Submission to South Africa’s High-Level Panel – elephant, lion, leopard and rhinoceros

Stephen Wiggins Article 7 Comments

Banner Image courtesy of Mark Boulton – “Lewa Conservancy, Kenya” – Elsa Trust and Elsamere

IWB’s Submission to the HLP, Dated 11 June 2020

IWB’s Response to HLP Questions Received, Dated 21 October 2020

The Republic of South Africa, Department: Environmental affairs has issued a “A general notice calling for submissions, scientific information, socio-economic information or any other relevant information to the Advisory Committee (High-Level Panel) appointed to review existing policies, legislation and practices relating to the management and handling, breeding, hunting and trade of elephant, lion, leopard and rhinoceros” as notified in Government Gazette, No. 43172, Department: Environmental Affairs (DEA), Notice 221 of 2020, dated 27 March 2020, with a 60 day (26 May 2020) deadline.

[Update] – “Extension granted [to 15 June 2020] for submissions on work relevant to the high level panel into lion, rhino, elephant and leopard management,” 13 May 2020

Under the current COVID-19 pandemic circumstances an extension to the deadline has been requested, because the science of COVID-19 and the potential impact on animal handling, breeding, hunting and trade, are  still to be determined and therefore, the risks and potential impacts are not transparent.

The HLP Secretariat has issued  Terms of Reference today, 22 April 2020.

By post:

Advisory Committee (High-Level Panel), c/o Department of Environment, Forestry and Fisheries

Attention: Ms. Pamela Singh/Ms. Olenbee Mashiyane, Private Bag X447, Pretoria, 0001, South Africa

By e-mail: submission2HLP@[email protected] (enquires to Ms O. Mashiyane: [email protected], or Ms Pamela Singh: [email protected])

Related Submission

“ALRSA and EMS Meat Safety Act Comments,” Animal Law Reform South Africa (ALRSA) and the EMS Foundation, 30 June 2020

“Meat Safety Act, 2000 (Act 40 of 2000) – Proposed Update to Schedule 1, Section 1(2),” 27 April 2020 – Note: South Africa, Eswatini, Namibia, Zimbabwe, Botswana, Tanzania, DRC and Zambia have filed “Reservations with reference to the amendments to Appendices I and II of the Convention and related communications” to self-exempt themselves from the up-listing of the giraffe to Appendix II

“Didiza’s attempt to legalise the consumption of wild animals is unfathomable,” Issued by Hannah Shameema Winkler MP – DA Deputy Shadow Minister Environmental Affairs, Forestry and Fisheries, 25 May 2020

“Outrage as South Africa law change could put elephants and giraffes on dinner table,” The Express, 29 May 2020

IWB’s letter to The Democratic Alliance (DA), 1 June 2020

“THE DEMOCRATIC ALLIANCE FULFILLING IT’S ROLE AS A CREDIBLE ALTERNATIVE TO THE RULING GOVERNMENT,” EMS Foundation, 1 June 2020:

Open Letter – “THE DEMOCRATIC ALLIANCE FULLFILLING IT’S ROLE AS A CREDIBLE ALTERNATIVE TO THE RULING GOVERNMENT,” EMS Foundation, 1 June 2020

 

Further Reading

“Claws out — catfight looms on lion breeder exit strategy,” Daily Maverick, 6 September 2022

“Investors Join Landmark Wildlife Conservation Bond to Support Black Rhinos and Local Communities in South Africa,” World Bank, 31 March 2022

“The world’s last rhinos are in bad trouble – here’s why,” The Daily Maverick, 20 March 2021

“The Sick Five’: Captive lion breeding industry poses public health risk,” The South African, 11 March 2021, referencing:

“African Lions and Zoonotic Diseases: Implications for Commercial Lion Farms in South Africa,” Green et al., MDPI, August 2020

“Press Release – Minister Creecy kicks the lion can further down the road (March 2020),” Blood Lions Press Release, 3 March 2021

“Unethical practices in lion farming and elephant tourism are increasing disease risk,” The Canary, 27 February 2021

“Public Hearing on the Draft Norms and Standards (2020) for Trophy Hunting of Leopards in South Africa“- Mpumalanga Provincial Legislature, IWB Submission, 22 February 2021

“Something to hide? Department of Environment takes the path of least disclosure,” Don Pinnock, Conservation Action Trust, 15 February 2021

Linda Park Voice4Lions TB in lions – YouTube, 11 February 2021

“Proposal to allow ‘the sale of lion meat in SA’ blocked by minister,”  The South African, 20 November 2020

“It’s high time SA shut down the captive lion breeding industry,” Andreas Wilson-Spath, Daily Maverick, 12 October 2020

“Will legal international rhino horn trade save wild rhino populations?,” Eikelboom et al., Science Direct, Global Ecology and Conservation, Vol. 23, September 2020 – “…we conclude that legalizing rhino horn trade will likely negatively impact the remaining wild rhino populations.”

“Zoonotic disease: Study warns about cuddling, keeping and slaughtering farmed lions, ” Louise de Waal, Daily Maverick, 30 September 2020

“African Lions and Zoonotic Diseases: Implications for Commercial Lion Farms in South Africa,” Waal et al., 18 September 2020

“Wildlife experts spurn invite to serve on environmental panel, indicating bias and co-option,” Daily Maverick, 15 July 2020

“Bring the lion trade to an end,” The Star, 8 July 2020

“SA Government notes content of book alleging wrongdoing in the Lion Management Sector,” Republic of South Africa, Department: Environment, Forestry and Fisheries 6 July 2020

“Rhino horn trade – Tourism & conservation leaders lobby SA minister Creecy,” Africa Geographic, 17 June 2020

“The poaching crisis and the Covid-19 pandemic have thrown up huge challenges for South Africa’s ‘experiment’ in megafaunal privatisation,” Daily Maverick, 19 June 2020

“Private rhino conservation: Diverse strategies adopted in response to the poaching crisis,” Clements, H.S.; Knight, M.; Jones, P.*; Balfour, D.,  Conservation Letters, 15 June 2020

*Pelham Jones, Private Rhino Owners’ Association (PROA) was one of the authors of the study, a man with a vested interest duly noted.
Funding rhino conservation is a dilemma of course – but just because some speculators heavily invested in rhino in the belief that a legal international trade in rhino horn could be obtained (and overturn the 1977 ban) and bring themselves wealth is not a scientific justification for sanctioning such international trade.
The argument given by SANBI/DEA/PROA is that rhino security costs are increasing (ironically, due to the poaching risk they themselves have helped create by messaging which legitimises the demand for rhino horn), plus rhino monetary values are also dropping etc….so ‘we must get income for our investment from international rhino horn trading’ to ‘conserve’ all of our privately held rhino stock (and try to ignore the potential increased demand/poaching risks that would mean for all rhino, private and wild). Not to mention rhino meat market proposals, pseudo hunting etc……
Speculative investment in rhino, demanding international trade (and that message legitimising/stimulating rhino horn demand and the poaching risk!) all stems from an inherent breed them/exploit them ‘sustainable utilisation’ mentality………without that, demand could have been squashed, there would be no poaching risk (or at least, a much reduced risk).

“MANAGEMENT, BREEDING, HUNTING, TRADE, HANDLING AND RELATED MATTERS: ELEPHANT, LION, LEOPARD AND RHINOCEROS,” EMS Foundation Submission, 15 June 2020

“South African proposal to breed wildlife for slaughter courts disaster,” The Conversation,  14 June 2020

“‘I want my horns back’ says SA rhino baron after trade deal goes pear-shaped,” Daily Maverick, 14 June 2020

“Barbarous trade in bones from captive lions for use in Chinese ‘medicines’, wines and jewellery could spark risk of new pandemic, warn experts,” Daily Mail, 14 June 2020

 

“Notice prohibiting certain restricted activities involving rhino horn published,” Department: Environmental Affairs (DEA), 3 June 2020

“Report of the Portfolio Committee on Environment, Forestry and Fisheries on the Strategic Plan 2019/20—2023/24, Annual Performance Plans (Apps) 2020/21 and the Budget Vote 32 of the Department Of Environment, Forestry and Fisheries (Deff),” 20 May 2020

Colin Bell’s presentation, “Rhino horn trade – why trade is bad for our wild rhino populations,” 4 June 2020

Colin Bell’s presentation, “Ban all trade in the body parts of rhino and elephant,” 22 May 2020

“Neoliberalism and sustainable use are cut from the same paradigm,” Ian Michler, Daily Maverick, 26 May 2020

“Farming wild animals – is China the model for South Africa?” Africa Geographic, 4 May 2020

“Barbara Creecy’s wildlife panel is trying to reinvent the wheel,” News 24, 3 May 2020

“Why SA’s courts place ecological sustainability ahead of government’s reductionist sustainable use – Part 2,” Ross Harvey, Daily Maverick, 30 April 2020

“Is the environment minister captured by vested interests?,” Don Pinnock, Daily Maverick, 29 April 2020

“Wildlife trade: The unsustainability of ‘sustainable use’ (Part 1),” Ross Harvey, Conservation Action Trust, 23 April 2020

“EMS FOUNDATION APPEALS FOR MORATORIUM ON THE LION BONE INDUSTRY,” EMS Foundation, 18 April 2020

The Honourable Ms Barbara Creecy, The Minister for Environment, Forestry and Fisheries – “Captive Lion and Other Big Cat Breeding Industry and Coronavirus,” EMS Foundation, via Cullinan & Associates attorneys, 15 April 2020

The Honourable Ms Thoko Didiza, Minister for Agriculture, Land Reform and Rural Development – “Wildlife Trade and Coronavirus,” EMS Foundation, via Cullinan & Associates attorneys, 15 April 2020

The Honourable Dr Zwelini Mkhize, Minster for Health – “Wildlife Trade and Coronavirus,”EMS Foundation, via Cullinan & Associates attorneys, 15 April 2020

“China’s ban on wildlife consumption is an overdue death knell for lion bone industry,” IWB, 24 February 2020

“New ‘expert’ panel may be weighted to duck Parliament’s call to shut down canned hunting,” IWB, 26 November 2019

“Minister Barbara Creecy appoints an advisory committee to review policies, legislation and practices related to the management of elephant, lion, leopard and rhinoceros,” 22 October 2019

“Zoonotic tuberculosis in human beings caused by Mycobacterium bovis—a call for action,” The Lancet, 20 September 2016