Kill the Captive Lion Farming and Hunting Industry for Once and For All

The Department of Forestry, Fisheries and the Environment’s revised Policy Position on the Conservation and Sustainable Use of Elephant, Lion, Leopard and Rhinoceros stated that the intensive breeding of lions in controlled environments, and the commercial exploitation of captive or captive-bred lions had negatively affected their iconic status.

Despite DFFE’s policy to end the captive keeping of lions for commercial purposes and close the lion facilities in order to half to the intensive breeding of lions in controlled environments and end the commercial exploitation of captive and captive bred lions nothing has changed in South Africa. We consequently call on your office to urgently give effect to the Policy Position and take positive steps to end this practice, which has only brought the country into disrepute .

There are number of immediate actions can be taken by the South African government to bring a halt to this industry. In 2023 the EMS Foundation obtained a legal opinion in relation to the implication of the changes to NEM:BA effected by the National Environmental Management Laws Amendment Act.

Withdraw the Draft ‘Game’ Meat Strategy

DFFE recently put out a draft ‘game’ meat strategy for public comment. The draft strategy was produced by an outsourced company – Alsson (Pty) Ltd (Bid no.: E1561, Year: 2021), for an amount of R 1 806 075.00. Alsson did not consult with civil society stakeholders other than those in favour of the industry.

There are major environmental, health and animal welfare risks and concerns in relation to the draft strategy.

Based on all the risks and the direct negative ramifications for biodiversity, ecological restoration and animal well-being, WAPFSA calls on the Honourable Minister to withdraw the draft strategy.

In addition, we are requesting that the Honourable Minister prohibits the intensive breeding for commercial purposes of any wild fauna, including the indigenous species of wild animals listed in the Animal Improvement Act.

The draft strategy stands in direct opposition to the on-going DFFE policy review process (intended to lay down the overarching policy guidelines on South Africa’s conservation of biodiversity), is inconsistent with Section 24, Chapter 2 of the Bill of Rights in the South African Constitution and discounts indisputable scientific evidence.

The draft strategy is also in conflict with prevailing climate and societal conditions and stands in stark contradiction to South African governmental policies aimed at trying to address the dire challenges of the sixth extinction caused by anthropocentric activities.

It is a matter of serious concern that the draft strategy (which makes the case for industrial-scale farming and slaughter of wild animals) does not integrate any of the progressive concepts drafted in the Biodiversity White Paper, and undermines the White Paper. Indeed, there are irreconcilable differences between the Draft White Paper on Conservation and Sustainable Use of Biodiversity and the draft strategy.

DFFE cannot resort to the old-style consumptive and exploitative economic model, and must commit to regenerative conservation methodologies central to true conservation today. Unfortunately, the model illustrated by the draft strategy is more of the same, if not worse.

The draft strategy is crass commercialisation of wildlife that is inconsistent with South Africa’s climate resilience and ecosystem restoration and preservation goals, and goes against the ‘One Health’ approach.

The draft strategy is promoting the intensification and increase of an industry which is inherently problematic and which has many risks and harms and which lacks critical data and research. Wild animals are sentient beings with individual interests and intrinsic value.

The strategy completely ignores legal obligations in this regard. Furthermore, the draft strategy is inconsistent with the requirement in section 24(b) of the Constitution to have the environment protected through legislative and other means. It is unclear how the draft strategy, which seeks only to commercialise wildlife, would ever be able to fulfil this constitutional imperative.

It has been shown that where commercial farming of wild animals takes place for meat a number of concerns have been raised, including the problems of fragmented legislation and regulatory oversight, lack of transparency for the consumer, false labelling of products, an increase in the rise of illegal killing of wild animals and disease transfer.

In addition, the draft strategy includes several of the main drivers of zoonotic disease emergence – making the strategy weak, flawed, indefensible and unsustainable.

The DFFE seeks to achieve a 3-fold objective: 1) addressing the food shortage crisis, 2) economic

upliftment and job creation, and 3) restoration of biodiversity. With regards to objective 1), there are better, healthier, more sustainable ways of feeding the nation, which integrate modern science with indigenous knowledge. With regards to objective 2), there are greater opportunities for rural livelihood creation, and job creation through permaculture and other regenerative methodologies. With regards to objective 3), the approach heralded by the draft strategy opens the door to mono-species industrial production and genetic pollution. It is rooted in methodologies that are inconsistent with biodiversity conservation, and instead pose many risks to it.

A Moratorium on the Trade, Hunting and Killing of South Africa’s Indigenous Primates

The main findings of a research report compiled by the EMS Foundation and Ban Animal Trading in relation to the status South Africa’s indigenous primates show that South Africa’s laws are failing to protect (nonhuman) primates and are not preventing the negative consequences of South Africa’s so-called legal trade in (nonhuman) primates and their body parts.

We are requesting that a moratorium on the trade, hunting and killing of South Africa’s indigenous (nonhuman) primates and the breeding, trading and keeping of exotic (nonhuman) primates as pets needs to be put in place immediately so that it can be re-evaluated.

The report also uncovers how nonhuman primates have been neglected in terms of population assessments either at the national level (SANBI did not produce any Non-Detriment Findings in terms of the requirements for export of CITES Appendix II species) than at the provincial level. In other words, there is no data available relative to primate populations in any of the nine provinces. The scarcity of data and population trends, create a misleading impression of the abundance of the six indigenous primate species, leading to inadequate protection. As a result, some provinces issue hunting permits liberally or don’t require them at all, enabling hunters to irresponsibly continue to decimate entire troops in the wild.

Moratorium on the Export of Wild Cheetah from South Africa to India

WAPFSA wishes to raise several serious concerns with the DFFE project to remove 120 wild cheetahs from South Africa and send them to India over a period of 10 years. In summary we are concerned:

that contrary to the requirements of the National Environmental Management: Biodiversity Act (NEM:BA) the decision is based on an outdated and unpublished non-detriment finding (NDF);
that the scientific information based on which the decision was made to agree to the project is not robust;
that in fact, there is evidence that the risks of the proposed project to the cheetah population do not justify proceeding with the project; and
that from an animal welfare perspective, the project will result in an unjustifiable number of animals lost due to the risks of immobilisation and transport and also due to conditions in the destination habitat in India.
Nearly two years after they arrived from Africa, these cheetahs are kept in enclosures awaiting a more and more improbable release into the wild. Experts raise inbreeding concerns and question if the project is a conservation or simply a captive breeding exercise.

WAPFSA requests that a precautionary approach be adopted and the project be halted until DFFE has obtained public comment and more robust information regarding the effect of the project on the cheetah population in South Africa and on the welfare of the individual animals concerned.

Moreover:

DFFE’s decision is based on information in an outdated and unpublished NDF
The scientific evidence that the project will not be detrimental to the survival of the species is not robust
There is evidence that the risks of the proposed project to the cheetah population do not justify proceeding with the project
The project will result in an unjustifiable number of animals lost

The anticipated benefit to relations between South Africa and India of the project is outweighed by the risks to the local cheetah population, the high likelihood that the project will not have significant benefit to global conservation, and by the likely harsh impact on individual cheetah welfare. Accordingly, WAPFSA requests that the project be halted until the risks, particularly the risks to the survival of cheetah in South Africa can be properly established and assessed and until proper public comment has been obtained.

Address Illegal Unregulated and Unlawful Fishing

South Africa needs, urgently, to domesticate the Agreement on Port State Measures to address illegal, unregulated and unlawful fishing. It is imperative that South Africa ratify the High Seas Treaty which concerns biodiversity conservation in international waters.

Climate Change Bill (B5-2022) Signed but Not Operational

On the 23^rd July 2024, President Ramaphosa signed the highly anticipated Climate Change Act into law. This pivotal legislation is designed to define, manage, monitor, and implement South Africa’s response to climate change.

The Act is not yet operational, as it will only come into effect on a future date when the President issues a proclamation. This delay is concerning because the crucial mechanisms provided by the Act cannot yet be enforced, and important timeframes have not yet commenced.

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