Claws out at lion trade colloquium: hearing in detail
Fur flew during a two-day colloquium on captive lion breeding, hunting and the bone trade. Opinion was sharply divided among experts, officials, and lobby groups about the dangers and benefits of the industry.
The size of quotas and the benefits (or otherwise) of captive breeding from a conservation point were a source of disagreement at the get-together, hosted by Parliament’s Portfolio Committee on Environmental Affairs on August 21 and 22.
Environmental Affairs Minister Edna Molewa cautioned delegates that any ban on the trade would comes with its own set of challenges and consequences. “Whatever decision is made requires trade-offs with a set of outcomes,” she said, warning that a trade ban would open space for illegal sources and syndicates. “This may increase illegal killing in the wild, which at present is at very low levels,” she said….
Captive lion breeding for hunting in South Africa colloquium Day 1, with Minister present
1 August 2018
Chairperson: Mr M Mapulane (ANC)
The Portfolio Committee on Environmental Affairs hosted a two-day colloquium on captive lion breeding under the title: Captive Lion Breeding for Hunting In South Africa: Harming Or Promoting The Conservation Image Of The Country. Day One of the Colloquium was divided into four parts. In part one, the Chairperson of the Portfolio Committee on Environmental Affairs gave an opening address and Ms Edna Molewa, Minister of the Department of Environmental Affairs (DEA) gave the keynote address.
The Chairperson stressed that this Colloquium will not be just another talk shop without being followed by action. Meticulous records of the proceedings will be kept and a detailed report will be produced with detailed recommendations to be considered by the PC Committee, after which it will be tabled in the House for adoption. Whatever outcome to the Colloquium, it will be followed up by the Committee with the sheer tenacity of the hungry lion chasing its prey. It is deliberate the theme of this colloquium poses a fundamental question in relation to the conservation image of South Africa. Even though it is in favour of the sustainable use of biodiversity resources, South Africa finds itself increasingly isolated at important international conservation and hunting platforms as a result of this policy stance. Major questions are not only raised in relation to ethical and fair chase hunting considerations, but more concerns are being raised about the absence of scientific evidence showing the conservation value of canned hunting as well as the application of the precautionary principle.
In the keynote address, Minister Molewa stressed that the Committee’s decision to have this discussion is welcome. This is an opportunity to clarify South Africa’s position around the captive breeding of lions for hunting and for the trade of lion specimens. This position was formulated a while ago through the democratic process. Public representations are awash with slanted and misrepresented information. This is harmful for South Africa in terms of conservation. It is important for us to hear each other very carefully, lest we misunderstand or misrepresent some of the things which are said. These misrepresentations distract from the real discussion and the substantive issue around lion conservation. It is important for this discussion to be scientific and not anecdotal. Whatever decision is made requires trade-offs with a set of outcomes. A final decision requires very hard thinking. By way of conclusion, Minister Molewa stated that South Africa is one of the world leaders in conservation, in lion and many other species. All members of the public are expected to give the government information that relates to any malpractice involving wildlife.
The Department of Environmental Affairs spelled out the regulatory frameworks for wild and captive-bred lion hunting. The Department said that it supported an adaptive management approach and evidence-based approached informed by facts and science (International & National). In terms of the 2018 Lion Bone Quota of 1500 complete Skeletons, which was informed by the preliminary outcomes of the SANBI study and other sources, lion breeders can produce more skeletons than the current quota allows; the number of skeletons exported leading up to the 2017 quota was substantially higher than initial estimates; due to the quota restrictions there appears to be a growing stockpile of bones in South Africa (it appears that traders have been stockpiling skeletons and this is attested by the short period it took to fill the 2017 export quota of 800 skeletons); and there appears to be an increase in poaching for body parts (skull, paws, claws) but little evidence of poaching for bones. The Department also reported that it aims to balance conservation, sustainable use and beneficiation and adopts contextual approaches recognising differing dynamics in countries and regions.
The Scientific Authority reported that the 2017 Non-Detriment Findings for African lion was that it posed no major threats to the wild and managed lion populations within South Africa, trophy hunting of captive -bred lions poses no threat to the wild lion population within South Africa, consumptive use is restricted to private game reserves, and there is a low to moderate risk and trade is not detrimental.
The Department of Agriculture, Forestry and Fisheries outlined its role in captive lion welfare; the animal welfare definition; existing animal welfare related legislation in South Africa; other important game legislation; proposed guidelines for the welfare of captive lions and categories of captive lion operations in South Africa. The Department stressed that, among others, DAFF has a mandate on captive lion breeding and hunting in terms of animal health and welfare and that the successful implementation of this mandate is dependent on the cooperative governance between DAFF and DEA, due to overlapping functions. The Department highlighted the opportunities. These are the development of a widely consulted comprehensive animal welfare legislation; incorporation (in-part or in-toto) of existing private welfare standards; liaise with other departmental structures to incorporate the welfare mandate into existing certification and licencing; developing a ranking system for facilities in terms of welfare, biodiversity, conservation and community empowerment.
Smaragda Louw, on behalf of the EMS Foundation and the Ban Animal Trading (BAT), presented the outcomes of a study entitled The Extinction Business conducted by the EMS Foundation into South Africa’s role in the international lion bone trade, which reveals how the Minister, her Department and conservation agencies support and grow a trade which has strong links to international criminal networks, is providing a legal channel for the trafficking of illegal big cat parts, and is fuelling the demise of wild big cat populations. DEA’s ‘lion’ bone trade damages Brand South Africa’s image and tourism. EMS Foundation requested the Committee to a) place an immediate ban on the lion and other Big Cat bone trade for commercial purposes, including from captive sources; b) bring the criminal aspects of this trade to the attention of other relevant Parliamentary Committees and authorities to ensure that a forensic investigation and financial tracking of the industry is undertaken; c) Urgently ensure that animal protection, welfare, care and respect is included in the appropriate environmental legislation, particularly in relation to the issuing of permits for the keeping, sale, hunting and exporting of wild animals and their body parts; d) Close down the rogue Big Cat captive industry; e) Instruct DEA as a matter of urgency to provide a complete and audited list of all Big Cat breeding and keeping facilities nationally, and to make this list publicly available; f) instruct DEA to convene stakeholder meetings to discuss the dismantling of the captive Big Cat industry, including experts from the fields of animal welfare, sanctuary management and forensics, as well as NGOs.
Born Free Foundation focused on a report entitled “Cash before Conservation – An Overview of the Breeding of Lions for the Hunting and Bone Trade”, which was released in April this year and summarises investigations into the development and impacts of South Africa’s lion breeding industry. Serious welfare concerns persist in relation to the rearing of captive-bred lions in South Africa, particularly with the increasing profit-driven commodification of lion products. Recent images of clearly undernourished lions in captive facilities, and news reports suggesting that lion slaughterhouses have been established to facilitate the mass slaughter of lions to supply skeletons for international trade, only serve to exacerbate these concerns. The Foundation argued that if we are to secure a future for Africa’s lions, the lion breeding and canned hunting industries must be closed down, with responsibility resting squarely with the South African government for ensuring that such a process is conducted with intelligence, humanity, and above all compassion for the animals concerned.
The Professional Hunter’s Association of South Africa argued that South Africa’s conservation image is not being tarnished by the breeding or hunting of lions, but rather by key individuals profiteering from the focused attack on Brand South Africa.
The South African Predator Association presented that is members are breeding, raising and keeping their lions in Provincial government approved keeping facilities, built according to or better than the specifications of each Provincial Biodiversity Management authority. The animals are wisely raised and sustained for a period of three to five years thereafter; the animals are release for hunting purposes according to the guidelines of the SAPA Norms and standards for the hunting of captive lions and of the Provincial Biodiversity Management Authority. The Association emphasised that the captive lion industry in South Africa is a well regulated, manageable industry that contributes way more positively to South Africa than negatively, and ask the Committee to assist in maintaining this industry for South Africa.
The Custodians of Professional Hunting and Conservation stated that the bedrock of socially responsible hunting is the constitutional imperative of justifiable economic and social development, highlighting that perception determines the reputation (and therefore sustainability) of hunting & captive game/lion breeding. The organisation believed that conservation and the biodiversity economy needs hunting. Hunting can only be sustainable if practised responsibly. Responsible hunting must promote conservation; be ecologically sustainable; and be economically and socially justifiable.
The International Council for Game and Wildlife Conservation stated that captive lion breading may be legal, but it breaks moral and ecological basis and boundaries; it is bad for the reputation of South Africa at the global level; and is not good for the reputation of hunting, which is already demonized globally by false information.
During the deliberations, Members asked about lion bone cake, the provinces that have refused to implement the TOPS regulations, the mandate and composition of the Scientific Authority, the quota increase, the lion population in South Africa and whether at a regulatory level there are still challenges in terms of the systems that are there and the capacity of government to be able to monitor all these facilities with regards to what is happening both in public and private.
The Chairperson highlighted that this has been a fruitful interaction. The Committee is a bit more informed around this practice. This Committee would like to be briefed on the study by the Scientific Authority as it was used to come to a very key decision by the Executive. The Legislature would want to interrogate that report. From the information, there is overwhelming evidence that there is really no conservation value in the practice of captive lion breeding for hunting and for the lion bone trade. Neither does it add value to our tourism mandate. It is very clear that this kind of practice is really doing serious damage to brand South Africa internationally. The situation as it is isn’t sustainable. A solution that is acceptable to everybody must be reached by the end of this colloquium.
Welcoming and opening address
The Chairperson welcomed everyone to the Colloquium. It was during the budget vote debate of the Department (DEA) on 16 May 2018 when a commitment was made to the nation that this Parliament would be working together with the DEA to facilitate a national dialogue on the question of breeding of lions in captivity for purposes of hunting and the lion bone and skeleton trade. Three months down the line, we are gathered here today in fulfilment of that commitment and to interrogate the practice that has gained the reputation of being the most controversial subject in the conservation industry. Under the theme, ‘Captive lion breeding for hunting in South Africa: Harming or promoting the conservation image of the country?’, the greatest and finest brains in the conservation sector both locally and internationally have gathered here to debate over the next two days the desirability of South Africa continuing this practice or reviewing policy or legislation to put an end to this practise.
One thing can be guaranteed, this Colloquium will not be just another talk shop without being followed by action. Meticulous records of the proceedings will be kept and a detailed report will be produced with detailed recommendations to be considered by the PC Committee, after which it will be tabled in the House for adoption. Whatever outcome to the Colloquium, it will be followed up by the Committee with the tenacity of the hungry lion chasing its prey. It is deliberate the theme of this colloquium poses a fundamental question in relation to the conservation image of South Africa.
The Chairperson proceeded to give the backdrop to the international controversy and outcry against the hunting of captive-bred lions. The IUCN’s decision to request the South African government to halt this practice was in response to a motion filed by 7 non-government organizations to secure global conservation support for ethical conservation of South African lions estimated at about 7000 lions in captivity in comparison to about 2000 wild lions. It was at this congress that a move called ‘Blood Lion’ received huge interest. The Committee was part of the delegation at that conference and it could not stomach to attend the evening session when the movie was shown. The delegation thought it best to stay away.
South Africa’s contribution to the IUCN is well-known and highly recognised.
South Africa’s captive lion-breeding industry was dealt another serious and embarrassing blow at the international level when, among others, the Safari Club International, the world’s largest hunting club, finally closed its doors on the future captive-bred lions at their 46th wild lions sport hunting expo in Las Vegas. Dallas Safari Club also rejected the practice, stating the canned lion hunting is not in keeping with its values of ethical and fair chase hunting.
The difference between the Madrid CIC, and that which took place in Honolulu, was that there were no NGOs who were propagating for that decision. It was the international hunting association turning their backs on its own and on a hunting practice they considered to be unethical.
Even though it is in favour of the sustainable use of biodiversity resources, South Africa finds itself increasingly isolated at important international conservation and hunting platforms as a result of this policy stance. Major questions are not only raised in relation to ethical and fair chase hunting considerations, but more concerns are being raised about the absence of scientific evidence showing the conservation value of canned hunting as well as the application of the precautionary principle.
Giving the definition of this term as per the National Environmental Management: Biodiversity Act (NEMBA), the Committee understands the sensitivity around the usage of the term ‘canned hunting’. The primary point of contention regarding captive-bred lions appears to be ethical and welfare matters associated with raising lions specifically to be killed. The potential impact of captive-bred lions for hunting on the wider conservation of lions has been largely overlooked with the exception of attempts to justify the practice of the grounds that it may reduce pressure from hunters on hunts for wild lions. The counter-argument is that reduced demand potentially undermines the price of wild lions hereby reducing incentives for the conservation of wild lions. An additional conservation impact of captive bred lion hunting is through undermining the credibility of trophy hunting as a conservation tool in general at time when there is so much contention around this.
It seems as if South Africa’s conservation reputation is being compromised by this practice which does not seem to benefit the broader conservation benefit but a small number of breeders without proper scientific or conservation basis. Another bone of contention is the breeding of lions for the bone trade. Apparently the government has increased the lion bone quota to be traded and exported. The Committee is expecting a briefing from the Department on what necessitated this increase. Parliament must become particularly concerned when reputable conservation agencies – such as SCI, CIC and IUCN – turn their back and deplore practices. In this Colloquium, all the sides of the argument have to be assessed with cool heads and a sustainable way forward must be crafted.
The Chairperson again welcomed and appreciated all the participants and presenters.
Remarks by Minister
Ms Edna Molewa, Minister of the Department of Environmental Affairs (DEA), said that the DEA is looking forward to the outcomes of this colloquium. It is also important to remind ourselves that if there is a need for policy change, a broader discussion will be needed with all South Africans. This room is a little small for South Africa.
South Africa has a long established record for lion conservation even before its days in the democratic dispensation. It was skewed towards only a few people before the advent of democracy in South Africa. It has now been opened for all the people of South Africa. South Africa is one of seven countries around the world that has substantial lion populations. It is because of South Africa’s track record that this is the case.
All South Africans should be assured that the country’s policies in relation to lion conservation are not only firmly based on scientific evidence, but are in accordance with the prescripts of CITES. At CITES level, South Africa does have resolutions that have been taken as recently as 2 years ago. It may or may not be reviewed at the next CITES.
The Committee’s decision to have this discussion is welcome. This is an opportunity to clarify South Africa’s position around the captive breeding of lions for hunting and for the trade of lion specimens. This position was formulated a while ago through the democratic process. Public representations are awash with slanted and misrepresented information. This is harmful for South Africa in terms of conservation. It is important for us to hear each other very carefully, lest we misunderstand or misrepresent some of the things which are said. These misrepresentations distract from the real discussion and the substantive issue around lion conservation. It is important for this discussion to be scientific and not anecdotal. The African lion is said, according to some reports, not to be facing extinction or an unprecedented crisis from either captive breeding or even the trade in lion bone in South Africa. A IUCN report has found that lions are of least concern in terms of the stability of lion populations. The DEA has set up a body, the Scientific Authority, which has made this determination from a scientific point of view. 83% are in protected areas, including the Kruger National Park, where hunting is not permitted at all. The remainder of the wild animals, 500, are found in small protected areas where lions are being reintroduced and are intensively managed.
In terms of the non-detrimental findings, the Scientific Authority found that there are currently no major threats to the wild lion population in South Africa, they are stable to increasing. All activities involving the African lion, including hunting and trade, are regulated through a permit system. These policies are supported by solid scientific evidence. The authorities are allowing what is called ‘canned lion hunting’. For purposes of records, regulation number 26 of NEMBA was gazetted a while ago. Threatened Or Protected Species (TOPS) regulations is for the threatened species of South Africa, including the Lion. These regulations were established during the tenure of Minister Marthinus van Schalkwyk. It was created because there was a recognition that people are creeping in and doing unscrupulous things. This needed to be controlled.
The Minister read from the TOPS regulations.
These regulations were produced to curb all these malpractices. In South Africa, what can be defined as ‘canned lion hunting’ is not allowed in terms of these regulations. Hunting of a lion is part of South Africa’s policy of sustainable utilisation of natural resources. It is contained in the country’s Constitution, section 24, and is the only policy that can be practiced right now. This is consistent with South Africa’s multilateral environmental agreements. South Africa is a full member of, for example, CITES. South Africa is still considering becoming a member of CIC. CITES and South Africa’s Constitution speak to the sustainable utilisation of South Africa’s natural resources. Hunting in South Africa is a legal and well-regulated activity. It is subject to a permit being issued in terms of NEMBA and the provincial conservation legislation where it is required.
South Africa’s national and provincial spheres of government have been instrumental in using the hunting industry as a management tool in promoting the growth of the hunting industry. The industry is valued at R6.2 billion. This is a source of foreign exchange, especially with provinces, job creation and community development, especially of the rural areas. In addition to the wild life population, there are an additional 7000 that have been bred in captivity. The captive breeding of lions continues to be misunderstood.
The National Compliance Inspection of Captive-lion breeding facilities in South Africa has been instituted. Phase one is completed and the report will be given to Ministers and Members of Executive Council (MINMEC) soon. The DEA continues to engage with DAFF relating to the welfare matters to be addressed in terms of the APA, 1962. When the industry that is breeding lions took the government report to court, the court said that there is no word ‘welfare’ in the law. Therefore, the DEA cannot deal with matters of welfare as it is not its space. The DEA is gradually integrating matters of welfare into the law so that the Department can enter into this space.
Lions are bred in captivity for various reasons, including but not limited to trophy hunting. Trophy hunting does not pose a threat to the lion population that is out there in the wild. Although more evidence to this effect is needed, captive lion breeding could serve as a buffer to potential threats to wild lions. The concept of ‘canned lion hunting’ is actually strictly prohibited by South Africa’s laws. The government will move against anyone who practices canned hunting. The TOPS regulations laid out the conditions under which lions can be hunted. As with any legal activity, there are those illicit operators. South Africa is doing all it can to stamp out these activities. The legal hunters should not, however, be put into the same categories as unscrupulous actors. There are people who are out there who are poachers. It is important not to mix items at the same time. The government would like to engage with the movie that was mentioned earlier on. South Africa supports the trade in legally acquired specimens such as hunting trophies, skeletons etc. South Africa’s environmental legislation is directed at increasing the involvement of and improving community access to South Africa’s natural resources, while conserving South Africa’s rich biodiversity. Through this beneficiation initiative, DEA contributes significantly to the NDP, which is Vision 2030. The trade in lion originates at least as far back as 2008 and has been steadily increasing over the past decade to supply the demand for bone in Asia. It is necessary to challenge the assertion that the export of lion bone will result in the extinction of African lion. In 2016, TRAFFIC released a report called the Bones of Contention, which analysed the risk associated with the trade in bones. They could find no evidence that South Africa’s legal bone export was negatively impacting wild lion populations. Reports and existing policy documents are the resources used by the DEA until anything else comes to light. The key threat to lions, according to the IUCN, is a loss of habitat, reduction in available prey and conflict with humans. IUCN said that the lion is not ‘endangered’ in South Africa. The few incidents of captive-bred and wild lions being poached is said not to be linked to the lion-bone trade.
The establishment of an annual export quota for the export of lion bone follows a decision made at the COP. Parties at that COP agreed to a zero annual quota of the export of bones. However, parties agreed that South Africa should establish an annual export quota for bones derived from captive breeding facilities. This is what CITES said. The 2018 export quota is based on new evidence from this research project established by SANBI, in collaboration with Wits, Oxford University and the University of Kent. Implementation of the quota for 2018 is managed by DEA. Strict processes must be followed in line with provincial and national regulations to ensure that no illegal trade in lion bone takes place. Parties to COP 2017 further issued an instruction to the CITES secretariat to conduct studies on the legal and illegal trade in lions, including lion bones. The purpose is to ascertain the origin and smuggling routes. SANBI’s study will further strengthen the evidence base for the annual review of the export quota in order to ensure that it is sustainable and not detrimental to the wild populations.
The export quota for lion skeletons was determined after consideration of scientific information that was available and recommended by the Scientific Authority after the resolution at CITES. This recommendation which they made followed an extensive public consultation process and the consideration of inputs from stakeholders, some of them are in this room, as well as consideration of information on the trade data base. Decisions regarding wildlife trade typically involve three institutions, namely, the Scientific Authority, the DEA, and the Minister. The Scientific Authority has made significant progress in improving scientific oversight of wildlife trade and promoting an evidence based-approach. In reaching any decision regarding the hunting trade of rare species, the DEA and, ultimately, the Minister, has to weight up the advice of the Scientific Authority, a key component of how biodiversity conservation integrates with the development imperatives.
Regarding the total ban on the lion bone trade, this is not a simple step and comes with its own set of challenges and consequences. Whatever decision is made requires trade-offs with a set of outcomes. A final decision requires very hard thinking. If South Africa closes down the lion-breeding facilities and bans trade, there are more than 200 facilities and associated staff who will be negatively affected. In addition thousands of lions will have no value and there will be no income. A trade ban only restricts the flow of legal products and on-going demands will be supplied from the illegal sources and syndicates. This may increase illegal killing in the wild, which at present is at very low levels. These networks proliferate and are incredibly difficult to break. It was exactly in 2008 when a moratorium was put on local trade in Rhino bone when, all of a sudden, poaching rose to the levels it is today. A ban could stimulate an illegal trade in lion bones. South Africa has adopted a risk-averse approach that is considered to be in the best interests of the conservation of species for now.
By way of conclusion, Minister Molewa stated that South Africa is one of the world leaders in conservation, in lion and many other species. All members of the public are expected to give the government information that relates to any malpractice involving wildlife.
Department of Environmental Affairs
Mr Shonisani Munzhedzi, Deputy Director-General: Biodiversity and Conservation, DEA, spoke to the population status of the lion populations in South Africa.
Subsequently, Mr Munzhedzi outlined the Regulatory Framework which structures the international community’s response to lion conservations. Sustainable use is part of conservation. It is defined as the use of biological resources in a manner that would not lead to long term decline; would not disrupt the ecological integrity of the ecosystem in which it occurs; and would ensure its continued use to meet the needs and aspirations of present and future generations of people.
The wildlife sector comprises 3 sub-sectors: wildlife ranching, wildlife activities, and wildlife products.
Mr Munzhedzi clarified NEMBA’s regulations and objectives in so far as they relate to lion conservation. Section 56 contains a listing of species that are threatened or in need of national protection. According to the TOPS regulations, Lions are ‘vulnerable’, which refers to indigenous species facing an extremely high risk of extinction in the wild in the medium-term future, although they are not a critically endangered species or an endangered species.
Mr Munzhedzi elaborated on the legislative requirements, stating, among others, that the TOPS regulations prohibit the hunting of lion (wild or captive-bred) in certain manners (meaning a permit may not be issued).
Mr Munzhedzi broke down the lion court case base on a decision made by DEA in 2007 to institute a prohibition on the hunting of listed predators including lions within 24 month of their release (following public outcry).
Subsequently, Mr Munzhedzi clarified concerns around release period, camp sizes, and hunting methods.
Mr Munzhedzi highlighted the CITES regulations. In 2010, the CITES Regulations, 2010 were promulgated in terms of section 97(1)(b)(iv) of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004).
Mr Munzhedzi gave a breakdown of the Provincial Legislative overview.
Prof John Donaldson, Chairperson: Scientific Authority, South African National Biodiversity Institute, gave a breakdown of the role of the Scientific Authority, which was established in terms of NEMBA.
Prof Donaldson explained that the 2017 Non-Detriment Findings for African lion was that it posed no major threats to the wild and managed lion populations within South Africa, trophy hunting of captive -bred lions poses no threat to the wild lion population within South Africa, consumptive use is restricted to private game reserves, and there is a low to moderate risk and trade is not detrimental.
Prof Donaldson gave the background to the 2017 Lion Bone Quota, in which a quota of 800 lion skeletons was established.
Next, Prof Donaldson spoke to the trade-offs which comprise the banning of trade in lion bones versus managing the trade with a quota. Lion bone trade is complex and requires appropriate response.
Prof Donaldson explained that the precautionary principle offers little guidance when competing alternatives all have potential negative consequences. Assessments in 2015 (TRAFFIC/WildCru) and 2016 (IUCN Red List) concluded that the trade in bone from captive bred lion had a negligible impact on the status of wild lion populations in South Africa. The precautionary approach would therefore be to maintain the status quo (neither throttle nor stimulate trade), monitor impacts, increase understanding of the trade and its consequences and adjust management decisions accordingly.
In terms of the 2018 Lion Bone Quota of 1500 complete Skeletons, which was informed by the preliminary outcomes of the SANBI study and other sources, Mr T Motsiane, Deputy-Director: DEA, explained that lion breeders can produce more skeletons than the current quota allows; the number of skeletons exported leading up to the 2017 quota was substantially higher than initial estimates; due to the quota restrictions there appears to be a growing stockpile of bones in South Africa (it appears that traders have been stockpiling skeletons and this is attested by the short period it took to fill the 2017 export quota of 800 skeletons); and there appears to be an increase in poaching for body parts (skull, paws, claws) but little evidence of poaching for bones.
Mr Motsiane explained the controls that apply to the export of lion bones.
Mr Munzhedzi continued outlining the on-going research. Lions are categorised as ‘least concern’ in South Africa. Lions are appendix II listed species. The NDF allows trade as it is not detrimental to the survival of lions in the wild. By way of conclusion, DEA considered a mandate on wellbeing in NEMBA as part of NEMLA Bill 2017; it support an adaptive management approach; evidence- based approached informed by facts and science (International & National) are a priority; so is upholding the basic principle of ‘ensuring the survival of species in the wild’; DEA aims to balance conservation, sustainable use and beneficiation and adopts contextual approaches recognising differing dynamics in countries and regions.
Department of Agriculture, Forestry and Fisheries
Mr Mooketsa. Ramasodi, DDG: Agricultural Production, Health & Food Safety, outlined DAFF’s regulatory role in captive lion breeding for hunting. His presentation was divided into the introduction and explanation of DAFF’s role in captive lion welfare; the animal welfare definition; existing animal welfare related legislation in South Africa; other important game legislation; proposed guidelines for the welfare of captive lions; categories of captive lion operations in South Africa; other uniform guidelines for all categories; lions released for hunting; opportunities; and the concluding remarks.
Mr Ramasodi explained that this sector is regulated by multiple legislations that spreads mandates between multiple Departments, namely, the Department of Environmental Affairs (DEA) and the Department of Agriculture Forestry and Fisheries (DAFF). DEA administers provisions of the National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004) and other relevant regulations such as those dealing with Threatened or Protected Species (TOPS). Animal health and welfare legislation is administered by DAFF – Animals Protection Act, 1962 (APA) and the Performing Animals Protection Act, 1935 (PAPA).
DAFF’s role in captive lion welfare
Mr Ramasodi unpacked DAFF’s role in captive lion welfare and spoke to the animal welfare definition.
Existing animal welfare related legislation in South Africa
Mr Ramasodi outlined the existing animal welfare related legislation in South Africa, after which he outlined other important game legislation and the proposed guidelines for the welfare of captive lions. The existing animal welfare related legislation in South Africa is the Performing Animals Protection Act, 1935 (Act 24 of 1935) as amended; Animals Protection Act, 1962 (Act 71 of 1962); Animal Matters Amendment Act, 1993 (Act 42 of 1993); and the Societies for the Prevention of Cruelty to Animals Act, 1993 (Act 169 of 1993).
Categories of captive lion operations in South Africa
Mr Ramasodi subsequently highlighted the categories of captive lion operations in South Africa and other uniform guidelines for all categories; lions released for hunting.
Mr Ramasodi delineated the opportunities. These are the development of a widely consulted comprehensive animal welfare legislation; incorporation (in-part or in-toto) of existing private welfare standards; liaise with other departmental structures to incorporate the welfare mandate into existing certification and licencing; developing a ranking system for facilities in terms of welfare, biodiversity, conservation and community empowerment.
By way of conclusion, Mr Ramasodi stressed that, among others, DAFF has a mandate on captive lion breeding and hunting in terms of animal health and welfare and that the successful implementation of this mandate is dependent on the cooperative governance between DAFF and DEA, due to overlapping functions.
Ms Smaragda Louw, Ban Animal Trading (BAT), presented the outcomes of a study entitled The Extinction Business conducted by the EMS Foundation into South Africa’s role in the international lion bone trade, which reveals how the Minister, her Department and conservation agencies support and grow a trade which has strong links to international criminal networks, is providing a legal channel for the trafficking of illegal big cat parts, and is fuelling the demise of wild big cat populations. DEA’s ‘lion’ bone trade damages Brand South Africa’s image and tourism. A vast number of individuals rely on continued employment in the tourism sector. Their livelihoods are in the firing line in order to benefit only the few predatory elite in the ‘lion’ bone trade. Tourism itself is a National Asset. South Africa faces an onslaught of bad publicity because of all the elements involved in this shocking trade. Tourists will rather choose to spend their money elsewhere. A new peer-reviewed scientific report undertaken by the South African Institute of International Affairs reveals that the Big Cat breeders could cost South Africa over R54-billion over the next 10 years in loss of tourism brand attractiveness.
Ms Louw argued, among others that, the Minister this year effectively doubled the 2017 lion skeleton export quota of 800 skeletons to 1 500 skeletons, while in the midst of being served with papers demanding a legal review of her Department’s quota and policy. This incomprehensible decision was made without public consultation. It is also supposedly based on an interim research report, which clearly states that its research sample does not constitute a representative sample of the captive lion breeding industry. By no stretch of the imagination can this interim study translate into a conclusive scientific justification for a lion skeleton quota, and even less, an increase of the quota. Notably, some of the researchers involved in this study have distanced themselves from the decision-making process around the 2018 quota, stating that all the decisions were made by the Scientific Authority and DEA, and that the researchers provided no input on what the quota should, or should not, be.
Among other things, Michelle Pickover, Director: EMS Foundation, requested the Committee to a) place an immediate ban on the lion and other Big Cat bone trade for commercial purposes, including from captive sources; b) bring the criminal aspects of this trade to the attention of other relevant Parliamentary Committees and authorities to ensure that a forensic investigation and financial tracking of the industry is undertaken; c) Urgently ensure that animal protection, welfare, care and respect is included in the appropriate environmental legislation, particularly in relation to the issuing of permits for the keeping, sale, hunting and exporting of wild animals and their body parts; d) Close down the rogue Big Cat captive industry; e) Instruct DEA as a matter of urgency to provide a complete and audited list of all Big Cat breeding and keeping facilities nationally, and to make this list publicly available; f) instruct DEA to convene stakeholder meetings to discuss the dismantling of the captive Big Cat industry, including experts from the fields of animal welfare, sanctuary management and forensics, as well as NGOs.
A video clip was played after which, a petition, signed by more the 250 000 people, was handed to the Chairperson by Khoi San Chief Frits.
Khoi San Chief Frits explained that 1000s of years ago the Khoi San Ancestors used to call lions the sons of God because there was a mutual understanding between the lions and the Khoi people. This is why the lion is a sacred animal to the Khoi people. Not only is the practice of lion-breeding for the purposes of hunting killing Mother Nature, but a sacred animal and the heritage of the San people is being killed. Stop killing what is sacred to the Khoi people and what God has created. Let the animal live because it plays an important part in the Khoi San culture and history.
The regional coordinator of the Coalition of African Animal Welfare Organizations, highlighted, going forward, the need to look at traditional knowledge and what communities’ want, in terms of Ubuntu, where we are looking at human well-being and social development, animal wellbeing and environmental welfare. Moreover, where we are not only looking at economics and what money can be made in such activities, but whether they are morally justifiable? Do our people also want what is happening to happen? Although the 5 freedoms have been highlighted that South Africa is party to in terms the OIE, these freedoms are not enjoyed by these lions, especially the freedom of showing normal patterns of behaviour. Therefore, as this colloquium proceeds, let’s look at the wellbeing of the animal, society and the environment.
Ms Louise De Waal, in terms of lion bone quota, commented that DEA states that they have a system in place for permitting and at-source DNA sampling for whole skeleton exports. However, how do we actually account for those lion bone skeletons that are processed in South Africa and are then exported legally or illegally as lion bone cakes because they will not be counted in the 1500 skeleton quota?
The Chairperson asked what a lion bone cake is?
Ms De Waal explained that this is what they are called once they are processed. They cannot be identified anymore as lion bones because all the DNA has actually been destroyed and, therefore, they can be exported as anything as it is not recognizable anymore as lion bones or any sort of animal product.
Mr Will Smuts, from the Landmark Foundation, asked whether the Committee is aware that two provinces have refused to implement the TOPS regulations and there seems to be absolutely no accountability. The government departments are refusing to move against each other. This could be unconstitutional. The request is that DEA should look into this. One of the controls that seem to be absent is that some statutory bodies are not applying the TOPS regulations when trading in animals takes place.
The Chairperson asked for the names of the provinces?
Mr Smuts responded that it is Mpumalanga and the Western Cape that refuse to implement TOPS.
Mr Smuts continued, furthermore, that the other frustration seems to be with the Scientific Authority and there seeming unaccountability in dealing with these items. They select which experts they would like to engage, disregard others and are unaccountable to releasing reports. Thanks to the Committee for asking for that report. The public of South Africa needs access to these reports. There is also a report on leopards matters in the last few weeks. Can the Committee also look into these concerns?
Mr R Purdon (DA) highlighted that while the DEA says the total population size is 3490 wild lions, with the largest population of 1700 being in the Kruger National Park, the EMS reads that South Africa only has somewhere between 1300 and 1700 adult lions remaining in the wild. There is a huge discrepancy. Who is correct and who is incorrect?
Dr Z Luyenge (ANC) spoke to the need to sensitise communities around the importance of nature conservation in as far as the wild animals are concerned. Growing up in Eastern Cape, he never saw an elephant or a lion in his surroundings. It is only once he went to school that he understood that there is such a wild animal like a lion. However, he was never educated as to how he and his community could benefit from these animals. It is not morally correct for us to plot against these animals. Biblically, we are taught that ‘Thou shalt not kill.’ What is the necessity of this particular plotting against that? It is about our nature, life and love that we should have amongst us. We are coming from the same nature as these animals. It is not fair for us, with all the intellectuals that we have in our country, to converge and determine how many should we kill. If this is not about money or enriching someone, what is it? That compels us to get into this debate at that level? This is a very important debate and sophisticated subject and it is a matter that the majority of the communities in this country do not understand. Yet, we get to a discussion which says let’s get rid of these when we are starting, within our democracy, to understand the importance of these. In the past era, there were no departments of environment. We were never sensitised as to how the environment is important. Let us be serious enough and concerned. One of the speakers mentioned ‘least concerned.’ That ‘least concerned’ about the wild animal is a reality. Let us now be concerned, know more and make a determination if we want to get rid of them. Even if it means that that individual who want to get rich must wait a little bit so that we can all be at the same level of understanding our lions.
Mr Z Makhubele (ANC) highlighted that there are particular questions that must be responded to and that are of concern in this colloquium. First, bearing in mind all the spheres of government, there is a need to understand whether at a regulatory level there are still challenges in terms of the systems that are there and the capacity of government to be able to monitor all these facilities with regards to what is happening both in public and private. Second, there has been a slide referring to the quotas. If this slide refers to the legal activities, at any point has the DEA discovered illegal activities which were exposed? Third, what is the efficiency and effectiveness of the system that has been referred to that seeks to trace the origin of the bones, body parts etc. and whether they are from the lions that were bred in captivity or not? Has the government managed to trace where these bones and body parts are coming from? Finally, it was alleged by two presenters that a report was requested for some transparency from government and that the government was not forthcoming. Is the DEA in the position to respond as to what caused that? Why has there been no cooperation in this regard or with any other stakeholders? Are there any challenges faced by the government in this regard?
Ms Linda Tucker, CEO,Global Wildlife Trust, recalled that it had been previously gazetted in a colloquium chaired by a former chairperson of the portfolio committee that the our government would protect our sacred white lions as a living heritage. Can the Chairperson of the Portfolio Committee please consider that gazette? The Global Wildlife Trust has been engaging as a stakeholder in the process since 2002. Today, the organisation has been authorised to speak on behalf of South Africa’s traditional healers or the Tsonga and Sepedi peoples surrounding the Kruger National Park. Whenever a traditional council is called worldwide it is just and right that the silent stakeholder in the debate be granted a chair. Who will speak for the lion? Since the Minister of Environmental Affairs is not here, to the department: Who authorised the legalisation of this lion slave trade? Who authorised the legalisation of the mass killing of South Africa’s lions for blood money? Who legalised the killing of our living heritage? It has not been authorised.
A representative of Future for Wildlife asked for clarity on how the process of public consultation works? A petition for the 800 lion bone quota was forwarded. According to a letter as reported in the EMS Ban Animal Trading Report, SANBI replied that despite the fact that there were more than 1000 emails, Mr Tiane presented a sample of these emails, which range from organizations and individuals opposed to hunting to member of the industry opposed to the quota. Concerns raised included the ethics of hunting and of the lion bone trade, a lack of transparency, a lack of community beneficiation, animal cruelty, a lack of monitoring capacity in government, and impacts of wild populations of lion and other large cats. These important concerns were raised and considered although were many were related to policy and management matters that are beyond the remit of the Scientific Authority. The meeting discussed the present quota and the question of demand and supply. In the same letter, the Scientific Authority was advised that it should not exercise too much control over the market but rather gain a better understanding, the adaptive management that the honourable member was talking about. In terms of demand and supply, is the Scientific Authority a marketing authority? It should not adapt to demand and supply because an ‘authority’ is a person or organization having political and administrative power and control. The Scientific Authority’s mandate is to champion the exploration, conservation, sustainable use, appreciation and enjoyment of South Africa’s exceptionally rich biodiversity for all South Africans. Where is the market in the Scientific Authority’s mission?
The Chairperson said that the Committee expected to receive the report by the EMS Foundation, or at least a summary thereof. There are very interesting insights that emerge from the report. There may yet be an opportunity to launch the report. There is a lot that he needs to know about the Scientific Authority because this is the first time interaction with this entity. The Committee would like a copy of its report before this colloquium is concluded. What is concerning is that it is an interim report. What is the meaning of an ‘interim report’? Does it mean that upon further inquiry upon some of these things it can change? This is significant because there was a very important decision that was taken based on the interim report. He would have expected that a decision of that magnitude would have been time tested and would have been based on whatever science has been produced and that would be the final report. Who are the members of the Scientific Authority and what qualifications do they have so that the Committee can come to understand the diverse nature of the skills mix in that institution? In the view of the Scientific Authority, is there any conservation benefit of the breeding of lion in captivity, especially for the lion bone trade? Does it, as the Scientific Authority, consider that trade to be a conservation activity? Lastly, in increasing the quota from 800 to 1500, there is an argument that suggests that this increase is a response to the banning of trophies hunted from captive bred facilities, especially by the biggest consumer market in the US and other European countries. With this decline in trophy hunting, the animals that are there are therefore used for the lion bone trade because it is a very lucrative market. However, there is also a question of the DEA increasing the quota from 800 to 870. The Extinction Business report states that the permits awarded exceeded the quota by 70. What is the DEA’s response to this?
Mr Munzhedzi responded that in as much as DAFF presented on the Animal Welfare aspects, the DEA also looks at the wellbeing aspects of the main Biodiversity Act. The DEA operates within the legislative framework as it is. In situations where certain things are identified that need to be responded to through legislative means there is a process that also involves Parliament to make certain amendments or to repeal certain things. In this case, from DAFF and DEA’s presentations, when it was said that what was pronounced on what went beyond the current legislative framework or the legislative framework at the time on welfare and wellbeing, the DEA was found wanting because things tested in courts irrespective of how we feel about certain things which is the way things work unfortunately. It is all about what the prescripts are and the DEA works within that to make the necessary amendments, including using the tools of prohibition, banning, limiting, listing and suspending. In terms of the lion bone cake, there have been a number of innovations. The DEA has seen that they are coming in the horns and also in the other specimens that are traded. The DEA tries to be ahead of situations. The DEA will try to find out what it is all about. In terms of the implementation of TOPS and the DEA’s interface with the Provinces, this is one matter that is being attended to. To the amended TOPS, which is being processed, DEA had to add certain things because every year there are new developments. However, this time around the DEA had to follow an entire process which goes to the NCOP to ensure that everyone is singing from the same hymn sheet. In that regard, the finalization of the current TOPS, the approval and the promulgation thereof, will bring everyone into the same page. DEA does have co-operative governance mechanisms to try to deal with those areas where there are different applications of different things. When the DEA determines a quota, there is a specific time in which the Minister releases a statement to say that there is a particular quota that has been determined on the basis of various factors. This gets communicated. In terms of educating communities, SANParks has a programme called the National Parks week, where the parks are opened up free of charge so that people can interact. The DEA takes the Committee’s position to heart to intensify this process to make sure that people are clear on a number of things, not only regulatory but also exposure to an appreciation of nature. This is part of DEA’s responsibility as a conservation department. Finally, the Commission process which the Minister referred to was meant to visit all captive-bred facilities to ensure that the findings are going to inform the future actions and policy direction in regard to this.
Mr Ishaam Abader, Deputy Director-General Legal Authorisations and Compliance Inspectorate, DEA, explained that the DEA is not aware of this phenomenon concerning lion bone cakes,. The problem with lion bone cakes is that the DNA is destroyed, in which case it becomes irrelevant and difficult to trace. This raises further challenges for the DEA because anything could be taken and include it in the lion bone cake. It does not necessarily have to be lion bone.
The Chairperson asked for more clarity on lion bone cakes.
Ms De Waal explained that her understanding is that there are these processing plants in South Africa. If a lion bone quota for the export of skeletons is set at 1500, while South Africa is processing well above that amount, how many lions are actually being killed for the lion bone trade? These are then exported as these cakes that are then used in traditional medicine in the Far East.
The Chairperson asked whether Ms De Waal has anything concretem Is it a suspicion or allegation? Is there something concrete because the committee would also like to follow it up if there is something like that?
Ms De Waal said that she would try to get the Committee concrete information.
Mr Abader remarked that this would be very useful in terms of DEA investigating them as well. If there are illegal plants DEA would definitely go out and look. Furthermore, the Minister mentioned that the DEA has looked at some of the facilities that were inspected. The DEA looked at the three major provinces, namely, the Limpopo, Free State and the North West. 226 lion breeding facilities were inspected over the two financial years, 2016-2018. In Limpopo, there are 31 facilities, all of which were inspected. In the North West, there are 74 facilities, all of which were also inspected. In the Free State, there are about 170 facilities, of which 121 have been inspected. There are still 49 facilities which the DEA is hoping to finish by the end of this financial year.
The Chairperson asked whether the DEA can give the Committee the inspection reports so that the Committee knows what the inspection entails,
Mr Abader responded that the DEA can provide the Committee the specifics around these matters. In terms of some of the inspection findings, there are inconsistencies with regards to how the various provinces handle matters related to TOPS. In some instances, compliance monitoring is not conducted in facilities after the issuing of permits. The national department functions in concurrence with the provinces. The provinces are almost an autonomous body. In any event, the Minister has instructed the DEA to look at these facilities. Some of the permits have expired. These were never detected until the DA went around to the facilities. Among others, there was also some non-compliance with permit conditions, especially around monthly register submissions and some of the mortalities are not reported to the authorities. There were also some animal welfare concerns, which have been reported to the SPCA. From the perspective of what will be done with them, there has been a follow-up with the provinces in terms of what they are doing or what they will do in terms of each of these. The challenges in relation to why these things were not happening include capacity of the affected institutions in terms of conducting monitoring. There is a lack of approved provincial guidelines in policies for some of the facilities, inconsistencies in terms of permits conditions, unstandardized closure in terms of these. From the perspective of the report, their recommendations were that the national department would assist with enforcement actions against all non-compliant facilities, that there was supposed to be awareness around compliance-promotion that was supposed to be undertaken. The DEA has increased the compliance monitoring undertaken by the provincial authorities for the breeding facilities. There was also a move to standardise guidelines and policies for the enclosure facilities. The provincial authorities have to ensure consistency with the permit conditions. The industry associations should be assisting government in ensuring the members comply with the legislation. In terms of the concerns around the TOPS regulations, the difficulties in inconsistencies in application which exist with regard to the Western Cape and Mpumalanga specifically is that the old regulations were not tabled in the NCOP. Because of the autonomy of the provinces in relation to national, they can still act in terms of their provincial ordinances and this is where the anomaly comes in. Once the new TOPS regulations have been tabled in Parliament in terms of the new system, then the provinces would be bound to follow those regulations. This will ensure that these inconsistencies do not happen. Finally, in relation to compliance and enforcement matters and the 800 and 870 permits, the permits were issued for three countries and DEA’s records show 800. This records will, however, be sifted by the DEA. Moreover, the department does a random testing of the DNA samples when the consignment comes to the airport. A DNA sample is taken of the consignment that is going out and it then gets tested. The same applies to the Rhino horn. The DEA has a data base where it can verify the DNA. That is why the DEA can make links, if there is a Rhino seizure in another country, if it can be traced back to South Africa. The Department has a data base in terms of which it can verify of how rhino bone CITEs reinforcements are implemented.
The Chairperson asked the Department to wrap up the allegation of the 870 versus 800 quota which have been made by the Extinction Business. The Department must substantiate its response. The allegation is that the permits issued at OR Tambo was found to exceed 800.
Mr Wiseman Gqamana, Assistant Director, DEA, responded that all lion bones go via OR Tambo. To the knowledge of the DEA, there is no other exit. The process is as follows. When the Department received the permit, which had just been issued from the province in conjunction with the DEA, it allows the flight agent of the export to notify the DEA 48 hours before the export. There are two processes which are followed. An official would do the verification of the bones before it comes to the airport. All the documentation is given that is required in terms of the export 48 hours before. If the documentation does not comply with the norms and standards, the application is rejected. The booking is reconfirmed and the permit holder will be able to bring the documentation in line with the norms and standards which will be in line with the flight details. This usually happens two hours before the flight departs. Another official takes over the consignment to verify what the other official has conducted in terms of the assessment. The whole consignment and paperwork is looked at. The DNA of the particular piece of the bone is taken to be analysed at the National Zoological Gardens. If everything is fine an endorsement is given for the permit once off. This permit cannot be used twice. In terms of the systems and capacity, the DEA works 24/7 at the entry point but with limited capacity.
Prof Donaldson, in terms of the discrepancies in the number of lions, explained that based on a report from 2016 indicates that there are 3490 wild lions in South Africa, of which there are 1779 adult lions. The other discrepancy in terms of the weight of bones, one of the changes that have happened in the bone trade is a shift from trading in dry bones to trading in wet bones.
After Prof Donaldson explained the mandate of the Scientific Authority, in response to the allegations of being secretive, he clarified that the way it works is that the Scientific Authority reports back to the Minister, not the public. Up to now, this is the procedure that has been agreed. The Minister then makes the information public. The Scientific Authority is very happy with representations. When people approach it, it is very happy to listen to the information that they produce. In relation to the question on the objectives of the Scientific Authority, this entity does not have any institutional framework. The Act provides that SANBI must provide administrative support to the Scientific Authority. SANBI and the Scientific Authority are two separate organs of state. The functions of the Scientific Authority are completely different from what SANBI’s mission is.
The Chairperson asked for a brief explanation of these functions.
Prof Donaldson explained that the functions of the Scientific Authority is essentially to issue non-detriment findings; determine whether trade is detrimental to the survival of species; to advise on exports and determine whether these are of any detriment; to advise, when requested, on captive breeding facilities and whether these met the requirements of CITES; to advise on sustainability and trade; and advise on the issuing of permits.
The Chairperson asked whether there is no specific requirement to look at the conservation matters?
Prof Donaldson explained that the primary aim of the Scientific Authority is to determine when trade is to the detriment of wild populations, not to look at the conservation benefit. In terms of the conservation benefit of lion bone trade, the Scientific Authority has not commissioned any work to specifically evaluate that. It has just taken note of other reports that have made that conclusion. There are other references, however, that it can act as a buffer to impact on wild populations. There is uncertainty as to whether the legal trade reduces the impact on wildlife. There is an acknowledgement that more information is needed to inform decisions in this regard. With regards to the increase of the quota, the initial principle that was being employed to determine the quota was that, until adequate information became available, it was important not to either restrict the trade too much or allow the trade to expand. The initial requests that were received ranged from a request for a zero quota to 3800 skeletons per year. The principle that was adopted was to disrupt the trade as little as possible before the Scientific Authority understood what the trade was. The initial recommended quota was based on a prior understanding of what the trade was prior to the quota, namely, around 800. Evidence from the research study, and other inputs, however, suggests that that trade had been significantly higher and what the Scientific Authority was effectively doing is restricting and throttling the trade with potential consequences. This is one of the rationales for increasing the quota to the level that it actually was before the imposition of the quota in the first place.
The Chairperson said there is need for further engagement. From what is being said, it seems like there is no brief to look at the conservation mandate of the DEA. The non-detrimental findings look at the economics of the trade as opposed to the conservation part of it. The understanding was the existence of the Scientific Authority was to enhance the conservation mandate of the DEA using that as a scientific body to advise the DEA. What is being said is something different. There is nothing conservation about the economics of the industry. There will need to be a separate engagement with the Scientific Authority, especially on its report.
Mr Makhubele asked, while the exit point is OR Tambo, if the DEA is also dealing with illegal activities and whether those were ever discovered and exposed?
Mr Abader explained that, as per the report, there were findings of non-compliance and the DEA is dealing with those. There is an enforcement process that follows the non-compliance.
The Chairperson added that there was also a comment on the criminal, underground illegal networks that are feeding into this trade as well. This has not been rebutted
Born Free Foundation
Dr Mark Jones, Head of Policy, Born Free Foundation, commenced by giving a background, mission and vision of the Born Free Foundation, with the focus being on a report entitled “Cash before Conservation – An Overview of the Breeding of Lions for the Hunting and Bone Trade”, which was released in April this year and summarises investigations into the development and impacts of South Africa’s lion breeding industry.
Subsequently, Dr Jones gave a background of the plight of wild lions across Africa.
Dr Jones gave a breakdown of the lion breeding industry. South Africa is not the only country to breed large predators in captivity, but it does have by far the largest captive-breeding industry for lions.
Next, Dr Jones unpacked trophy exports. In terms of trophies, South Africa declared almost 7,000 exports of captive-bred lion trophies between 2006-2015, some 62% of which were destined for the United States.
Concerning the lion breeding industry, Dr Jones argues that far from contributing to lion conservation, the commercial activities associated with the lion breeding industry pose additional threats to wild lions and other big cats through the legal export of lion bones, mainly to Asia.
In terms of lion bone exports, Dr Jones explored the international trade in lion bones and skeletons from South Africa which began around 2008, mainly as an alternative to tiger bone in traditional medicines and tonics.
South Africa’s lion breeding industry, Dr Jones continued, has been the subject of significant international criticism from a great many prominent sources including:
- Government Ministers in Namibia, Botswana, and within South Africa;
- National and international non-Government organisations
- And International scientists.
Furthermore, criticism of the industry, Dr Jones stressed, has also come from within the hunting sector itself.
In terms of official attitudes for the lion breeding industry, Dr Jones argues that Lion breeding industry has received active support from key provincial politicians. Since the failure of attempts to push through restrictive legislation in 2010, the DEA has effectively facilitated the growth of the industry through enabling provinces to issue permits for lion breeding, canned hunting and more recently bone exports.
Serious welfare concerns persist in relation to the rearing of captive-bred lions in South Africa, particularly with the increasing profit-driven commodification of lion products. Recent images of clearly undernourished lions in captive facilities, and news reports suggesting that lion slaughterhouses have been established to facilitate the mass slaughter of lions to supply skeletons for international trade, only serve to exacerbate these concerns.
Concerning Brand South Africa, the fact that South Africa is the world’s primary destination for hunters who wish to hunt captive-bred lions, and is the world’s largest exporter of lion bones and skeletons, alongside the animal welfare concerns around the industry, have resulted in questions about the impact that the captive lion breeding industry is having in South Africa’s international image. In 2005, Marthinus Van Schalkwyk (then South Africa’s Minister of Environment and Tourism) described lion breeding for canned hunting as a ‘cancer’. More recently the current Minister for Tourism made it quite clear that captive-bred lion hunting is damaging Brand South Africa, and questioned whether the country wanted this industry. Significant players in the international tourism industry are beginning to take notice, including collective industry associations such as ABTA in the UK and ANVR in the Netherlands.
By way of conclusion, Dr Jones indicated that Born Free’s co-founder and President Will Travers OBE summarised the organization’s position as follows: “If we are to secure a future for Africa’s lions, the lion breeding and canned hunting industries must be closed down, with responsibility resting squarely with the South African government for ensuring that such a process is conducted with intelligence, humanity, and above all compassion for the animals concerned.”
What is damaging Brand South Africa?
Mr Richard York, Professional Hunter’s Association of South Africa, argued that South Africa’s conservation image is not being tarnished by the breeding or hunting of lions, but rather by key individuals profiteering from the focused attack on Brand South Africa.
South Africa’s tourist numbers?
Mr York highlighted that tourist arrivals in South Africa averaged 522583.99 from 1979 until 2018, reaching an all time high of 1598893 in January of 2018 and record low of 37430 in June 1979.
Vision of PHASA
Mr York highlighted that PHASA’s vision and objectives is through industry cooperation to develop meaningful solutions for wild, wild managed and captive bred lions in accordance to the Biodiversity Management Plan (BMP) for the African Lion.
Subsequently, Mr York unpacked the key opportunities of captive lion breeding in so far as Biodiversity conservation, economic development, social development, and assistance with management capacity are concerned.
The South African Predator Association (SAPA)
Mr. Kirsten Nematandani, President: South African Predator Association, addressed the question: where in the process is the human fear factor built in the animal? Unlike what some of the captive lion antagonists are promoting, SAPA members are breeding, raising and keeping their lions in Provincial government approved keeping facilities, built according to or better than the specifications of each Provincial Biodiversity Management authority . Animals are wisely raised and sustained for a period of three to five years thereafter; the animals are release for hunting purposes according to the guidelines of the SAPA Norms and standards for the hunting of captive lions and of the Provincial Biodiversity Management Authority.
SAPA members, Mr Kirsten continued, raise lions for the purpose of hunting these animals. These animals were raised in situations where they had limited contact with people, other than the caretakers. Thus, lions raised in captive facilities see, through their lifespan, less people than a lion that was born and raised in some “wild” area or National parks like Kruger National Park.
A lion, Mr Kirsten highlighted, can “sense” the fear of a person and then shift its focus more towards that person, enforcing its dominance over that person. People that are “working” with lions, are seldom afraid of lions, but carry a huge amount of respect for these animals. Experience has proved that lions that were raised in captive facilities, with limited human impact, are fearful of people. This is very similar behaviour to their “wild” lion counterparts. It is indicated in literature that some lions ‘loose’ their fear for people and may become “man-eater” lions.
Captive lions that are released for hunting cannot be claimed generically as lions that “has lost their fear” of humans. The hunt of a captive lion can each be classified as a unique experience – as lions differ from each other in behaviour patterns, fight or flight response, personality type, fitness levels, natural movement patterns, response on stress and levels of tolerance. The one thing that we as SAPA members can clearly indicate is that: a drugged lion cannot fight. We as SAPA members condemn the hunting of captive lions that are drugged or chemically tranquilised. We hunt animals that are not under the influence of any tranquiliser.
In conclusion, Mr Kirsten said that the captive lion industry in South Africa is a well regulated, manageable industry that contributes way more positively to South Africa than negatively, pleading with the Committee to assist in maintaining this industry for South Africa.
Custodians of Professional Hunting And Conservation – South Africa
Mr Paul Stones, Custodians of Professional Hunting And Conservation – South Africa, gave the background of the association, focusing on Conservation through Sustainable and Responsible Utilisation.
Mr Stones then unpacked the Partnerships In Wildlife-Based Tourism.
Mr Stones dealt with what happens if the country loses the contribution of hunting. With the transformation agenda of the biodiversity economy strategy – this may have major implications for the potential future contribution of hunting to the economy and communities.
Mr Stones said that the bedrock of socially responsible hunting is the constitutional imperative of justifiable economic and social development, highlighting that perception determines the reputation (and therefore sustainability) of hunting & captive game/lion breeding.
The criteria for hunting to be seen as responsible (i.e. sustainable and socially responsible) is that it has to be biologically sustainable; not substantially alter processes of natural selection and ecosystem function; maintain wild populations of indigenous species with adaptive gene pools; and not contribute to substantially manipulating ecosystems or elements in ways that are incompatible with the objective of supporting the full range of native biodiversity.
Captive lion breeding, Mr Stones argued, only fulfils the first criteria, namely, that it is biologically sustainable.
Subsequently, Mr Stones dealt with the attributes relating to ecological and evolutionary functioning.
In terms of the reputation of hunting, while lion is among the highest income generators, the income generated has declined from 195 million (2014) to 111 million (2016).
According to the Price Water House Coupers Sustainability Survey 2002, Mr Stones commented, ‘enhanced reputation’ is the main reason why respondents have adopted sustainable business practises.
Mr Stones continued that IUCN WCC 2016 voting results confirm that 72 countries and 409 national and international non-governmental organisations, perceived both “canned” and “captive-bred” hunting as undesirable hunting practices.
Mr Stones then indicated which international and African hunting organizations reject the practice.
Mr Stones concluded that conservation and the biodiversity economy needs hunting. Hunting can only be sustainable if practised responsibly. Responsible hunting must:
- Promote conservation
- Be ecologically sustainable
- Be economically and socially justifiable
International Council for Game and Wildlife Conservation (CIC)
Dr Ali Kaka, Regional Director, CIC, outlined the mission and vision of the CIC, a Worldwide Community for the Conservation of Wildlife through Sustainable Use.
Subsequently, Dr Kaka gave the backdrop to the issue of captive lion breeding for hunting purposes.
Next, Dr Kaka threshed out what the IUCN says about the captive lion breeding for hunting industry.
In terms of how it harms the animal, Dr Kaka explained that animal welfare NGO’s are using captive-bred lion (CBL) shooting to mislead the ill-informed public to assume lion hunting in general is like CBL and that the volumes shot reduce the number of lions living in the wild.
In terms of how does it effects South Africa, South Africa has legalised something which is considered unethical by even pro-hunting organisations and countries, including the respected global conservation organisation, IUCN. The South African conservation success, rightly or wrongly, will be questioned and smeared.
Concerning a solution, the CIC propagates the “African Hunting Charter”, which contains 13 principles, “to streamline and to raise standards of hunting in Africa, where well-managed and well governed hunting is the norm in all countries in Africa”.
By way of conclusion, captive lion breading may be legal, but it breaks moral and ecological basis and boundaries; it is bad for the reputation of South Africa at the global level; and is not good for the reputation of hunting, which is already demonized globally by false information: “we must be more responsible and propagate the good image.” Furthermore, if we follow the principles of convenience and of maximizing profit, hunting, with all the arguments in support of it, will still be doomed and in danger of becoming a thing of the past.
Comments from the floor
Ms Audrey Delsink, Executive Director: Humane Society International, referred the gathering to a nationally representative poll in a study conducted by IPSOS which gauged South Africans opinions towards the captive-breeding industry. South Africans, by more than a 3 to 1 margin, agreed that the industry is harming South Africa’s international reputation: 65% strongly agree and 21% strongly disagree. The survey also shows that 77% of South African strongly agree with conservationist will stimulate market demand and will increase the poaching of wild cats and lions. This comes off the back of SAIIA’s report. It finds that the captive breeding industry is less than 2% of South Africa’s tourism revenue. It also unpacks the so-called ‘community benefits.’ South Africa and its reputation as a tourism conservation leader cannot be dictated by the supply chain and the handful that control this industry.
Mr Ross Harvey, Senior Researcher: South African Institute for International Affairs, gave a breakdown of SAIIA’s report, which is divided into two parts. Firstly, it finds that the conservation and the economic benefit claims made by the industry are questionable. The second part of the report tries to understand the opportunity costs and the negative externalities associated with lion captive breeding. The reputational damage associated with this industry is real. The study projects a R54 billion loss to South Africa’s tourism industry over the next 10 years as a result. On the basis of the research, there is data that exists about this industry and yet it is clear that this industry’s conservation value is limited. The economic significance of the industry is severely limited too, especially when it comes to the negative impacts it can have on ethical hunting and South Africa’s brand value.
The Chairperson asked that the report be forwarded to the Committee.
The Chairperson highlighted that this has been a fruitful interaction. The Committee is a bit more informed around this practice. This Committee would like to be briefed on the study by the Scientific Authority as it was used to come to a very key decision by the Executive. The Legislature would want to interrogate that report. From the information, there is overwhelming evidence that there is really no conservation value in the practice of captive lion breeding for hunting and for the lion bone trade. Neither does it add value to our tourism mandate. It is very clear that this kind of practice is really doing serious damage to brand South Africa internationally. The situation as it is isn’t sustainable. A solution that is acceptable to everybody must be reached by the end of this colloquium.
The meeting was adjourned
The Portfolio Committee on Environmental Affairs hosted a Colloquium on captive lion breeding entitled Captive Lion Breeding for Hunting in South Africa: Harming or Promoting the Conservation Image of the Country.
Day Two of the Colloquium was divided into three parts. In part one, questions were asked and comments were made based on the previous day’s presentations. The Scientific Authority of the South African National Biodiversity Institute indicated that it was not answerable to the public, but was only answerable to the Minister of the Department of Environmental Affairs, even though it operated 100% off public funds. The Parliamentarians were asked to clarify whether that was an acceptable position. The Threatened or Protected Species regulation had been implemented by some provinces eleven years later. How could it take 11 years to take action on that very important matter?
Were there measures in place to serve as a deterrent to canned lion hunting? What were the punitive measures, and were those measures enough or should they be strengthened? If it was the view of the Department that there was nothing wrong with the captive-breeding of lions and that there were only a few rogue elements, what was being done about those rogue elements? What was the extent to which the industry had been transformed, not just in terms of beneficiation, but with regards to participating in the mainstream activities of the industry? How could Western NGOs who had no idea of Africa, its people and its wildlife come to Africa thinking they knew best?
The Born Free Foundation argued that it was not at the colloquium to instruct Africans how to manage African wildlife, but was supporting the larger and increasing number of South Africans, organizations and individuals, also from other African countries who believed the lion-breeding industry was damaging South Africa’s international reputation and putting wild lions and other predators across Africa and beyond at risk. That was an international concern because the actions of the lion-breeding industry might have ramifications that extended literally across continents. Even in the United Kingdom, there was a large and increasing movement calling for an end to the industry that bred and killed birds in huge numbers, with all the associated welfare concerns, but also denuded landscapes by stripping it of predators and managing the land purely to maximise the profitability of the industry.
The Portfolio Committee stated that any notion that Parliament could not get answers from the Scientific Authority was the wrong notion. Parliament could have access to any public record. The Scientific Authority was a body established by legislation utilising public funds and advising the Minister on the attitude to be taken in terms of public policy. The Scientific Authority agreed that there will be a follow-up.
In the second part of the Colloquium, there were presentations by Dr Pinnock of the University of Cape Town, South African National Parks, the Mpumalanga Tourism and Parks Agency, the University of Oxford, the Endangered Wildlife Trust, National Confederation of Hunters Associations of South Africa, and Brand South Africa.
Dr Don Pinnock’s submission brought to light three issues relating to hunting in the Greater Kruger National Park to the attention of the Portfolio Committee on Environmental Affairs: legislation which was contradictory or not applied; non-compliance, non-transparency and questionable trophy hunting practices and the Kruger National Park’s dereliction of duty in that regard; and reputational damage caused by trophy hunting in private reserves. Dr Pinnock presented his recommendations.
South African National Parks responded to claims of trophy hunting in the Greater Kruger National Park and delved into the breeding approaches, trends, challenges and opportunities for the South African lion conservation in the wild. The Parks recognised the importance of maintaining and protecting the broader conservation estate, whilst having an obligation to positively impact on the broader socio-economic environment with cooperative partners.
The Senior Conservation Officer at the Department of Environmental Affairs clarified the steps followed to inform quotas. The Endangered Wildlife Trust explained why there was no conservation benefit for captive lions. It noted that captive lions were bred for size or colour and were genetically compromised. True conservation breeding was carried out with a view towards release as goal, which captive lion-breeding did not do. Captive lion-breeding was not recommended in any conservation action plan. The Endangered Wildlife Trust was concerned about the increasingly dismissive response towards public sentiment which was largely against canned hunting. The Trust also wanted about being selective about the use of science.
The Chairperson of the National Confederation of Hunters Associations of South Africa highlighted how, in 2015, the Minister had proposed a solution: clean up the fringe elements, work to the higher bar, support the South African Predator Association to enforce their norms and standards. Let the permit system function by empowering the national Department and the provinces effectively. Was it the practice of captive-bred lions that was damaging the conservation image of the country or was it a select few people who kept it in the public space all the time?
The General Manager: Brand South Africa, stressed that the concern of Brand South Africa was how to position the country much more coherently when it came to biodiversity and how to build the deeper picture of South Africa’s conservation industry into the positioning of the country. Apart from the captive-lion breeding matter, the broader message to be entrenched, in the local as well as the international, markets was the unique position of South Africa in the global conservation space. South Africa was home to 70-80% of the world rhinoceros population. That is a majorly important factor for the country. Brand South Africa stood ready to support the work of not only the Committee but even the private sector and people active in that space.
In part three, the floor was once again opened for questions and discussion. Some important questions emerged. Had South Africa’s wild population been doing well incidentally to the existence of the captive-breeding industry? Did the Scientific Authority report support that Department’s increase of the lion-bone quota from 800 to 1500 skeletons? Did the Department understand the product that it had agreed to sell to outside markets? Had consultations been held with the neighbouring countries as per the CITES Conference? How was it possible that the Mpumalanga Tourism and Parks Agency completely ignored SANParks’ recommendations in terms of issuing a hunting permit? Did that not show weaknesses in the processes and systems of managing an open system?
Asked whether the interim report supports an increased quota, The Scientific Authority explained that the interim report did not make any recommendations, although the information could have been in support of an increased quota. The previous year’s quota had been a constriction and it had failed to recognise that stockpiles were building up. However, it was the Department of Environmental Affairs that determined quotas.
The Portfolio Committee indicated that it would deliberate over the Scientific Authority report and make it public. The report will be made available in Parliament with a brief statement of what the Committee recommended. The Committee would ensure that the recommendations that arose out of the process were implemented to the letter.
The Chairperson welcomed everyone to the last day of the colloquium. There were two apologies, namely, from the Minister and the Director-General. The previous day it had been agreed that the colloquium would interrogate the last presentations, ask questions and make comments that morning.
The Chairperson gave a breakdown of the day’s proceedings. The DEA was supposed to brief the Committee on the hunting quotas. However, it had been agreed that the Mpumalanga Department would also speak to that concern because the DEA was not responsible for the determination of hunting quotas in the Kruger National Park. Responsibility lay with Government, and Mpumalanga and Limpopo, the provinces adjoining the Kruger National Park.
The Chairperson indicated that a gentleman had approached him that morning and accused him of being biased. He would have an opportunity to give his submissions and explain his displeasure about the Chairperson’s facilitation of the meeting.
Mr Will Smuts, from the Landmark Foundation, explained that he had been troubled the previous day when the Scientific Authority indicted that it was not answerable to the public, but only answerable to the Minister of the DEA, and yet they operated 100% off public funds. Could the Parliamentarians clarify whether that was an acceptable position to take?
On the follow-up answer to the Threatened or Protected Species (TOPS) Regulations, it had been 11 years that that legislation has not been implemented by some provinces. If the DEA was fixing the problem when records existed that legislation had been tabled, even if not voted on, at the provincial COP, how could it take 11 years to take action on the very important matter of the TOPS regulations being implemented?
After giving some context to the organization to which he belongs, Mr Andrew Venter, Chief Executive Officer at Wildlands Conservation Trust, said that his colleague from the South African Predator Association (SAPA) had made a number of comments that needed to be challenged. Mr Venter was the Executive Director of the Blood Lions movie which was identified as a ‘low-budget propaganda film.’ Mr Venter suggested that the gentleman from SAPA and the presenter from The Professional Hunters’ Association of South Africa (PHASA) watch the film to understand the point of the film. Not only did it point out key concerns around the ethics and morality of the captive-lion bred industry, but, more importantly, it talked to the systematic fraud and the corrupt practices that underwrote that industry.
One example of those practices was the thousands upon thousands of paying volunteers who had been fleeced of their funds under the belief that they had been rescuing thousands of lion cubs that had been abandoned next to the road and needed to be hand-reared and bottle-fed for their survival, and yet not one of those cubs makes it into the wild. Another example was that of the thousands of hunters that had come into the country in the last decade believing they were going to live their dream and hunt a lion, that there was a fair chase and there was a chance that the lion would kill them. Nobody had told them that the lion was bottle-raised or that it had only been in the wild for a couple of days, just long enough for the drugs to wear off, and had no ability to defend itself. That counted as fraud in both instances. Both entities needed to answer whether they were going to repay tourists or hunters the millions that had been invested. The lion bone industry was the next level of fraud. There were two further instances of fraud. Firstly, the substitution of tiger bones with lion bones and branded as tiger bones; and, secondly, underwriting a treatment or behaviour that has no medicinal benefit and was bad for tiger conservation.
In conclusion, the gentleman from PHASA had gone as far as to refer to the coalition in the room. It bore pointing out that that was unprecedented, namely, in that room there were hunters, conservation agencies, NGOs, conservation sustainable-use NGOs, NGOs from the animal welfare perspective, all united against that industry: the that group SAPA had referred to the previous day as being Nazis and terrorists. The last time he had been labelled a terrorist was roughly 30 years ago and the previous occupants of that building had labelled him a terrorist for standing up against what was wrong in the country. It was necessary to take cognizance of the fact that there was a movement that believed that was wrong.
Karen Trendler, from the National Council of SPCA’s Wild life Trade and Trafficking Unit, commented on the welfare concerns, stating that the Council had three specialised units with staff that had been formally conservation-trained and qualified and who monitored and inspected the wildlife facilities. It was done on a systematic basis. It did not respond to cases of sad and unhappy lions but responded to genuine welfare concerns. In February, 41 wild lion facilities had been inspected. A number of notices and cruelty warnings under the Animals Protection Act were issued.
The legislation to prevent cruelty and ensure welfare to animals was not just a moral imperative but also a legal imperative supported by the Animals Protection Act. There were not only significant welfare problems in the lion industry with the breeding, but with the reduction in trophy hunting, the focus on killing and slaughtering of the lion for lion bone without any regulations is also leading to a number of welfare and cruelty concerns. The Council had opened cases against the cruelty. There was research which showed what the most humane way was for a cow, sheep, etc. to be slaughtered and there was legislation and committees to support how those animals were handled. There was nothing for the slaughter of lions. There were reports from within the lion industry that, with the production of the meat and the bone, lions were being shot in inhumane ways and were sometimes not killed. There were welfare problems. It was not adequately regulated. From the SPCA’s point of view, it was a very serious concern. DEA and DAFF were mandated to address welfare.
Mr Hermann Meyeriericks, a member of the Custodians of Professional Hunting and Conservation – South Africa, in response to comments by PHASA on the so-called conservation value of the captive-breeding of lions, referred to a quotation saying that the International Union for Conservation of Nature (IUCN) condoned captive-breeding as a conservation tool. What PHASA had neglected to tell the gathering was how the captive-breeding should take place. He proceeded to read from the policy. What the IUCN had in mind was not what one saw in the captive-bred lion industry in South Africa.
Mr Z Makhubele (ANC) commented, for the benefit of the gathering, that when Richard York, Professional Hunter’s Association of South Africa, had made his presentation, he had indicated all the good things about captive-breeding for the purposes of hunting. If a lion had been kept in captivity, nobody had clarified how long, after the release of the lion, it could reasonably be hunted. The DEA was challenged in court primarily on that very concern. Moreover, the Scientific Authority referred to the trade-offs of a ban versus a quota system. Could that be expanded upon? Moreover, were there measures in place to serve as a deterrent to canned lion hunting? what were those punitive measures, and were those measures enough or should they be strengthened? Additionally, to what extent had the industry been transformed, not just in terms of beneficiation, but with regards to participating in the mainstream activities of the industry?
Ms Linda Tucker, CEO of the Global Wildlife Protection Trust, explained that as an organization, the Trust had been participating in the public participation processes and the stakeholder meetings around the matter since 2002 and it had submitted expert scientific opinion on the issue. How had the Scientific Authority been selected? In 2009, a panel of experts was convened by the government to discuss that question. There were many authorities in the room who could add value to the panel of experts and that panel was well-represented at the time. In 2009, the Bloemfontein High Courts ruled against the industry in favour of the government’s intention to prohibit it with the help of the panel of experts. Why had that panel of experts been disbanded following the court case? When the case returned to the Supreme Court on 29 November there had not been a panel of experts to answer the questions in the Supreme Court. The government had lost the case against the captive industry.
Dr John Wilson, Chairperson of the Animal Ethics and Welfare Committee of the South African Veterinary Association, commented that in the address by the Honourable Minister, what had been stressed most strongly was that the discussion had to be scientific. Everything that she referred to had been underpinned by scientific facts. What the Minister and, possibly many people, were missing in the discussion was that science is not value-free. Science was saturated with all sorts of cognitive and moral considerations. Morality had to be the motivating factor for the international reaction to that particular industry. One of the questions that needed to be asked and answered for the benefit for the Portfolio Committee was: Why were lions the subject of moral concern? It was very simple. It was because they were sentient. They were able to feel sensations and emotions just as human beings did. Therefore, it was important that that be respected. That fact was blatantly disrespected by the industry. Ethics was concerned with what was the good or the right thing to do when duties or desires were in conflict. Yet, there had been no ethical analyses presented at the colloquium. That was one of its weaknesses. An ethical analysis would create an understanding of what underpinned the opposition to the industry.
There was also the question of political persuasion. An important theory of political persuasion dealt with public sentiment, which was completely different from public opinion. There had been derogatory statements about public opinion because it was uninformed and emotional. Public sentiment, however, was about how people felt about something, intuitively. There was something grossly unfair about taking a wild animal, in this case a magnificent animal at the top of the animal kingdom, from its natural environment and turning it into a commodity, a plastic bag full of bones. It generated enormous censure. There was a very good English word for it, namely, ‘opprobrium’, which means ‘disgust’. There was no way of getting around something that generated opprobrium. A very wise person once said, ‘public sentiment is everything. With public sentiment on its side, nothing can fail. Without public sentiment, nothing can succeed.’ Public sentiment made statutes, regulations, and decisions possible, or impossible, to execute. That had to be borne in mind especially by the DEA. If public sentiment was against the DEA, there was no way but to address it. It was fair to say that everything was in place for the generation of a perfect storm of opposition. If that gathering storm descended on South Africa, it was going to land in the backyard of the DEA. If matters in the political sphere were not handled properly, people frequently found themselves without a job.
Mr Ron Thomson, a wildlife management and national park administration specialists as well as a wildlife, conservation and African big game hunting writer, commented that people should be looking a lot further for solutions to problems and gave a breakdown of the human population figures for Africa South of the Saharan Desert. People were going to have trouble finding land for people to live on, let alone for lions. If one was going to find solutions to the problem and other wildlife problems, one was going to have to look ahead and ask whether what was being put in place now and whether it was going to work in the year 2100. If it was doubtful because of the numbers of people, then it was a waste of time. It was easy to juggle figures. The Born Free Foundation had done so quite freely the previous day.
The real reason for the decline in lion in the 20th Century was principally because of human population expansion and encroachment. Without space, either lions nor nothing else could survive. The losses in the current century, for the same reason, were going to be even more worrisome. The problem would not be solved by allotting false reasons to it. The truth of the matter was that, by the turn of the current century, if there were any wild lions left, they would be found only in the bigger national parks, and then only if there were any national parks left. One would be lucky if anything survived the current century other than cattle, sheep or goats and that was because the rural people of Africa depended on them for their survival. They could not afford for those animals to become extinct. That taught one that, if one wanted to keep one’s wildlife alive by the end of the century, one had to replace cattle, sheep and goats with elephants, lions and buffalos, etc. It had to be possible for the rural people of Africa to earn a living through the sustainable utilization of their wildlife.
Mr Thomson said that the plan to make it possible for the rural people of Africa to earn a living through the sustainable utilization of wildlife, was by integrating the needs of the people with the needs of the wildlife. But wildlife needed to have a value for that strategy to succeed. With the way the NGOs were getting around that currently, soon everything would be worthless. In 1975, there was no trade in rhino horn; in 1989, there was no trade in ivory; in 2018, there was no trade in lion skeletons. What would be next? The Western NGOs had a monumental cheek to come to Africa and tell Africans just what one could and could not do with one’s own wildlife.
The previous day, Dr Ali Kaka had said that it was fine to breed wild animals, but it is not alright to hunt them. He had news for Dr Kaka and the presenter from the Born Free Foundation: 50 million captive-bred pheasants and 10 million partridges were released into the wilds of Great Britain to be hunted by 500 000 hunters every year. It brought £2 billion to the country’s economy. Those presenters had to sort out their own backyard before they started interfering with Africa’s wildlife affairs. Mr Thomson’s experience of the captive-bred lion industry had left him with the hope that the government would nurture the infant industry and not close it down.
Africa had solutions to the problems that were discussed. They included fenced enclosures and captive-breeding of all game species, of utilising elephants and rhinos for the benefit of South Africa’s people and for the captive-breeding of lions. For the NGOs who felt that that was sacrilegious, he could say that there were far too many lions in Southern Africa. There were more elephants than the space could support. Yet, Western NGOs came here to tell South Africans that they were not allowed to shoot even one elephant. Every elephant had to be protected. South Africa had to look at the wildlife concerns in a far more pragmatic manner than it had done under the influence of the pressure from the Western NGOs. The country had to find solutions that would work by the end of the century. Africa should encourage the West to help Africa to solve its problems with constructive contributions to Africa’s solutions. If Western NGOs were set on coming to Africa to tell poor ignorant Africans what could and could not be do, they should keep away, because those contributions were destructive and injurious to Africa’s own wildlife management solutions.
How could Western NGOs who had no idea of Africa, its people and its wildlife come to Africa thinking they knew best? If they could not come to help properly, they should not come at all because they were not welcome. Mr Thomson had been in the business of wildlife all his life and he was affronted by the fact that Western NGOs could come from city-slicker situations and tell people like him how he should behave with his wildlife. They did not have the knowledge to do that. Solutions could be found amongst experienced Africans in Africa and not in the NGOs of the Western world.
Ms Adri Kitshoff-Botha from Wildlife Ranching South Africa, speaking on behalf of the land owner, responded to Dr Kaka’s comments. He had given a lot of accolades to the South African model which was acknowledged worldwide and respected. Everyone agreed on the success that South Africa had achieved with its conservation model. He also referred to a Charter that was being developed, namely, the Charter on Hunting, Wildlife Conservation and Habitat Protection. The Charter, as it currently read, however, did not recognise the South African model which had proven so successful. If South Africa wanted to proceed with the success story, it would be extremely important that that Charter was amended to acknowledge South Africa’s success story and model.
The Chairperson, by way of correction, stated that Dr Ali Kaka was at the colloquium representing an international hunting association, the International Council for Game and Wildlife Conservation (CIC). He had not spoken against the practice of hunting because his organization promoted hunting. He referred to the Charter which Ms Botha was talking about, the African Charter and how the Charter was supposed to propose well-managed and well-governed hunting in Africa.
Mr Thomson responded that while Dr Kaka had not said anything about being anti-hunting, what he had said was that animals should continue to be bred, but not in order to hunt them. Captive-bred animals should not be hunted. In his own backyard, namely, in England, they were killing 60 million birds a year that were captive-bred by hunters in England. Nobody was doing anything about that.. Yet he thought he could come to Africa and tell Africans what to do with their wildlife, when his own backyard was not clean.
The Chairperson informed Mt Thomson that Dr Kaka was from Kenya. The Committee had a responsibility to make sure he was not misunderstood. His organization was against captive-lion breeding. That was the reason that it had taken the decision it had in Madrid 2017.
Ms Pippa Hankinson from Blood Lions stated that earlier that year the Endangered Wildlife Trust (EWT), together with a number of partners, including Blood Lions, had sent a letter to the Minister containing shocking statistics of captive-carnivore fatalities over the last decade caused by tourist interactions with captive-bred predators. She asked DEA what was being done in terms of ‘I call on the South African government to institute […] regulations for the management of all carnivores held in captivity, to ensure that only qualified experienced people have access to these animals, that no risks are posed to either human or animal life by unrestricted, unregulated access by all people and also finally the potential damage to Brand South Africa’?
Mr Kirsten Nematandani, SAPA CEO, referring to the corrupt practices in the industry as depicted in the Blood Lions film, explained that SAPA was being misunderstood. SAPA was an organization that had members that followed its norms and standards. Those members would not fall under those who were characterised in the Blood Lions movie. SAPA had very clear norms and standards and was not involved in, amongst others, hand-rearing of cubs. SAPA was also not involved in the tourism matters that people had concerns about. SAPA’s members were not involved in a situation depicted by a previous speaker as the tourism of captive-lion breeding. The gentleman who thought he had been labelling him a terrorist had misunderstood him. He had said that they were called terrorists by the Apartheid system. It was mentioned that the captive-bred lion was actually used to substitute tiger bones. SAPA follows the quota determined by the DEA to the letter. Captive-bred lion bones were tested against the DNA findings that were recorded. If proven otherwise, those bones would be discarded. That, he agreed, was fraud, but, fortunately, it was unlikely it would get past the Green Scorpions’ watchful eyes that ensured that everything was above board.
There was a second speaker who had mentioned the specialised unit that had to do with welfare. In fact, SAPA embraced that welfare because that would uphold the standards of SAPA. Without that welfare, he agreed that the industry would not go anywhere. Unfortunately, there are members who were engaged in captive-bred lions who were not part of SAPA. As a result, the organisation could not be responsible for such members. His plea, as part of what SAPA had recommended, was to ensure that anyone who was given a permit was a member of an organization that had clear norms and standards that were acceptable.
Mr Nematandani said that SAPA’s norms and standards had been made available to everybody including the welfare groups. The organisation had called a meeting to ask for inputs. Inputs were still coming in because it was a living document. The colloquium had to acknowledge that there were welfare problems, particularly from those who were outside SAPA, and maybe, amongst even those who were part of SAPA. That was why the policing needed to continue and SAPA was willing to work with the DEA for that purpose. The question of transformation was a very pertinent question. 80% of the people in the country were not involved in the wildlife industry. That was a serious concern. It should be top of the agenda to ensure that the playing fields were levelled. The industry had that challenge. People were asking how they could reach out. Those were the issues that needed to be addressed. With regards to public sentiments, those were very important questions.
A representative from PHASA indicated that PHASA had watched the Blood Lions video. It was unfortunate that only a rogue element had been portrayed in the entire film. Everyone knew what was wrong in the industry. Why was there no party there with solutions? Everybody was identifying the problem that everyone knew about. It was unacceptable that South Africa was dictated to by the West. The country’s largest trading partner was China. Why was China not present? When was South Africa going to stop being dictated to by the colonial West? South Africa was unique in what it had and there is no way South Africa could be compared to another country. The South African wildlife model spoke for itself. South Africans were extremely successful in what had been done and yet were criticised. Lion had been singled out, but what about the other species? South Africa had a captive-bred model throughout and should be proud of what the country had. Was it a sin to make money? It was mentioned that there was a financial interest in motion number nine. Motion number nine was flawed and contradicted itself. Wildlife might be utilised to generate an income. PHASA was working for its people. It was trying to support government in making informed decisions and finding solutions to the problems, and not to avoid them.
Mr Richard York asked, regarding to the proposal that only six wild lions be hunted, where the members of the Custodians were going to hunt in South Africa? Were they proposing that South Africans had to go out of the country and pay R1.5 million to hunt? How many parks in South Africa were financially feasible? There was an economic burden on South Africa. One lion consumed food to the value of R120 000 per year. That equated to R250 million in economic value that they ate. Was the captive-bred lion industry was to be banned by banning all the sanctuaries throughout South Africa and banning all forms of tourism unless the establishments could prove their conservation value to the IUCN. They had to bear in mind that the lion populations in small reserves were non-viable populations. If that was the route to be taken, then the small reserves in South Africa were having a detrimental effect because the genetic integrity of the small reserves was definitely under question.
The Chairperson asked if Mr York was suggesting that all forms of tourism be banned.
Mr York said that it was immoral to ban one sector based on emotion and yet allow other sectors to profit. The Born Free Foundation made more money in 2016 from donations than the entire lion industry in South Africa from hunting.
The Chairperson stressed that if tourism was banned, it would have dire repercussions.
Mr Paul Stones, Safari Africa Game Hunting, responded that it was not a God-given right to hunt a lion. The fact that lion-hunting was allowed across many parts of Africa was a massive injection into the conservation areas. The people who opted to, and could afford to, do that were only satisfying their own desire to go into the wilds in Africa to hunt. They also contributed huge sums of money. To say that one had to open the Fizz-Pop shop to let anyone buy what one wanted just because one should be allowed to was completely out of line.
To say that South Africa had a captive-bred ‘industry’ was very misleading. To compare the lion-bred industry to anything else, e.g. buffalo, sable antelope etc. that was intensively bred was misleading. 15 years ago one could not hunt sable antelope or buffalo because there were very small numbers in South Africa. Today, testimony to South Africa’s conservation model, there were hundreds and thousands of these species running around natural and bio-diversified game ranches and areas. Through the intensive breeding of these species, they had been returned generally to the wild. Today, Africa was not what it was 200 years ago. To say that the captive-lion bred industry was parallel to sable antelope, buffalo and roan antelope was completely false. Where could one find lions that had been created by the industry and were roaming free? The Captive-bred lion industry could not show one single lion roaming free today.
Prof John Donaldson, Chairperson: Scientific Authority, South African National Biodiversity Institute, concerning who the Scientific Authority reported to, reminded the gathering that it was important to remember that the Scientific Authority was part of a decision-making process and has different modalities depending on what it was doing. Amongst others, it undertook non-detriment findings, undertook risk assessments, advised on exports to appropriate destinations, and did assessments on captive-breeding facilities. The process involved did not always allow the Scientific Authority to engage in a public debate about it. The non-detriment findings went through a public consultation process. There was consultation with experts. The draft of the non-detriment findings were published in the government gazette to obtain additional information. That information was then reassessed and the non-detriment finding was revised before it was published for implementation. There were public consultation processes. In terms of reporting back on those processes, generally the report went to the Minister. There were investigations, however, as to how public consultation could be furthered. That was an area that could be worked on.
Furthermore, in terms of who was on the Scientific Authority, it was established in terms of the National Environmental Management: Biodiversity Act (NEMBA) and TOPS regulations which stipulated that there was one member from each of the nine provinces, one from the South African National Biodiversity Institute (SANBI), South African National Parks (SANParks), National Zoological Gardens, Museums and two from the Department of Environmental Affairs (DEA). It depends on who was nominated and there was a process for appointment. Moreover, it was important to know that there was a difference between the Scientific Authority and Panels of Experts or the Committee of Inquiry, that had been established to deal with particular concerns. The Scientific Authority dealt with routine matters. When there have been specific questions, like the matter of captive-lion hunting or the potential of the trade in rhinoceros horn, that required a separate panel of experts for a wider range, intensive debate, ethics, and societal involvement.
Dr Mark Jones affirmed that the Born Free Foundation worked out of its United Kingdom base. It was important to remember that Born Free had long-established bases in Kenya, Ethiopia and in South Africa which were led and managed by local staff. He had not come to tell Africans how to manage African wildlife, but had come to support the large and increasing number of South Africans, organizations and individuals, also from other African countries who believed the lion-breeding industry was damaging South Africa’s international reputation and putting wild lions and other predators across Africa and beyond at risk. It was an international issue because the actions of the lion-breeding industry might have ramifications that extended literally across continents. It was not a large number of Western NGOs that had rolled up to tell folk in South Africa what to do. The voices that he heard were well-informed South African voices across many sectors of South African industry and society. There was also a large and increasing movement calling for an end to the industry that bred and killed birds in huge numbers, with all the associated welfare concerns, but which also denuded landscapes by stripping predators and managing the land purely to maximise the profitability of the industry. That industry would come to an end and the Foundation’s message was consistent across those industries.
Mr Shonisani Munzhedzi, Deputy Director-General: Biodiversity and Conservation, DEA, explaining the scientific-basis of South Africa’s conservation approach, said that apart from the role of the private sector in that success, there was also this question of evidence-based science which was very important. The law made provision for a Scientific Authority to assist in providing views that needed to be considered in decision-making. In the 2016 Convention on International Trade in Endangered Species of Wild Fauna and (CITES), South Africa had raised a number of questions. In South Africa’s decision-making, the founding principles of CITES and the IUCN were very explicit and clear. One critical aspect was the role of science in informing decision-making. If that was not taken into account, South Africa would have serious problems. If South Africa’s decisions were not informed by science, they would come back again. While it was not value-free, the role of science should not be undermined.
The Scientific Authority was not a decision maker. The DEA made the decision. The test of rationality was used to assess a number of things. DEA needed to ensure the survival of species in the wild. Whatever decision was taken, it should ensure that the survival of species was not compromised. That was the fundamental principle that was considered when investments were made. Concerning the TOPS regulations and how the DEA worked with provinces, he said that the DEA had invested in a cooperative governance process that involved all provinces, including the national department. In that concurrent function, permits were issued by provinces. People had to comply with permit conditions. In the processing of the new TOPS regulations, the process would ensure that everything else went through the NCOP to avoid a situation where there might be a disjunction. In the current situation, they needed to work together.
The National Society for the Prevention of Cruelty to Animals (NSPCA) related some of the non-compliance actions that they have been taking on some of the areas that they had visited. DEA had gone to more than 200 facilities, one by one. The various matters that were being, or needed, to be acted upon were highlighted. Together with the provinces, those were the things that had to be dealt with on the basis of that report. The finalization of the report with the MEC and the Minister might have a fundamental concern that might impact on how DEA dealt with such matters, even moving forward in terms of the industry itself. DEA did have cases that it won, but others that it lost.
A representative of DEA explained that the then Minster of Environment and Tourism, Minister van Schalkwyk, had appointed a panel of experts in April 2005. The purpose of the panel of experts was to advise the Minister on trophy hunting in buffer zones adjacent to national parks and also on canned hunting, which was as a result of the Cook report of 1997, and to review the hunting industry in South Africa. Once their work had been completed, the panel of experts released their report and their work was concluded. This was why they were disbanded.
The Chairperson asked when the report had been released.
The representative of DEA responded that the report had been released at the end of 2005 and the beginning of 2006. DEA had the report. The Senior Counsel (SC) who represented the DEA at the time in the case against the South African Predators/Breeders Association had had access to all the documents that were used and produced by the panel of experts. The SC consulted with individual members who were part of the panel. All the information from there had been taken into account for the court case. As a result of the panel’s report, the Protected Species Regulations were then developed. It was on those that the DEA was taken to court.
Ms Boshoff, a DEA official, added that the DEA had stated its position in the High Court. The then Predator Breeders Association had appealed to the Supreme Court of Appeal. DEA had defended the position it had taken in the High Court process and confirmed its position and argument in the High Court case. It was not necessary to bring in all those extras to the Supreme Court case because the Counsel had all the information and the reports. The legal experts within the DEA had assisted. It was about defending its case from a legal point of view and convincing the Supreme Court of Appeal why it should not come to a different conclusion from that of the High Court. That was why the members from the panel were not involved in the Supreme Court case.
Mr Meyeriericks explained that the DEA had often used the court case as a reason for not acting on captive-bred lion hunting. The DEA said that the Court rightly found that the DEA has no mandate to legislate hunting ethics. That was correct. The irony was that there were a lot of ethical issues legislated by the DEA in the hunting legislation. He submitted that it was no longer an ethical or moral question only. It had become a conservation subject too. DEA and the Scientific Authority should take cognisance of the fact that captive-bred lion hunting was no longer conservation-neutral. It was posing a threat to wildlife populations across the continent.
The reason was plain and simple. Areas of wildlife outside of national parks across the continent largely depended on a hunting income for the conservation efforts in those areas. Without that income, the anti-poaching, social upliftment and the protection of the species and the populations could not continue. That income was needed. Captive-bred lion hunting was placing all hunting at risk. If South Africa lost the ability to export wildlife to the United States and the European Union, those lions had no value and the hunting areas had no income to finance and sustain the conservation efforts. It was already happening. Bans on exportations were already in place purely due to the public disgust with the captive-bred lion industry. It was tarnishing hunting and placing at risk the conservation efforts in wild lion range areas. The conservation question needed to be addressed. Mr Meyeriericks suggested that one should forget about morals and ethics and look at the risks that the conservation industry was running because of one small industry in South Africa. Should the precautionary principle then not apply?
The Chairperson said he was disappointed that the gentleman who had accused him in private of being biased was not able to make the same accusation when given a public platform. If he was not able to substantiate his argument, he had to keep quiet. Yesterday, the request was made for solutions. The gathering still waited to be briefed in that regard by those who were in favour of the practice. They could not behave like ostriches before the mountain of criticism. He suggested that the colloquium looked for alternatives and solutions.
What was quite worrying was how the debate became racially polarised, talking about the West telling Africans what was right or wrong. This debate was not racial. It was about conservation and protecting the conservation record of South Africa. It was wrong to take this line of argument. The country had come from a very difficult past and the government was trying to reconcile the country. People should not take the easy way out and argue about black and white, the West and African. It was even worse when one was not an African in the proper definition of being an ‘African.’ That argument should be avoided. It was not helpful. It only stoked racial connotations into the argument and it was not about that. In the arguments against the practice, there were the animal welfare organizations, NGOs, and those who subscribed to sustainable use, and the hunting associations.
The Committee had asked for the report from the Scientific Authority because everybody was supposed to account to Parliament. It had yet to be determined whether it would be presented then or in a different session. There was a lot more engagement that had to happen with the Scientific Authority. Any notion that Parliament could not get answers from the Scientific Authority was the wrong notion. Parliament could have access to any public record. The Scientific Authority was a body established by legislation utilising public funds and advising the Minister on the attitude that had to be taken in terms of public policy. No one was beyond parliamentary scrutiny or oversight. The Scientific Authority had agreed that there would be a follow-up.
He reiterated Mr Makhubele’s question about any palliative measures taken by the DEA against canned hunting as a way of deterrent. The Committee had been told that an audit had been carried out on the farms which had picked up a number of things. What had been done by the DEA to punish those? If it was the view of the DEA that there was nothing wrong with the captive-breeding of lions and that there were only a few rogue elements, the question was what was being done about those rogue elements. There was a notion that the DEA had not done anything, even against those who were tarnishing what was the right practice. That was very worrying. It looked like the Department was not doing anything.
Presentation by the University of Cape Town
Dr Don Pinnock explained that he would like to bring three issues relating to hunting in Greater Kruger to the attention of the Committee on Environmental Affairs:
1. Legislation which was contradictory or not applied, both of which needed to be remedied.
2. Non-compliance, non-transparency and questionable trophy hunting practices, particularly in the Associated Private Nature Reserves (APNR), plus the Kruger National Park’s dereliction of duty in this regard.
3. Reputational damage caused by trophy hunting in those private reserves, particularly the hunting of lions.
A positive external image, Dr Pinnock stressed, was essential for attracting overseas tourists. For many years foreign visitors had associated South Africa with iconic wildlife in natural habitats. But over the last few years, revelations about the truth and scale of the lion hunting and captive lion breeding industry in South Africa, and its direct links with the lion bone industry, had seriously tarnished that image.
Dr Pinnock concluded with two suggestions. Firstly, South Africa should designate core areas where no hunting could occur, and the Greater Kruger National Park was the most important area. If hunting was to occur, designated geographically peripheral areas had to be identified where that could take place.
Secondly, South Africa should ban the hunting of all iconic and protected animals, all of which were under terrible threat from poaching across the continent. Lion, elephant and rhino numbers were crashing across Africa and tourists knew that. It did not cut ice with them to say that South Africa had more so they could be killed.
Briefing by South African National Parks
Mr Fundisile Mketeni, CEO: SANParks, informed the audience that SANParks had just been through a vigorous process of reviewing the management plan of Kruger National Park. SANParks was in the process of regularising what was happening in the western part of the Kruger National Park, an area of two million hectares. Mr Mketeni proceeded to outline the mandate, vision, mission and SANParks’ core pillars and the evolution of conservation in South Africa.
SANParks’ response to claims of trophy hunting in the Greater Kruger National Park
Mr Glenn Philips, Managing Executive: Kruger National Park (KNP), provided SANParks’ response to claims of trophy hunting in the Greater Kruger National Park. Among other activities, KNP had hosted a Management Plan consultation, which more than 54 public and interest group meetings had attended in 2017-2018; with 501 inputs received on the draft Plan; and an approximate cost to develop the plan of R3.6 million. Mr Philips clarified the outcomes of the management plan consultation.
Mr Philips referred to the GLTP Treaty (2002) and the three implementation phases thereof. He gave some background to the media statements on trophy hunting in the Greater Kruger National Park. SANParks’ position on hunting in the Greater Kruger footprint was that hunting was a legitimate practice in protected areas. SANParks would not allow hunting in a National Park. SANParks’ Policy framework supported ethical and sustainable hunting in cooperative conservation areas open to KNP. What could be improved, Mr Philips stressed, were procedural matters, open transparent communication between all parties, and the Greater Kruger/GLTFCA (Great Limpopo Trans-frontier Conservation Area) should demonstrate contribution to various outcomes.
By way of conclusion, Mr Philips said that the SANParks Vision recognised the importance of maintaining and protecting the broader conservation estate, whilst having an obligation to positively impact on the broader socio-economic environment with cooperative partners, a key focus was to promote responsible access and benefits to communities. The GLTFCA Cooperative Agreement was an innovative transboundary institutional process, providing for a range of consistent & well-governed protected area management models and practices in the open system, in pursuit of local and landscape ecosystem, social and economic outcomes. Misleading media statements did not further the cause of conservation or represent the interest of the Greater Kruger Park. Such parties should state their interests and funding streams. Legitimate and responsible hunting in the open system was not the same as ‘captive bred hunting’.
The Chairperson said that the tirade against the media made him feel very uncomfortable. Parliament relied on the media. They were not the enemy. The media was what one gave them. If one were hostile, the media would be hostile. The duty of the media was to inform. It was the responsibility of those in public office to give the media the right information so that journalists could do their work. Public officials were meant to hold the media to a higher standing of ethical reporting and to distinguish between what was opinion and what was the news.
A SANParks representative delved into breeding approach, trends, challenges and opportunities. The key thing to consider was the roles that lions played and how to ensure that role persisted.
The Chairperson highlighted that, in light of Dr Pinnock’s submission, it was not about sustainable use or hunting per se as a means of sustainable use. The matter was a specific incident where a lion which had left the Kruger National Park had been hunted and some of the issues surrounding that. There had been very little by way of responses. Written responses were necessary. There were specific allegations that had emerged which the speakers had failed to respond to.
Mr Mketeni said that once SANParks had received the presentation, it would respond formally in writing.
Mpumalanga Tourism and Parks Agency (MPTA)
After a few opening remarks, Mr Bheki Malaza of MPTA clarified the mandates of MTPA and Limpopo Department of Economic Development, Environment and Tourism (LEDET), which were the regulatory authorities for protected areas open and adjacent to KNP. Among others, the MTPA and LEDET were overseeing the current regularisation process of the areas on the western boundary of KNP, in strong cooperation with SANParks, who was facilitating the GLTFCA/Greater Kruger Agreement to support consistent practices in the open landscape. SANParks did not hunt in National Parks, and no hunting took place in the KNP.
Mr Riaan De Lange clarified the steps being followed to inform quotas.
Step 1: Management plans to provide for hunting, including cooperative aspects around it within an open landscape – consultation, ecological management, governance.
Step 2: Ecological surveys, censuses, specialist studies, observation to inform offtakes around August- October.
Step 3: Submit detailed post-offtake records, in consideration of the above around October.
Step 4. Offtake committees make recommendations, and submit to respective EXCO structures for approval, including the APNR Joint Management Committee, in November.
Step 5: EXCO obtains support from KNP, MTPA and LEDET, based on the following supporting documentation: pre- and post-offtake information, management plans, signed protocols and members being part of the Constitution, motivation of financial sustainability, service level agreements, e.g. with respect to LEDET.
Step 6: MTPA or LEDET issues the permits, as per recommendations.
It was agreed that the MTPA would provide a formal response to Dr Pinnock’s submission.
The possible effects of lion bone trade on lion conservation in the wild: Stimulating or buffering the demand? Key threats to wild African Lions – University of Oxford
Dr Michael Sas-Rolfes presented on behalf of the Oxford Martin Programme. He identified the following factors as key threats to wild African lions:
1. expanding human populations and increasing resource demands;
2. land conversion – habitat loss and fragmentation;
3. loss of prey;
4. human-wildlife conflict; and
5. unsustainable harvesting.
The Asian Connection
Among others, Dr Sas-Rolfes had elucidated how, in 2007, the purchase of lion bone from ex-captive-bred, hunted lions in South Africa had begun to supply the demand for Traditional Chinese Medicine in Asia.
Evidence to 2015
In the light of legal skeleton exports since 2008, Dr Sas-Rolfes spelt out the evidence since 2015 that captive-bred lions might play an important buffer role for wild lions (Lindsey et al, 2012). South Africa was the only country with commercial captive lion breeding and also the only country in Africa in which all wild lion populations were increasing (Bauer et al, 2015). There was no evidence that lion bone exports were negatively affecting wild lion populations in South Africa (Williams et al, 2015).
Dr Sas-Rolfes gave a breakdown of significant developments since 2015, which included the Cecil, the lion, incident, the Blood Lions campaign, increased public focus on trophy hunting, trophy hunting import bans in Australia and France in 2015, the US Endangered Species Act petition and listing, US trophy import ban from captive bred lions in 2016, a new focus on trade and CITES CoP17 outcome with SA’s skeleton export quota. What were the effects of those changes?
Research collaboration in 2016
Dr Sas-Rolfes discussed SANBI’s decision to initiate research collaboration in 2016, the goal of which had been to deepen understanding of South Africa’s captive lion breeding industry and its links to wild lion conservation. He elaborated on the grey areas of wildlife trade policy, the complex supply chains, the sustainable use and adaptive management, animal welfare matters, findings regarding the wildlife trade prohibition hypothesis and the legal supply hypothesis. He explained policy and research challenges, the policy and research approach, the collaborative research partners, the trade policy decisions and inputs and the new information in 2017.
2017 National Captive Lion Survey results
Dr Sas-Rolfes elaborated on the draft of the National Captive Lion Survey results. Dr Sas-Rolfes referred the gathering to the quota uptake in 2017 over the period of 5 weeks. Did South Africa’s exports, Dr Sas-Rolfes asked, affect other wild cats elsewhere? There was evidence of targeted lion poaching in Mozambique, but there was no evidence of causal link. The global demand for big cat products, such as teeth and claws appeared to be increasing, e.g. reports of jaguar poaching in Latin America. But that could not be causally attributed to lion skeleton exports. Dr Sas-Rolfes expanded upon the public concerns related to lion breeding, and the risks of an immediate zero quota, i.e. ban.
What is a ‘precautionary’ approach?
According to the precautionary approach, Dr Sas-Rolfes stressed, it should be incumbent upon proponents of a zero quota to provide assurances, backed up by scientific evidence, that it would not lead to expansion of illegal trade and poaching of wild lions or other wild cat species.
Conservation status of lions in South Africa – Endangered Wildlife Trust
Dr Kelly Marnewick, Senior Wildlife Trade Officer: Endangered Wildlife Trust (EWT), started by speaking to the conservation status of lions in South Africa, of which there is a total of approximately 3,500 wild lions and 8,000 captive-bred lions.
Purpose of captive lions
Dr Marnewick explained the purpose of captive lion breeding, which was tourism, interactions with captive lions, volunteerism, lion bone trade, and ‘hunting’.
Captive Hunting – what and where?
Dr Marnewick detailed the location of hunts that had taken place in 2010: 82% in the North West, 7% in the Eastern Cape, and 6% in the Free State. He spoke of the numbers of trophies resulting from captive ‘hunting’ over the period 1977 to 2011 versus the hunting of wild lions over the same period.
Dr Marnewick stated that the trophies went to, inter alia, Australasia, Asia, Europe, and the Americas. There were different hunters for captive and wild lion and the bulk of the market was not transferable to wild hunts. 50% of hunters would consider hunting wild lions.
The Value of hunting in SA
According to Dr Marnewick, the SA Professional Hunting Statistics of 2016 reflected a sum-total of R1.38 billion for animals only, with R110 million for lions, which was likely to have been fewer in 2017/8. Less than 8% of the value of hunting in South Africa was due to lion hunts. He expounded on the differences between captive and wild hunts in terms of the area, cost, time, success rate, and trophy quality.
No conservation benefit for captive lions
Dr Marnewick explained why there was no conservation benefit for captive lions. Captive lions were bred for size or colour and were genetically compromised. A true conservation breeding was with a view towards release; captive lion-breeding was not recommended in any conservation action plan, including the Biodiversity Management Plan. There was also habitat destruction in breeding camps.
Dr Marnewick also unpacked the consequences of concerns and international pressure on SA’s conservation reputation, SA’s tourism reputation and SA’s general hunting reputation. He gave a breakdown of the captive lion poaching statistics per province. After detailing the impact if captive lion ‘hunting’ was stopped, Dr Marnewick spoke to how wild lion hunts could benefit conservation by creating financial incentives to conserve lions and wildlife-based land use; increasing local tolerance of lions; and reducing retaliatory killing. True sustainable use, according to the IUCN, embraced biological sustainability, non-conservation benefit, socio-economic-cultural benefit, adaptive management, and accountable and effective governance.
In conclusion, Yolan Friedman, CEO:EWT, stated that the EWT was concerned about the increasingly dismissive response towards public sentiment which was largely against the trade, when all South Africans had the right to feel emotions for their wildlife heritage. EWT could not be selective about the use of science from a variety of different sources, especially when some scientists had different relationships with government. It needed to be a far more transparent process. EWT was increasingly worried about a trend towards closed door decision-making, and open consultative processes, after the fact. That had definitely happened in the current case. The decision to trade in lion bones had taken place in a closed-door environment. The decision around the quota had had some degree of public participation, albeit limited, but that was after the decision had been taken. EWT stood by colleagues in government who held conservation as their driving principle. EWT could not stand by decisions which threatened the very fabric of South Africa’s proud conservation heritage, as everyone had a very critical role to play going forward.
National Confederation of Hunters Associations of South Africa (CHASA)
Mr Stephen Palos, Chairperson: CHASA, presented the background to CHASA. CHASA and PHASA were the two associations that were frequently mentioned as the supportive associations of captive-lion hunting in South Africa. Referring to the profile of a hunter in South Africa, Mr Palos stated that the fact of the matter was that there were all kinds of lion hunters in the world. There was no typical hunter.
There were people in the colloquium who were rabidly anti-hunting. They were picking the low fruit of canned lion hunting. If that fell, they would move to the next low fruit, which could be something like trophy hunting. It was with that in mind that CHASA had taken the decision that that particular domino had to be supported. There were different ethics for different folks. There were members in his organization who were happy to hunt lions who they knew had been raised in captivity but at a certain bar. SAPA had set norms and standards and had raised that bar. Those hunters were happy knowing that those lions came from captive stock. It was not a God-given right, but they had paid for it.
Were they talking about an ethics war or a trade war? Maybe it was just simply a trade war. The single biggest benefactor in the International Council for Game and Wildlife Conservation (CIC) was a German national resident in Cape Town who mined in Zimbabwe and owned a major ranch there. A lion earned him $35 000 more than an elephant earned. Why was he antagonistic to the practice? It was based on ethics, or was it just bad business to have competition like that in South Africa?
A consequence of trying to appease certain people was that government would start legislating on emotion. The problem with that kind of legislation was that it would fall flat in court. One could not legislate ethics. The worst thing the country needed was a set of laws that would be overturned in the courts of law down the line. Why was one particular species treated differently to all the other species hunted in the country. That would not stand up in the Constitutional Court.
The approximately one thousand people who worked in the lion sector had a right to earn a living. How did one make legislation just because of the emotional attachment to that specific animal? Was the country going to make a specific law for that animal? South Africa was going to have to write a law that made that practice universal across all species, which would mean total devastation for all private wildlife ownership in the country, or the Department would have a piece of legislation that would be easy to knock out of court.
Ethics, fair chase and conservation were not in the same conversation. One could not legislate ethics. What was the solution? In 2015, the Minister had proposed a solution: clean up the fringe elements, work to the higher bar, support SAPA all the way to enforce their norms and standards. Let government adopt that as its norms and standards. Set the bar at a level that would not make everybody happy but would be a bar that would at least set a position for the country. Government had to find the budget to empower the Department. The officials were motivated and able but they needed to be able to build the resources they needed to police all aspects of wildlife in the country. Let the permitting system function by empowering the national Department and the provinces effectively.
Mr Palos believed that there was a solution to the problem. Enable the Minister and her Department, and enable the provinces that dealt with the problem. Lastly, almost everyone who was damaging Brand South Africa on that subject was represented in the room. Was it the practice of captive-bred lions that was damaging the conservation image of this country or was it a select few people who kept it in the public space all the time? If one looked at a lie often enough, it became the truth. If South Africa was going to stop anything, it should stop the people telling the world about South Africa’s ills in negative ways. South Africa should show the good news and kill the bad news. That was what Brand South Africa was all about.
Dr Petrus de Kock, General Manager: Brand South Africa, gave a breakdown of global reputation indicators and South Africa’s Performance on the Nation Brand Index, expanding on how South Africa ranked overall on the six pillars the National Business Initiative (NBI) in 2015, 2016, and 2017.
The damage to the national brand posed a huge risk for tourism growth in South Africa, as the world headed towards more and more responsible tourism and commercial practices. The current practice and South African legislation was unanimously criticised at an international level, and members of the colloquium had to ask themselves if that was an image they wanted for the BrandSA. It was important to discuss the possibility of changing legislation and ensuring sustainability. Was the financial revenue from the activity worth compromising the country’s reputation and position as a unique wildlife destination?
Issuing of hunting licences at provincial level needed to be done in a context of a national policy on sustainable management of South Africa’s wildlife. The most positive outcome from a reputation management point of view would be for South Africa to ban captive lion breeding, as well as that of other animals.
Dr de Kock stressed that South Africans needed to be aware that BrandSA was not only about the debate on captive lion breeding and canned hunting, but rather how the Brand should position the country much more coherently when it came to biodiversity and the legacy of biodiversity. BrandSA would be very interested in the thinking of the Committee on the matter and would like to get into a room with all the important stakeholders to wrap heads around how to build the deeper picture of South Africa’s conservation industry.
When South Africa had hosted the BRICS summit that year, BrandSA had worked in an intergovernmental space with teams from the Government Communications and Information Service (GCIS) to the Department of International Relations and Cooperation (DIRCO), etc. Apart from the captive-lion breeding question, the lesson for BrandSA had been the broader message they needed to be entrenching in the local and the international markets on the unique position of South Africa in the global conservation space.
In the final analysis, Dr de Kock suggested that BrandSA needed an answer from the leadership of the National Assembly. If one looked at some global reporting, South Africa was home to 70-80% of the world rhino population. That was a majorly important factor for the country. Somebody had referred to the growth number of species in managed environments where, for example, hunting was practiced. The ultimately reality to be faced was how to conserve what the country had and to build that resource to the benefit of society. From the perspective of managing South Africa’s reputation as a country that was a critical concern. Brand South Africa stood ready to support the work of not only the Committee, but also the private sector and people active in that space.
Mr Ross Harvey, from the South African Institute of International Affairs, thanked the presenters, especially Dr Sas-Rolfes. Firstly, had tiger farms helped, bearing in mind the conditions under which predator breeding did and did not work? It was not clear whether those conditions had or could be met by South Africa’s Predator Breeding Association. Secondly, the Lindsay Paper (2012) which had looked at the relationship between captive-lions and wild lions elsewhere in Africa, had qualified its statement quite heavily that captive lions could serve as a buffer. That qualification needed to be stated quite clearly. Thirdly, had South Africa’s wild population been doing well, separate from the existence of the captive-breeding industry? The parallel market had existed long before there had been a quota. It was not clear that the existence of the quota would do away with the existence of a parallel market, or the links to organized crime, which were particularly well-documented already.
One of the major questions, methodologically, was how one ensured accurate and reliable supply-side information. In that context, the Williams and Sas-Rolfes interim report was much more methodological than the paper by Richard York the previous day. Lastly, one of the arguments that the captive predator breeding industry cited was job creation. It was not clear that 600 jobs was at all worth defending. Even if one took half of the available space and transformed that into wildlife ranching, at least the same number of jobs could be created through alternative land use. That was a potential solution. In terms of income and jobs, it was not clear that that was an industry worth defending, given the opportunity costs. The accusation that prohibitionists did not consider the potential negative consequences was not necessarily true. There were opportunity costs and negative externalities that were considered and were the reason behind the suggestion that the quota should be reduced to zero.
Mr Deon Swart, from SAPA, explained that if one searched Google one would find, among others, Sable Antelope being advertised according to size because a client determined the type of animal he wanted to hunt. The animal was then offloaded on the farm and hunted. That was the industry, every day. Sometimes those animals were offloaded and shot the next day. But if it was not a lion, it was fine. Furthermore, people had bought farms and hunted lions on them, and those farms had expanded. If you look at the State of the Environment Report, all game farms were rated as conservation areas, which meant that the biodiversity index was an indicator of how well it was managed. That was indirectly linked to conservation. When high value species were farmed, there was more money to buy more land. The index at the end of the day went up because the goats were sold and wildlife was farmed. There was a direct conservation impact from the money that was made from lions.
Dr Pinnock asked Dr Sas-Rolfes whether the Scientific Authority report supported DEA’s increase in lion-bone quota from 800 to 1500 carcasses per annum? He asked Riaan De Lange of the MTPA, when doubt had been raised about the identity of the lion that was hunted in Umbabat Private Nature Reserve. Why had an independent viewing of the carcass and skeleton refused? That refusal had spiralled into huge international reputational damage.
A representative from the South African Veterinary Council voiced his appreciation of the day’s occasion. The energy or ‘creative abrasion’ could be used positively. He asked DEA if there was a guiding document that was being looked at or worked on regarding animal welfare. Was DAFF involved? DAFF had an animal welfare policy document. Was DEA involved in that? How old was the average a hunter currently? He asked in light of the recent study which had found that future generations would outnumber the millennials? By 2019, the average age of the population of the world would be less than 40 years. Lastly, SANParks had made reference to nutrition with regards to the five freedoms. There was a conflation of the nutrition of wild animals in captivity, which had to be provided for, and those in the wild, where animals have to fend for themselves that led to confusion. The South African Veterinary Council was forming a National Animal Welfare Forum. All those involved in the animal welfare arena should contact the Council for the way forward.
Mr Kirsten responded that it was untrue that captive-bred lions had zero contribution to make to conservation. SAPA was conducting a study, which was in its second year, and which established the conservation value of captive-bred lions. SAPA would, with the DEA, deal with the rogue elements that were not within the control of SAPA and see how it could take things forward. South Africans were resilient people, and there was no challenge that the country could not overcome. South Africa had managed to find a settlement without bloodshed and to host a very successful World Cup, contrary to speculation.
A journalist from International Publications thanked the Chair for his statements about the media. The media in South Africa worked under very difficult conditions and was very badly paid in general, and worked under terrible time constraints. Over and over again, the media was lambasted for getting things wrong. More often than not, when approaching a government department like DEA, DAFF and SANParks for comment or response, there was absolutely no response, or there was obfuscation. If the people in the room wanted the correct information out there in the public, he asked that they communicated a lot better with journalists who approached them for comment. More often than not, journalists hit an absolute blank wall.
An audience member from the NGO sector stressed that all the NGOs’ books had been transparent. If anyone wants to view them, they could be contacted. The agreement signed between the APNR and the KNP in 1996 needed to be reviewed. Would discussion on the revision of that cooperative agreement be open to all stakeholders? Mr Sas-Rolfes’ survey had been conducted online. How had he ensured the integrity of the data? It was said that there was evidence that captive lion-breeding did not harm wild populations. Could the gathering have sight of that evidence? If there was no negative impact, was there a positive impact to the wildlife population from a conservation perspective?
Mr Don Scott, from the Timbavati Private Nature Reserve, stated that, given the title of the colloquium, it was confusing that the subject of trophy hunting was on the agenda of the Committee meeting as it seemed to mix the concerns of captive-predator breeding with the hunting of wild predators.
Furthermore, in Dr Pinnock’s address, he had made three allegations in his address that had previously been published in the media. All three allegations had been answered in the media in a statement by Timbavati Private Nature Reserve. Why had those allegations once again been rehashed as fact in the Committee Meeting when they had been responded to? Timbavati Private Nature Reserve had specifically responded to those allegations so that it would not have to face talking about those issues in a Committee meeting that day. At no stage, despite the statements in the media against Timbavati, had any journalists actually contacted any member of Timbavati. Mr Scott invited Dr Pinnock to visit Timbavati so that he could show him what the Private Nature Reserve was doing so that his perceptions on its governance matters could be corrected.
The Chairperson, in response to Mr Don Scott’s confusion around the title of the colloquium, stated that the Committee had thought that trophy hunting needed to be included and dealt with by SANParks because it also included an escaped lion from Kruger Park that had been hunted. The Committee could itemise anything which, in its view, was relevant because it was the Committee’s agenda and programme. The Committee did want to interrogate that question. The colloquium should not end on a level of defensiveness as to why the item had been put on the agenda. The Kruger National Park had been asked to respond in detail to the issues that had been raised by Dr Pinnock. The duty of the Committee was to ask very robust questions to get responses.
A representative from Four Paws asked the DEA whether or not it understood the product that it had agreed to sell to outside markets. Why was the country selling it and who were the consumers behind it? In looking after lions that come from terrible conditions, including from lion-breeding, one of the interesting factors was that the health of most of these animals was compromised; their ability to behave as animals in a rational way was compromised, and many bones deficiencies were present. How was South Africa supplying a bone product to a market when those bones were compromised by arthritis and other deficiencies? How did an arthritic bone cure somebody from arthritis?
Endangered Wildlife Trust: CEO, Ms Yolan Friedman asked what consultation was held with the neighbouring countries concerning the decision by South Africa in view of the CITES Conference? Everyone spoke of an ‘African’ Lion, which also belonged to many other African countries. In any engagement on a multilateral environmental agreement, it was a good political practise to engage with your neighbouring countries as a bloc and consider their approaches to the trade in lion bones and canned trophies. She been told that none had been held.
Ms Louise De Waal, #HandsOffOurWildlife campaign, referred to a letter of 6 February 2018, that SANParks had addressed to Timbavati and Umbabat for offtake requests. Given the number of irregularities and requests for clarifications expressed in both letters, SANParks had not recommended the offtake based on the fact that both NPRs were not able to show towards which conservation management and socio-economic benefits the hunting revenue generated was being directed. As was mentioned by SANParks, the socio-economic benefits are a major focus. How was it possible that the MPTA completely ignored SANParks’ recommendations in terms of issuing a hunting permit? Did that not show weaknesses in the processes and systems of managing an open system?
A woman speaking on behalf of 29 organizations and 140 000 citizens who signed a petition to be given to the Committee, SANParks and the representative from Umbabat said that the petition asked the authorities to give answers after a transparent investigation. An email has been sent several times. SANParks had replied, saying that it was not their competence. The private reserves needed to tell them if group 13 was in Limpopo or Mpumalanga.
Dr Michael Sas-Rolfes responded to the question of whether tiger farms had helped. It was not a fair question. Legal trade in tiger bone or medicine had been banned since 1993. Even though there were tiger bone plants in China, they could not legally trade. Therefore, it was not possible to say whether tiger farms had helped. Ten years previously when China made the decision to reopen the market, there had been a proliferation of farms in neighbouring countries under quasi-legal conditions. Since that had happened, India’s tiger populations were recovering. There were routine seizures of tiger bones in East Asia and a lot of them are farmed animals. They did not seem to have hurt but there was no legal trade so it could not be assessed in that way. The Lindsay report of 2012 had caveats. It was a very good paper but it did call for more research and that was what his organization was trying to do. He asked Mr Harvey to restate the question regarding the parallel market.
Mr Harvey asked whether the conservation success of South Africa’s wild lions could be incidental to the existence of the predator-breeding industry?
Dr Sas-Rolfes responded that it could be incidental but the point was that conservation was not being harmed. There was no evidence of large scale commercial poaching. There might be a buffer effect that would only be discovered once the legal supply was removed. As for illegal parallel markets, there was very little evidence that they existed. The paws and skull poaching that was taking place was an interesting phenomenon. It was not certain whether they were going to the local muti market. Furthermore, the interim report did not make any recommendations regarding quotas. It had not been asked to do so, but to provide information. The information could have been in support of an increased quota. It indicated that the previous year’s quota had been a constriction and it had failed to recognise what had happened in 2016 and that stockpiles were building up. How the DEA interpreted that information was for the DEA to say. Concerning the integrity of the data, Vivien Williams would be better placed to answer that question because she had taken the lead in the survey. The data, however, had been through research ethics clearance. It was pre-tested. In some instances go-betweens were necessary for face-to-face studies. Having looked at the information, there was no reason to believe that the information was compromised in any way.
The Chairperson thanked Dr Sas-Rolfes for the clarification on the interim report because the impression that had been created was that the report had been used as the basis for increasing the quota.
Dr Sas-Rolfes added that the report was not the only source of information available to the DEA. There were two other peer-reviewed papers and other information. It was one of multiple inputs. It had been stressed that the sample had not been large enough and that it was not to enter the public domain before completion.
Mr Mketeni supported an investigation into the matter. He had difficulties answering some of the questions, such as whether the lion had been traversing between Umbabat and the KNP, and how old the lion had been. It is not possible to answer these questions. In a nutshell, it is better to support an investigation. Furthermore, was it possible to work out a response to Dr Pinnoch’s paper, especially by way of an investigation?
The Chairperson reminded the Committee that it had been agreed that SANParks would give a formal response to Dr Pinnoch’s paper. Some of the issues for which SANParks had answers would be addressed. The Committee would decide how to proceed once it had received a detailed response.
Mr Shonisani Munzhedzi explained that DEA had received a variety of requests, most of them that morning. The team did its best under the circumstances. The issue of cultural and religious beliefs and how people decided what to take or not to take in the demand and supply aspects, that space had its many concerns and, hence, the many studies DEA had commissioned. It was not fair to question cultural or religious practises. Generally, CITES was different from other conventions. CITES also worked by voting. In terms of implementation, some decisions could be negative to conservation. That was why South Africa stressed that all decisions should be science-based. When South Africa was at CITES, the biggest issue was not about votes. The biggest concern was up-listing lion to Appendix 1. When South Africa hosted a summit, DEA chaired the meeting. There were certain dynamics for different countries that would come out. In as much as there was a collective approach to certain things with other African countries, there was allowance for a common but differentiated approach. Lastly, on the welfare aspect, DEA was more than happy to check.
Dr Pinnock stated that the MPTA should really answer the question as to why they had not allowed the skin of the hunted lion to be viewed independently.
Mr Riaan explained that, under the Game Theft Act, once an individual shoots an animal legally or illegally, he/she takes ownership of the animal. What happened was that the skin was transported to the taxidermist. There were a number of requests to have the skin viewed but the client had indicated that he did not want the skin viewed.
The Chairperson said that the response was not satisfactory. The response to that question could be part of SANParks’ written response.
Mr Riaan De Lange added that the EMS Foundation’s request has been received and a response was being compiled. The due date for the request was the 24 September 2018.
The Chairperson stressed, however, that the Committee would like a formal response.
Mr Mketeni asked if the MPTA could process their response separately from SANParks.
The Chairperson said that they could both do so via the DEA.
The Chairperson thanked all the stakeholders for the very fruitful engagement. The Committee would receive a report from the Committee Content Advisor and the Secretariat. The Portfolio Committee would deliberate over the report and make it public. The report would be made available on the Announcements, Tablings and Committee report of Parliament with a brief statement of what the PC recommends. What is quite clear is that this matter is firmly on the agenda. The Committee would ensure that the recommendations that arose out of the process were implemented to the letter.
The meeting was adjourned.