘logic’ then applies to the creation of a distinct, farmed rhinoceros sub-species for example, with a manufactured genetic propensity to regrow its harvested rhino horn (no matter any other negative side-effects/consequences for the breed and/or wild species)…….and so on. The industry no longer trying to hide behind a mantle of conservation, but exploitation for exploitation’s sake – namely, money – when such trade clearly exposes the wild species to potentially detrimental, irreversible impact.

Of course, any pretence of the industry’s conservation imperative must be discarded (rather than maintained to mask commercial intent), as such genetic species’ modification endeavours threaten the genetic pollution and conservation status of wild species if uncontrolled and unforeseen cross-breeding manifests – which indeed it will without the necessary funding directed to secure the separation of genetically modified sub-species and wild species. But when profit is at stake, such bio-security funding tends to be a low priority when there is money to be made – eg. ‘farmed salmon gene pollution threatens wild salmon.’

Questions Unanswered

Who is responsible for animal welfare for any species/breed encompassed within the AIA?

In the mire of animal welfare neglect in the pursuit of profiteering from animal exploitation, the Department for Environment, Forestry and Fisheries (DEFF) has sought to make clear in its July 2019 statement “the legal status of game species” the conservation of wild species should be encompassed by DAFF within its consideration of listings in the AIA (including those of the 17 May 2019):

It is important to note that animals listed under the Animal Improvement Act, 1998 (Act No. 62 of 1998) (AIA) are still subject to the requirements of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA) and provincial conservation legislation” – ie. the exploitation of wild species as now listed under the AIA must be proven as not detrimental to the wild, protected species.

In the DAFF’s own “National Plan for Conservation and Sustainable Use of Farm Animal Genetic Resource (2016),” definition of “Sustainable Use” calls for the conservation of endangered breeds – so it’s a concern that a species such as lions can be listed by the DAFF within the AIA with seemingly little regard for the conservation impact on the wild species.

Also under Objectives (Paragraph 3.2) this “National Plan” seeks to “Support all actions concerning the conservation of animal genetic resources and establishing a transparent system of competence and responsibilities between the country and DAFF, NGOs and private livestock sector” – So why weren’t interested persons/NGOs consulted before the DAFF’s fait accompli announcement in Gazette 42464, 17 May 2019, Amendment to AIA, Table 7?

On 12 September 2019 (NW545) questions were raised in the Republic of South Africa parliament by Mr N Bagriam to the Minister of Agriculture, Land Reform and Rural Development (part of the DAFF):

“(1) Regarding the amendment of the Animal Improvement Act, Act 62 of 1998, which places more than 30 wild animals within the legal purview of agriculture and, essentially, farming,

(a) what are the reasons this has been done,

(b) was there a public consultation process and

(c) what research was undertaken by scientists in planning the amendment;

(2) Whether, in view of the Animal Improvement Act, Act 62 of 1998, allowing improvement of genetically superior animals to increase production and performance, permitting breeders to manipulate breeding outcomes and also allowing artificial insemination to be used, her department has considered the implications of the change for the 33 species of wild animals listed in the Amendment; if not, why not; if so, what are the implications?”

The DAFF answers given were evasive and inadequate and make clear that an industry command has seemingly been blindly followed by the DAFF with little regard for the consequences or detrimental risks to wild species (as dictated by the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA)):


(a) The AIA amendments conducted by the DAFF were at the behest of the industry “in a letter dated 15 January 2017 to have game animals declared in terms Animal Improvement Act, 1998 (Act 62 of 1998).

(b) “The DAFF did not conduct public consultation on the declaration of these animals. These animals are landraces (endemic) to South Africa, hence the declaration of landrace (a kind of animal indigenous to or developed in the Republic). However, research will be executed on the species based on research questions in areas such as genetic purity, feeding and nutrition.”

Where “Landraces” is defined by DAFF as “….breeds with small population sizes or animal groups found in specific regions or ecological niches. They are often the remainder of a former larger local breed which, owing to prevailing environmental conditions or less efficient breeding programmes, has fallen behind in performance compared with intensively bred farm animals. These breeds therefore deserve particular attention in programmes designed to conserve animal genetic resources.”

How does giraffe, lion or rhino etc. fit within this DAFF definition of “Landraces” and how exactly for example, does breeding genetically specific lions to supply the lion bone trade seek to “..conserve animal genetic resources” when such trade has no such conservation imperative, but is based purely on commercial endeavour?

(c) “No research was undertaken by scientists in planning to have the game animals declared in terms Animal Improvement Act, 1998 (Act 62 of 1998)……”

(2) “The Animal Improvement Act, Act 62 of 1998, provides for improvement of genetically superior animals to increase production and performance. This act is progressive, and can therefore not be implemented to the detriment of animal (biological) genetic resources. Declaration of the animals is aimed at ensuring that these landraces are conserved. It is also important to indicate that, due to changing farming systems in South Africa, game animals are included as these are already part of farm animal production systems in the country.”


The question remains why has this action been taken by DAFF at the behest of the game breeding industry to encompass wild species, such as the African lion into the murky, commercially driven world of “improvement of genetically superior animals to increase production and performance, permitting breeders to manipulate breeding outcomes and also allowing artificial insemination to be used…?”

The science to back such actions and prove such actions are not detrimental to the survival of the species in the wild remains elusive (ie. non-existent). There is no precautionary principle evident, assessing and duly weighing the risks before any reckless actions are adopted (such as promoting lion bone trade quotas without regard for animal welfare and not considering the continent wide risks to wild lions before, or since the lion bone trade was implemented in 2008).

As an example of South Africa leading the conservation of vulnerable species, such actions are again weighted by commercial profiteering and intent, with little regard for the risks to conservation and South Africa’s international image.

And it is not just the ‘Animal Rights’ NGOs (such as WildLifeDirect, National Council of SPCAs (NSPCA), Blood Lions, Conservation Action Trust…… ) raising concerns over the potential risks the May 2019 AIA amendments pose.

The South African Hunters and Game Conservation Association (“SA Hunters”) wrote in March 2019:

“SA Hunters is gravely concerned about this amendment that puts Black Wildebeest, Blue Wildebeest, Blue Duiker, Bontebok, Gemsbok, Impala, Oribi, Red Hartebeest, Roan, Sable, Springbok, and Tsessebe at risk of genetic manipulation and genetic  pollution, amongst other concerns…….. The intention of the Animal Improvement Act is predominantly to enhance animal species through breeding practices for improved food production. This practice certainly cannot be argued to be beneficial for threatened species [such as lions].  It will be problematic to distinguish between, or permanently separate, domesticated game and free-roaming game, with potential reputational risks to the hunting sector that already bears the brunt of local and international criticism because of unacceptable hunting practices.

SA Hunters requested that the matter be placed on the agenda of the Wildlife Forum where government interact with the wildlife industry to ensure official responses from both DEA and DAFF on the matter. Although DAFF confirmed that they would report on the matter at the meeting, they did not show up and no response was given on the matter” – “SA Hunters concerned about new regulations that allow cross-breeding of wildlife,“ March 2019 – there is nothing to suggest SA Hunters have since received the assurances and explanations sought from the DAFF.

Once again, the Republic of South Africa’s departments for environment (DEA/DEFF) and agriculture (DAFF) appear to be lost within their own machinations, by continuing to appease the captive lion breeding industry for example – listing lions for genetic manipulation under AIA amendments for commercial purposes, but with no supporting reasoning, logic or pre-emptive risk assessment evident (assessing if such actions are detrimental to the survival of the species). This is despite a 2018 Parliamentary Report calling for an end to captive lion breeding in South Africa, not encouraging new means to exploit captive bred lions.

The dichotomies within South Africa’s disparate game breeding policies grows ever wider –  increasingly distant from any credible conservation imperative, but transparent in commercial intent – and ever more damaging to South Africa’s residual, but diminished conservation reputation.

Further Reading

South Africa wants to promote wildlife consumption,” African Conservation Foundation,  25 March 2020

The Bastardising of Wildlife,” Peter Flack, 28 January 2020 – of course, trophy hunters have driven the demand for genetically altered, exotic game to kill for trophies – a fact seemingly lost on Peter Flack and his disparate ‘defence’ of trophy hunting and angry, emotional outbursts in defence of “hunting culture” (sic).

Government ignored its own science task team by redefining 32 wild species as farm animals,” Don Pinnock, Daily Maverick, 28 January 2020

Lions Classified as Farm Animals: Why You Should Care,” Blood Lions, 28 October 2019

Simba’s sanctuary: Bred to be shot by trophy hunters, this magnificent lion was doomed until LORD ASHCROFT masterminded a dramatic rescue. Now, he has found a permanent home,” Daily Mail, 26 October 2019

Minister Barbara Creecy appoints an advisory committee to review policies, legislation and practices related to the management of elephant, lion, leopard and rhinoceros,” Republic of South Africa, Department of Environmental Affairs (DEA), High Level Panel (HLP), 22 October 2019. It should be noted, that one of the overriding criteria for HLP membership was a ‘belief’ in ‘sustainable utilisation’ – the terms of reference for the HPL was given in Gazette 42761 (Notice No. 1317), dated 10 October 2019.

Domestication Is A Fate Worse Than Extinction,” Jared Kukura, Wild Things Initiative, 22 October 2019

SA reclassifies 33 wild species as farm animals,” Lions4Lions, 21 October 2019

Lions and rhinos are farm animals, says South Africa,” Jane Flanagan, The Times, 18 October 2019

Audrey Delsink, of Humane Society International (HSI, Africa) (The Times, 18 October 2019) cited the cross-breeding in other countries of lions with tigers, which produces very unhealthy animals. As exotic animals, tigers have no protection in South Africa.

Antelopes are already being bred for unusual colour variants to sell to collectors or hunters. “How can we categorise species such as lions and rhinos as threatened or protected . . . and then list them as farm animals and manage them in the same way as livestock?” Ms Delsink asked. “It seems there is a conflict of interest within the government departments.”

WildlifeDirect calls on South Africans to overturn the amendment to the Animal Improvement Act (AIA) that has categorized selected endangered species as farmed animals,” Wild Life Direct, 17 October 2019

SA reclassifies wild species as farm animals,“ Leila Stein, Getaway, 17 October 2019

South Africa Law Allows Domestication of Wild Animals Including Endangered White Rhino,” Urbwise, 16 October 2019



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