SUBMITTED ON THE 15TH JUNE 2020
The submission relates to the Management, Breeding, Hunting, Trade, Handling and Related matters to the Elephant, Lion, Leopard and Rhinoceros.
Please note that this Submission is non-exhaustive and does not represent all the responses to the issues and matters raised herein. We reserve the right to provide any further or additional information on aspects raised herein.
We are submitting so as to be able to record our initial high-level views and resources; however, our Submission is by no means a complete one in relation to the topics, objections or matters that may be raised.
We wish to note upfront that we believe there are various issues with the contents, processes, and related matters in respect of the Panel generally, as well as the Call for Submission. Consequently, our Submission does not constitute a waiver of any rights we may have, including but not limited to challenging the Department, the High-Level Panel/ Advisory Committee or otherwise, or take any other action we deem fit in respect thereof.
Specifically, we believe that insufficient time and notice has been provided for us to provide complete comments. The entire process on this Call for Submissions has been done during a declared National State of Disaster and lockdown of the country. During this time, particularly as NGOs, we have experienced major strain on our resources and capacity to deal with matters.
The views expressed herein are those of the two organisations and do not necessarily represent those of every individual director, member, employee, representative, volunteer, affiliate or others of either EMS and/or ALRSA.
We have attempted to be as comprehensive as possible, given the time, resources and other relevant factors and constraints, however we may not have responded or included each and every relevant consideration. Accordingly, it should be noted that different persons have provided input and we have tried within these constraints to collate this input as effectively, consistently, and practicably as possible.
We have further attempted to reference as footnotes or hyperlink the resources relied upon for this submission. Should you require any further information in respect of these or the Submission more generally, we are happy to provide these.
We reserve any and all rights, remedies and actions available to us.
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