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SOUTH AFRICA’S CAPTIVE LION INDUSTRY

WILDLIFE ANIMAL PROTECTION FORUM OF SOUTH AFRICA OPEN LETTER ADDRESSED TO THE LEADERS OF THE DEMOCRATIC ALLIANCE

WAPFSA-LETTER-TO-THE-LEADERS-OF-THE-DA_12May-23Download

SOUTH AFRICA’S CAPTIVE LION INDUSTRY

WILDLIFE ANIMAL PROTECTION FORUM OF SOUTH AFRICA OPEN LETTER ADDRESSED TO THE LEADERS OF THE DEMOCRATIC ALLIANCE

The Wildlife Animal Protection Forum of South Africa is an alliance of twenty-four South African organisations that share certain values, knowledge and objectives and who collectively contribute to a body of expertise from the scientific, conservation, legal, welfare, rights, social and climate justice and public advocacy sectors.

The undersigned Members of WAPFSA and their colleagues in wildlife conservation hereby extend their congratulations and offer their official gratitude to the Democratic Alliance for their forward-thinking decision to adopt a policy resolution against the practice of captive or canned lion hunting, the breeding of lions for the intent of canned lion hunting and the breeding of lions for the sale of their bones and other derivatives.

Five years ago, in 2018, the 5th Parliamentary Committee on Environmental Affairs adopted a Report compiled during a two-day Colloquium on Captive Lion Breeding for Hunting in South Africa: Harming or Promoting the Conservation Image of the Country.

The Colloquium achieved an exceptionally high turnout, drawing speakers and participants from the captive lion breeding industry, hunting associations, conservation and animal protection organisations and the government.

Two members of WAPFSA presented the results of an eighteen-month investigation into the captive lion industry published in a Report titled: The Extinction Business: South Africa’s Lion Bone Trade.

According to the Report of the Portfolio Committee, which was later adopted by Parliament, there was a predominant view that the captive lion breeding industry did not contribute to conservation and was doing damage to South Africa’s conservation and tourism reputation.

The captive breeding of lions for hunting and lion bone trade came under severe criticism from both local and international conservation organisations for harming South Africa’s well-established and highly respected conservation image.

The then Portfolio Chairperson, Honourable Mr Philemon Mapulane, remarked that although South Africa is in favour of sustainable use of biodiversity resources, South Africa finds itself increasingly isolated at important international conservation platforms as a result of the captive lion industry. It seems as if South Africa’s conservation reputation is being compromised by this practice which does not seem to benefit the broader conservation, but a small number of breeders without proper scientific or conservation basis. Parliament, he warned must become particularly concerned when reputable conservation agencies such as the International Union for Conservation of Nature turn their backs and deplore these practices.

In May 2021 a Press Release, issued by the Parliamentary Communication Services on behalf of the Portfolio Committee on Environment, Forestry and Fisheries, Mr Fikile Xasa, stated that the Portfolio Committee welcomes the announcement made by the Minister of Environment, Forestry and Fisheries, that South Africa plans to ban the breeding of lions in captivity for trophy hunting or for tourists to pet.

The Chairperson of the committee, Mr Fikile Xasa said: “It was indeed satisfying to have attended the launch of the Report of the High-Level Panel that agreed with our parliamentary resolution to consider banning this destructive practice for the greater public good, our conservation brand and the dependant tourism industry. As public representatives, we feel our people have been heard.”

We are relying upon the Democratic Alliance to continue to be a strong voice in order to strengthen the enforcement of the closure of this abhorrent industry in order to save and preserve South Africa’s conservation reputation and to preserve lion populations in the wild for future generations.

SIGNED BY THE FOLLOWING MEMBERS OF THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA AND COLLEAGUES IN WILDLIFE CONSERVATION:

Mr Henry Smith, MP Crawley Constituency House of Commons, London
Will Travers OBE, Co-Founder and Executive President Born Free Foundation
Richard Peirce, Author “Cuddle Me, Kill Me”, Investigator “Lions, Bones & Bullets”
Eduardo Goncalves, Founder of the Campaign to Ban Trophy Hunting
John Read, International Director Campaign to Ban Trophy Hunting
Daniela Freyer, Co-Founder Pro Wildlife e.V.
Dr Barbara Maas, Founder and Chief Executive, People for Nature and Peace


Sairusha Govindsamy, Climate Program, African Climate Alliance, South Africa
Dave Du Toit, Founder, Vervet Monkey Foundation, South Africa
Fiona Miles, Director, Four Paws (SA)
Jabu Myeni, Env, Education Programme, Gifted for Good, South Africa
Les Mitchell, Director, Institute for Critical Animal Studies (Africa)
Lex Abnett, Director, Southern African Fight for Rhinos, South Africa
Linda Tucker, CEO Founder, Global White Lion Protection Trust, South Africa
Lizaene Cornwall and Catherine Nyquist, Co-Founders, Panthera Africa Big Cat Sanctuary, South Africa Megan Carr, Founder, Rhinos in Africa, South Africa
Michele Pickover, Executive Director, EMS Foundation, South Africa
Renee Bish and Peter Oxford, Co-Founders, Betty’s Bay Baboon Action Group, South Africa
Sera Farista, Climate Justice Campaigner, Youth Climate Group, South Africa
Smaragda Louw, Director, Ban Animal Trading, South Africa
Stefania Falcon, Co-Founder, Future 4 Wildlife, Africa
Stephen Fritz, Indigenous Leader, South Peninsula Khoi Council, South Africa
Stephen Munro, Director, Centre for Animal Rehabilitation and Education, South Africa
Steve Smit, Co-Founder, Monkey Helpline, South Africa
Toni Brockhoven, Chairperson, Beauty Without Cruelty (South Africa)
Vivien Law, Regenerative Farming Program, Parliament for the People, South Africa
Wynter Worsthorne, Founder of Animal Talk Africa, South Africa

Image Credit: EMS Foundation

©WAPFSA 2023. All Rights Reserved.

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THE WILDLIFE ANIMAL PROTECTION FORUM OF SOUTH AFRICA APPEAL THE ENVIRONMENTAL AUTHORISATION PROVIDED TO TEEPSA FOR THE EXPLORATION WELL DRILLING IN BLOCKS 5/6/7 ON THE SOUTH WEST COAST OF SOUTH AFRICA

THE WILDLIFE ANIMAL PROTECTION FORUM OF SOUTH AFRICA APPEAL THE ENVIRONMENTAL AUTHORISATION PROVIDED TO TEEPSA FOR THE EXPLORATION WELL DRILLING IN BLOCKS 5/6/7 ON THE SOUTH WEST COAST OF SOUTH AFRICA
WAPFSA-Appeal-on-TEEPSA-567-ESIA_FINALDownload

The Department of Environmental Affairs acknowledged receipt of the Appeal submitted by Members of WAPFSA on the 10th of May 2023.

WAPFSA registered as an Interested and Affected Party and has previously submitted preliminary comments to the Draft Scoping Report and the Members of WAPFSA have also submitted comments on the Environment and Social Impart Assessment.

©WAPFSA 2023. All Rights Reserved.

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CAPE PENINSULA BABOON STRATEGIC MANAGEMENT PLAN

Members of the Wildlife Animal Protection Forum South Africa delivered a submission with their comments on the Draft Cape Peninsula Baboon Strategic Management Plan on Friday 31st March 2023.

READ THE FULL SUBMISSION HERE:

WAPFSA-Comments-Cape-Peninsula-BSMP-31032023Download

The Plan should be titled: CAPE PENINUSULA HUMAN-BABOON CO-EXISTENCE STRATEGIC MANAGEMENT PLAN (HBCEMP) this will speak to a more useful framework to help support more sustainable people-nature interactions in the context of the conservation of African baboons to achieve human-baboon coexistence, by balancing the integrity of nature with human wellbeing. A new ethos is necessary to ensure changes not only to what is done but how things are done. The MP should be based on Ubuntu and within the context of changing people’s attitudes to Nature and wild species so that they understand that their conservation is essential to the long-term flourishing of humanity and aspire to co-exist harmoniously within Nature instead of simply regarding wild species as merely economic “resources” or “damage-causing”.

WAPFSA believes that this merits a separate goal (Ubuntu and harmonious co-existence within Nature are promoted) which focuses on how conservation will be undertaken in future, with an emphasis on applying ethics such as Ubuntu to change how people view, and relate to Nature, and to contribute to ways for people to co-exist with wild species so that life in all its diversity can be sustained and that human wellbeing is increased as a consequence of protecting and restoring natural ecosystems instead of at their expense.

The Plan cannot be developed in a vacuum. It therefore must include a preface which provides the overarching context and background in relation to South Africa’s primate populations including the lack of credible data, the urgent need for a population census, regulation and oversight insufficiencies and the outdated legislative framework (both provincially and nationally) – for example, sections of the Western Cape Biodiversity Act have not come into effect, particularly the Ordinance has not been repealed and this relates specifically to the status and killing of baboons. Please take note of the contents and findings of this 2023 research report on South Africa’s nonhuman primates: 

OUR KIN DISCARDED, SOUTH AFRICA’S CRUEL AND GRATUITOUS TRADE AND KILLING OF (NONHUMAN) PRIMATES

Transformational changes (game-changing shifts) are urgently needed if we are to secure humanity’s future. To do this we need to address the interlinked emergencies of human-induced climate change and the loss of wild species. What is needed is a progressive vision and policy for conservation based on the ethic of Ubuntu and the recognition that humanity can only flourish in the long term by conserving the natural systems that support all life and finding ways to coexist in harmony with Nature.

Conservation policies and decisions must be guided primarily by ecological and welfare considerations, i.e. decisions about wild species and biodiversity must be based on ecological considerations (e.g. what is best for the ecosystem) and welfare considerations (e.g. treating wild animals with respect and without cruelty both for their own sakes and to foster consideration for other species in accordance with the ethic of Ubuntu.

WAPFSA notes that some organisations are of the opinion that the entire BSMP process is flawed and illegal. This needs to be taken seriously and investigated by the JMC to determine if all the necessary steps in this process were correctly followed.

WAPFSA wants to place on record that there are transparency and accountability concerns as stakeholders were not provided with the Terms of Reference of the CPBMJTT or the Memorandum of Agreement between the three parties. These are essential documents to verify policy, budget, or resources, amongst other things, from and between the three spheres of government involved. In addition, stakeholders were never informed of the criteria for the selection of the members of the CPBMJTT and had no opportunity to comment on such criteria.

WAPFSA requests that any changes to the existing Baboon Management programme be consultative and inclusive of all stakeholders.

WAPFSA is concerned that the City of Cape Town (“COCT”) Urban Baboon Programme is to be terminated in June 2023 with apparently no plan in place to ensure the safety and well-being of the Peninsula baboons. If the programme is resumed, WAPFSA is of the view that the protocols for the monitoring of baboons needs to be re-examined and re-imagined, through wide stakeholder consultation.

WAPFSA urgently requests a moratorium on the killing of baboons while the Management Plan is being amended, updated, consulted on, and implemented.

Image Credit: Jenny Parsons Pringle Bay, South Africa

©WAPFSA 2023. All Rights Reserved.

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REQUEST TO MINISTER BARBARA CREECY REGARDING THE EXPORT OF SOUTH AFRICAN CHEETAH TO INDIA

Members of the Wildlife Animal Protection Forum sent Minister Barbara Creecy a letter on Friday 24th of February 2023 with regard to the export of South African cheetah to India.

WAPFSA-REQUEST-TO-MINISTER-BARBARA-CREECY-RE-CHEETAHS_240223Download

The WAPFSA Members, who signed the letter to Minister Creecy, are concerned that the project to export twelve cheetah from South Africa to India every year for the next twelve years, which is being coordinated by DFFE, the Department of International Relations and Cooperation, the South African National Biodiversity Institute, South African National Parks, the Cheetah Metapopulation Initiative, the Faculty of Veterinary Science of the University of Pretoria, the Endangered Wildlife Trust with the Ministry of Environment, Forest and Climate Change of India, the High Commission of India, National Tiger Conservation Authority and Wildlife Institute of India and Madya Pradesh Forest Department, is relying on outdated an unpublished non-detriment finding and that the scientific information that this decision was based upon is not sufficiently robust.

The Requests include the following:

  1. Halt any further capture for export until Minister Creecy publishes for public comment an updated NDF supporting with credible data that similar exports will not be detrimental to the survival of the Species in South Africa. Such NDF will have to follow a public process before being finalised and gazetted as per NEMBA.
  2. Issue a public statement on the fate of the unfit cheetahs who were swapped and left behind on the 17th of February 2023.
  3. Provide clarity on the positive conservation outcomes from this project.
  4. Commit to reporting on the survival rate of the exported cheetahs, on an ongoing basis.

Image Credit: Brian Abrahamson

©WAPFSA 2023. All Rights Reserved.

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SPEAKING OUT AGAINST TROPHY HUNTING PRIOR TO THE JAGD UND HUND, EUROPE’S LARGEST HUNTING FAIR

Jagd und Hund Hunting Fair in Dortmund, Germany (Image Credit worldanimalsvoice.com 2022)

AN AFRICAN PERSPECTIVE ON THE NEGATIVE IMPACTS OF THE COLONIAL-STYLED COMMERCIALISATION OF ENDANGERED WILDLIFE SPECIES ADVERTISED AT JAGD UND HUND, IN DORTMUND IN GERMANY

24TH – 29TH JANUARY 2023

Advertised is the largest most prestigious shopping paradise for hunters, the 41st Jagd Und Hund is a trade show held annually in Dortmund in Germany, this year the show will be take place from the 24th to the 29th of January 2023.

Tens of thousands of animals are hunted and killed by hunters who pay handsomely for this pleasure. Many European and British citizens are losing the appetite to continue to support or participate in the colonial sport of trophy hunting.

This is an open letter written to the Mayor of Dortmund which has been signed by members of WAPFSA, members of the Pro Elephant Network and endorsed by a number of world renown wildlife conservationists, wildlife veterinarians, international dignitaries, politicians and environmental lawyers.

Please find the OPEN LETTER:

AN-AFRICAN-PERSPECTIVE-ON-THE-UPCOMING-DORTMUNDS-JAGDHUND-FAIR-2023-1Download

Image Credit: https://worldanimalsvoice.com/2021/06/22germany-your-hunting-and-dog-shame/

Germany – your “hunting and dog” – shame!

©Wildlife Animal Protection Forum South Africa 2023. All Rights Reserved.

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COMMENTS ON THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT FOR THE PROPOSED OFFSHORE EXPLORATION WELL DRILLING IN BLOCK 5/6/7 SOUTH WEST COAST OF SOUTH AFRICA

WAPFSA Members formally submitted comments on TEEPSA ESIA on the 7th December 2022.

WAPFSA-COMMENTS-ON-TEEPSA-ESIA-071222Download

The Wildlife Animal Protection Forum South Africa (WAPFSA) submitted preliminary comments to the Draft Scoping Report (DSR) on the 4th of July 2022. This network consisting of thirty-one member organisations remains deeply concerned about the overall lack of urgency in addressing the shift towards renewable energy alternatives in South Africa.

We highlight the fact that the public response to the DSC (Annexure 4.2- Comments to the DSR) reflects an overwhelming outcry against the proposed project.

This negative response to the prosed project included well-represented feedback from local municipalities, provincial and national government authorities, and National Parks and Provincial Environmental authorities.

The public adverse response to the project included representation from ratepayers’ associations, community associations, councils and coalitions, scientists and researchers, representatives of local businesses and a very large number of concerned local residents.

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WILDCHOICES

Members of the Wildlife Animal Protection Forum Formally Distance Themselves from WILDCHOICES

A formal communication was delivered to the owners of WildChoices and the South African Tourism Services Association on Wednesday 7th of December 2022.

WAPFSA-RE-WILDCHOICES-LISTING-OF-FACILITIES-071222Download

WILDCHOICES LISTING OF WILDLIFE FACILITIES

The Wildlife Animal Protection Forum South Africa (WAPFSA), is a network of thirty-one diverse South African NGOs that share certain values, knowledge and objectives, and that collectively comprise a body of expertise in various fields in South Africa, from scientific, conservation, and welfare, rights, tourism, social justice, indigenous rights, public advocacy sectors and the law.

The South African Tourism Services Association (SATSA) is a member-driven, non-profit association representing the private sector. In 2018 SATSA established a Board Committee on Captive Wildlife Interactions and commissioned BDO South Africa, an independent consulting firm, to:

  1. Define the types of entities that fall within the ambit of captive wildlife interactions including standardising definitions and terminology;
  2. Develop an ethical framework to evaluate operations that involve captive wildlife interactions to underpin the debate and establish the principles upon which the ethicalness of animal interaction operations may objectively be evaluated; and,
  3. Develop a set of guidelines for the self-regulation of captive wildlife interaction tourism experiences.

In November 2019 SATSA published their Captive Wildlife Attractions and Activities Guidelines and Decision Tool which is endorsed by a number of organisations.

Apparently, in 2021, two members of the 2018 SATSA Board Committee, Brett Mitchell and Gavin Reynolds founded WildChoices which is owned by Wildly Adventures (Pty) Ltd (reg No: 2020/635217/07), to identify and assess all the captive wildlife interaction facilities in South Africa using the SATSA Guidelines and Decision Tool.

According to the information on the website: ‘WildChoices assists local and international tour operators, agents, and individual travellers to make informed, ethical choices about captive wildlife tourism facilities in South Africa’. WildChoices employs the SATSA Decision Tree to make its assessments.
After receiving complaints about various listings on the WildChoices website, WAPFSA conducted internal research and discovered numerous potentially problematic listings, for example, WildChoices has listed zoos, petting zoos and facilities that have traded wild animals as places to “support with caution”.

WAPFSA organisations do not support the captive wildlife industry, especially where animals are utilised for entertainment and/or breeding for trade.
It is an additional concern that animal welfare issues and trophy hunting are not considered in the SATSA Decision Tree.

As testimony to the fact that this Tool is faulty and inaccurately applied, a Member of WAPFSA has been wrongly listed on the WildChoices’ website. To be more specific, the Global White Lion Protection Trust (“GWLPT”) has been listed as a facility “to avoid”. GWLPT is a non-profit, non-commercial organisation, and not a tourist facility – and therefore does not qualify for listing in the first place. Some of our members have objected to this inaccuracy to WildChoices and have asked specific questions of relevance, which have not been answered by WildChoices.

Until such time as these errors are corrected and the Tool is vetted by WAPFSA as a valid measure of unethical establishments, we as a forum cannot support or be associated with this initiative. We therefore formally distance ourselves from the WildChoices listing.

SIGNED BY MEMBERS OF WAPFSA

Image Credit: EMS Foundation

©WAPFSA 2022. All Rights Reserved.

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WAPFSA INFORMS EUROPEAN POLITICIANS ABOUT RECENT SURVEY AND STUDIES ON THE SUBJECT OF TROPHY HUNTING IN SOUTH AFRICA

WAPFSA members appreciate the concerns of European politicians and decision-makers, with regard to supporting the implementation policies that might negatively affect developing countries such as South Africa.

The Care2 Petition titled “It’s Time to Ban Trophy Hunting in South Africa” has 432 635 supporters.
https://www.thepetitionsite.com/en-gb/200/628/320/its-time-to-ban-trophy-hunting-in-south-africa/

WAPFSA members were recently offered the opportunity to address the German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety.

WAPFSA used this opportunity to share, amongst other, the results of surveys recently conducted which reflect the view of South Africans on the subject of trophy hunting in South Africa.

A IPSOS Survey commissioned by the animal protection charity Humane Society International Africa revealed that 68% of the South African population oppose trophy hunting and the majority oppose the practise of canned lion hunting. The survey reported only on local data sourced from a diverse South African demographic across all provinces.

 WAPFSA members reminded the German Federal Ministry representative about the fact that trophy hunting is rooted in colonial modes of extraction which perpetuate notions of abuse, subjugation, control and inequality, including gender inequality.

WAPFSA members referred to Dr Muchazondida Mkono, whose research focuses on sustainable tourism and ethical tourism including wildlife tourism, environmentalism, tourism impacts and air travel. Dr Mkono states that existing studies on the trophy hunting controversy in recent years have largely represented the anti-hunting views of the Western public, while overlooking the opinions of African people.

Her research has found that trophy hunting was objectionable as a consequence of its complex historical and postcolonial associations−the dominant pattern was resentment towards what was viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife. The growing concerns in relation to trophy hunting include its social, environmental and economic impacts. Trophy hunting artificially selects the biggest and strongest animals (largest tusks and thickest manes), weakening populations’ genetic health and variation. Research also suggests that increasing selectivity of trophy hunting is strongly associated with an increasing risk of extinction. Trophy hunters target the largest, strongest individuals. Killing the lion pride male, the matriarch of the elephant herd, big males or irreplaceable tuskers results in social dislocation in the surviving members of the group, disrupting social bonds and behaviours. Trophy hunting undeniably damages the structure and viability of wild populations of animals.

WAPFS referred to a 2022 Report by Good Governance Africa (GGA), a South African not-for-profit organization whose mandate focuses on research and advocacy to improve governance across Africa, questioned whether the South African government had grounds to determine trophy hunting quotas and whether they should promote trophy hunting as a conservation tool on economic grounds. In addition to Economists at Large, Paksi and Pyhälä and Koot, the Report argues that trophy hunting does not play an important role in the economic development of African communities.

Furthermore, WAPFSA members included the details of a study by the World Travel & Tourism Council which confirmed that wildlife is worth more alive than dead. In another study conducted in eight African countries by economists, it was concluded that, tourism which relies for the most part, on wildlife contributed between 2.8% and 5.1% of GDP, and foreign trophy hunters made up less than 0.03% of the same GDP on average. Similarly, photo safaris, in comparison, allowed for sustainable, lucrative tourism activities without killing wildlife.

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NOMINATIONS FOR MINISTERIAL LION TASK TEAM

PUBLIC STATEMENT FRIDAY 26TH AUGUST 2022

THE APPOINTMENT OF SOUTH AFRICA MINISTERIAL TASK TEAM TO IDENTIFY AND RECOMMEND VOLUNTARY EXIT OPTIONS AND PATHWAYS FROM THE CAPTIVE LION INDUSTRY 

On the 21st and 22nd of August 2018, the Portfolio Committee on Environmental Affairs conducted a successful colloquium on the Captive Breeding of Lions for Hunting and the Lion Bone Trade.  There was an overwhelming consensus from the local and international stakeholders, participating in the colloquium, that the South Africa must bring an end to this controversial practice that is threatening to harm the proud conservation image of our country.  The subsequent Report by the Portfolio Committee was adopted by Parliament, they requested that the Department of Forestry, Fisheries and the Environment initiate a policy and legislative review with a view to putting an end to the captive breeding of lions for hunting and the lion bone trade. 

On the 10th of October 2019, the Minister of Forestry, Fisheries and the Environment appointed a High Level Panel of Experts in response to a number of emotive and complex conservation and sustainable use issues including the lion bone trade, the hunting of captive bred lions, the elephant culling debate, the ivory stockpile and the trade in rhinoceros horn.

On the 2nd of May 2021, the High Level Panel Report, which had been approved by the Cabinet, was released.   The majority of the High Level Panel recommended that South Africa does not captive breed lions, keep lions in captivity, or use captive lions or their derivatives commercially.  Honourable Minister Barbara Creecy requested that the Department action this accordingly and ensure that the necessary consultation for implementation is conducted.

On the 12th of August 2022 the Minister gave notice of her intention to appoint a Ministerial Task Team that will function as an advisory committee, to identify voluntary exit options and pathways from the captive lion industry, and to oversee the implementation and monitoring of the same. 

The prerequisite Members of the appointed Task Team, were such that when viewed collectively, must be persons who are selected by virtue of qualifications, expertise, and experience. 

After careful consideration the Members of the Wildlife Animal Protection Forum (WAPFSA) nominated and endorsed seven eligible candidates, the details of whom have been presented to Dr Tsepang Makholela. 

0-WAPFSA-NOMINATIONS-LETTER_VOLUNTARY-EXIT-TASK-TEAM.doc-2Download

The Members of WAPFSA acknowledge their candidates for their preparedness, their disposition and their inclination to assert themselves for this task. 

0-WAPFSA-Organisational-Profile-26.8.2022-1Download

END OF STATEMENT

Image Credit: Gurcharan Roopra Photography

©WAPFSA 2022. All Rights Reserved.

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TEEPSA 5/6/7 THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA MEMBERS SUBMISSION

Monday 4th July 2022

Following the release of the draft scoping report for a 30 day comment period on the 20th May 2022, SLR Consulting received several requests for an extension of the comment period on the Draft Scoping Report. Members of the Wildlife Animal Protection Forum submitted comments today.

TotalEnergies Exploration & Production South Africa (TEEPSA) and its Joint Venture partners invited consultation with interested and affected parties with regard to their proposal to undertake exploratory well drilling in Blocks 5/6/7 a 10 000 square kilometre area between Cape Town and Cape Agulhas.

COPY OF WAPFSA SUBMISSION:

WAPFSA-SUBMISSION-TEEPSA_040722Download

TOTALENERGIES – ESIA FOR PROPOSED EXPLORATION DRILLINGS IN BLOCK 5/6/7

The Wildlife Animal Protection Forum South Africa (WAPFSA) is an alliance of South African based organisations which share certain values, knowledge and objectives and which collectively comprise a body of expertise from scientific, conservation, legal, welfare, rights, social and climate justice, public advocacy sectors.

WAPFSA has registered as an I&AP.

COMMENTS

1. Meaningful Consultation

The undersigning members of WAPFSA believe that the communities living in highly populated areas of the South Western Coast must be meaningfully consulted about the proposed perspective operations which may impact upon their customary rights, which include customary fishing rights and livelihoods. The ocean is also integral to the Khoisan community’s cultural identity and customary system.

These communities should have been engaged with in person (they don`t read national newspapers and cannot be consulted via virtual meetings, nor would they have the opportunity to travel to Cape Town in order to  attend an in-person meeting, such as the meeting which was held in Cape Town on the 9th of June, on a working day at 4h00 pm). 

The TEEPSA project has, in our view, been poorly advertised and the subsequent communication by SLR Consulting has in our experience been inadequate.  

Indigenous communities have strict rules about consultation that emphasise the importance of seeking consensus within the whole community. In the High Court Judgement: Sustaining the Wild Coast NPC vs MRE, Shell Explorations, Case No. 3491/2021 of 28 Dec 2021, it is noted: 

[26]       ‘Meaningful consultation entails providing communities with the necessary information on the proposed activities and affording them an opportunity to make informed representations’. 

WAPFSA members believe that TEEPSA-567 had a duty to meaningfully consult with the communities and individuals who could be impacted by this project.

2. Climate Change

“Ignoring climate change will yield ‘untold suffering,” a panel of 14,000 scientists warned in July 2021, calling for urgent global deal on climate policies[1]. We have reasonable apprehension for irreparable harm on residents and the environment, resulting by both drilling and extracting operations.  

In  May 2022, a Report from the United Nation Office for Disaster Risk Reduction (UNODRR), warned of ‘Total Societal Collapse’ due to breaching of planetary boundaries. The Report is GAR 2022 and was endorsed by UN Secretary-General António Guterres. The report indicated that escalating synergies between disasters, economic vulnerabilities and ecosystem failures are escalating the risk of “global collapse”. For the very first time, the UN has openly flagged that existing global policies are accelerating toward the collapse of human civilisation. 

3. Predicted Impacts, Potential Harm and Risks

We are particularly concerned about all the predicted and unpredicted impacts and risks on people, their businesses and livelihoods and on wildlife and the environment. 

Drilling discharges and normal discharges such as deck drainage, machinery space drainage, sewage and galley wastes from the drilling unit and support vessels will all result in reduction of water quality in the area. Water quality will also be impacted at both local and regional levels due to accidental oil spills during the exploration drilling or in the event of a blow-out. These spills will have adverse effects on marine fauna and will also result in the oiling of coastal habitats and seabirds.

WAPFSA members are concerned about the migration of about 130.000 whales from East Africa trough the prospected areas, towards the Cape where they breed and nurse their young. Concerns also refer to the interference with many delicate species as Turtles, Cape Fur Seals, African Penguins and the Black Oystercatcher. 

These species all stand to be negatively affected by the proposed well drilling, irrespective of whether the project area avoids all MPAs. The fact that the project has even a 5,4% overlap with Critical Biodiversity Areas is a cause for concern as the physiological, mental and emotional effects of the drilling has been seen to cause negative impacts varying in severity, the most severe resulting in death of a variety of marine faunal species. 

In terms of the benthic habitats which might be affected, of the marine species, 98% live on or in the ocean floor[2]. These benthos or bottom dwellers can live buried in the sand, shells or mud or attached to rocks. Sedentary benthic species and other relatively immobile species will experience smothering and biochemical effects, such as direct toxicity and bioaccumulation of the discharge of cuttings, drilling fluid and cement during the well drilling process. The benthic zone maintains a substantial part of the world’s biodiversity. These areas are extensively exploited and destroyed by human activities[3].

[1] Ignoring climate change will yield ‘untold suffering,’ panel of 14,000 scientists warns | Live Science

[2] Thurman, 1991

[3] Investigating the effects of mobile bottom fishing on benthic biota: a systematic review protocol | Environmental Evidence | Full Text (biomedcentral.com)

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