On the 24th July 2024, this submission was made by the Wildlife Animal Protection Forum of South Africa (WAPFSA) in response to the draft Biodiversity Management Plan for Black Rhinoceros (Diceros Bicornis) and White Rhinoceros (Ceratotherium Simum) in South Africa published under Government Notice 4980 in Government Gazette 50829 of 18 June 2024.
WAPFSA was established as a vehicle to engage with government on wild life issues, and to put wild animals onto the political agenda based on ethical and compassionate conservation and harmonious coexistence within nature.
WAPFSA is a civil society network currently consisting of twenty eight (28) South African-based protection, conservation, environmental and community organisations that share certain common values, expertise and objectives.
WAPFSA’s activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy. WAPFSA also advocate for the concepts of UBUNTU, the intrinsic value of wild animals and an integrative policy approach.
Collectively, WAPFSA offers the South African government, a body of expertise from scientific, animal welfare, rights, social and climate justice, indigenous knowledge, public advocacy sectors and environmental law experts.
Given all the issues raised in this submission, WAPFSA’s recommendations are:
Close the domestic market for rhino horn by imposing a moratorium.
Conduct on-going mandatory audits of private and state-owned rhino horn stockpiles.
Strengthen and Improve law enforcement and operations to dismantle rhino horn trafficking syndicates.
Cooperate with all relevant and national foreign authorities.
Shut down all facilities that breed rhino for any purpose other than solely for conservation.
South Africa must abandon the idea of trading in rhino horn and encourage other Range States to do the same.
Rather than banking on the extinction of rhinos, South Africa must embrace rhino horn stockpile destruction as an anti-poaching, anti-trafficking, and demand reduction tool to meaningfully contribute to the ethical protection of rhino populations in Africa and Asia and to mitigate their extinction. Doing so will send a strong signal that South Africa is firmly committed to preserving and protecting rhinos, and to truly ensuring their welfare and well-being.
By virtue of the precautionary approach, South Africa, and other CITES States Parties must act in the best interest of the conservation of the species and urgently uplist rhinos currently on Appendix II to Appendix I.
EMS Foundation Address at the Four Paws State of Animal Welfare in South Africa Event
Michele Pickover, Executive Director of the EMS Foundation and founding member of WAPFSA delivered an address at WAPFSA close colleagues’, Four Paws South Africa, event in Cape Town on Friday evening 10th May 2024. The subject matter is extremely relevant considering that South Africans will be voting in the seventh democratic general election on the 29th May 2024.
“I cannot really talk about the Wildlife Animal Protection Forum of South Africa – WAPFSA for short – without referring to the historical context, because it has a lot to do with where WAPFSA is located and what we focus on.
In 1994, those of us that had been fighting the animal protection battle for years, were optimistic that our new democracy would also bring positive changes for non-human animals in South Africa – precisely because of the systemic commonalities which oppress both humans and nonhumans. Clearly, other animals were also victims of the systems of colonialism and apartheid. In essence, what we were advocating for – and still advocate for – is inclusive justice – one struggle – showing compassion across the species barrier and building a better future in a post-Apartheid South Africa.
As Archbishop Desmond Tutu observed – and I quote – “I have seen at first- hand how injustice gets overlooked when the victims are powerless or vulnerable, when they have no one to speak up for them and no means of representing themselves. Animals are in precisely that position. Unless we are mindful of their interests, and speak out loudly on their behalf, abuse and cruelty goes unchallenged.”
Other animals are sentient, conscious, feeling, and thinking beings; they have complex needs and relations; they have a will to live; and they play key roles in ecological systems necessary for our own existence. They have a life before they are traded, captured, enslaved, hunted and killed. They have agency. Indeed, they have their own cultures and traditions.
Nonetheless, they are conveniently kept in large amorphous groups and then disassembled and packaged in ways that reinforce the collective and conceal their individuality. They are viewed as a source of income, or as part of an aesthetically pleasing landscape, mere scenery – a backdrop to human activities. They are refigured, devoid of identities and, to all intents and purposes, almost invisible and imaginary.
If our non-human compatriots could speak our languages though, they would tell us they do not want to be our food, our trophies, our entertainment or our research tools.
After the death of apartheid, there was a window of opportunity for inclusive justice to be part of the process of building a new society and for the interests of non-human animals to be included in our new Constitution. Sadly, this never happened. And in relation to “wild animals,” there was no transformation of policies – but rather a seamless continuation – and in many ways a speeding up of existing exploitative practices and beneficiaries, including the so-called “wildlife industry”.
Historically, South Africa has always taken a pro-consumptive use stance in relation to wild animals. In the past it was so that a few people could benefit and have private hunting grounds. Now it is located within the language of development.
So, in a very real sense the South African government was – and still is – a formidable barrier to those fighting for justice for animals. In the wild life space, government was also only meeting with industry – via the Wildlife Forum – and, consequently, their agendas were driving government policies. Indeed, it is because the State was not taking any legislative responsibility that it has, to all intents and purposes, outsourced and devolved animal welfare issues to under-resourced animal welfare NGOs.
This is all particularly concerning because we are living in the Anthropocene Sixth Extinction Crisis. And humanity is the cause of this catastrophic collapse of nature’s ecosystems which is killing species and disrupting vast intricate webS of life. Currently there is an average 69% decline in wildpopulations globally. This is of existential importance.
Clearly, our fates are intertwined, and what we do to wild life, we do to ourselves. Because nature is in trouble, we are in trouble. Further massive losses in biodiversity can be prevented, BUT only through radical TRANSFORMATIVE change”. The world is speeding headlong toward disaster in flagrant disregard of science. And rhetoric, policy-making, and global agreements thus far have amounted to very little. A new moral compass, is desperately needed to guide and inform the institutional and conceptual changes necessary in this world.
So…..getting back to South Africa. There was no channel available for animal protection organisations to address their concerns to the government.
WAPFSA was therefore explicitly set up and designed as a vehicle to engage with the government on wild life issues and to put wild animals onto the political agenda, on the basis of ethical and compassionate conservation and harmonious coexistence within nature.
Our members share clearly articulated principles that are part of our Founding Document, initiated in 2016.
Our common goal is to safeguard and protect wild animals and their welfare and well-being, as well as biodiversity, individual species, individual animals and the interests of fragile people. All our activities are underpinned by an understanding that the inter-relationship between environmental protection, animal well-being, conservation and the values of dignity, compassion and humaneness are foundational to our constitutional democracy. We also advocate for the concepts of UBUNTU, the intrinsic value of wild animals and an integrative policy approach.
Also key to WAPFSA’s activities is the understanding that there is an urgent need to reimagine human-animal relations and that animal welfare and climate change are intertwined.
Currently there are 30 organisational members of WAPFSA – including other large networks and movements, for example The Climate Justice Charter Movement. The WAPFSA members span various areas of expertise, including: advocacy; education; Rights, Welfare, Conservation and Faith based approaches; species specialists; rescue and rehabilitation; legal and litigation; research; investigation; conflict mitigation and mediation; food sovereignty; community support and engagement; and indigenous knowledge.
Where there were previously silos, WAPFSA fosters collaboration, solidarity, unity, and action- to powerfully and collectively – lobby, campaign, mainstream and provide solutions to critical challenges and burning issues facing wild animals, nature and people in South Africa.
To conclude, WAPFSA’s strength lies in our unified approach to addressing these pressing issues from DIVERSE perspectives in an ethos of care and within the framework of inclusive social justice, so that our society can be transformed and so that we can all become good citizens of the BIO community. ALUTA CONTINUA AND THANK YOU.”
WAPFSA have sent an urgent letter to the Minister of Forestry, Fisheries and the Environment, Barbara Creecy with regard to the permit that was issued by LEDET to shoot to kill twenty baboons in the Blyde River Botanical Reserve in Limpopo Province. The permit is valid for one month and commences today, according to correspondence that we have received a hunter has been commissionedand he will be using a silencer.
WAPFSA addressed an urgent cease and desist letter to the Limpopo Department: Economic Development, Environment and Tourism today. Please download the letter:
The WAPFSA cease and desist letter sent this morning refers:
We have been advised that the permit to shoot and kill a troop of baboons in their natural range, has been issued by the LEDET. The culling exercise over the period of one month will be starting today 6th May 2024 at the Blyde River Botanical Reserve in the Limpopo Province. This permit has been apparently issued to reduce the baboons’ presence and so-called destructive nature, and a hunter has been appointed for the task.
We believe that it is the onus of the permitting authority to verify if the conditions to issue a permit exist and are legitimate, particularly when such issuing can have so grave consequences on the environment and the well-being of animals.
Please confirm that all procedures have been put in place and you have verified that:
a. There is effective proof of the so-called damage the baboons have caused. b. Methods used to discourage baboons from entering the residences in the aforementioned botanical reserve have been unsuccessfully applied; c. Photographic and video evidence of the destruction that these baboons have caused, have been provided to LEDET; d. Photographic evidence that baboon-proof measures and all mitigation procedures have been unsuccessfully put in place by the Reserve management, have been provided to LEDET before LEDET granted the permit.
Providing a permit to kill baboons because humans are inconvenienced is no legal basis upon which to issue such a permit. Kindly confirm the above.
The Wildlife Animal Protection Forum (WAPFSA), is a forum consisting of thirty South African organisations that are all actively involved with the protection and conservation of wild animals and the natural environment in South Africa. The members share a body of expertise from vastly different fields including, but not limited to, science, the environment, the law, animal welfare, human and non-human rights, social justice, the climate, the ocean, the indigenous perspective and public advocacy.
For the reasons expressed below in this document, WAPSA members firmly oppose the Adaptive Management Plan to move the Pringle Bay baboon troop out of the urban area, announced by the Overstrand Municipality on the 29th of April 2024.
In particular, WAPFSA opposes the reintroduction of weapons as a means to manage the baboons in Pringle Bay, because there are good reasons to believe that it will have a negative impact on the welfare of baboons and will not solve the problems.
WAPFSA proposes that the municipality adopt a different approach, focusing on tackling the factors drawing baboons into residential areas, as detailed further below.
In 2021 the residents of Pringle Bay highlighted the following points for change, these points are still applicable today:
No resident wants the baboons in their houses, but they also don’t want baboons constantly harassed, chased and shot at.
A shepherding approach needs to be followed by all monitors. The previous system used in Pringle Bay by the PBRA/PBBAG was an excellent method of managing the baboons. The monitors were polite and loved the baboons. They also notified residents by blowing whistles, clapping and ringing doorbells when thebaboons were in the area.
The infringement of private property needs to stop. Pringle Bay residents are tired of seeingbattles intheir gardens. Plots are crossed on foot by monitors, damaging sensitive fynbos.
Waste management needs to be addressed. Baboon-proof bins must be used by residents.The public bins scattered all over the Overstrand need to be fixed and maintained to prevent baboon access. Holidaymakers need to be made aware by rental agents and/or homeowners of the baboons. Homeowners also need to ensure any waste is disposed of in the correct way, e.g. taken to the dump, not left on the side of the road.
Signage at holiday homes, restaurants and shops must be erected. The message should be clear: no feeding of the baboons, no illegal dumping.
Newresidentsshouldbemadeawarebyestateagentsthattheyliveinabiosphereandithas animals that we need to protect. An information welcome pack should be provided to all new residents, and new builds and placed in the rental properties for the educational value it can provide regarding the presence of baboons in the area.
Houses must be baboon-proofed and access by baboons prevented. Special groups within the village should be set up to advise new residents on baboon proofing, etc. Building plan approval should be conditional on the inclusion of baboon proofing.
Shop owners in the central business district should display baboon information in their windows and have information pamphlets available to the public. Baboon-proofed bins and baboon safety doors should be requirements for all business owners.
Conclusion
WAPSA Members Oppose the Adaptive Management Plan to Move Pringle Bay Troop Out of the Urban Area Announced by the Overstrand Municipality on the 29th April 2024
WAPFSA hereby officially opposes the reintroduction of weapons as means to manage the baboons in Pringle Bay.
WAPFSA is hereby officially appealing for the immediate cessation of the anti-baboon rhetoric and the dangerous disinformation campaign that is being allowed to perpetuate on social media, which is fuelling the aggressive behaviour of some of the men in Pringle Bay.
KVET has conducted meetings with the South African Police Services and a criminal attorney and can confirm the activities that they are carrying out in Pringle Bay are not illegal. KVET is not collecting data on the residents of Pringle Bay, they are not hindering or obstructing the Overstrand Municipality employees in any manner whatsoever.
KVET is carrying out valuable community work in Pringle Bay at no cost to the Overstrand ratepayer.
A number of baboon experts, who have vast documented experience working with the Pringle Bay troop, have offered their learned opinions about the current baboon behaviour in Pringle Bay. A non-violent, transparent management strategy agreed upon by all stakeholders must be sought so that the troop can safely enter their sleep sites.
The Municipality should be encouraged to rebuild the waste dump site at no cost to the ratepayers and to make sure that residents baboon-proof their homes and the waste bins.
C.A.R.E. PRESENTATION ON WEDNESDAY 20TH MARCH 2024 TO THE MEMBERS OF THE WILDLIFE WELL-BEING FORUM
WAPFSA members Samantha Dewhirst and Stephen Munro from the Centre for Animal Rehabilitation and Education, C.A.R.E, invited the members of the Wildlife Wellbeing Forum to watch their presentation today. The objective of the presentation is to advise the Department of Forestry, Fisheries and the Environment and the Provincial Conservation Agencies, that there is a need to comply with the new provision of NEM:BA which now encompasses animal well-being. The presentation was also to encourage the increased protection of primates.
WAPFSA Members Agree and Request the Following from the Department of Forestry, Fisheries and the Environment:
All indigenous primates must be added to the TOPS list
Complex NDF’s are required for all indigenous primate species
Norms and Standards for all indigenous primate species need to be developed
A moratorium should be put in place until the NDF and N&S process, including transparent stakeholder consultation, is completed.
The Members of the Wildlife Animal Protection Forum of South Africa addressed an urgent letter to the Chief Executive Officer of the Mpumalanga Tourism and Parks Agency with regard to their concerns about permits issued by the MTPA which would enable the cruel, indiscriminate and unscientific management of vervet monkeys in Mpumalanga.
GRAVE CONCERNS ABOUT MPUMALANGA PROVINCIAL AUTHORITIES ENABLING THE CRUEL, INDISCRIMINATE AND UNSCIENTIFIC MANAGEMENT OF VERVET MONKEYS
The Wildlife Animal Protection Forum of South Africa (WAPFSA), a collective of thirty organisations, has a history of interest in the protection and conservation of wild animals in South Africa, sharing a body of expertise from different sectors including but not limited to scientific, environmental, legal, welfare, rights, social justice, climate, indigenous and public advocacy backgrounds.
Members of WAPFSA are also part of the Ministerial Wildlife Well-being Forum, instituted by the Department of Forestry, Fishery and the Environment (DFFE) in May 2023, by special request of Minister Barbara Creecy, in order to consult with organisations focused on best practices for the protection of wildlife.
The NEM:BA amendments came into effect on 30 June 2023. The Honourable Minister of Forestry, Fisheries and Environment, is currently in the process of implementing a legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals and to make regulations in relation to the well-being of wild animals, as per Section 2 of NEM:BA.
In the aforementioned section of NEM:BA, it is specified that all procedural activities that constitute biodiversity management, conservation and sustainable use of wild animals, including the issuing of permits, must consider the well-being of animals.
Section 9A of NEM:BA in particular, refers to any activity where there is reasonable evidence of a potential negative impact on animal well-being, using the wording “that may have a negative impact” which means that it is not required to have absolute proof of a negative impact to prohibit any activity. It implies that a precautionary approach, in line with the NEMA principles, must prevail.
WAPFSA members wrote a letter to the Minister of Forestry, Fisheries and the Environment on the 14th December 2023 requesting the inclusion six indigenous non-hum primate species in the South African Threatened or Protected Species Listing.
It is the Minister’s discretion to list species that fall into the criteria in Section 56 (1) (d): protected species. Such species do not necessarily have to be mentioned in other conservation lists such as the IUCN List or any other external lists. Provided that the proposed species fall into the description of those categories, they can be added to the TOPS list.
This followed the formal request from WAPFSA members on the 21st November 2023.
Despite new provisions in NEM:BA and a new vision of “secured, restored, and rewilded natural landscapes with thriving populations of Elephant, Lion, Rhino, and Leopard, as indicators for a vibrant, responsible, inclusive, transformed, and sustainable wildlife sector” this version of the TOPS Regulations remains focussed on the monetization of wildlife, including the endorsement of the continuation of certain activities such as commercial exhibitions, travelling exhibition of TOPS species, which include zoos and circuses and the continuation of the breeding, trading and exporting of TOPS.
In a reply from Minister Barbara Creecy to a letter from WAPFSA members Ban Animal Trading/EMS Foundation: “The legislative mandate to regulate the well-being of wild animals, which has been included in NEM:BA as an amendment through the National Environmental Management Laws Amendment Act, 2022 (Act No. 2 of 2022), came into force on 30 June 2023 when Proclamation Notice No. 125 was published in Government Gazette No. 48869. I now have the legislative mandate to prohibit activities that may have a negative impact on the well-being of wild animals, and to make regulations in relation to the well-being of wild animals. These legislative amendments will be initiated in due course.”
WAPFSA members have proposed the addition of non-human indigenous primates to the current TOPS list as protected species.
South Africa is home to six indigenous non-human primate species: the Chacma baboon, Samango monkey, Vervet monkey, Thick-tailed Bushbaby, Southern lesser Bushbaby, and Mozambique dwarfed Bushbaby.
WAPFSA Members strongly support the fact that non-human primates have high conservation value and national importance which require regulation in order to ensure that these species are managed in an ecologically sustainable manner and are protected in compliance with Section 24 of the Constitution.
The Wildlife Animal Protection Forum of South Africa WAPFSA is a collaborative network consisting of 30 (thirty) organisations representing the interests of wild animals and the natural environment as a vehicle with which to engage with the South African government on subject matter which includes, amongst other, wild animal protection, ethical and compassionate conservation, welfare, biodiversity loss and climate change.
South Africa is home to the world’s largest commercial lion farming industry. Lions are bred, often in appalling conditions, they are exploited for profit at every stage of their short lives.
At some facilities in South Africa cubs are removed from their mothers within a few days of their birth and are placed in the care of unsuspecting foreign and local volunteers who pay handsomely for the opportunity to look after “orphaned lions and other big cats”. Captive lions and other big cat cubs are also utilised in cub petting and various tourist interaction industries such as “walking with lions”.
When the cubs have reached the desired age and are no longer considered safe to be utilised in the tourist industry some of the lions are hunted for trophies either for the local hunting industry or for trophies that are exported to countries that condone canned lion hunting. Canned lion hunting reserves in South Africa typically have reinforced fences to prevent the lions from escaping during a hunt. Some of the lions are kept in small enclosures so that hunters with minimal skill, energy, patience or time can still successfully kill them.
The Members of WAPFSA are pleased that the Minister and the Department of Forestry, Fisheries and the Environment are finally initiating concrete steps against this distasteful industry. We encourage the South African government to do more to prevent the disturbing practices taking place at these breeding facilities.
WAPFSA members remain concerned about the trade, including live lions, the hunt and consumption of lions and all big cats and they stress the need for a just transition and re-establishment of harmonious coexistence with Nature and the protection of the web of life.
WAPFSA members support the acknowledgement of sentience in this Document and recommend that sentience is included and recognised in all DFFE policies and legislation in relation to wildlife. The inclusion of sentience is in line with the implementation of NEM:BA and the principles of wildlife well-being.
In the Draft prohibition, we noted the mention of the prohibition, of the introduction of live specimens of African lion; this therefore covers the prohibition of breeding and introducing new cubs. WAPFSA members are of the strong opinion that sentience should be referenced in this Prohibition and all the policies in relation to wildlife, underscoring the current efforts to implement principles of animal well-being as stated in NEM:BA and they stress that sentience should for no reason been removed in the finalised version of the document.
WAPFSA members would like the Draft Prohibition to properly address the issue of stockpiling, and implement the abolishment of all big cat bone stockpiles.
The prohibition to breed ALL big cats in South Africa is urgently required as currently there is a lack of effective monitoring and regulation at captive breeding facilities to monitor births, deaths transportation of live cats and the disposal of carcasses. This means that captive breeding facilities can act as a conduit for illegal and illicit trade. Similarly, prohibitions should be urgently promulgated to end the handling of, petting of and interactions with lions by humans for commercial purposes.
