Skip to content

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Biodiversity has been welcomed by many professionals in different sectors, as it represents a paradigm shift away from outdated policies and models, towards more modern approaches to the conservation of biodiversity, while adopting One Health and One Welfare principles in the management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

×
donate