South Africa Proposes Far-reaching Policy Position on Wildlife

The South African Department of Forestry, Fisheries and the Environment (DFFE) has invited comments on its draft Policy Position regarding the Conservation and Sustainable Use of Elephant, Lion, Leopard and Rhino. This Policy Position was built around the outcomes of the deliberations of a 'High Level Panel' of consultants from various sectors, but has been extended beyond the HLP ideas into a national policy proposal with wide implications for the whole wildlife sector in South Africa.

The invitation was published in the South African Government Gazette No 44776 dated 28 June 2021, and allowed comment for 30 days from the date of publication. That deadline has passed at the time of writing this column, so it will be interesting to learn what comments have been received. The HLP itself was divided on certain matters, and some of the most controversial and challenging issues such as hunting of captive-bred lions, the semi-domestication and captive breeding of rhinos, and the trade in elephant ivory and rhino horn, remain contentious and divisive. It is debatable whether a government Policy Position alone can change such longstanding conundrums. However, it is encouraging that the Policy Position is positive in respect of hunting generally, so overall this should be welcomed by the hunting community.

Let's begin by looking at the issues identified for the attention of the HLP. These were (a) the captive holding and breeding of lion and rhino; (b) hunting of captive-bred lions; (c) trade in captive lion parts and derivatives; (d) unsustainable practices in hunting of leopard; (e) feasibility of legal international trade in rhino horn and elephant ivory for commercial purposes; (f) ineffective and inefficient legislation and implementation, resulting from duplicated and conflicting legal requirements; (g) ineffective and inefficient management of State Protected Areas; (h) non-optimisation of the full potential of a vibrant Biodiversity Economy; (i) inadequate access and benefit-sharing to communities; and (j) untransformed wildlife sector.

This is a detailed, 47-page document, so let's look at just a few of the proposed interventions articulated in its pages:

Management Policy Interventions

• Put an immediate halt to the domestication of lions and the commercial exploitation of captive lions, and establish a process to close captive lion facilities. • Reverse the domestication and intensification of management of rhino. • Enhance the conservation and sustainable use of leopard.

Most ethical hunters will approve the intention of trying to stop the practice of 'canned lion' hunting, but on the other hand a number of landowners have created work opportunities and economic benefit from these activities, and will probably not give them up without a fight. Then there is the prospect of many lions having to be killed as a consequence of government's policy interventions. While their deaths will be described as 'being euthanased', this is likely to create emotional debate. In the case of rhino, the intensive management being conducted by some landowners is largely because the animals are at grave risk of being killed by poachers if they are allowed to range more widely. And because government will not countenance a review of legal sale of rhino horns, the only trade that will thrive is the illegal trade. Not a smart outcome, as far as I am concerned.

Trade Related Policy Interventions

• South Africa will not submit an ivory trade proposal to CITES as long as current specified circumstances prevail. • South Africa will not propose or support amendments to the CITES appendices relating to South African rhino species. • Prevent the export of live specimens of the five iconic species outside of their range states, or into captivity in other countries,

• Explore potential benefit of disposal of elephant ivory and rhino horn stockpiles and to put in place the Commission of

Enquiry recommendations on rhino horn trade.

I have serious reservations about these trade policy interventions. They create a policy chasm between South Africa and other SADC states – which are totally opposed to the CITES bans on the legal sale of ivory and rhino horn. For rural communities to benefit from wildlife conservation and management, it is reprehensible to prevent valuable wildlife products from being legally traded between willing buyers and sellers. South Africa should stand united with SADC states in facilitating a legal market for wildlife products from sustainably managed populations. I will make further comments on point four above, because it has some very unpalatable undertones. South Africa should take care not to be seen to be aligned in any way with the animalrights lobby that has infiltrated CITES and is vehemently opposed to hunting or the legal trade in wildlife products.

Conservation Policy Interventions

• Develop an overarching national policy on biodiversity and sustainable use. • Enhance the conservation of iconic species, through increased wildness, naturalness and wellbeing of fauna. • Adopt a One Welfare approach to wildlife wellbeing. • Reposition South Africa as a destination of choice for the legal, humane, regulated and responsible hunting of the five iconic species. • Reconceptualize the role of state and other protected areas for conservation scaling and as a socio-economic catalyst.

Point four on hunting is obviously a welcome intervention from the hunting community's perspective. The use of the words 'iconic species' is imprecise terminology. Surely 'iconic species' in South Africa are not restricted to the mammals dealt with here? In my view, the Cape Vulture is certainly an 'iconic species', as are many other birds. As an aside, many of these 'iconic birds' are being killed by wind turbines that are given environmental approvals by the Department of Forestry, Fisheries and the Environment.

Conservation Transformation Interventions

• Restore a transformative African approach to conservation and sustainable use, consistent with Ubuntu. • Enhance sustainable use of iconic species, especially leveraging responsible eco-tourism and its benefit flows. • Promote and enhance human-wildlife co-existence, while empowering and capacitating people living with or near wildlife.

The first point will probably puzzle some readers – I am one of them. If South Africa wants a 'transformative African approach to conservation and sustainable use', why is it alienating our fellow Africans in SADC by not supporting their calls for a New African Deal regarding trade in wildlife products, and their pleas to the UK and the USA not to ban the import of trophies into their countries from Africa?

Conservation Capacity Interventions

• Targeted capacity development for key components of the wildlife sector. • Improve the evidence-base for best practice within the wildlife sector.

These are clearly useful interventions.

This statement of intent is also a positive one: "The role and contribution of the private sector to conservation and the sustainable use of biodiversity are recognised and acknowledged, and the potential enhancement of these contributions identified. Importantly, communities living with wildlife are placed at the centre of the thinking, with a focus on enhancing human-wildlife co-existence, and mechanisms for leveraging their economic, social and cultural benefits through transformative approaches to access and benefit-sharing. Finally, the outcomes will result in both protection and enhancement of South Africa's international reputation, repositioning the country as an even more

competitive destination of choice for ecotourism and responsible hunting."

With regard to trade in ivory and rhino horn, the document is very defensive in deferring to CITES and saying that the latter is not likely to change its stance in the near future and that South Africa is not in a strong position to oppose this. This is a weak defence and I would expect South Africa to show more backbone and solidarity with its SADC neighbours in seeking to challenge the CITES position on trade in wildlife products.

The South African policy view on ivory and rhino horn stockpiles is discussed here: "South Africa has substantial stockpiles of rhino horn and ivory which have been obtained through rhino dehorning for protection, natural mortality, and collection from the field or confiscation from poachers. The costs of maintaining these stocks are substantial, with ongoing risks of horns and ivory ending up in the illegal trade. Communities have identified the positive impact of sales of stockpiles, and there is global interest from NGOs and philanthropists willing to buy stockpiled horn and ivory in order to then have them destroyed; however, such an approach, which has been repeatedly rejected by other SADC countries, is highly controversial and raises significant concerns." As stated above, I believe South Africa is letting down the SADC sustainable utilization team by not coming through with strong support for a legal trade in wildlife products. To shed crocodile tears about stockpiled product coming onto the illegal market, when there is NO LEGAL MARKET is the height of hypocrisy. The burning of ivory and rhino horns by Kenya and other countries, funded by anti-use NGOs and governments, was a despicable and senseless act. More elephants and rhinos would simply be killed to replace the destroyed wildlife products, because those much-reported cremations did not harm the illegal markets in the slightest, nor affect the demand for valued wildlife products by those who are willing to pay good money to obtain them. Surely it is axiomatic that if there are no legal markets for products that people want, only illegal markets will thrive?

There is no doubt that this document is an important piece of work, and one that deserves critical input. "..(it) will be reviewed within ten years after publication. This will provide for sufficient time for the policy objectives to have the intended effect on the outcomes". "This Policy Position sets out policy objectives and outcomes towards achieving secured, restored and rewilded natural landscapes with thriving populations of lion, elephant, rhino and leopard, as indicators for a vibrant, responsible, inclusive, transformed and sustainable wildlife sector."

These are lofty goals indeed, and given the fraught social, economic and political situation that South Africa finds itself in during the second half of 2021, it will require a massive and coordinated effort by all concerned to achieve even a few or more of the objectives and outcomes. Government will not be able to do this purely through legislation. Issues of land ownership are already a source of conflict and suspicion, with Government seemingly working towards legislation that will allow 'expropriation without compensation'. South Africa's burgeoning population and stagnant economy, coupled with unworkable labour laws and restrictive and discriminatory practices in hiring employees, has resulted in massive unemployment, especially among the youth, an explosive formula for civil unrest.

Readers can access the full PDF at http://www.gpwonline.co.za/

Dr John Ledger is an independent consultant and writer on energy and environmental issues, based in Johannesburg, South Africa. John.Ledger@wol.co.za