Stephanie Klarmann – Page 2

Submission on the Draft Game Meat Strategy

Submission on the draft Game Meat Strategy

The draft White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity has been welcomed by many professionals in different sectors, as it represents a paradigm shift away from outdated policies and models, towards more modern approaches to the conservation of biodiversity, while adopting One Health and One Welfare principles in the management of our wildlife, as well as principles of Ubuntu.

The draft Game Meat Strategy for South Africa has however come as a complete surprise, as its vision is purely to intensify, commercialise, formalise and transform the game meat industry in South Africa to contribute to food security and sustainable socio-economic growth, without giving due consideration to the progressive draft White Paper principles. This is particularly apparent with regard to the following issues so clearly highlighted in the Draft White Paper which:

recognises that all wild animals are sentient, have intrinsic value, should be treated humanely, have their well-being secured, and have the right of respect;
defines well-being as the holistic circumstances and conditions of an animal which are conducive to its physical, physiological and mental health and quality of life, including its ability to cope with its environment;
identifies the need to protect wild animals in the wild and to expand protected areas;
understands the need to reverse the domestication of wild animals, which it refers to as a “poor practice that erodes the sense of wildness and the cultural heritage and stewardship for the environment”;
aligns with Section 24 of the Constitution with regard to the promotion of ecologically sustainable use, and the protection and conservation of our biodiversity;
defines Ubuntu as being built upon compassionate, respectful, and interdependent relationships, and that the very essence of Ubuntu hinges on consolidating the human, natural and spiritual tripartite;
states the need to prevent, where possible, or minimise risk of the animal-human transmission and further evolution of zoonotic diseases associated with wild animals;
confirms the importance of maintaining South Africa’s conservation reputation;
recognises the need for an improved and updated permitting system, as well as the monitoring and enforcement of legal compliance with regard to our wildlife industry.

In contrast, the Draft Game Meat Strategy:

disregards the rights of animals, and depicts wildlife purely as commodities, simply to be utilised as resources of commercial value;
fails to recognise that wild animals are sentient and therefore the need to protect their welfare and well-being. For example, Strategic Objective 1 refers to developing Industry Standards for Game Meat to ensure product safety and quality; and Strategic Objective 7 refers to skills development to ensure meat integrity, safety and quality, but neither include the welfare and well-being challenges of the wild animals involved;
does not acknowledge the need for comprehensive industry norms and standards that fully incorporate ALL aspects of the value chain, including the welfare and well-being of the wild animals and their quality of life and death, i.e. the breeding, keeping and slaughter;
promotes the intensification of farming wild animals, which inevitably leads to domestication. This is in direct conflict with Policy Objective 3.7 in the draft White Paper identifying the need to reverse the domestication of wild animals;
promotes the intensification of the game meat industry without due consideration to Goal 3 (Biodiversity Conservation Promoted) of the draft White Paper and, in particular, Objective 3.9 which acknowledges the risks associated with zoonosis, and the need to minimise them;
promotes the farming of wild species for commercial use, but does not define which species are included in the term “game species”; whether they are captive, ranched, wild/free-roaming; intensively and/or selectively bred (e.g. colour variants); or whether the animals are indigenous and/or exotic;
none of the guiding principles in the Game Meat Strategy speak of securing biodiversity and/or expanding protected areas through growing the game meat market, as would be expected of a DFFE led document. It only speaks of economic development, job creation and transformation, which are no doubt important issues to consider but are not the sole mandate of DFFE. Even the Game Meat Strategy’s vision (i.e., a formalised, thriving and transformed game meat industry in South Africa that contributes to food security and sustainable socio-economic growth) is one-dimensional. As such, this document is an agricultural strategy that belongs under DALRRD;
endorses Ubuntu in respect of the need to create improved livelihoods, but fails to incorporate the need for respectful co-existence and harmonious relationships with our wildlife and its environment;
fails to adequately address solutions for the monitoring and enforcement of industry compliance with existing legislation and regulations;
does not satisfactorily explore or promote alternative income streams besides game meat.

Furthermore it should be noted that:

The draft Game Meat Strategy fails to take into account the evidence brought forward by the Scientific Authority’s Intensive and Selective Breeding report^[1] which concludes that intensive management and selective breeding of game poses a number of significant risks to biodiversity at landscape, ecosystem and species levels, as well as to other sectors of the biodiversity economy of South Africa, and may compromise the current and future contribution of the wildlife industry to biodiversity conservation.

Key biodiversity risks identified on an ecosystem and species level include:

The killing of predators and other conflict species may result in a reduction in population numbers, which in turn may lead to a change in the conservation status of the species and thereby furthering the extinction risk.

Key biodiversity risks identified on an ecosystem level include:

Fragmentation of the landscape through impermeable fencing restricts movement of free-ranging species and reduces habitat quality and quantity;
Concentration of species in small areas with impermeable fences for intensive breeding purposes results in habitat degradation within such areas;
The removal of predators will at a certain scale disrupt predation as a natural process in the broader landscape/environment thereby affecting ecosystem functioning.

Key biodiversity risks identified at species level include:

Loss of genetic diversity resulting in decreased fitness and reduced adaptive potential;
Domestication of wild species resulting in a loss of their natural ability to adapt to wild conditions;
Changes in natural genetic composition, evolutionary trajectory and adaptive potential of wild populations through the introgression of captive population genetics wherein genetic changes in the captive population may lead to an altering genetic composition and/or evolutionary trajectory and/or adaptive potential of wild populations through deliberate and accidental introductions.
The draft Game Meat Strategy promotes marginal lands as being better suited to wild species, but whether we intensively farm domestic cattle and sheep or domesticated antelope and buffalo, the impacts on the environment and the potential for habitat degradation will remain the same. We understand that Government wishes to reduce poverty, create food security and advance the rights of communities by growing the game meat industry, however this should not be at the detriment of the environment, biodiversity and/or the well-being of individual wild animals.
The intensive breeding of animals, whether domestic or wild animals, has far reaching impacts on the environment, particularly with regard to greenhouse gas emissions. Hence, the strategy does not seem to align with United Nations Sustainable Development Goal 13 (take urgent action to combat climate change and its impacts), as well as the Paris Agreement on climate change that was signed at COP21.

We believe the above aspects are of serious concern and we trust that these contradictory stances are rectified in the final Game Meat Strategy document.

Yours sincerely,

Dr Louise de Waal

Campaign Manager and Director

Comments on the Draft Notice Prohibiting Certain Activities Involving African Lion (Panthera leo)

The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Ms Magdel Boshoff
Private Bag X447
Pretoria 0001

Delivered by email to: revisedlionprohibition@dffe.gov.za

19 November 2024

Comments on the Draft Notice Prohibiting Certain Activities Involving African Lion (Panthera leo)

Dear Ms Boshoff,

Thank you for the opportunity to comment on the Draft Notice prohibiting certain activities involving African lion (Panthera leo), gazetted under notice 51581.

We are in full support of the Minister’s decision to implement appropriate and necessary measures to avoid the establishment of new captive lion facilities whilst the voluntary exit process is underway and legislation under consideration to phase out the commercial captive lion industry in South Africa.

Blood Lions is in full support of the following issues:

With regards to captive lions, we fully support the initiative to prohibit the establishment and registration of any new breeding, exhibition or rehabilitation facility or any other type of captive lion facility. This initiative is a positive step towards preventing any further growth of the captive lion industry.
We support the inclusion of ecological reasons to stop the domestication of lions and move towards a future in which South Africa holds no lions in captivity. As outlined in the prohibition notice, apex predators have complex needs, including social organisation, diverse diet, hunting behaviour, and territorial nature, that are central to their overall welfare and well-being. These complex needs are best provided for in natural environments and functioning, self-sustaining ecosystems.

The recognition that controlled environments cannot adequately account for the complex needs of these apex predators is an important and necessary step towards phasing out the commercial captive lion industry. It demonstrates the Minister’s progressive recognition of in-situ biodiversity conservation, animal well-being and the need to restore South Africa’s reputation as a leader in the conservation of wildlife and as a responsible tourism destination with iconic wild lions.

Blood Lions have concerns with regards to the following issues:

The exclusion to establish and register a new sanctuary. Even though the proviso has been made that the Minister should determine that such a new sanctuary is necessary to accommodate sterilised captive lions arising from the voluntary exit process, we feel that this exclusion can be used as a loophole.

Any commercial captive lion facility could potentially register their commercial captive lion facility as a sanctuary, especially since permits are issued on a provincial rather than national basis and the TOPS definition of sanctuary is too ambiguous:

A sanctuary means “a facility that provides permanent care to a specimen of a listed threatened or protected species that would be unable to sustain itself if released in an environment other than a controlled environment, irrespective of the reason for such inability”. This definition specifies neither conditions to guarantee the welfare and well-being of the wild captive animals in such a controlled environment, nor in terms of breeding and/or trading practices.

If the Minister wants to leave the opportunity open for the establishment of sanctuaries that can accommodate some of the surrendered lions coming out of the voluntary exit process and/or the future prohibition, such facilities should be identified solely as being run under internationally recognised best practices that allow for the welfare and well-being of these apex predators to be guaranteed, as outlined in the various protocols developed by the Ministerial Task Team.

Currently, numerous commercial captive lion facilities in South Africa have already included the word ‘sanctuary’ within their business name to create the impression that their facility/predator park rescues and/or rehabilitates wildlife, rather than having vested interests in commercial activities. We are concerned that such a loophole may encourage this practice to expand, which would not only deceive the public but also allow commercial activities to continue under the guise of a sanctuary label, and thus leaving the system wide open for abuse.

2. Our second concern relates to the omission of prohibiting captive breeding of lions at existing commercial facilities. The continuation of captive breeding perpetuates the growth of the captive lion population and the associated animal welfare and well-being implications. This will in turn hamper the phase out process by increasing the number of captive lions that may require veterinary care, sterilisation, potential euthanasia, and/or lion safe haven space.

It is therefore critical that a moratorium on captive breeding of lions is implemented as soon as possible to expedite not only the voluntary exit but also the ultimate closure of the commercial captive lion industry.

PRESS RELEASE: “You’re Killing Them Softly” Mural For World Lion Day

NEWS RELEASE
“You’re Killing Them Softly” Mural For World Lion Day

For Immediate Release

“You’re killing them softly” is an impactful message released for World Lion Day (10 August) by South African NGOs campaigning to bring an end to the commercial captive lion industry in South Africa. To extend awareness beyond World Lion Day, we are excited to announce the release of a striking mural by graffiti artist Giffy on the Durban Promenade.

The mural continues to bring awareness to the fact that any visitor or volunteer paying to play, bottle feed, and/or hand-raise captive-bred predator cubs, use them as photo props, or merely visit predator parks, are fuelling South Africa’s cruel commercial captive predator industry.

“Blood Lions decided to translate the “You’re Killing them Softly” message into a powerful mural by graffiti artist Giffy on the Durban Promenade. We want the public to be fully aware that their actions fuel this unethical industry that is responsible for the brutal death of 1,000s captive-bred lions and many other predator species”, says Dr Louise de Waal (Director, Blood Lions).

Giffy is a Durban street artist, who takes his inspiration from his local environment. He is known for his colourful and life-like wildlife murals in predominantly Durban’s public spaces, not only bringing our South African natural beauty to life but also encouraging people to be more involved in wildlife conservation efforts.

“This is not the first time that Giffy has raised his artistic voice for the Blood Lions cause, to bring an end to the captive lion industry in South Africa. In 2020, he created a poignant mural for the then 800 Voices for 800 Lions campaign”, says de Waal.

In South Africa, lions and many other predators are bred solely for commercial purposes, such as cub petting, walking with predators, voluntourism, “canned” or captive trophy hunting, the live trade, and the trade in their bones, parts and derivatives.

Each time we choose to visit a predator park or engage in interactive activities with lions or other predators, we are perpetuating captivity. Our actions and choices are killing them softly.

– END –

World Lion Day 2024 video and campaign information: check HERE

For more information contact Dr Stephanie Klarmann:

Email: info@bloodlions.org

Phone: (+27) 082 304 8447

Short history of the commercial captive lion industry in South Africa

The commercial captive lion industry in South Africa started in the 1990s and has been allowed to grow unimpeded.
In 2015, the award-winning Blood Lions Documentary premiered, blowing the lid off misleading claims made by the predator breeding and canned hunting industries in South Africa.
Lions and many other indigenous and exotic large felids are bred in captivity for commercial purposes, such as cub petting, walking with lions, voluntourism, “canned” or captive hunting and for their bones, parts and derivatives for the domestic and international traditional medicinal use, predominantly for their bones in Chinese Traditional Medicine until 2019.
In August 2018, the Parliamentary Portfolio Committee for Environmental Affairs convened a Colloquium on “Captive lion breeding for hunting in South Africa; harming or promoting the conservation image of the country”. The recommendations of the Colloquium were adopted by the national assembly on December 6, 2018, including that “the Department of Environmental Affairs should as a matter of urgency initiate a policy and legislative review of captive breeding of lions for hunting and lion bone trade with a view to putting an end to this practice”.
In August 2019, a High Court judge ruled that the setting of the bone quota in 2017 and 2018 of 800 per year was “unlawful and constitutionally invalid” and that consideration should have been given to welfare issues relating to lions in captivity when determining such quota. Since this ruling, the DFFE has deferred the setting of a CITES lion bone export quota.
In 2019, the Minister of DFFE appointed a High-Level Panel (HLP) of experts to review policies, legislation, and practices on matters of elephant, lion, leopard and rhinoceros management, breeding, hunting, trade and handling. The majority recommendations in terms of captive lions included that South Africa would not breed lions in captivity, keep lions in captivity, or use captive lions or their derivatives commercially.
These recommendations were adopted by Cabinet and on May 2, 2021, Minister Creecy announced that the Department will be adopting the majority recommendations on these issues.
In 2023, a Ministerial Task Team (MTT) was appointed by Minister Creecy to identify and recommend voluntary exit options and pathways for the captive lion industry. Their recommendations were approved by Cabinet in March 2024 and their final report published. One of their key recommendations was that voluntary exit should only be the first step in the longer-term government objectives of ultimately closing the commercial captive lion industry in South Africa.

To view more details about the progress we have made, click here.

PRESS RELEASE: World Lion Day

South African NGOs launch awareness campaign ahead of World Lion Day calling for an end to the commercial captive lion industry in South Africa.

“You’re killing them softly” ― a powerful message released for World Lion Day (10 August) by South African NGOs campaigning to bring an expedient end to the commercial captive lion industry in South Africa, a significant move pledged by the South Africa government in 2021.

The “You’re killing them softly” campaign brings awareness to the fact that any visitor or volunteer paying to play, bottle feed, and/or hand-raise captive-bred predator cubs, use them as photo props, or merely visit predator parks, is fuelling South Africa’s cruel commercial captive predator breeding – and killing – industry.

National and international animal welfare and conservation organisations – Blood Lions, FOUR PAWS South Africa, Humane Society International/Africa, and Voice4Lions – have come together as one unified voice this World Lion Day.

“However well-intentioned people’s actions are, these cubs are not orphans, they have no conservation value, they are purely bred to feed an unethical and insidious industry that commodifies these predators,” the group states.

Lions and many other predators are bred solely for commercial purposes, such as cub petting, walking with predators, voluntourism, “canned” or captive trophy hunting, the live trade, and trade in their bones, parts and derivatives.

The dignity of our iconic species has been replaced by the commodification of captive lions and other predators at every stage of their lives. Currently, at least 8,000 lions and thousands of other big cats, including many tigers and cheetahs, are bred and kept at approximately 350 lion farms in South Africa.

World Lion Day 2024 comes at a significant time for South Africans as we have entered a new Government of National Unity. Across the world, the public and NGOs are appealing to governments to consider the importance of environmental issues in their policies and legislation.

The commercial captive lion industry is one such pressing issue that has garnered substantial attention, leading to a Parliamentary Colloquium in 2018, the formation of the High-Level Panel and subsequent Ministerial Task Team under ex-Minister Barbara Creecy’s leadership. This process led to the commitment of the government to take steps to ultimately close South Africa’s commercial captive lion industry.

“We acknowledge the significant progress achieved and marked by the recently approved report of the Ministerial Task Team on voluntary exit options and the policy position on the conservation of elephants, lions, leopards, and rhinoceroses in South Africa. However, we urge the Department of Forestry, Fisheries, and the Environment (DFFE) to publish a detailed implementation plan with time-bound goals,” the coalition of NGOs say.

“There is hope to end this cruel and rampant industry and we commend the Cabinet for their commitment. This move will ensure that these majestic animals are no longer bred to suffer for profit. However, we urge the government to ensure the well-being of other predators by extending the ban to all captive big cats and prohibit their ownership as pets and playthings.”

Together, Blood Lions, FOUR PAWS South Africa, Humane Society International/Africa, and Voice4Lions continue to raise vital awareness amongst the public that we are all capable of pushing for meaningful change and ending the exploitation of one of South Africa’s most iconic species.

The public can make their voices heard by signing the Big Cats SA petition to help urge the DFFE to introduce legislation that prohibits keeping tigers, lions, other big cat species and predators as pets. This legislation should include banning public contact with all big cat species and predators, not just lions, including keeping such species for promotional, educational or entertainment purposes, and interactive experiences like cub petting and walking with big cats. Sign hsi.org/bigcatssa.

Remember, our actions and choices have far-reaching consequences. Let us all work together on World Lion Day to end harmful captive breeding industries and to stop killing them softly.

– END –

World Lion Day 2024 video available HERE

For campaign images check HERE

For more information contact Dr Louise de Waal:

Email: management@bloodlions.org

Phone: (+27) 076 148 1533

Comments on the Draft National Environmental Management: Biodiversity Bill (Gazette no 2024)

The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Ms Magdel Boshoff
Private Bag X447
Pretoria 0001

Delivered by email to: biodiversitybill@dffe.gov.za

25^th July 2024

Comments on the Draft National Environmental Management: Biodiversity Bill (Gazette no 2024)

Dear Magdel Boshoff,

Thank you for the opportunity to comment on the Draft National Environmental Management: Biodiversity Bill Kindly find below our comments including areas of support, concerns, and missed opportunities for development.

Yours sincerely,

Dr Louise de Waal

Blood Lions | Director and Campaign Manager

Comments on the Draft National Environmental Management: Biodiversity Bill

Introduction

We fully support the explicit inclusion of both a duty of care towards biodiversity and consideration for the well-being of wild animals. We believe this is a positive and innovative approach to the conservation of biodiversity and will place South Africa as a progressive example of conservation. Furthermore, we are encouraged by the Department’s goal to address historical imbalances and achieve greater equity in the biodiversity sector and to address the need for greater regulation in the legal and illegal trade of species.

However, we believe it is necessary to note that the new Bill does not provide improved clarity compared to the current National Environmental Management Biodiversity Act 10 of 2004 (NEMBA). For this reason, there is significant scope to revise the Bill and strengthen legislation. Specifically, it would be beneficial to see a shift towards terminology incorporating ‘ecologically sustainable use’ as opposed to ‘sustainable use’ in order to give effect to Section 24 of the Constitution.

Areas of support

We appreciate the inclusion of a duty of care towards biodiversity, including a recognition of animal well-being, sentience, and how these closely link to human well-being as well as nature’s cultural and spiritual significance for many South African cultures. We strongly believe that South Africa’s diversity is reflected in both the people and our natural heritage.
We support Sections 41 and 42 in which necessary management of non-listed species may be undertaken by the Minister. However, we do feel it is important to define ‘management’ for improved clarity.
We support the development of Part 2 Scientific Authority and Part 3 Trade in Species which introduces regulations related to both legal and illegal wildlife trade.

Areas of concern

We feel the legal framework and permitting system is unnecessarily complex and we are concerned that members of the public would find it difficult to access and navigate these spaces with confidence and accuracy, which could lead to needless non-compliance.
Furthermore, permit obligations are unclear and as a result are unlikely to enhance compliance where permit applicants may be unsure of their obligations.
Rather than focusing on penalties for non-compliance, we feel there is a need to consider stronger incentives for compliance, which may avoid the need for stronger penalties as a way forward to protect biodiversity.
We are concerned that the definition of biodiversity does not extend the concept of ‘duty of care’ towards individual animals. The definition may be remedied and expanded by including ‘specimen’ in addition to ‘genetics, species, ecosystems’ to ensure a more encompassing definition.
The removal of the duty of care related to alien and invasive species in Chapter 6 is problematic. We believe in this instance that a general duty of care towards biodiversity ought to be included in the Bill.
It is unclear if section 61(d) refers to permits for exotic pets and livestock. Greater clarity is required.

Missed opportunities for development

We believe there is a missed opportunity for this Bill to address and resolve the conflicts inherent in the 9+1, concurrent national and provincial legislation for environmental matters. As we all know, this concurrence creates a challenging legislative landscape in which legislation is fragmented, complex, and lacking in harmony. The Biodiversity Bill ought to address this fragmentation and resolve the conflicts evident in the 9+1 concurrent legislation.
We noted with concern the absence of target setting in the Biodiversity Bill.

Comments on the Draft National Biodiversity Economy Strategy

The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Mr Khorommbi Matibe
Private Bag X447
Pretoria 0001

Delivered by email to: nbes@dffe.gov.za

5^th April 2024

Comments on the Draft National Biodiversity Economy Strategy

Dear Mr Matibe,

Thank you for the opportunity to comment on the Draft National Biodiversity Strategy (NBES), gazetted under notice 50279.

We recognise that this draft NBES has the potential to build upon some of the groundwork laid by the White Paper on Conservation and Sustainable Use of South Africa ‘s Biodiversity. As such, if developed appropriately it could play a vital and positive step towards improved protection of South Africa’s rich biodiversity heritage and its international reputation as a global leader in conservation and ecotourism.

We commend some of the ambitious goals therein and acknowledge reference to promotion of the Kunming-Montreal Global Diversity Framework. We commend Goal 1 that leverages biodiversity-based features to scale inclusive ecotourism industry growth in seascapes and sustainable conservation land-use.

However, we are concerned that the draft NBES involves aspects that seek to aggressively expand the consumptive use of wildlife without giving due consideration to the principles of international and national policy commitments. In particular considering that the HLP report called to reverse the domestication of species such as lion and rhino and the Policy Position Paper on the Conservation and Ecologically Sustainable use of Elephant, Lion, Leopard and Rhinoceros Objective 1 is to close the commercial captive lion industry.

Goal 2 of the draft NBES and its aggressive expansion of the consumptive use of game from extensive wildlife systems to drive transformation and expand sustainable conservation compatible land-use, is problematic. This goal aims to increase the contribution to South Africa’s GDP from the consumptive use of game from extensive wildlife systems from ZAR 4.6 billion in 2020 to R27.6 billion by 2036, which requires a substantial 5.7% year-on-year growth. Even if the animal welfare and zoonotic disease risks of this type of endeavour are set aside, aggressively expanding the game meat industry from extensive wildlife systems would require a substantial growth in capacity of the regulatory bodies. Currently, the provincial nature conservation authorities regulate the wildlife industry and are already seriously under-resourced. With the recently added NEMBA clause on animal well-being, the DFFE in concurrence with the provincial authorities now have the additional responsibility to ensure the well-being of the individual animals involved in the wildlife industry.

Even though we don’t believe that this aggressive promotion and expansion of commercial consumptive use of wildlife is the right way to go for South Africa, there are also issues of animal welfare and well-being to consider that are not adequately covered in this NBES. The DFFE animal well-being mandate should require the development of strict Norms & Standards (N&S) for the breeding, keeping, transport and slaughter of any wild animal species involved in this purportedly rapidly expanding industry, whereas we currently don’t even have N&S for iconic species like lions. We acknowledge that these requirements are partly covered in Action 7.2, “develop and implement mechanisms and tools to improve duty of care, animal well-being and ethical and effective practices, with the inclusion of voluntary wildlife standards”. We strongly believe that voluntary standards are wholly inappropriate and ineffective and may lead to conflicts of interest, a lack of uniformity in standards across the industry, and a lack of incentives for compliance. Compliance monitoring should remain in the hands of an external body and therefore the current Environmental Monitoring Inspectorate should be significantly and meaningfully expanded and provided with additional authority to include animal well-being. The latter will require intensive training on animal well-being and collaboration with animal welfare organisations, such as the NSPCA, who exercise their statutory duty under severe capacity constraints due to the lack of state financial support. Furthermore, new entrants into this industry may not have any prior expertise in the keeping of wild animal species, which can potentially lead to animal welfare and well-being issues and, in turn, impact South Africa’s reputation as a leader in conservation, as has happened with the commercial captive lion industry.

In addition, Goal 2 speaks of a substantial increase in wild “fair chase” trophy hunting at a time when hunting tourism is becoming less economically viable due to negative public perceptions and declining wildlife populations. More and more countries are implementing importation bans on hunting trophies and approximately 45 airlines are no longer willing to carry hunting trophies. A ban on importing hunting trophies from threatened species into the UK, for example, is highly likely to become law in the near future following Government backing in March 2024. International sentiment demonstrates a growing aversion for trophy hunting, which may again impact on South Africa’s reputation as a wildlife and ecotourism destination.

Action 10.4: to “Develop and implement a strategy for a market for regulated domestic trade in high-end parts and derivatives (e.g., rhino horn and elephant ivory) for local value-add enterprises based on processing and use of products” is also of serious concern. Concerningly, this action is further annotated in the draft NBES as follows: “Innovative approaches are needed to identify products and develop the necessary local markets. For example, health clinics to administer traditional remedies using rhino horn for health tourists from the far East, or ivory carving being done locally for local sale and export for personal use”.

There is no mention where the rhino horn and elephant ivory would be sourced from. Would this be from private and/or governmental stockpiles? Would this be from de-horning programmes? How would the DFFE/provincial authorities be able to distinguish between legally and illegally (poached) sourced products? It seems senseless to invest a significant amount of capital and resources on anti-poaching measures and de-horning programmes, to subsequently allow communities to create a commercial trade in the by-products. This sends a message out to communities that these products don’t just have value internationally but also domestically, which can in turn further increase the poaching of these TOPS species. Action 10.4 is highly likely to ultimately negatively impact on South Africa’s conservation and eco-tourism reputation, as it did with the trade in lion bones, parts and derivatives. In particular since the “local value add would need to be developed to such an extent that the sale of derived products can generate sufficient funds”.

Furthermore, it seems farcical to identify products using rhino horn and contemplate developing health clinics to administer such traditional remedies for health tourists from Southeast Asia that are not part of South Africa’s traditional health practitioner remedies and are not grounded in scientific evidence.

In relation to this action and as stated in the draft NBES, the international commercial trade in rhino horn and elephant ivory is currently restricted by CITES. Therefore, whilst South Africa could work towards submitting a proposal, this would seriously risk undermining international and national efforts to protect threatened or protected species and curb illegal wildlife trade globally – in particular, stimulating unsustainable consumer demand and providing a legal cover for poaching.

In addition, it would fail to recognise the seismic shifts being contemplated in attitude and behaviour elsewhere, for example, the growing evidence of increased interest and desire by consumers and traditional health practitioners in China to shift away from wildlife-based Traditional Asian Medicine and instead seek to promote more humane and sustainable herbal alternatives that do not carry the same animal welfare and zoonotic disease risks.

Such a large shift in policy direction would stand in contradiction to more detailed and engaged processes that have examined the impacts of this type of domestic and international trade of other South African wildlife. For example, it stands in opposition to the High-Level Panel report and subsequent Policy Position Paper, which concluded that the international commercial trade in lion bones has a negative impact on South Africa’s economy and reputation.

Our concern is that this aggressive consumptive approach to sustainable use could not only lead to negative welfare and well-being outcomes for wild animals, but also have unintended net negative impacts on biodiversity and local communities in South Africa. Moreover, in the spirit of Ubuntu, the recognition and protection of individual wild animal interests should be clearly considered and not solely reduced to commodities, simply to be utilised and exploited for commercial gain.

Specifically, we recommend that at a minimum, the draft NBES should be amended to remove Action 10.4, as this could seriously harm national and international efforts to protect TOPS species and curb poaching. More broadly, the draft NBES should shift from the proposed major expansion of consumptive use to one that includes a new conservation and sustainable use policy objective, which clearly confirms that non-consumptive wildlife use will be actively promoted and prioritised above consumptive wildlife use as part of South Africa’s admirable vision rooted in public sentiment and the potential for improved income generation.

As it stands, this draft NBES requires substantial intergovernmental collaboration, which is never an easy goal to achieve, and needs considerable capital investment to implement all the action points. If this kind of effort is to be achieved, rather than promoting and expanding the consumptive use of wildlife, more emphasis should be put on the promotion of access to non-consumptive money streams, for example, wildlife credits, a lion levy, and ecosystem services, which can help to foster the idea that wildlife is worth more alive than dead. In particular when the goal is transformation and inclusivity of communities into the wildlife industry at large, we need to foster a sentiment towards care and protection of wildlife.

In conclusion, while we appreciate the opportunity to contribute feedback on the draft NBES, we must emphasise our concerns regarding the potential negative consequences of aggressively expanding the consumptive use of wildlife. It is imperative that any strategy aligns with international and national policy commitments while safeguarding biodiversity, local communities, and the welfare and well-being of individual animals. Failure to do so jeopardises not only South Africa’s rich biodiversity heritage, but also its international reputation as a global conservation leader and ecotourism destination.

Yours sincerely,

Dr Louise de Waal

Blood Lions | Campaign Manager and Director

Comments on the Draft Notice Prohibiting certain activities involving African lion (Panthera leo)

The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Mr Khuthadzo Mahamba
Private Bag X447
Pretoria 0001

Delivered by email to: lionprohibition@dffe.gov.za

25^th October 2023

Comments on the Draft Notice Prohibiting certain activities involving African lion (Panthera leo)

Dear Mr Mahamba,

Thank you for the opportunity to comment on the Draft Notice prohibiting certain activities involving African lion (Panthera leo), gazetted under notice 49383.

We are in full support of the Minister’s decision to implement appropriate and necessary measures to avoid the establishment of new captive lion facilities whilst the development of a policy, strategy and legislation are under consideration to phase out the captive lion industry in South Africa.

The Blood Lions film and global campaign was launched in 2015 and has worked tirelessly to end the cruel and unethical captive lion industry and its spin-off activities. The announcement in May 2021 by Minister Barbara Creecy following the Parliamentary Portfolio Committee Lion Colloquium and the subsequent release of the HLP report, the publication of the White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity, and the recent draft Policy Position on the Conservation and Ecologically Sustainable use of Elephant, Lion, Leopard and Rhinoceros demonstrate highly significant steps towards enabling the restoration of South Africa’s reputation as a leader in the conservation of wildlife and as a responsible tourism destination with iconic wild lions.

We welcome the shift in thinking to include animal well-being as an objective in NEMBA, and the recognition of lions as sentient beings demonstrates the progressive nature of the Department’s stance on conservation of wildlife and biodiversity. As stated in the draft Prohibition Notice, lions are sentient and social animals with complex needs that are best served in wild habitats in which their social structures, hunting behaviour, and territorial nature can be met. The recognition that controlled environments cannot adequately account for these complex needs of these apex predators is an important and necessary step towards phasing out the commercial captive lion industry.

We are hugely encouraged with the publication of this draft Prohibition Notice and are in full support of the following issues:

To prohibit the establishment or registration of new captive lion breeding facilities, commercial exhibition facilities, rehabilitation facilities or sanctuaries.
The explicit focus on the promotion of well-being, recognition of animal sentience, recognition of natural behaviours associated with wild lions and social groups, and their physiological needs.
Recognition that it has become critical to implement appropriate measures to avoid the establishment of new captive facilities for lions, whilst the development of a policy, strategy and legislation are under consideration to phase out the captive lion industry.

We are however deeply concerned to see the inclusion of exceptions for prohibition of the establishment or registration of new captive lion facilities, namely those facilities that: –

Provide a public function: To our knowledge, “public function” is an expression that is currently not defined in any existing conservation legislation. A public function can be defined as an activity that benefits the vast majority of society and is as such an extremely broad concept. It generally relates to activities, services, or events that have a public or community-oriented focus, either through government provision, non-profit organisations, open accessibility, or engagement with the public.

When making exceptions under such an all-encompassing concept, this inevitably creates legal loopholes for facilities to operate under the pretence of fulfilling a public function. We are hugely concerned this will allow for the establishment or registration of new captive lion facilities and pseudo-sanctuaries that may operate under the guise of providing for example an educational function. Furthermore, there is currently not sufficient scientific evidence to support the notion that lions in controlled environments can serve a strong enough educational function that may warrant their captivity.

Furthermore, it is necessary to question what functions could potentially justify the establishment of a new facility that keeps lions in a controlled environment and how can we guarantee that such a facility adheres to its narrow function? This leads to our additional concern of the future regulation and enforcement of such facilities by the provincial authorities with already limited resources and capacity.

Operate on a non-profit basis: To operate a captive lion facility on a non-profit basis, whether the entity is registered as an NPO, NPC or NGO, is not the equivalent to being run based on ethical standards, standards that put the well-being of the lions as a priority, and may not even be sufficient in determining a non-commercial entity. There are numerous examples of commercial captive lion facilities that have registered a non-profit as a sideline, in particular facilities with public access, voluntourism, and/or research interests.

We are extremely concerned that this may again open up a legal loophole in which facilities operate on a non-profit basis as a means of circumventing the prohibition of establishing and/or registering new commercial captive lion facilities.

If the Department wants to leave the opportunity open for the establishment of true lion sanctuaries or lion safe havens that can rehome some of the surrendered lions coming out of the voluntary exit process and/or the future prohibition, such facilities should be identified solely as being run under internationally recognised best practices that allow for the welfare and well-being of these apex predators to be guaranteed.

At present, the exception of facilities that provide either a public function or operate on a non-profit basis leaves the system wide open for abuse.

We sincerely hope that you will take the above comments into consideration when developing the final Prohibition Notice.

If you have any queries, please do not hesitate to contact me.

Yours sincerely,

Dr Louise de Waal

Blood Lions | Director and Campaign Manage

Feedback on the revised draft White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity

To: The Director-General
Department of Forestry, Fisheries and the Environment
FAO: Ms Tsepang Makholela
Email: whitepaper2@dffe.gov.za

Date: 9^th November 2022

Feedback on the revised draft White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity

Introduction

Blood Lions welcomed the first draft White Paper on the Conservation and Sustainable use of South Africa’s Biodiversity gazetted in July 2022. We recognised in our first submission that this White Paper had the potential to lay the foundation for a more holistic and contemporary approach to biodiversity conservation and hence a better protection of South Africa’s rich biodiversity heritage. It represented a paradigm shift away from outdated policies and models, and towards more modern approaches to the conservation of biodiversity, founded on the principles of Ubuntu, which we applauded.

It is encouraging to see that the second draft of the White Paper has been condensed significantly, making it a lot easier to follow and digest. We are also encouraged by the renewed focus on equitable sharing and removing barriers for local communities to experience and get involved with biodiversity. This is long overdue to, among others, help raise awareness and change mindsets of local communities towards wildlife and biodiversity conservation in Africa.

We are pleased to see that the principle of “people first” has substantially been reduced in this second draft, however this seems to have been replaced by a strong focus on sustainable utilisation which is still anthropocentric, rather than being focussed on the conservation of biodiversity for present and future generations with an emphasis on the intrinsic and existence values of the environment and its components.

These two key definitions and tenets (intrinsic value and existence value) have effectively been removed from the Guiding Principles and the remainder of the White Paper, which is extremely worrisome. These values have now been reduced to vague mentions in sentences such as “South Africa supports the sustainable use of biodiversity of the intrinsic, relational and instrumental values of biodiversity” and “In addition to these economic benefits, there are a wide range of other values and benefits that people derive from nature, including existence value”.

We strongly recommend returning the clear focus on the intrinsic, existence and ecosystem service values of wildlife and biodiversity, with all the benefits this brings for human health and well-being as well as to the wider economy, as opposed to the existing focus of the White Paper on the commercial value of wild animals through consumptive use. Contribution to GDP should not be the primary measure of the value of biodiversity, as this can also be achieved through non-consumptive uses.

This second draft of the White Paper again puts a lot of emphasis on giving effect to and aligning with Section 24 of the Constitution of South Africa, which is commendable. However, the phrase used in Section 24 of the Constitution is “Ecologically Sustainable Use” and should therefore be used consistently throughout the White Paper document. Currently, the White Paper distinguishes in parts between consumptive and non-consumptive sustainable use, however in other parts the generic term “sustainable use” remains and is sometimes replaced with “ecologically sustainable use” or “sustainable development”. The multitude of terms used for this one concept not only creates potential confusion but can also lead to loopholes in this vitally important document.

Furthermore, animal well-being and sentience have taken a massive step backwards in this second draft and there is no mention of One Health – One Welfare. This is not only deeply concerning from an animal welfare/well-being perspective, but also from a standpoint of human health. Wild animals are believed to be the source of at least 70% of all emerging zoonotic diseases and their commercial trade provides many opportunities for the movement of pathogens across national and international boundaries. Evidence has shown that wild animals involved in sustainable use and/or commercial wildlife trade often experience compromised immune systems when subjected to stressful and substandard welfare conditions, and in particular when kept in close proximity to other wild animal species, which can exacerbate the risk of zoonotic disease transmission.

The considerable and real risk of the transmission of zoonotic diseases between wild animals and humans should not only receive careful consideration but should be the principal concern of any ex-situ use of animals, as the economic consequences of an epidemic (or pandemic for that matter) are far greater than the economic benefits of the activity itself.

You will find below some additional comments and feedback on specific parts of the revised draft White Paper.

Executive summary:

Page 3 – paragraph 2: The reasons why the White Paper has been developed, “to set the country on a strong path of sustainable development based on the rich biodiversity and ecological infrastructure which supports ecosystem functioning for livelihoods and well-being of people” is too anthropocentric and omits the intrinsic and existence values of the environment and its components.
Page 3: We are encouraged to see the identification and inclusion of challenges that require policy intervention, in particular points 1, 2, 5 and 6 are welcomed.
Page 4 – Goal 2: Should speak of “ecologically sustainable use” per Section 24 of the Constitution – see also comment in Introduction above around sustainable use.

Introduction and Background

Section 1.1 – Policy Issue Identification: Positive to see the “uneven effectiveness in governance and shortages of human, financial and other resources” acknowledged as a key barrier.
Vision: The new vision omits a vitally important mandate of the Department of Forestry, Fisheries and the Environment, namely to conserve biodiversity for present and future generations.
5.2 Pressures and Drivers (Page 11 – paragraph 1): The sweeping statement “Both wildlife ranching and livestock farming are vitally important land uses for both socio-economic development and biodiversity conservation, but can have negative impacts if conducted too intensively, or inappropriately”:
- A definition of “wildlife ranching” should be included in the White Paper to provide clarity, a common understanding of the meaning and implication of the term, as well as potential identification of issues such as best practice.
- The statement that these land uses are vitally important for biodiversity conservation, rather than solely providing socio-economic benefits, should be backed up with solid scientific evidence or otherwise omitted from this sentence.
- The wording “conducted too intensively, or inappropriately” is ambiguous and subjective, and should be explained further or have examples provided.
1.5.3 Benefits derived from South Africa’s Biodiversity: Throughout this section the term “sustainable use” should be replaced with “ecologically sustainable use”.
1.6.3 Provincial and Municipal Laws and Policies: The section should strongly promote the updating and alignment of provincial nature conservation statutes with existing national legislation, to avoid conflicting mandates and potential litigation.

Definitions

Animal well-being: This definition needs to include the wording in red “…and quality of life and death, including….”.
Conservation: We are encouraged to see the removal of reference to “sustainable use” and inclusion of “intrinsic value” in this definition.
Humane: We applaud the inclusion of this new definition, but the word undue in the phrase “undue pain, stress, suffering, or distress” is problematic and ambiguous. The definition also fails to recognise animal sentience.
Sustainable Use: It is encouraging that the definition now includes reference to ecological sustainability. However, the definition fails to recognise the intrinsic value of individual animals and populations, and not only their humane use.

Guiding Principles

General comment: It is hugely disappointing to see that the recognition of intrinsic and existence values and animal well-being, and hence the recognition that animals are sentient beings capable of suffering and experiencing pain, have completely disappeared from the White Paper guiding principles.
It is encouraging to see the addition of “Good Governance” as a guiding principle.

Goals and Enablers

General comment: All reference to human health and the prevention or minimisation of the risk of animal-human transmission and further evolution of zoonotic diseases associated with wild animals has been removed, which is concerning (see also comments in Introduction).
Goal 2 – Sustainable Use:
- Should refer to Ecologically Sustainable Use.
- Paragraph 1 should also include “animal well-being”.
- Encouraging to see the inclusion in the last paragraph that sustainable use should avoid practices, actions or activities that are inhumane.

Goal 3 – Equitable Access and Benefit Sharing:
- We are encouraged to see one of the focal points has moved from “concerns with ownership of biodiversity” to “concerns with access to biodiversity”, something which is vitally important for biodiversity conservation.

Goal 4 – Biodiversity Conservation and Sustainable Use is Transformative:
- This goal puts crucial emphasis on environmental rights, as intended in the Constitution, including but not limited to preventing harm to human health or well-being. However, this is not followed through in the remainder of the White Paper, where reference to potential harm to human health from zoonotic diseases is no longer featured (see also comments in Introduction).

Enabler 1 – Integrated, Mainstreamed and Effective Biodiversity Conservation and Sustainable Use:
- It is concerning that all reference to funding and resourcing as a key constraint on sustaining the sector, let alone growing it, has been removed. This is absolutely key to the ultimate success of the intent of the White Paper and we would like to reiterate the need for sustainable funding and resourcing. Innovative funding schemes, such as UNDP Biodiversity Finance Initiative, Rebalance Earth initiative, and carbon debt schemes, should be considered to (partly) replace the contested revenue from consumptive use.
- We are encouraged to see that multi-sectoral approach and cooperation has been adopted.

Enabler 2: Enhanced Means of Implementation:
- We support the overall focus on implementation mechanisms, such as mobilising resources, capacity development and knowledge generation. Capacity building and education across the board are essential to ensure conservation of South Africa’s biological diversity sustainably, in particular considering the disconnect between an increasing urban population and the lack of respect and understanding of nature, ecosystems and biodiversity.

Strategic Linkages and Impact

Page 26 – paragraph 2: The old Vision (from the first draft White Paper) has been used in this section and needs to be amended.

Policy Objectives and Expected Outcomes

Goal 1:
- Concerned that prevention of zoonotic diseases has been removed in its entirety (as outlined above).
- Policy Objective 1.6 – Output 8 and 11: Breeding for commercial purposes (output 11) contradicts the minimization of risk of domestication of wild animals (output 8). Allowing breeding for commercial purposes rather than conservation purposes – even if that is done responsibly, has demonstrable conservation benefits or advances sustainable use – will inevitably lead to domestication. Ex-situ breeding practices should be limited to those circumstances where the conservation needs of the species requires such ex-situ interventions, e.g., breeding for repopulating conservation areas. We therefore recommend deleting output 11.

Goal 2:
- Policy Objective 2.5: It is positive to see the promotion of duty of care, including humane practices towards wild animals. However, with the lack of recognition of animal sentience and the use of the word “undue” in the definition of humane, this leaves this policy objective wide open to abuse.
- The integration of well-being of wild animals and populations into policy, legislation, tools and practices is welcomed, but the proof is in the pudding when it comes to enforcement and prosecution.

Goal 3:
- The output (“efficient permitting system to regulate and promote bioprospecting and biotrade, while protecting biodiversity and ecosystem services”) seems to have been removed which is concerning as regulation can only work if a robust, electronic national/central permitting system is put into place. The provincial (often outdated paper-based) systems are not adequate for effective regulation.

White Paper Submission By Blood Lions

Keep South Africa’s Iconic Species Wild

Delivered by email to: knaicker@environment.gov.za and bcreecy@environment.gov.za

28^th September 2021

Dear Honourable Minister Creecy and Dr Naicker,

Keep South Africa’s Iconic Species Wild

There are many reasons why Blood Lions and our partners around the world are in support of the Minister’s recent announcement to end the predator breeding industry in South Africa and the subsequent draft Policy Position document on the conservation and ecologically sustainable use of elephant, lion, leopard and rhinoceros.

The reputational and marketing damage to Brand SA and our proud conservation and ecotourism heritage that comes with failing to act is one of the most important issues. By ending the commercial captive lion breeding and keeping practices, the Minister and government will be sending a compelling message to the world that South Africa indeed supports sound conservation, and our tourism products are ethical, responsible and authentic.

After the release of the Blood Lions documentary in 2015, the campaign launched the Born to Live Wild Tourism Pledge. Every one of the 200 logos below, of which half are internationally recognised South African tour operators, representing 2,738 members worldwide, commit:

To not knowingly book or otherwise support any captive lion breeder or tourist facility that contributes to the cycle of breeding, exploitation and senseless killing of predators. This includes all petting and walking with lions activities.
To continue our support and promotion of the formal conservation community in their endeavours to secure the survival of Africa’s predators in the wild. Without wild lions and the rest of the predator guild extant in functioning ecosystems, there will be no African tourism industry – a calamitous situation for many economies.
To continue in our own endeavours towards wildlife conservation and economic development wherever we operate across the world.
To continue supporting an ethical and responsible interaction with wilderness and wild animals in their natural habitat.
To continue promoting Africa as an authentic, wild and rewarding tourism destination.

This means, the signatories of our Born To Live Wild pledge have committed to keeping South Africa’s iconic species wild and do not support any facility that contributes to the cycle of captive breeding, canned hunting and the wider commercial exploitation of wild animal species.

This pledge places every one of these operators, as well as their subsidiary companies and guests, as firm supporters of the High-Level Panel recommendations, the Minister’s announcement to end predator breeding, and the subsequent draft Policy Position on the conservation and ecologically sustainable use of elephant, lion, leopard and rhinoceros.

We would like to draw attention to the following statistics provided in the State of the Wildlife Economy in Africa report, compiled by the African Leadership University School of Wildlife Conservation (2021). According to their study, the total contribution of travel and tourism in 2019 was US$24.6 billion or approximately 7% of the total South African economy creating 1.4 million jobs (i.e. 9.1% of total employment). In contrast, the direct contributions to SA’s economy in 2015 from trophy hunting were a mere US$153 million and the wider wildlife ranching sector contributed a further US$438 million.

Clearly, the risks in continuing the commercial captive predator industry, with all its spin-off activities such as canned hunting, tourism interactive activities, and lion bone export trade, are substantial.

Warm regards,

Dr Louise de Waal

On behalf of Blood Lions and our Born to Live Wild signatories