ENOUGH IS ENOUGH:
HOW SOUTH AFRICA’S POLICIES ARE KILLING
AFRICA’S WILD ANIMALS.
A document prepared for CITES COP 17
EDITOR: Michele Pickover
RESEARCHER: Mike Cadman
DESIGN, LAYOUT AND TYPESETTING: Visual 8 Creative
Published 24 September 2016
PO Box 3018 Honeydew 2040, South Africa
[email protected]
www.emsfoundation.org.za
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A document prepared for CITES COP 17 | 1
Table of Contents
SMOKE AND MIRRORS: WILDLIFE POLICIES IN POST-APARTHEID SOUTH AFRICA
SOUTH AFRICA’S FALSE CLAIM OF EXCEPTIONALISM
Hunting for Official Answers
4
5
6
SERIOUSLY…YOU ARE KILLING ME: THE WILD LIFE TRADE BACKGROUND
AN OVERVIEW OF THE ILLEGAL TRADE IN SOUTH AFRICA
RHINOS IN SOUTH AFRICA: AN EXAMPLE OF TRADING INTO EXTINCTION Overview South Africa’s - Pro-Trade Position
Legal Trade: A Cover for Illegal Trade
Statistics and Comparative Data
Recommendations
8
8
10
12
12
14
15
16
17
‘SUSTAINABLE USE’ IS LEADING TO THE EXTIRPATION OF AFRICA’S ELEPHANTS
Elephants are Africa’s Heritage South Africa’s Elephant Population
Zimbabwe and Namibia’s Elephant Populations
South Africa and the Ivory Trade
Elephants Are Not Tyres: Why all Trade in Ivory Must End AFRICAN GREY PARROTS
19
19
20
21
22
22
25
HUNTING FOR PROFITS: SOUTH AFRICA AND TROPHY HUNTING
THE ROLE OF NATIONAL AND PROVINCIAL PARKS Turning a Blind Eye: ‘Sustainable Use’ Policies and Hunting in the Kruger National Park ‘Buffer Zones’
Letaba Ranch
Makuya Nature Reserve (MNR)
Makulele Contract Park
Manyaleti, Andover and Mthethomusha Nature Reserves
Associated Private Nature Reserves (APNR)
‘SUSTAINABLE USE’ ON STEROIDS: SOUTH AFRICA’S CANNED LION INDUSTRY ”You can make as much money as you like”: Lion Hunting in South Africa
Inadequate Lion Hunting Statistics
Captive Breeding of Lions South Africa’s Support for the Lion Bone Trade
CITES Cop 17 and South Africa’s Position on Lions
27
29
29
31
32
33
33
33
34
35
35
35
36
37
CONCLUDING REMARKS
38
REFERENCES 39
ENDNOTES
40
2 | A document prepared for CITES COP 17
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ACRONYMS
AEC
APNR
CITES
COP
DCA
DEA DRC
EU
GDP
INTERPOL
IUCN
KNP LEDET
MNR
MPTA
NGO
PAIA PASA
SANBI
SADF
SADC
SANParks SDGs
SPCA
UNEP
UNITA
VAT
African Elephant Coalition
Association of Private Nature Reserves
Convention on International Trade in Endangered Species of Wild Fauna & Flora
Conference of the Parties
“damage causing animals”
Department of Environmental Affairs
Democratic Republic of Congo
European Union
Gross Domestic Product
International Criminal Police Organization
International Union for the Conservation of Nature
Kruger National Park
Limpopo Department of Economic Development, Environment and Tourism
Makuya Nature Reserve
Mpumalanga Tourism and Parks Authority
Non-Governmental organisation
Promotion of Access to Information Act
Parrot Breeders Association of South Africa
South African National Biodiversity Institute
South African Defence Force
Southern African Development Community
South African National Parks
Sustainable Development Goals
Society for the Prevention of Cruelty to Animals
United Nations Environment Programme
National Union for the Total Independence of Angola
Value Added Tax
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A document prepared for CITES COP 17 | 3
SMOKE AND MIRRORS: WILDLIFE
POLICIES IN POST-APARTHEID
SOUTH AFRICA
This Report tries to unpack South Africa’s role in a
world where Africa’s animals are literally “Under Siege”.
We highlight an obvious pattern: legal trade in both
ivory and rhino horn is part of the problem and
should be prohibited, because it has been used to
launder illegal ivory and rhino horn which in turn
has stimulated demand. Criminals, benefitting from
corrupt and inefficient administration in many parts of
the world, including in South Africa and other Southern
African countries, have taken full advantage. As a result
of these factors many wild animals are under siege and
facing extirpation. Numerous studies mentioned in the
report present a large body of evidence supporting
this view.
While Africa’s wild animals are becoming extinct in
their natural habitats, on the other hand, in South
Africa, they are being commercially bred purely
for the purposes of killing and naked profit. And
unacceptably, their endangeredness makes them
In taking
a self-centred,
‘exceptionalism’
approach,
South Africa is
distancing itself
from other African
countries, displaying a
disregard for the
rest of the continent
and placing Africa’s
wild animals
in danger.
4 | A document prepared for CITES COP 17
even more of a target for trade and slaughter. The
recasting of wild animals as disposable commodities
without intrinsic value, is taking place as the Earth is
reaching finite limits and “resource use” is intensifying
as a consequence.
South Africa’s wildlife policies of “sustainable use” are
not only leading to the extirpation of wild animals
but are deliberately positioning people against them.
When you add to the mix: the lack of fiscal resources
needed for effective institutional capacity and
enforcement; private ownership; and corruption, it is
a lethal situation indeed.
Historically, South Africa has always taken a pro
“consumptive use” stance in relation to wild animals.
In the colonial and apartheid past it was so that a
few people could benefit and have private hunting
grounds. In terms of whom benefits now, this still
holds true – it is a few greedy people who are making
short term profits, albeit located within the language
of development and livelihoods.
South Africa’s excessive wildlife policies have ushered
in an extensive increase in the trade in animals and,
what is essentially, the farming of wild animals.
It is advocating endless exploitation, concealing
ethical issues and real suffering underneath this raw
commercialism. The country’s position on ivory sales
and the growth of the hunting industry are examples
of its overt “consumptive use” conservation policies.
Internationally, South Africa puts forward the image
that it is a “world leader” and should be respected
when it comes to conservation, but in reality this
is not the case. Its increasingly hard line approach
to the “consumptive use” of wild animals, regularly
puts the accumulation of profits ahead of ethics,
livelihoods, the interests of other African nations or
the well-being, protection and conservation of the
earth’s wild animals.
South Africa is advocating the sale of ivory despite
a compelling body of evidence to the contrary, the
decimation of Africa’s elephants and the opposition of at
least 70% of the 37 African elephant range states and other.
South Africa allows and promotes the largest canned
lion hunting industry in the world. The breeding of
lions in captivity for the hunting industry is also fully
supported by the government and has also led to the
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exportation of large quantities of lion bones for the
traditional medicine market in Asia. Far from trying to
improve the country’s image as a responsible custodian
of nature and natural heritage, the Government now
chooses to support this “reprehensible practice,”
as it was once described by former Minister of
Environmental Affairs Martinus van Schalkwyk.
South Africa has the largest hunting industry in subSaharan Africa. It is Africa’s most popular destination
for foreigners wishing to kill anything from elephants
and buffalo to tiny antelope. South Africa remains
the worlds’ top destination for the hunting of captive
raised lions and is also the premier market for those
wishing to shoot rhinos.
Over the past 30 years South Africa has regularly
promoted the sale of rhino horn despite evidence
that sales fuel the killing of rhinos which increased
by 7,000% between 2007 and 2013 alone. As this
document shows, it is clear that the rhino hunting
permitting system, internal legal trade and poor
enforcement have all contributed to promoting the
global illegal trade in rhino horn. Legal hunting merely
paved the way for the laundering of illegal horn.
South Africa has for decades lobbied for the opening
of trade in rhino horn, although in early 2016, on
advice from the Committee of Inquiry established to
deliberate on rhino poaching and matters relating
to its effects, the government had no choice but to
decide against making a request for sales. Although a
full explanation for this decision has never been made
public, South Africa has declined to destroy stockpiles,
obviously in the expectation that they may be used at
some time in the future.
South Africa also allows the breeding of a wide range of
colour variant wild animals. This in the face of widespread
evidence that it is of no conservation value, counter to
protecting biodiversity and unethical. Through selective
breeding wildlife ranchers have developed a highly
lucrative industry breeding animals (for which they have
created names) such as Golden wildebeest, Black impala,
Copper blesbuck, Golden oryx and others.
The country is one of the leading exporters of Africa’s
wild animals to zoos and so-called “safari parks” all
over the world. It is also often used as a conduit for the
smuggling of wildlife including gorillas, chimpanzees,
African grey parrots and abalone as well as reptiles and
birds from Madagascar and elsewhere.
Although South Africa regularly states its virulent
support for the concept of the “sustainable use of natural
resources”, and it is included in all its environmental
policies, it has no effective monitoring mechanisms,
such as a central database where information relating to
trade and hunting can be sourced, let alone monitored
and interrogated by civil society organisations.
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A FALSE CLAIM OF EXCEPTIONALISM
The nationalist, exceptionalism narrative that southern
African countries, such as South Africa, Zimbabwe,
and Namibia, have “successful conservation practices”
and should therefore be treated differently to the
rest of the Continent is not only spurious but cleverly
and carefully crafted to obfuscate real problems in
relation to their own policies and the consequences
they are having for wild animals. Moreover, all of these
countries have serious problems with corruption,
enforcement and the illegal trade.
The South African exceptionalism position, with
increasing support from Zimbabwe, continuously
distances itself from other African countries on issues
related to elephants and displays a disregard for the
rest of the Continent.
South Africa’s promotion of ivory sales and its
support of the canned lion hunting industry are
but two examples of putting profits before ethics
and the needs of other African countries. There is a
considerable body of academic work which shows
that the 2008 “once off’ sale of ivory contributed
directly to an increase in elephant poaching and a
wide range of people, even including professional
and amateur hunters in South Africa, oppose canned
lion hunting on ethical grounds.
Legal trade is also used as a cover to launder illegally
gathered ivory, rhino horn, abalone, etc. into the
market. Poor administration and control of trade is
easily exploited by criminal networks. Nonetheless,
South Africa promotes both trade and canned
hunting because it argues that elephants and lions
in South Africa are “well managed” and that ivory
sales and captive lion hunting will not threaten local
populations of these animals. This attitude shows a
lack of concern for what is happening with lions and
elephants elsewhere in Africa, the circumstances of the
country’s whose views on these subjects differ and the
detrimental affect South Africa’s position is having on
Africa’s wildlife.
South Africa’s spin and apparent belief that because it
manages its wild animals “well” - a view that is contested
by many - it should be able to do as it pleases at the
expense of other African countries, emphasises a false
sense of exceptionalism, a belief that it is somehow
justified to impose its view. In adopting these and
similar positions South Africa is increasingly isolating
itself from world opinion on wildlife conservation and
from its own citizens.
This trend also needs to be looked at in the context
of political developments over the past year which
indicates a hardening of attitudes amongst senior
government representatives, including the President,
with regard to South Africa’s international image.
A document prepared for CITES COP 17 | 5
In March 2015 the South African government flouted
an international convention, an International Criminal
Court warrant of arrest for al-Bashir and a South
African High Court order. South Africa refused to arrest
Sudanese leader Omar al-Bashir who is wanted for
war crimes and was invited to South Africa. Instead of
arresting him the government gave him safe passage
out of the country.
The South African Supreme Court of Appeal found that
the government should have arrested al-Bashir and
this decision was later confirmed by the Constitutional
Court. Despite the decisions of the courts, the flouting
of an international convention and widespread
international criticism no action has been taken against
those who ignored the requirements of South African
and international law.
Human Rights Watch, an NGO that monitors human
rights abuse around the world, notes that in 2014 South
Africa abstained on votes at the United Nations Human
Rights Council dealing with human rights abuses in
Burma, North Korea and Zimbabwe yet supported
the votes against abuses in the OPTs (occupied Arab
territories). It also did not support motion on abuses in
Bahrain and Egypt.
According to Human Rights Watch, “The contrast
between South Africa’s votes on the resolutions on the
OPT’s and its votes on all other situations raises serious
questions about double standards and selectivity in
its approach to the Council…South Africa should base
its positions on an objective evaluation of the needs
of victims and the international obligations of the
government concerned.”
In March 2016 South Africa supported Saudi Arabia in
opposing the establishment of a UN body to look into
the issues relating to the surveillance of citizens and in
July abstained on a vote to create an expert position on
sexual identity and discrimination.
6 | A document prepared for CITES COP 17
Some Southern Africa countries, notably Zimbabwe,
Namibia and Swaziland are also adopting increasing
nationalist positions with regard to wildlife “utilisation”
(Botswana is the exception, and has banned trophy
hunting). Supported by strong hunting and wildlife
ranching lobby groups they argue that as sovereign
nations they have a right to propose sales and other
utilisation as they believe this will not impact on
wildlife in their countries.
Members of the Southern African Development
Community (SADC) have been the primary drivers of
requests for ivory sales since 1997 and according to
Swaziland, also agreed at a meeting earlier this year to
support proposals to open trade in rhino horn, again
with the exception of Botswana.
The comments by Human Rights Watch that South
Africa should “base its positions on an objective
evaluation of the needs of victims and the international
obligations of the government concerned” has
direct relevance to the position with wildlife. The
widespread slaughter of elephants across Africa, the
surge in rhino killing in South Africa, and elsewhere
and the decline of lion populations to their lowest
levels in history are all issues of relevance to the entire
continent and anyone in the world who cares about
the environment and wildlife.
In taking a self-centred approach South Africa ignores
its commitment to wildlife elsewhere and the need
to coordinate action to ensure its survival. Decisions
made in Southern Africa can, and do, influence wildlife
elsewhere in the Continent and the world. Sales of
African ivory and rhino horns have impacts in Asia too.
Hunting for Official Answers
Record keeping by the Department of Environmental
Affairs and provincial conservation authorities is, as
pointed out numerous times in this Report, notoriously
poor. There is no centralised database and some
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provinces still have to contact various sub-offices by
phone or email to gather information which should
be easily available. Even data on rhino poaching was
not kept centrally until 2009, only after the poaching
crisis had intensified. At one point the Department of
Environmental Affairs released rhino poaching figures
on a regular basis but this is no longer the case.
According to a 2010 Animal Rights Africa Report,
Seeking the Path of Least Disclosure, “It is very difficult
to understand how the Ministry and the Department
of Environmental Affairs can make informed decisions
about the management of South Africa’s wildlife when
the information they use, and provide to the public,
is frequently inadequate. It also raises doubts, of the
accuracy of information provided to international
bodies such as CITES and is exemplified by the
information demands on international treaties, such
as CITES and the Convention on Biological Diversity, to
which South Africa is signatory.
All too often doors are closed in the face of researchers
wishing to get clarity on a wide range of issues.
Officials in some provinces are particularly poor in
this regard. Even officials from the Department of
Environmental Affairs sometimes struggle to get
access to accurate and up to date information from
some provincial officials”.
Unfortunately, all too often, this is still the case.
Problems with access to information and the
permitting structure were also flagged as a problem
by TRAFFIC, the wildlife trade monitoring network,
in 2015 in their Rhino Horn Trade: An Update Report.
“Understanding South Africa’s wildlife trade remains
clouded by delays, abuse and miscommunication
within the current permitting structure, providing
loopholes and opportunities for illegal trade or
unintended activities for many species and wildlife
products to proliferate.”
Reliable statistics relating to the hunting and killing of
so-called “damage causing animals” (DCA), including
high profile animals such as leopards is poor. The South
African Scientific Authority, the South African National
Biodiversity Institute, in a 2015 document examining
circumstance surrounding the hunting of leopards, also
noted that “record-keeping is generally poor amongst
the provinces.” SANBI also noted that “some provinces
record the numbers of DCA permits awarded but few
actually note whether putative DCAs were successfully
removed (translocated or killed)”.
It is unclear why there is such a reluctance to improve
record-keeping with regards to South Africa’s
wildlife. Without accurate information it is difficult to
understand how responsible decisions can be made
and also questions South Africa’s credibility when
submitting reports to organisations like CITES.
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South Africa’s
wildlife ‘sustainable
use’ policies are
leading to the
extirpation of
wild animals
and positioning
people against
wildlife.
Conservation offcials in some provincial head offices
often have to contact sub-offices by phone or mail
requesting information, some of which is kept in hard
copy only, if at all, because no central database exists.
A centralised database system, funded by donor
money, was developed as early as 2000, but nothing
has yet been implemented.
During a CITES stakeholder meeting organised by
the Department of Environmental Affairs in July 2016,
officials promised that a centralised system would be
in place before the beginning of CITES COP 17 on 24
September but at time of writing (September 2016)
nothing further had been heard on whether or not this
would happen.
A 2014 Department of Environment Affairs report
entitled, The viability of legalizing rhino horn trade in
South Africa, concluded that due to inefficient recordkeeping and the subsequent submission of statistics
to CITES “it is impossible to determine exactly how
many [rhino] trophies were exported legally out of
South Africa.” That this is the case with such a wellstudied animal during one the worst poaching crises in
decades is nothing short of shocking.
Some provincial officials are unwilling to provide
information to journalists or researchers and often
insist that an application be made in terms of PAIA
(Promotion of Access to information Act, 2 of 2000)
legislation before information will be released. This is
a lengthy procedure that allows officials a month to
gather information or, alternatively provide reasons as
to why it should not be released. In the latter instance
those requesting have the option of talking the matter
to court, an expensive time consuming process. In
some instances the information has simply not been
recorded or has been done so in a way that makes
it very difficult for anyone, including conservation
officials themselves, to access.
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SERIOUSLY…YOU ARE KILLING ME:
THE WILD LIFE TRADE
BACKGROUND
The violent geography of the trade in Africa’s wild
animals is extensive, lucrative and ever expanding. The
international trade (legal and illegal) involves millions of
animals every year and is one of the key drivers of species
extinction, population decline, suffering, abuse and
death. The trade in African mammals, birds and reptiles
has grown dramatically since the early 1990s. Profitmotivated dealers and middlemen, and a seemingly
bottomless market, drive this trade. And it all takes place
as a direct consequence of the vague, misused and
misinterpreted concept of “sustainable use”.
Many countries, South Africa being one of them, base
their pro wild animal trade policy formulation on a false
premise that trade is a conservation solution for socalled “endangered species” and that legal markets are
a panacea for the illegal trade. For example, in relation
to the trade in rhino horn, in March 2013, the South
African Minister of Environmental Affairs, Edna Molewa,
stated that she believes the legalisation of the trade
is the right direction to take to curb rhino poaching,1
Many countries,
base their pro-trade
policies on a false
premise that trade is a
conservation solution
for “endangered
species” and that legal
markets are a panacea
for the illegal trade.
while the Department of Environmental Affairs (DEA) in
its Rhino Issue Management Report stated that “banning
of the rhino horn trade by CITES and the concomitant
moratorium on domestic trade by South Africa has had
the unintended consequence of increasing poaching
of live animals as there is no other horn available.”2
The tenet of the pro-trade argument is that trade bans
produce high prices and scarcity leading to higher
illegal trading and that this can be eliminated by a flow
of legal supply through captive breeding (farming),
sales of stockpiles, “culling” etc. In this way they believe
they will be able to out-compete the illegal suppliers
and drives prices down thus making “poaching”
unprofitable while ensuring high returns for the legal
market. Private ownership and business enterprise is
key to this argument, and implicit is the development
of expanding demand.
A pivotal study by Nadal and Aguayo reviewed the
analytical economic arguments3 used to support the
legal market framework. It powerfully shows that
“the literature advocating trade as a conservation
solution for endangered species relies on models that
are based on simplistic and/or extremely restrictive
assumptions. In most cases, these models also rely
on conceptual tools that have been theoretically
discredited.” (Nadal & Aguayo 1:2014) They argue
that the belief that markets behave as self-regulating
mechanisms that lead to equilibrium and greater
efficiency cannot be substantiated and that “the
economic analysis of wildlife trade…appears to
have been trapped in the backwaters of textbook
economics” (3:2014) resulting in “incongruities and
misleading conclusions” (4:2014).
A major contradiction is the separation of the illegal
trade (trafficking) from the legal trade, despite the fact
that the two are naturally, and obviously, intertwined
and part of the same continuum. Allowing a market
and having a legal trade in wild animals and their body
parts is at the root of demand and the conversion of
living beings into commodities on the “supply” side.
Trade (whether illegal or legal) opens the door for
abuse, including illegal laundering, the hankering of
unlimited profit and the notion of limitless growth in
demand, supply and sales.
The clandestine nature of the illicit trade makes it
extremely difficult to track, measure and quantify.
Curiously estimated figures for the illegal trade are
much more in evidence and readily available than the
statistics for the so-called regulated legal trade in wild
8 | A document prepared for CITES COP 17
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animals. In addition, the term “wildlife” often includes
charcoal, plants and timber, making it impossible to get
accurate information in relation to wild animals only.
So, uncovering the mystery of the amount of profits
generated from trading in wild animals and their body
parts as a legally and regulated ‘‘commodity” is elusive.
According to TRAFFIC during the years 2005 to 2009,
CITES recorded an annual average of more than 317,000
live birds, just over two million live reptiles, 2.5 million
crocodilian skins, 1.5 million lizard skins, and 2.1 million
snake skins. In terms of hunting trophies, CITES data
shows that 10,000 lions were legally trophy hunted
between 2003 and 2013, while between 2003 and 2013,
15,518 African elephants were killed for trophies.4
These numbers are a low estimate because most of the
countries from where the animals traded originate, are
poor record-keepers and corruption is common. The
exotic pet trade industry is one of the key drivers of the
trade in wild animals. Countries involved in the exotic
pet trade – both exporters and importers - do not
compile reliable data on the extent but nonetheless, in
2005 Karesh et al suggested that the magnitude of the
global trade for the exotic pet trade involves over 350
million live animals a year, including primates, birds,
reptiles and fish.
Written evidence submitted by TRAFFIC to a 2012
United Kingdom House of Commons Environmental
Audit Committee on Wildlife Crime claims that in
the early 1990s the estimated value of legal wildlife
products imported globally was around USD160 billion,
while in 2009 it was over USD323 billion. TRAFFIC also
estimated the legal trade of “wildlife products” into the
EU alone was worth an estimated €93 billion in 2005
and that this increased to nearly €100 billion in 2009.
(Ev88:18 October 2012).
While in 2013, Hübschle valued the global legal trade
in wildlife (excluding fish) to be worth between
US$22.8 billion and US $25 billion per annum (46:2014).
CITES5 stated that “for key commodities of CITESlisted Appendix II animals the monetary value is
conservatively estimated to range from USD350-530
million per year, or almost USD2.2 billion over the five
year period 2006-2010”.6
According to a recently published UNEP/INTERPOL
Report7 environmental crime (which includes the
illegal trade in wild animals) is growing two to three
times faster than global GDP, dwarfing the illegal trade
in small arms and is the world’s fourth largest criminal
enterprise after drug smuggling, counterfeiting and
human trafficking. At the same time, the Report
concedes that “given this level of volatility in both the
seizure record and what is known about the underlying
markets, it is nearly impossible to give an accurate and
consistent estimate of the criminal revenues generated
by wildlife trafficking” (21:2016).
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The European Commission argues that “wildlife
trafficking” is one most profitable organised crimes in
the world with the illegal elephant ivory trade having
more than doubled since 2007 and rhino poaching
increasing by 7,000% in South Africa between 2007
and 2013, “endangering the very survival of this
species”. (European Union Action Plan against Wildlife
Trafficking: 2016).
In 2013 the United States government estimated that
the monetary value from the illegal trade in “wildlife”
was between USD $45 billion to $120 billion each year
with the illegal trade in “endangered wildlife products”
(including elephant ivory, rhino horns, and turtle shells)
worth at least an estimated $7 billion to $10 billion
annually (Wyler & Sheikh:2013).
There are thousands of species of wild animals who fall
outside of so-called “regulated” international trade yet
they are “legally” traded internationally and accompanied
by the appropriate permits and official documents.
According to the United Nations, permits for about
900,000 legal shipments of protected “wildlife products”
are issued annually. (UNEP Interpol Report, 2016:10)
These animals are often obtained illegally but
laundered through the legal regulatory framework,
including trophy hunting, live sales, “wildlife” farming
and ranching, breeding and captive operations,
including zoos. According to a June 2015 CITES press
release their trade database had exceeded 15 million
records of trade since the mid-1970s – this would mean
many millions more animals as each record usually
represents more than one individual being.8
A recent study which analysed CITES wild animal trade
records for Appendix I and II species exported out of
Africa (involving 2,337 species), between the years
2003 to 2012 found that 90% of the records contained
discrepancies across almost every type, including
SOUTH AFRICA IS
AN IMPORTANT
TARGET FOR
WILDLIFE
TRAFFICKERS.
A document prepared for CITES COP 17 | 9
quantity, appendix, origin, purpose, source, term, year
etc. and that records missing an import quantity were
the most frequent type of discrepancy, occurring in
63% of all trade records. It also found that the 50 African
countries included in the study were involved in data
discrepancies with Appendix 1 species having more
divergences than the other appendices. (Russo: 2015)
The specific use of desensitised and detached language
used to refer to Africa’s wild animals by governments
and bodies such as CITES - such as “game,” “wildlife
products,” “wildlife production,” “off-takes,” “quotas,”
“harvest,” “high value natural resource,” “wild sourced
inputs,” “specimens,” “derivatives” and “derived
products” - plays an important role in legitimising and
sanitising the unspeakable. The main actors - the very
beings who are traded and killed - and the holocaust
that is unleashed on them, is deliberately obscured
through trade and commercial activities.
AN OVERVIEW OF THE ILLEGAL TRADE IN
SOUTH AFRICA
Corrupt officials and politicians also play an important
role in illegal wildlife trade by helping poachers
and traffickers evade law enforcement agencies.
Wildlife traffickers also exploit inefficiencies in law
enforcement, insufficient conservation staffing and/
or incompetent or poorly trained officials. Poor recordkeeping and limited access to information also works in
favour of those involved in illegal trade.
Illegal trade is sometimes also undertaken by zoos,
wildlife breeders and wildlife traders using legal trade
as a cover. South Africa has a large, well developed
wildlife industry and hundreds of thousands of animals
are legally traded annually. A trade criminals sometimes
use as a screen for their activities. Taxidermists, a key
component of the hunting industry, have also been
involved in illegal trade.
10 | A document prepared for CITES COP 17
Pet shop and domestic pet breeders are also sometimes
involved in illegal trade. The internet is also often used
as a means of marketing illegal wildlife sales but because
the global nature of the internet, and sometime the
anonymity of people who post the adverts, it is often
difficult to prosecute sellers.
Without the end users the illegal trade would not exist
but use of wildlife, alive or dead, is deeply interlinked
with traditional beliefs, perceived status (as in the use
of rhino horn based medicine), ignorance, vanity (as
in the creation of private zoos), financial greed and
sometime desperation (subsistence “poaching” for
food) driven by poverty. A key component of reducing
the illegal and legal wildlife trade is educating end
users about the need to protect wild animals and
suggesting alternatives.
South Africa is one of the most biologically
diverse countries in the world and this, coupled
with poor border controls, weak record-keeping,
poor administrative skills, lack of resources and
corruption has made it an important target for
illegal wildlife traffickers. The examples below form
but a small illustration of the illegal trade in wildlife
in South Africa.
• South Africa is the epicentre of the world rhino
“poaching” crises.
• Elephant tusks believed to be worth more than
R17 million were seized by police at a business
premises in Pretoria on 3 March 2016. In 2015
Kruger National Park announced that 19 elephants
had been killed for ivory in the Park.. In several of
these cases poachers laced carcasses with poison
and a result more than 100 vultures and other
species have been killed.
• South Africa is one of the world’s largest sources of
illegal abalone for use in the Far East.
• South Africa has 37 cycad species, 26 of which are
endemic. The illegal trade in cycads has resulted
five endemic species becoming extinct in the wild
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in the last seven years. According to the South
African National Biodiversity Institute cycads worth
R11 billion have been illegally traded over the past
15 years.
In 2014 Northern Cape Nature conservation officials
estimated that at least 1,000 snakes, tortoises and
lizards are smuggled out of South Africa every
month. These animals are all destined for the
international pet trade.
According to Rowan Martin, Director of the World
Parrot Trust, many illegally caught wild parrots are
used in the captive breeding industry in South
Africa and that it relies heavily on wild birds as
breeding stocks. In 2011 750 grey parrots died on
a flight to Durban. They were part of a consignment
of 1650 parrots imported from the Democratic
republic of Congo. At the time authorities said the
parrots had been legally imported.
In August 2014 eight sitatunga antelope had to
be euthanized at OR Tambo International Airport
after arriving in shocking condition on a flight from
Europe. They were destined for the Johannesburg
Zoo and a private person.
Six South Africans and a Zimbabwean were arrested
in Zambia as they loaded 12 sable antelope calves
on to a modified aircraft, total value $12-million
(R157-million). In 2015 a French couple in the
Western Cape were found with 2,000 rare succulents
they intended to ship to Spain.
About 240 frogs including 180 rains frogs and 80
bull frogs destined for Vietnam were confiscated at
OR Tambo International Airport in January 2016.
. Although the Department of Environmental Affairs
state that “bushmeat” it is not a serious problem in
South Africa landowners and various environmental
groups across South Africa report that snaring
and the illegal killing of wild animals for food is a
widespread problem.
There is a thriving internet pet trade in birds and
reptiles. Many of the species are South African
although exotic species are also imported into
South Africa. Some of this trade is legal but a large
amount is illegal. Some exotic species, such as corn
snake, are released into the wild which has adverse
effects on biodiversity.
There are many traditional “medicine” markets
that sell both plant and animal based products.
Large numbers of species are part of this trade,
body parts from vultures, pangolins, African rock
pythons, spotted hyena, owls, and many other
species are openly sold. Authorities have done
little to curb this trade, which includes Red Data
Book or CITES Appendix I or Appendix II listed
species.
South Africa is often used as a transit hub illegal
wildlife trafficking from Madagascar, (particularly
reptiles and birds for the pet industry), the
Democratic Republic of Congo, and (Grey parrots
– pet industry) Mozambique (birds – pet industry)
and other countries.
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South Africa is at
the epicentre of the
rhino horn trade. The
trade in rhino body
parts, specifically their
horns, has meant that
more rhinos have
been killed illegally
in South Africa since
2008 than at any
other time in the last
90 years.
Many factors contribute to the prevalence and
scale of wildlife crime. Poverty, corruption, greed,
exploitative attitudes towards wildlife, (including
the neoliberal concept of the “sustainable utilisation
of natural resources”), regional conflict, traditional
beliefs (food and medicine) and many other issues
influence “poaching” and trafficking. The South African
government has enacted laws which provide for the
criminal prosecution of those accused of wildlife
crimes and various sets of regulations and norms and
standards also specify how wildlife and environmental
policy is managed. Wildlife conservation issues are
overseen by the Department of Environmental Affairs,
but powers to manage wildlife administration are
devolved to each of the nine provinces.
The country has one of the largest economies in Africa,
and by far the best infrastructure, and a significant
amount of state funds are spent on countering
“poaching” and illegal trade annually. Large amounts
of money are also regularly received from NGOs
and other donors as contributions towards funding
“anti-poaching” efforts and a range of other wildlife/
environmental programmes.
Why then, given such widespread effort, is there
very limited data available about the scale of wildlife
crime in South Africa, and why are attempts to
curtail “poaching” and subsequent trade, apparently
floundering. Civil society organisations regularly
struggle to access accurate and comprehensive
information from the Department of Environmental
Affairs head office and particularly from provincial
environmental agencies.
A document prepared for CITES COP 17 | 11
Government officials acknowledge that poor recordkeeping feeds into the illegal trade problem. In October
2015 South African Revenue Service Commissioner, Tom
Moyane, encapsulated many of the difficulties when
told a government meeting that “In our sub-region
[Southern Africa] we are confronted by the challenges
of cross border illicit trade, VAT fraud, contraband
cigarettes, money laundering, smuggling in alcohol,
cash economy and illegal trade in wildlife. Another of
the serious scourges confronting our administration
is the rampant scourge of corruption which continues
to retard our progress. This flourishes where weak
institutions, poor governance and under resourced
customs services and police forces stationed in our
porous borders are difficult to control. “
The Minister of Environmental Affairs and other senior
government official regularly point out that wildlife
crime and other forms or of crime often go hand-in-hand.
RHINOS IN SOUTH AFRICA: AN EXAMPLE OF
TRADING INTO EXTINCTION
Overview
Trade and trophy hunting has driven rhinos in Africa
to the edge of extinction. In the 1960s there were
approximately 100,000 rhinos but in 2015 the IUCN
provisionally estimated the number of white rhinos
to be between 19,682 and 21,077 and black rhinos
estimated at between 5,042 and 5,455.9
South Africa currently holds 79% of Africa’s rhinos10
and the fact that its population is currently the largest
in the world has perversely meant that this perceived
“population success” has been used as a justification,
particularly in a country where greed and poverty
intersect, for their exploitation, commodification and
killing, through trophy hunting, local auctions, live
international sales, and consumption of their horns. Not
surprisingly, and in tandem, the illegal killing of rhinos
is also growing exponentially and rhinos are being
12 | A document prepared for CITES COP 17
slaughtered on an industrial scale to meet demand
for rhino horn in newly affluent Asian countries. South
Africa is at the epicentre of the rhino horn trade. The
war on rhinos is also being fed by private ownership
and there also seems to be a relationship between the
rise in the proportion of rhino horn entering the illegal
trade and the increase in some private ownership.
The State, through its environmental agencies,
has purposefully transformed private wildlife
ownership into a full-blown agricultural activity. Its
conceptualisation of “conservation” as utilisation and
commodification is also actively encouraging and
legitimising criminal and unethical activities.
According to World WISE, in order of importance, South
Africa, Mozambique, Zimbabwe and Kenya are the
main sources of seized shipments of rhino horn. The
United Arab Emirates and European countries (including
Slovakia, the Czech Republic, Belgium, Italy and Germany)
are indicated as transit countries. In order of importance,
Vietnam, China, Ireland, Czech Republic, United States
and Thailand are indicated as destination countries (UN
71:2016). Europe is currently a destination market and a
hub for trafficking in transit to other regions. (EU Action
Plan against Wildlife Trafficking 2016).
The killing of rhinos in South Africa has reached the
highest levels since the 19th century and in the past
16 years at least 7 853 rhinos have been killed for their
horns, a figure, far high than government records show.
The South African government says at least 5,162 rhinos
were killed illegally by “poachers” from 2001-2015 and
the CITES trade database records a further 2,691 (20012014) animals killed for their “horns” and “trophies”
which were imported from South Africa by a number
of other countries around the world.11 According to the
Department of Environmental Affairs and the South
African National Parks (SANParks), 1,492 permits were
issued from 2001 to 2015 - a discrepancy of 1,199 (about
80%) if compared against the official CITES figure.
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The origins of the surge in rhino killings in South Africa
are complex but in part are linked to poor control
of the hunting and rhino farming industry which
enabled so-called “rogue” elements in this sector
to launder horn into illegal market which helped
stimulate demand. Organised crime syndicates took
full advantage of the situation.
The illegal trade in rhino horn, and elephant ivory,
has been exacerbated by corruption and official
inefficiency in Africa but also across the globe. South
Africa is by no means exempt from this. The same
syndicates that smuggle horn or ivory also become
involved in other forms of crime including the drug
trade, money laundering and human trafficking.
A number of reports published in the mid-2000s
identified major weaknesses in South Africa’s ability
to control and monitor illegal activities but authorities
responded slowly and in some instances these issues
remain unresolved today, a decade later.
Successive South African governments have regularly
promoted trade in both rhino horn and ivory. Although
thus far CITES has only permitted trade in ivory, not rhino
horn, these sales send mixed messages suggesting
that it is acceptable to use ivory from some sources
but not others. This helps stimulate a “gray market”
where criminals take advantage of the presence of legal
supplies to launder illegal “stock” to end users who are
unable to differentiate between the two.
It is well-known that smugglers have taken
advantage of South Africa’s pro-trophy hunting
environment by laundering rhino horn as hunting
trophies through the official South African and CITES
permitting system.12
In line with their pro-hunting position, and despite
the unconscionable number of rhinos that are dying
as a result of the rhino horn trade, South Africa is also
the premier market for those wishing to shoot rhinos
legally for trophies.13
Using the CITES legal regulatory framework, and
therefore with full knowledge of the South African
government and the CITES Secretariat, the movement
and sale of rhino horns (as trophies) and live rhinos to
overseas destinations (including those who consume
rhino horn such as Vietnam and China) constitutes
not only a convergence of the legal and illegal trade
but also a conscious stimulation of the trade and the
resultant massive killing of rhinos in South Africa for
the so-called illegal trade.
According to CITES the total number of rhino trophies
that were exported from South Africa from 2001 to
2014 was 2,693 with 24% of these going directly to
countries in the East, mainly Vietnam.14
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There is
overwhelming
evidence to
show that
the 2008 sale
of ivory by
South Africa,
Botswana and
Namibia helped
stimulate the
current wave
of elephant killings.
Between 1995 and 2014 South Africa exported 1,096
live rhinos, of which 35% went to countries in the East,
mainly China, Vietnam and Thailand.15 What is interesting
to note is that the number of live rhino export sales,
particularly to the East, increased from 2010, as the rhino
“poaching” statistics were increasing, the public outcry
grew ever louder and the government gave assurances
that it was trying to address the problem.16
Within South Africa and elsewhere hundreds of people
have been charged with rhino poaching offences
and include wildlife ranchers, professional hunters,
veterinarians, employees of national and provincial
parks as well as farmworkers, career criminals and
sometimes residents from communities living near
wildlife areas. Nearly 500 Mozambicans have been
killed by anti-poaching teams in the Kruger National
Park since 2010.17
Large numbers of live rhinos have also been
exported from South Africa to reserves and zoos all
over the world. Between 2001 and 2014, South Africa
exported 986 live rhino with about one quarter being
sold to countries in the Far East, the primary market
for most rhino horn.
A document prepared for CITES COP 17 | 13
Photographer Jennifer Bruce
South Africa’s - Pro-Trade Position
Although the international trade in rhino horn was
banned in 1977, South Africa has consistently refused
to destroy its rhino horn stockpiles.
The 1977 ban meant that rhinos were listed as Appendix
1, although they could still be trophy hunted “for noncommercial purposes.” The ban failed to include stockpiled
horns or the destruction of stockpiles and this provided a
major loophole for the pushing of continued trade. In 1987 (Resolution conf.6.10) CITES acknowledged
that trade was the “primary factor responsible for
the destruction of rhinos populations” and urged
all Parties to destroy their stockpiles of rhino horn.
Domestic trade was also outlawed. It is extremely
unlikely that South Africa heeded this call, particularly
because deeply woven into the fabric of South Africa’s
Apartheid history is the killing of, and profiting, from
wild animals, whose fates were closely bound to the
use of State sanctioned violence.
to have their rhino population down-listed to Appendix
II. In 1992 South Africa went to CITES and proposed that
the trade in rhino horn be allowed.
Although this was not accepted by the Parties, twoyears later in 1994 (COP 09), not only was South Africa’s
proposal to down-list their population adopted, but
Resolution Conf. 6.10 was repealed (Conf.9.14), opening
the way for the amassing and privatisation of rhino horn
with the end game being trade. Part of their rationale
for trade was that it would “benefit rhino conservation…
[and that it] results in improved intelligence, as the legal
entrepreneur informs on the black market activities, and
that a dependable supply of products depresses black
market prices. In addition, private land-owners will be
encouraged to invest in rhino populations and protect
them as utilisable, economic assets.”
The Apartheid State was deeply involved in slaughtering
tens of thousands elephants and in the sustained
smuggling of ivory, rhino horn drugs and diamonds
through South Africa for resale internationally, to
support its war machine in Africa in the 1970s and 1980s.
In 1994, at South Africa’s behest, the white rhino was
down-listed to Appendix II. This meant that some internal
trade, the exportation of horns as hunting trophies and
stockpiling of horns by private individuals was allowed.
The official 1994 CITES annotation down-listing the
white rhino to Appendix II stated that the change in
status was “ For the exclusive purpose of allowing
international trade in live animals to appropriate and
acceptable destinations and hunting trophies.”18
The smuggling trade in wild animal body parts was not
only allied to the South African security apparatus but
protected by them and as a result their networks and
reach grew unimpeded and into the post-apartheid
era. (Humphreys & Smith 2014:803). After the demise
of the Apartheid State and the dawn of democracy
in 1990, when the social and political landscape was
being recast and reimagined, the official approach
towards wild animals remained seamlessly callous
and inhumane.
Currently South Africa’s rhino horn stockpile in the
hands of government is said to be approximately
21 tonnes19 (representing 5,250 dead rhinos). The private
industry is said to have a stockpile of approximately
6 tonnes20 (representing 1,500 rhinos). But these
figures may not be accurate because authorities have
struggled to confirm the amount in private hands.
Poor stockpile management practices of ivory and
rhino horn in South Africa has encouraged leakage into
illicit markets.
Post-1990, South Africa actively began to lobby CITES for
the trade to be legalised. The first step in this process was
Despite an alarming increase in rhino killings, the
Private Rhino Owners Association (PROA) and Wildlife
14 | A document prepared for CITES COP 17
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Ranching South Africa (WRSA), have pursued a strident
campaign calling for the opening of “controlled trade”
in rhino horn. In 1993 there were 650 rhinos in private
hands and there are now 6,200 owned privately.21
rejected the claim that it had agreed to make a joint
submission on trade. Officials would not say if South
Africa will support the Swaziland proposal. 27
South Africa’s deliberate promotion of the
commodification of rhinos and their ownership by
private individuals has not only grown the trade (both
legally and illegally) in, and trophy hunting of, rhinos
but has also meant that they are being bred and farmed
as agricultural products so that they can be cruelly and
continuously de-horned.
The trophy hunting permitting system in South Africa,
internal legal trade and poor enforcement by the
State have all contributed to promoting the global
illegal trade in rhino horn and the killing of rhinos. The
information below shows how South Africa, through
lax control of rhino hunting, rhino farming and internal
trade, promoted demand for rhino horn.
Rhino farmer John Hume, who is essentially factory
farming rhinos currently owns approximately 1,200
rhinos and is the largest rhino breeder in South Africa
(and the world). According to Hume he “harvests” rhino
horn to save them.22 Hume also bought hundreds of
rhinos directly from the Kruger National Park. The
fact that SANParks has chosen to sell so many rhinos
to one single buyer, particularly given the increase in
the illegal killing of rhinos and the stockpiling of horns
by private individuals, reveals much about the State
position. According to Hume he has five tonnes of rhino
horn stockpiled and he harvests a tonne every year. 23
Izak du Toit, John Hume’s lawyer is quoted as saying:
“We would sell to the poachers to prevent them from
killing rhinos,”24 so it seems that breeders such as Hume
may have no problem with selling their stockpiles off to
transnational criminal smuggling networks.
Rhinos bought directly from the Kruger National Park
and KwaZulu-Natal Wildlife auctions are known to
have been shot soon afterwards under “put and take”
circumstances so that the horns could be removed
and sold (“put and take” means that the animal is shot
under circumstances where it has no chance of escape
- it is the same as “canned hunting”).28
In anticipation of CITES COP17 and because of civil society
pressure, the Minister of Environmental Affairs convened
a Committee of Inquiry in 2015 tasked with investigating
the issue. The Committee advised against requesting
CITES COP 17 for an opening of trade, advice accepted
by the Cabinet, although it said that South Africa would
not destroy any rhino horn stockpiles. The full findings
of the committee have never been made public despite
numerous requests for copies of its report.
Following the Cabinets’ decision, Swaziland
subsequently submitted a trade proposal to CITES and
in official documentation accused South Africa of
reneging on a pro-trade agreement made during
an earlier meeting between 12 Southern Africa
Development Association (SADC) nations. 25
According to documents submitted by Swaziland there
was a consensus (with the exception of Botswana) at
the meeting in favour of rhino trade and it was agreed
that South Africa would make a trade proposal this
year. “Swaziland was expecting South Africa to submit
a rhino horn trade proposal to CoP17 and was ready
to support it. However, Swaziland was informed on
21st April, 2016 that this was not going to happen” the
Swaziland submission to CITES stated. “That decision
gave rise to this proposal by Swaziland at the 11th
hour.”26 The Department of Environmental Affairs
confirmed South Africa had attended the meeting but
EMS FOUNDATION
Legal Trade: A Cover for Illegal Trade
In other instances rhino horn from private stockpiles
was sold within South Africa but later laundered into
the illegal medicinal medicine market. Hunting permits
were also issued, allowing rhino horn to flow into the
illegal international trade.
As stated above, internal trade in rhino horn became
legal in South Africa after CITES down-listed the local
population to Appendix II in 1994 and remained so
until 2008 when the government placed a moratorium
on trade. Rhino owners successfully won a High Court
Appeal in 2015 which rejected the moratorium. Although
the Department of Environmental Affairs appealed
this decision in the Supreme Court of Appeal in May
2016 they again lost the case but in June 2016 filed an
application for leave to appeal to the Constitutional
Court. The moratorium on internal trade will remain in
place until the Constitutional Court has made a decision.
The Department of Environmental Affairs record
keeping has been poor with regard to all wild animals,
and even in 2016 it is still unclear how much rhino horn
is in private hands or has left the country.
According to a 2015 TRAFFIC Report29, “ironically the
source of many illegal horns to date has been from poorly
documented private horn stockpiles and the continuing
poor management will simply continue to undermine
conservation efforts and any attempt to legalise trade.”
They further make the point that “understanding South
Africa’s wildlife trade remains clouded by delays, abuse
and miscommunication within the current permitting
structure, providing loopholes and opportunities
for illegal trade or unintended activities for many
species and wildlife products to proliferate…This issue
remains unresolved with many wildlife professionals,
including professional hunters, hunting outfitters,
wildlife veterinarians and wildlife capture operators,
A document prepared for CITES COP 17 | 15
arrested in conjunction with rhino crime still operating
within the industry. So far self-regulating private sector
structures have been insufficient to prevent unethical
practices…There are many examples where legal and
illegal trades end up co-existing in parallel without
reducing illegal off-take for the affected species: South
Africa’s abalone trade is a classic example, with illegal
harvest swamping the legal quota system to the point
of collapse of the wild resource.”
The significant scale of the use of legal trophy hunting
permits to move rhino horn to unknown destinations
was raised in official CITES documents as early as 2007.30
Other research undertaken at the same time noted
that during this period Vietnamese hunters, using legal
permits, began to hunt rhinos in order to use their horn
for medicinal purposes, rather than as hunting trophies.
According to Hall-Martin, Du Toit, Hitchens and Knight,
“During 2005 the first legal white rhino hunts with
Vietnamese clients were conducted in South Africa.
These hunts were legal as a trophy hunt but there can
be little doubt that the trophy became medicine on
its way to the East and we have therefore referred to
these hunts as medicinal hunts. It was also reported
that several clients purchased multiple rhino hunts
whereas traditional trophy hunters would generally
only take one rhino trophy on a hunt. The impact of
these medicinal hunts on the rhino industry was huge,
with an estimated income between 2005 and 2008
of R121,050,000.”31
According to a 2009 Animal Rights Africa Report, (Under
Siege: Rhinos in South Africa) despite selling hundreds
of live rhinos, sometime to known hunting concerns,
SANParks said they had no responsibility to monitor
what happened with the animals after the sale. “One
buyer [of rhinos from a KNP auction] also told the
Sunday Independent [newspaper] that he dehorned
rhinoceroses once they arrived on his farms. He said
he was stockpiling the horns so he could sell them
if the market was re-opened,” ARA reported. “This
also brings into question whether or not SANParks’
recent auction of white rhinoceroses from the Kruger
National Park could be contributing to the exploitation
of legal trophy hunting by those involved in the rhino
horn trade. As previously stated, SANParks does not
see a conflict with selling the rhinoceroses to trophy
hunters, claiming that the animals are no longer their
responsibility after the sale”.32
In relation to rhino sales in 2014, SANParks spokesperson
said that they “had transactions with several businesses
and were not at liberty to divulge who they were doing
business with.”33 There have been several reports of
rhinos that had been bought from the State being shot
almost immediately, some even in their crates for their
rhino horn, or for trophies in canned (so-called “put
and take”) “hunts” which in relation to rhinos have been
16 | A document prepared for CITES COP 17
described by one provincial government official as “... buy
rhino, kill it, replace it, kill it...[sic]” (Hübschle, 2016:197).
And the South Africa State seemed not to be concerned
about what happened to the wild animals once they
left their national parks or who they sold them to.
Several of the buyers are known criminals or have
been formally charged with crimes, including illegal
activities relating to wild animals. For example, since
2004 SANParks, through the Kruger National Park, sold
120 rhinos, “at a massively reduced fee,” to white-lion
canned hunter Alexander Steyn a notorious “outfitter”
for various Vietnamese rhino hunts.34 Perversely the
authorities claim that revenue from sales goes “back
into conservation,” and these include anti-poaching
activities, research, land acquisition and community
beneficiation projects.35
SANParks said that once sold the fate of rhinos became
the responsibility of the provinces which issued permits.
The ARA report added that “SANParks statement such as
...the sale of rhinoceroses to sources outside of national
parks is governed by the provincial conservation
permits,’ ring hollow because they have not put a policy
in place relating to the sale of wild caught rhinoceroses
into captivity or to hunting destinations.
SANParks also appears to be abdicating its national
responsibility when it claims that because the permits
are issued by the provinces this precludes them from
having such a policy. In terms of the South African
Constitution, responsibility for the Environment is
a shared and concurrent competency between the
national government and the provinces and therefore,
surely, SANParks and the provincial authorities have
a close working arrangement and the terms of the
permits can be jointly agreed upon.”
Statistics and Comparative Data
CITES trade data is drawn from information submitted
by members of CITES. The CITES Trade Database does
not differentiate between rhino “horns” and rhino
“trophies” but since no legal trade in horns, except
for hunting trophies, a has been allowed since 1977 it
is assumed that all horns listed are the result of legal
rhino hunting. In South Africa the Department of
Environmental Affairs submits data to CITES.
According to the CITES Trade Database, the total number
of rhino horns/trophies imported from South Africa
from 2001 to 2014 was 2,691 and the total number of live
rhinos imported from South Africa for the same period
was 922. The total number of rhino hunting permits
issued from 2001 to 2015 was 1,492. The official number
of rhinos “poached” from 2001 to 2015 is 5,162.
In a 2014 Department of Environmental Affairs Report,
The Viability of Legalizing Rhino Horn Trade in South Africa
is conceded that government itself cannot provide
accurate trophy hunting exports and attributes this to
EMS FOUNDATION
1400
Live rhino imports fro
Number of horns/trophies
imported from SA*
1200
Reported poaching (n
Number of rhino hunting
permits issued**
1000
Number of rhino hunt
800
Reported poaching
(nationally)***
600
Live rhino imports from
South Africa****
Number of horns/trop
400
200
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
0
*Source: CITES Trade Database
**Source: The hunting permit data for the period 2001- 2008 is sourced from Hall-Martin, AJ, du Toit, JG,
Hitchens PM and Knight, MH. 2008. Survey of White rhinoceros, Ceratotherium simum simum
on private land in South Africa. Hunting data for 2010 to 2015 was provided by the Department
of Environmental Affairs to the EMS Foundation in 2016.
***Source: Department of Environmental Affairs
CITES Trade Database
****Source: problems associated with the CITES reporting system as
well as internal inadequacies in the collection of statistics
in South Africa as the primary reasons for this failure.
According to the Report trophy hunting data obtained
from the CITES database has limitations that affect
accuracy. “Each party to CITES designates a management
authority to issue permits and compile annual reports
that are entered into the database. Although there are
guidelines for the preparation of these reports many
Parties do not follow them completely resulting in
inconsistencies…As a result of these limitation, when
import and export permit counts for rhino trophies do
not match up on the CITES database it is impossible to
determine exactly how many trophies were exported
legally out of South Africa.”36
Recommendations
The South African government’s pro-use, pro-abuse,
pro-trade and pro-private ownership stance towards
rhinos, particularly because they are stockpiling rhino
horn and encourage private owners to do the same,
means they are actively not limiting supply and in so
doing are spurring on the proliferation of rhino deaths,
playing a role in stimulating demand and pushing up
the price and perceived value for dead rhinos and their
body parts (both legally and illegally). Rhinos have
become the victims of financial speculation.
EMS FOUNDATION
Protecting rhinos for who they are is not on South
Africa’s agenda, but rather it is the disembodied rhino
as a highly profitable commodity which has some
owners (both government and the private industry)
incentivised by the black market value of rhino horn,
even if this means accelerating the poaching crisis,
causing pain and suffering and threatening the very
existence of rhinos as a species.37
As Hübschle has noted, “regulatory breaches and
the exploitation of legal and regulatory loopholes,
including illegal hunting and dehorning of rhinos,
as well as the stockpiling and laundering of illegally
harvested rhino horn into legal trade flows constitute
modes of ‘production’”. What renders these flows
particularly efficient and safe is the early stage
conversion of an essentially illegal good to legal status
(the laundering of illegally harvested horn into legal
trade flows), and contrariwise, the conversion of a legal
product (the hunting trophy) into an illegally traded
good in consumer markets.” (Hübschle 2016:292)
While the United Nations Office on Drugs and Crime,
has shown that “case studies show that when illegally
traded wildlife is introduced into legal commercial
streams, criminals have access to a much larger source
of demand than they would have had on the black
market alone.” (2016:10).
A document prepared for CITES COP 17 | 17
Photographer Jennifer Bruce
The irregularities in the South African rhino hunting
and breeding industry that were noticed in the early
2000s were, according to Annette Hübschle in her PHD.
Thesis, A Game of Horns: Transnational Flows of Rhino
Horn published in 2016, a clear driver of demand which
stimulated the rhino poaching that surged in 2008.
Hübschle argues that a “gray” trade was created where
it became difficult to distinguish between legal and
illegal rhino horn. “A key feature of these gray flows is
the exploitation of legal and regulatory loopholes as
actors ride on the edge of legality”.
Hübschle interviewed 360 people and found that, ”South
African wildlife professionals and rhino breeders who
form part of the country’s white economic elite are the
principal actors” and that “the significant role of wildlife
industry players in rhino extinction (as opposed to rhino
conservation) is noteworthy. While public attention has
been drawn to rhino poaching in public parks, rogue
elements within the wildlife industry were the catalyst for
poaching to increase in national and provincial parks.”38
Hübschle’s findings may help explain to some degree
why, Hall-Martin, du Toit, Hitchins & Knight, found
unwillingness, from some in the wildlife industry,
to assist in them in their research. “The level of
cooperation afforded by many individual owners
of white rhinoceros, their managers, the provincial
and national authorities and various elements of
the organized game ranchers associations has
been disappointing. The professional hunters and
individuals involved with hunting were particularly
unhelpful,” they noted. “Much of the official
cooperation was grudging at best and many owners
and management authority officials refused outright
to provide information when requested. Indeed,
the diffusion of effort, and even chaos, in managing
wildlife and the associated trade in many species in
South Africa that was addressed by Bodasing and
Milluken (1996) appear to be as great a problem now
as it was more than a decade ago.”
18 | A document prepared for CITES COP 17
Despite the very high levels of illegal trade in rhino
horn the South African government, supported by
rhino farmers, hunters and others in the wildlife
industry have regularly promoted rhino hunting,
trade in horn and the trade in live rhinos. Very little
has been done by these parties to contribute in any
significant way to campaigns aimed at reducing rhino
horn trade in Asia.
South Africa’s position and that of some private
owners of rhino, hunters and supporters of the
concept of the “sustainable use of natural resources”
is clearly aimed at generating profits without
consideration to the fate of rhinos in South Africa
or elsewhere.
“We find that a legal trade will increase profitability,
but not the conservation of the rhino population,”
economists Dr Douglas Crookes and Professor James
Blignaut state in a paper entitled “Debunking the myth
that a legal trade will solve the rhino crises: A system
dynamics for market demand” which was published in
the Journal for Nature Conservation in June 2015. “It is
only through education in consumer nations that this
trend [in rhino poaching] could be reversed.
In their 2009 report Under Siege: Rhinos in South Africa,39
Animal Rights Africa called for the following steps to be
taken to effectively counter the killing of rhinos:
• Improve data collection at both provincial and
national level;
• Re-examine the permit system under which
government sellers of rhinoceros abrogate their
responsibility with regard to what happens to the
animal once it has been sold;
• End all rhinoceros hunting in South Africa because
it has been proven to be as great a problem as
poaching;
• Re-examine the entire CITES reporting procedure
because it is quite clear that limited and often
inaccurate information is submitted;
EMS FOUNDATION
• Open the policy of ‘sustainable use’ and trophy
hunting to public debate;
• Publicly publish through websites up-to-date
applications for hunting permits and hunting
statistics.
Now, seven years and thousands of dead rhinos later
the EMS Foundation calls for the same steps. Will the
proponents of killing rhino and selling their horns
finally put rhinos before profits and change their views?
History and the facts listed above insist they should.
‘SUSTAINABLE USE’ IS LEADING TO THE
EXTIRPATION OF AFRICA’S ELEPHANTS
Elephants are Africa’s Heritage
As a direct result of the trade in elephant ivory (both
legal and illegal) and ‘sustainable use’ policies elephant
populations across Africa have been catastrophically
decimated. Alarmingly in the last seven years alone
more than a third of Africa’s elephants have been
savagely killed. Add to the mix the effects of widespread
and proliferating trophy hunting and the live trade
in elephants to overseas zoos and the very existence
of Africa’s elephants hang in the balance. CITES COP
members have the power to save them by taking a stand
to protect elephants.
Statistics from the Great Elephant Census released on
1 September 2016 show that the savannah elephant
population has dropped to about 350,000 with forest
elephant numbers as low as 70,000.40 To put this figure
in perspective, approximately 1.3 million elephants
inhabited Africa in the 1970s. The pace of the slaughter
varies from region to region.
Between 2009 and 2015 Tanzania lost half of its
elephants and their population has plummeted
from about 109,000 to 51,000, a fall of 53%. Elephant
populations in the Niassa Reserve in Northern
Mozambique dropped from about 20,000 in 2009
to 13,000 in 2013, a decline of about 35% in just five
years. Both these countries are strong proponents of
‘sustainable use’ including of course trophy hunting.
Despite this cataclysmic decline three countries, South
Africa, Zimbabwe and Namibia, will ask CITES COP 17 for
permission to sell ivory stocks, a direct rejection of the
pleas made by 29 African nations (the African Elephant
Coalition)41 for all trade to be stopped and for ivory
stockpiles to be destroyed. There is overwhelming
evidence to show that a sale of ivory by South Africa
Botswana and Namibia in 2008 helped stimulated the
current wave of elephant killing. 42
South Africa, Zimbabwe and Namibia are amongst the
foremost supporters of trade in ivory and rhino horn
and have for years gone against the majority of global
opinion that trade bans must be enforced without
exception. CITES has, despite their 1989 ban on ivory
EMS FOUNDATION
“Today’s elephant
populations are
suffering from a form
of chronic stress, a…
species-wide trauma.
Decades of poaching
and culling and
habitat loss…have so
disrupted the intricate
web of familial and
societal relations…
that what we are now
witnessing is nothing
less than a precipitous
collapse of elephant
culture.”
Charles Siebert An Elephant
Crackup, New York Times
trade, granted two previous “once off sales” of ivory,
both subsequently linked to increases in poaching.
These countries are also strong supporters of “killing
animals to save them” thinking and all have thriving
but poorly managed trophy hunting industries.
According to a 2016 International Fund for Animal
Welfare Report, 10,294 African elephant “trophies” were
exported from the continent between 2004 and 2014.
IFAW notes that these records may not be complete. 43
During the same period South Africa exported 1,740
elephant “trophies”.
Trophy hunters argue that their presence deters
poaching but this theory has imploded with the
massive slaughter of elephants in and around hunting
concessions in Tanzania and Mozambique.
The Selous Reserve complex in Tanzania, an area
of some 80,000 square kilometres, is divided into
47 operating blocks of which only four are devoted
A document prepared for CITES COP 17 | 19
to tourism, the rest being reserved as hunting
concessions. Despite the preponderance of hunting
concessions the elephant population has dramatically
plummeted.44 A similar situation exists in the RuahaRungwa Complex in Tanzania and the Niassa Reserve
and surrounding concessions in Mozambique, both
sought after hunting areas.
boundaries with the park. The remaining elephants
occur in much smaller national, provincial, and
some private parks and reserves. The South African
Department of Environmental Affairs has published
a set of National Norms and Standards for the
Management of Elephants in South Africa (2008) but
these may be reviewed in 2017.46
In 2015 CITES granted Zimbabwe the right to export
1,000 trophy tusks (effectively 500 elephants),
South Africa 300 tusks, Tanzania 200, Mozambique
200, Namibia 180 and Zambia 160. CITES has given
Zimbabwe the right to kill 500 elephants annually
and export their tusks although the country faces a
plethora of economic sanctions imposed in an attempt
to force the reform of its undemocratic and corrupt
government. Zimbabwe has no currency of its own, (it
uses the U.S Dollar) and is regularly unable to pay its
civil servant or soldiers.
South Africa has also seen an increase in elephants
being killed for their body parts, with at least 54 killed
in the Kruger National Park in the last 18 months. Park
officials have expressed their extreme concern by this
sudden increase in elephant killings and fear that it
could mirror the pattern of rhino killing, which has
soared since 2008.
In 2012 four baby elephants were exported but three
died within months of the export. It is reported
that Zimbabwe was paid US$60,000 for each calf.
Zimbabwe has said it sold of the animals because it
needs the money sales would raise. In 2015 Zimbabwe
also captured at least 34 young elephants for sale to
zoos in China, an action widely condemned as cruel.
South Africa’s Elephant Population
To keep the numbers of elephants high so as to ‘harvest’
their tusks for the ivory trade, South Africa used the
farming practice of so-called “culling”. Between 1967
and 1997 a total of 14,629 elephants were killed in this
way in the Kruger National Park.47
This cruel practice, which severely and negatively
impacted the elephant survivors, was discontinued as a
result of a local civil society campaign which successfully
challenged the scientific and ethical reasons for this
unjustifiable tradition and ultimately brought about a
change in thinking by SANParks scientists.
South Africa has an elephant population of about
20,500 and differs from other African elephant range
states in that all of these animals occur within fenced
reserves.45 The vast majority, about 17,500 occur, in
the Kruger National Park and neighbouring private
and provincial “buffer reserves” which share unfenced
In 2014, SANParks, large mammal ecologist, Dr Sam
Ferreira said that the elephant population growth rate
during the period when “culling” took place was about
6.5% but under a different management regime which
included the closing of various artificial water holes
and dams the growth rate dropped to just over 2%.
The capture
and export of
young elephants
is exceptionally
cruel, is driven
by profit and has no
conservation value.
South Africa also developed a terrible and inhumane
industry from the elephants they deliberately orphaned
though culling, namely the elephant-back safari industry.
Over and above the “cull orphans” other young elephants
were allowed to be deliberately abducted and kidnapped
from their mothers and families for use by the industry.
Further emphasising the idea that elephants must be
part of “sustainable utilisation” and that they have to “pay
their way”. South Africa has the largest elephant back
riding/elephant interaction industry in Africa with more
than 100 animals held in captivity for these purposes.
A strong trend is developing to move away from this
exploitative and cruel practice and at least 2 elephantback safari operators have recently stopped operations,
rehabilitated the elephants and allowed them to
become free ranging wild animals again. These are for
ethical and economic reasons.
There are strong indications that the industry is in
decline. The Waterberg Elephant Back Safaris at
Shambala Private Reserve have released 10 elephants
as free ranging animals and the Pilanesberg Elephant
20 | A document prepared for CITES COP 17
EMS FOUNDATION
Back Safaris released their 7 elephants into a reserve
in the North West province. Shambala has established
a scientific programme to monitor the animals as
they become accustomed to their new lives. A third
operator, Camp Jabulani at the Kapama Reserve has
stopped elephant back rides but will still allow their
14 elephants to interact with humans. At least one
other private reserve, the Gondwana Private Reserve
in the Western Cape has also allowed former captive
elephants to become free ranging animals again.48
Despite its Apartheid past, South Africa remains wedded
to the concept of “sustainable se” of so-called “natural
resources”. It therefore actively drives the trophy
hunting of elephants. In 2015 CITES gave permission for
the export a total of 300 tusks as hunting trophies (150
animals). Similar quotas were granted in previous years.
The killing does not stop there. Elephants are also shot
as so-called “damage causing animals” (DCA) in some
provinces. These are animals that have crossed through
fences surrounding parks and strayed into communal
or agricultural areas. A culture of killing is the preferred
solution. Tusks from these animals are supposed to
be marked, catalogued and stored in government
storeroom or other safe places.
Between 2010 and 2015 Mpumalanga Tourism and
Parks Authority (MTPA) conservation officials permitted
the killing 153 elephants as DCAs. Most of these
elephants came from the Kruger National Park. During
the same period Limpopo’s Department of Economic
Development, Environment and Tourism (LEDET)
conservation officials killed 69 elephants as DCAs.49
Zimbabwe and Namibia’s Elephant
Populations
According to the 2016 Great Elephant Census,
Zimbabwe has an elephant of population of about
82,000 which has declined by 6% since it was last
reliably surveyed. CITES has for several years awarded
Zimbabwe a trophy hunting quota of 1000 tusks (500
animals) the largest elephant trophy quota granted
by CITES to any country. Zimbabwe (and prior to 1980,
Rhodesia) carried out the largest legal mass killing of
elephants in the 20th century shooting at least 44,500
elephants between 1960 and 1988.
Elephant scientists and long-term and detailed scientific
research has clearly shown that the capture and removal
of young elephants disrupts social groups and causes
intense distress in the captives and those left behind.
For example, in October 2014, Zimbabwe captured 35
elephant calves from wild herds in Hwange National
Park for export to China. Although the capture and
export was widely condemned as cruel and without
any conservation value the Zimbabwean Government
argued that it needed to raise funds and selling
elephant calf was a legitimate use of “natural resources”.
In September 2015 National Geographic reported that
the elephants that went to China were being mistreated
and were slipping into poor health. In 2012, Zimbabwe
exported eight elephants to China. Only four survived
the journey. Another three died shortly after arriving in
China, leaving only one surviving elephant.
Elephants, nor any other animals, should be kept in zoos.
A 2012 Seattle Times special report found that elephant
births in U.S. zoos have failed to offset deaths, which
will lead to the demographic extinction of the country’s
zoo elephants in the next 50 years. Half the elephants
documented in the study were dead by age 23, about
a third of their expected life span in the wild of 50 to
60. The report noted that the infant mortality rate for
elephants in zoos is 40 percent, nearly triple the natural
rate in the wild in Asia and Africa. Most had died from
injury or disease associated with their captive conditions:
foot and joint disease, reproductive disorders, infertility,
aberrant behaviours such as infanticide.50
Namibia has an elephant population of approximately
19,500 elephants, most of which occur in the north of
the country close to the borders of Angola, Botswana
and Zambia. Poaching of elephants and rhinos has
increased, and from 1 Jan 2015 to July 2016 at least 80
elephants were killed by poachers and approximately
167 rhinos. Namibia is also popular destination for
foreign hunters.
The killing of elephants for the illegal ivory trade has
significantly increased and this is negatively impacting
on their population and their social dynamics. In
addition to animals that are shot at least 350 elephants
were killed between 2013 and 2015 by criminals using
cyanide to poison waterholes. The poison not only kills
elephants but many predators and scavengers that
feed on the carcasses including vultures, lions, hyenas,
jackals and other carnivores. Controversially, with the
consent of CITES, Zimbabwe also kidnaps elephant
calves for sale to zoos. Photographer Morgan Trimble
EMS FOUNDATION
A document prepared for CITES COP 17 | 21
South Africa and the Ivory Trade
The global ivory trade has existed for centuries and
as weapons become more advanced the slaughter
of elephants across Africa and Asia increased
correspondingly. Continued demand for ivory,
promoted by both legal and illegal sales, has ensured
that elephants continue to be killed for their tusks.
According to information obtained through a
Promotion of Access to Information Act (PAIA) request
by the Centre for Environmental Rights from the
Department of Environmental Affairs in August 2016,
the total weight of the national ivory stockpile held
by South Africa National Parks and other national
and provincial governmental and parastatal bodies in
South Africa is 65,043.48 Kg.
The total number of ivory pieces that form part of this
stockpile consists of 76,354 pieces (raw and worked).
50,171.60 Kg is sourced from, “damage causing animals”,
natural mortality, and donations and 14,871.89 Kg
from confiscations (ivory from criminal activities. The
current stockpile does not include ivory from so-called
“culling, i.e. obtained prior to 1997 as the ivory was sold
in the CITES COP approved once-off sales in 2008.
South Africa too has a long history of trading in ivory,
rhino horn and the skins and horns of other wild
animals. By the end of the 19th century most of the
elephants and rhinos that had been found in what
comprises modern South Africa had been shot and
killed with only small isolated populations surviving.
Colonial records show that between 1844 and 1904
(60 years) at least 883,491 kg of elephant ivory was
exported from the port of Durban alone. During the
same period 19, 246 rhino horns and 2, 015, 246 skins of
various animals were also exported.51
Conservation efforts over the next century ensured
that wildlife populations recovered in South Africa.
The country was spared the rampant killing of
elephants and rhinos that took place elsewhere in
Africa during the 1980s partly because of the intense
military and police activity aimed at crushing political
dissent secured the country’s borders during the last
years of apartheid and also because of international
trade embargoes which isolated country from formal
global commerce.
During the 1970s and 1980s senior members of the
South African Defence Force (SADF) participated in
the in the almost total destruction of the elephant
and rhino populations in southern Angola as part of a
scheme to sell ivory and rhino horn rhino to fund the
UNITA rebel movement.
In 1995 the Kumleben Commission of Inquiry into
the Alleged Smuggling and Illegal Trade in Ivory and
Rhinoceros Horn was told that the SADF had created
a front company to transport ivory and rhino horn
22 | A document prepared for CITES COP 17
and that in 1979 alone fraudulent import permits for
at least 3,922 elephant tusks and 700 rhino horns had
been issued at Rundu on the Angolan border within
South West Africa (now Namibia). The Commission
was told that SADF soldiers assisted UNITA in killing
elephants and rhino. The ivory and rhino horn was
transported through areas controlled by the SADF
and then smuggled through South Africa and other
countries. Some private individuals within the SADF
also benefitted from sales.
Elephants Are Not Tyres:
Why all Trade in Ivory Must End
In an attempt to quell the elephant poaching which
swept Africa in the 1980s CITES finally imposed a ban
on international trade in ivory in 1989 (International
commercial trade in rhino horn was banned in 1979).
Elephant poaching declined to relatively low levels
for the next decade but researchers noted a marked
increase in the poaching of forest elephants in the early
2000s followed by dramatic surge beginning in 2008.
Despite the international ban various Southern African
nations have nevertheless persistently campaigned for
the right to sell ivory since 1997:
• In 1997 CITES agreed to allow Namibia, Zimbabwe
and Botswana a “once off” sale of 49 tons of ivory to
Japan. This sale took place in 1999.
• In 2002 CITES approved requests by South Africa,
Botswana and Namibia for another “once off” sale,
this time agreeing to the sale of 60 tons of ivory
from government stockpiles. This only took place
in 2008 but CITES raised the amount 108 tons, all
of which was sold to China and Japan. (In this sale
South Africa sold 47,356 kg of ivory for US$ 6,703,
000; Botswana sold 43,153 kg for US$7 093 550;
Namibia 7,226 kg for US$ 1, 862,60 and Zimbabwe
3,700 kg for US500,000. The average price per kg
was $157).
• In 2010 Tanzania requested permission for a once
off sale but this was rejected by CITES.
In 2016 prior to CITES COP 17 South Africa, Zimbabwe
and Namibia again submitted proposals to CITES
for further sales. Namibia and Zimbabwe have also
requested that their elephant populations be delisted
altogether an action which would allow them to sell
ivory by auction. Approval for this proposal requires a
two thirds majority vote.
The African Elephant Coalition (AEC) persuasively
argues that if African nations are serious about
stopping poaching they should support proposals
that all ivory stockpiles should be destroyed and that
no legal trade should be permitted. Currently most
Southern African elephant populations are listed
on CITES Appendix II which allows trade in special
circumstances, such as the special “once off” sales.
(http://www.africanelephantcoalition.org)
EMS FOUNDATION
“The current listing of southern African elephants in
Appendix II – allowing trade – has stimulated poaching
and smuggling of ivory,” the AEC states “Elephant
populations are declining significantly across most
of Africa. A universal listing in Appendix I will outlaw
the ivory trade, simplify enforcement and send a clear
message to the world of a global determination to halt
the extinction of African elephants”.
Since the ban on open trade was imposed in 1989 at
least 14 countries have burnt ivory stockpiles In March
2016 Kenya, supported by other AEC members and a
wide range of global and local conservation NGOs
burnt a 105 ton ivory stockpile thereby emphasising
their rejection of any trade in ivory, legal or illegal.
South Africa, Zimbabwe, Namibia and Botswana have
all rejected the destruction of stockpiles.
At a ceremony held in Nairobi where the ivory was
burnt Kenyan President Uhuru Kenyatta said that “Noone, and I repeat no-one, has any business in trading in
ivory, for this trade means death of our elephants and
death of our natural heritage.”52
The view that ivory sales promote usage and thus the
killing of elephants is supported by economists Nadal
and Aguayo In the science journal Pachyderm they
argue that ivory stockpiles should be destroyed because
keeping stockpiles in place supports expectations about
future supply and the establishment of an international
legal market and that this consolidates expectations
about profits from future trade and acts as an incentive
for legal and illegal traders and processors to remain in
business. They also say that selling of stockpiles can lead
to new investments and new market-related institutions
that lock-in society into a trajectory of more, not less,
ivory trade. The synergies between legal and illegal trade
may very well be strengthened (2016:Vol.57).
The view that no further ivory sales should be permitted
is also strongly supported in a peer-reviewed paper
published in June 2016 by Solomon Hsiang and Nitin
Sekar. According to their findings, the 2008 “once off”
sale by South Africa, Namibia and Botswana stimulated
the huge spike in poaching.53
Their research has shown that “the international
announcement of the legal ivory sale corresponds
with an abrupt 66% increase in illegal ivory production
across two continents, and a possible ten-fold increase
in its trend” and that “an estimated 71% increase in
ivory smuggling out of Africa corroborates this finding,
while corresponding patterns are absent from natural
mortality and alternative explanatory variables. These
data suggest the widely documented recent increase
in elephant poaching likely originated with the legal
sale.” Their results “are most consistent with the theory
that the legal sale of ivory triggered an increase in
black market ivory production by increasing consumer
demand and/or reducing the cost of supplying
black market ivory, and these effects dominated any
competitive displacement that occurred”.
Elephants Are Not Tyres:
Why The Ivory Trade Should Not Be Allowed
CITES COP
Elephant
Slaughter and
Decimation
Ivory Trade
Southern African
countries
Stimulation of Demand
and the Market in Asia
Corruption &
Transnational Crime
Photographer Morgan Trimble
EMS FOUNDATION
A document prepared for CITES COP 17 | 23
James Baker, a former US Secretary of State and a
dedicated hunter, also surprisingly voiced support
for a ban on all ivory sales “ One-off sales of African
countries’ stores of confiscated ivory in the past two
decades - which were permitted under the assumption
that they would drive down the price of ivory - instead
appear to have had the opposite effect … Poached
ivory looks nearly identical to legal ivory, enabling vast
amounts of illicit material to be laundered and sold
openly- further driving trafficking and the poaching of
elephants. It is time to end all ivory sales worldwide”.54
A wide range of NGOs including the EMS Foundation,
The WWF, IFAW, the Environmental Investigation
Agency (EIA), Amboseli Trust for Elephants, Big Life
Foundation, the Born Free Foundation, the David
Sheldrick Wildlife Trust, the David Shepherd Wildlife
Foundation, Elephant Action League and others have
opposed the current application by South Africa,
Zimbabwe and Namibia for trade. TRAFFIC, the global
wildlife trade monitoring network, has also rejected
the sales proposals.
SADC Members have been the primary drivers of
requests for ivory sales since 1997. Public comments
from senior officials and politicians in South Africa,
Zimbabwe and Namibia reveal that raising funds
irrespective of the plight of elephants elsewhere in
Africa is the primary driver of their position.
South Africa has taken a strong line in differentiating
between management policy relating to elephants in
southern Africa and elsewhere in Africa, often refusing
to acknowledge that decisions on trade could have
Continental, or global, implications. They are also
often victims of their own ideological position and
spin-doctoring, seemingly deliberately ignoring the
mounting evidence, analysis and research as well as
large-scale seizures of ivory which have more than
doubled since 2009.
Edna Molewa, the South African Minister of Environmental
Affairs, told an audience during the signing of a rhino
anti-poaching agreement with Mozambique in April
2014 that selling rhino horn might help reduce poaching
as had been learnt from “South Africa’s ivory sale”. “…
just taking the lesson we have learn from ivory. We did
a once-off sale and elephant poaching has not been a
problem since…”55
Zimbabwe, which is in a political crisis, with its economy
in ruins and massive unemployment, has made it clear
that it wants to sell ivory purely for the money. The
Minister of Environment Water and Climate, Oppah
Muchinguri-Kashiri told the Zimbabwean National
Assembly in July 2016“ We have 96 tons of ivory and
if we sell it, we will realize about $9,1 billion,” Minister
was quoted as saying in the state controlled Herald
newspaper in Harare.
24 | A document prepared for CITES COP 17
The report noted that the Minister said this amount
of money “could turnaround the fortunes of the
country should a ban on ivory trade be lifted.”56
This figure is wildly inflated and makes the assumption
that Zimbabwe’s stockpile if is worth about US$94,791
a kilogram. The Hong Kong Tourism and Natural
Resources Minister, Professor Jumanne Maghembe
said in September the average wholesale price of ivory
in Hong king’s was $150 a kg.57
In a formal document submitted to CITES Zimbabwe
argues that “The proposed move by the proponents
essentially infringes upon Zimbabwe’s sovereignty to
make decisions over its wildlife resources, for the benefit
of its economy and its citizens without interference.”58
The same Minister concedes that Zimbabwe has
been unable to stop theft from its ivory stockpiles.
Commenting on a theft of ivory from stockrooms at
the Hwange National Park in April 2016, the Minister
said “...the investigations we have conducted since
late last year prove that there was indeed a lot of ivory
theft from within the parks authority itself,” and that
the “markets included Chinese people, some of whom
sometimes buy ivory legally from government sales.”59
Namibia’s position is similar that that of Zimbabwe.
“We will get a lot of money and the proceeds will go to
state coffers to alleviate poverty” Namibia’s Minister
of Environmental and Tourism, Lobamba Shifeta, told
the New Era newspaper in 2015. The Minister also
said the burring of ivory stockpiles would be waste of
potential revenue.60
In demanding another “once off sale,” if granted it
would be the third since 1989, South Africa, Namibia
and Zimbabwe have clearly taken a stand to lobby for
their own economic gain at the expense of elephant
populations in other African nations. None of these
SADC countries has produced any evidence to show
that sales will not jeopardise elephants elsewhere in
Africa, or Asia, despite considerable evidence that this
is likely.
In arguing that it is their sovereign right to make
decisions about how to manage their wildlife resources
they fail to acknowledge that these rights must be
exercised in a way that does not impinge on the
sovereignty of others. The decisions taken by South
Africa, Zimbabwe and Namibia will clearly have an
impact on elephants throughout Africa.
The South African government’s current position in
relation to ivory sales and stockpiling is mercenary and
counter-intuitive and it is holding the rest of the continent
to ransom. South Africa is misguidedly following a “South
African exceptionalism” position, which continuously
distances itself from other African countries and displays
a disregard for the rest of the continent.
EMS FOUNDATION
All three countries were signatories to the CITES
African Elephant Action plan signed in 2010 by 37
African elephant range states in Africa. The signatories
agreed that “the African elephant range States shall
continue their constructive elephant dialogue aiming
to develop joint conservation policies and exchange
of management experience in order to improve the
management of elephant populations,”, the proposal
submitted to CITES in March 2010 stated, adding that
“African countries have progressively strengthened
understanding and cooperation within and amongst
elephant range state on numerous social, economic and
environmental issue of mutual interest and concern.”61
The “constructive dialogue” has clearly broken down
and in the proposal to CITES Zimbabwe perhaps
explains the stance of the three pro-sale nation’s
most clearly. “Zimbabwe would oppose any moves
that seek to prescribe an umbrella approach to the
management of African elephants particularly to
range states that have proven to manage thriving
elephant populations through successful conservation
practices,” the country states in a document submitted
to CITES supporting the appeal to trade. “The proposed
move by the proponents essentially infringes upon
Zimbabwe’s sovereignty to make decisions over its
wildlife resources, for the benefit of its economy and its
citizens without interference”.
This shows little commitment to a continent-wide
coordinated approach to reducing poaching. The
focus on revenue generation through increased trade
in ivory is counter to widespread calls for demand
reduction programmes in user countries.
South Africa, Zimbabwe and Namibia seldom enter
into meaningful discussions about demand reduction
for ivory or rhino horn although South Africa recently
declined to lodge a request to sell rhino horn because
it was felt that it was unclear whether sales under the
present conditions would stimulate poaching. This is
a concern clearly not felt with regard to ivory and the
circumstances of elephants elsewhere in Africa.
The killing of elephants is fuelled by corruption,
poor administration, demand for wildlife “products”
and many other socio economic issues. Legal trade
in wildlife is widely used as a cover for illegal trade.
South Africa, for example, allows a limited amount of
legal abalone (perlemoen) trade and also maintains a
number of abalone aquaculture projects but poaching
still continues unabated and illicit trade far outweighs
the legal trade.
As the Report on South Africa’s illicit abalone trade; an
updated review and knowledge gap analysis states, “The
legal trade is regularly used as a cover by poachers
and the smuggling syndicates to move abalone
through neighbouring countries, some of which are
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landlocked” and that “the poached abalone enters the
general market stream in which it instantly becomes
indistinguishable from the legal equivalent.
This is the case with ivory too. End users cannot
easily distinguish between what is legal and what
is illegal meaning that legal sales simply fuel trade.
The transnational criminal syndicates involved easily
move between species depending on the profitability.
Rhino smugglers easily become elephant or pangolin
smugglers, people smugglers or drug merchants.
Promoting legal trade in ivory, or rhino horn, sends a
signal that it is acceptable to use these animal parts.
In proposing trade when wild animal populations
in unprecedented decline South Africa, Namibia
and Zimbabwe are setting themselves above the
interests of the rest of Africa and other countries that
are determined to ensure that elephants survive and
continue share the planet with humans.
AFRICAN GREY PARROTS
South Africa is one of the largest exporters of
Africa grey parrots in the world.
Although African Grey Parrots do not occur naturally
in South Africa, tens of thousands have been imported
into South Africa from other African states, notably the
Democratic Republic of Congo and very large numbers
are also bred in captivity for sale into the global pet
trade and to provide breeding stock for commercial
breeders.62 According to the Parrot Breeders
Association of South Africa (PASA), South Africa has
1,632 breeding facilities which hold 97,928 African grey
parrots (48,964 pairs).
African grey parrots are experiencing significant
population declines in the wild due to the capture of
birds for the pet trade and habitat loss. Mortality rates
are very high amongst captured birds.
The World Parrot Trust says that only about 560,000 of
the birds may be left in the wild and that “Over 1.3 million
wild-caught individuals of mostly P. erithacus (African
grey parrot) entered international trade in four decades.
Taking into account a mortality rate of 40-60% the true
number trapped could be upwards of 3 million.”63
A motion requesting that the protection of Grey
parrots be improved by listing the population to CITES
Appendix I will be made at COP 17 by Angola, Chad,
the European Union, Gabon, Guinea, Nigeria, Senegal,
Togo and the United States of America. They argue
that placing the African grey on appendix I is essential
because “the African Grey parrot has experienced
marked population declines throughout its range. In
June 2012 it was re-categorised as Vulnerable on the
IUCN Red List of Threatened Species on the basis that
“the extent of the annual harvest for international
A document prepared for CITES COP 17 | 25
trade, in combination with the rate of ongoing habitat
loss, means it is now suspected to be undergoing rapid
declines over three generations (47 years).”64
This document also points out that in many instances
trade figures for African grey imports by South Africa
do not match export documents from the Democratic
Republic of Congo and that fake or falsified permits
have been used to launder illegally caught birds into
the legal trade. “In 2009, 2010 and 2012, reported
imports by the Republic of South Africa from the
Democratic Republic of Congo exceeded their annual
export quota and the exports reported to CITES in
each of these years…The Republic of South Africa is
the largest exporter of captive-bred birds to the global
market and in 2012 exported over 42,000 specimens
under CITES code C…Currently commercial-scale
breeders in the Republic of South Africa import high
volumes of wild caught birds as inexpensive breeding
stock. Reported imports from the Democratic Republic
of Congo alone have regularly exceeded that country’s
export quota in recent years.”65
In response to questions in the South African
Parliament the Department of Environmental Affairs
said that 4,100 African grey parrots were imported from
the Democratic Republic of Congo in 2009.66 In 2011
at least 750 African grey parrots, part of an order of
1,650 wild caught birds from the Democratic Republic
Congo, died on an aircraft between Johannesburg
and Durban.67
In July 2016 the Vice Chairman of PASA, Antonie
Meiring, told a South African CITES stakeholder
meeting that the commercial breeding of African grey
parrots had increased exponentially in South Africa
since the 1990s. He said that the latest available figure
gathered by his organisation showed that:
• 1,632 breeding facilities in South Africa held 97,928
Grey parrots (48,964 pairs) for breeding purposes.
• 66,591 chicks were bred every year (it was not clear
26 | A document prepared for CITES COP 17
if this an average figure).
• The global demand for African grey parrots in 2014
was 97,706 birds of wild, captive and unknown
origin. Of these 82% were captive bred in different
parts of the world.
• Of the captive bred birds traded 96% came from
South Africa.
PASA opposes the submission requesting African grey
parrots be placed on CITES Appendix I on the grounds
that the listing will not assist in protecting wild parrots.
“Left on Appendix II South Africa can play a vital role to
supply enough aviary bred birds to satisfy the global
demand,” Meiring stated in his presentation.
As with South Africa’s position on trade in ivory, lion
bones, abalone and other animals and plants PASA
stance places trade above conservation of wildlife.
CITES notes considerable irregularities in the trade of
wild birds and it is clear that this trade is deeply linked
to severe population declines amongst wild African
grey parrots. Trade, both legal and illegal, is clearly
contributing to the decimation of the planets’ wildlife
and plants.
In a submission made to the Department of
Environmental Affairs in July regarding various
proposals regarding CITES listing EMS Foundation
noted: “It was clear from the… stakeholder meeting
held in June that parrot breeders in South Africa have
been trading in wild-caught parrots. This is supported
by statistics in the CITES trade database. Again it is a
case of a dual market and a legal trade providing a cover
for illegal trade. The EMS Foundation totally supports
the position taken by the World Parrot Trust, Africa
Conservation Programme as presented by Dr Lynn
Jackson and we concur that the rates of decline are
consistent with CITES guidelines for Appendix I listing.”
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HUNTING FOR PROFITS: SOUTH
AFRICA AND TROPHY HUNTING
The proponents of “trophy hunting as a conservation
tool” contention are primarily trophy hunting advocacy
organisations, like PHASA, CHASA, SAPA, Safari Club
International etc. These organisations often cite two
interrelated documents as alleged “proof” that trophy
hunting can be a “useful tool” to conservationists: the
IUCN SSC Guiding Principles on Sport-hunting as a
Tool for Creating Conservation Incentives (09 August
2012) and CITES Resolution Conf. 2.11 (regarding trade
in hunting trophies of species listed in Appendix I).
The primary theory for promoting trophy hunting as
a conservation tool behind the IUCN Principles and
the CITES’s Resolution is that hunting can: incentivise
governments in developing countries to generate
conservation programmes and directly raise funding
for on the ground conservation efforts in counties with
otherwise limited resources.
Supporters of trophy hunting based conservation
increasingly ignore that these so-called benefits of
trophy hunting have not overcome the long-term
negative effect of hunting - namely the allowance
for legalised killing of these animals continues to
decrease their overall chance of survivability as a
species in the wild.
In fact, development economists conducted a study
on illegal trade of wildlife and found that “the literature
advocating trade as a conservation solution for
endangered species relies on models that are based
on simplistic and/or extremely restrictive assumptions.
The study went on to explain that in most cases these
models rely on conceptual tools that have been
theoretically discredited.
Indeed, many objective scientific studies and in the field
observations that are not directly supported by trophy
hunting organisations have repeatedly concluded that
trophy hunting endangered or threatened species,
even if well managed, is one of the primary factors
driving the illegal trade of these species in the black
market. These findings show that the legal and illegal
markets are intertwined in a complex manner and that
their interactions create a dual market that is impossible
to regulate.
Development Economists such as Nadal and Aguayo
who ironically are also supported by South African
programmes driven by the Department of Trade
and Industry (DTI) and the Industrial Development
Corporation (IDC), for example through the African
Programme on Rethinking Development Economies
(APORDE). These economists are extremely concerned
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by the lack of serious economic analysis on market
structures and price formation dynamics in markets for
so-called wildlife ‘products’ (including, of course, ivory,
rhino horn, lion and tiger bones and skins, etc.).
They argue that advocates of trophy hunting and
deregulated trade of these ‘products’ have been
navigating in oceans of ignorance, both in terms of the
theoretical tools that are used as well as the superficial
analyses of real world (existing) markets. This means
that assertions concerning the movement of prices
and the amount of resources that are supposed to be
‘ploughed back’ into conservation are in reality just
empty statements.
South Africa has the largest hunting industry in
sub-Saharan Africa and it is Africa’s most popular
destination for foreigners wishing to kill anything
from elephants and buffalo to the 4.5 kilogram blue
duiker and 1.6 kilogram genet. South Africa also has a
large domestic recreational (“biltong” or South African
dried “meat”) hunting industry. In addition, so-call
subsistence or “bushmeat” hunting, usually referred
to as “poaching” (with all its cruel implications), takes
place in many parts of the country. Levels of “poaching”
are high in South Africa because it that coincides with
poverty, joblessness and market-driven “wildlife” trade
and policies.
The hunting industry is far from under control with
canned hunting officially endorsed and supported
by the State. The reality is that most trophy hunting
in South Africa is essentially canned to a greater or
lesser extent. South Africa remains the worlds’ top
destination for the hunting of captive raised lions and
according to the Department of Environmental Affairs
there are approximately 6,000 lions in captivity (at any
given time) held in about 200 facilities.68
Sixty eight percent of Africa’s wild animals that were
killed by American trophy hunters between 2005 and
2014 came from South Africa, i.e., of the 565,558 African
animals killed during this period, 383,982 came from
South Africa.69 A Humane Society International report
for the same period showed that out of a total of 5,587
lion trophies 3,999 came from South Africa. 70
Although the situation with regards to lion and rhino
hunting has attracted widespread attention and
criticism, both locally and abroad, the killing of all
species of wild animals has increased significantly over
the past ten years. It is worrying that in a country which
is aggressively advocating and allowing the killing of
other animals for profit that many hunting regulations
A document prepared for CITES COP 17 | 27
are poorly enforced and provincial and national
officials do not collect and collate the relevant data - a
failing which draws into question the basis on which
many decisions in relation to wild animals are taken.
Many officials, by the governments’ own admission,
either misunderstand or fail to apply national
environmental regulations such as the Threatened
and Protected Species regulations (TOPS). In addition,
despite the scale of the industry, the Department of
Environmental Affairs does not have an electronic permit
system that allows it to collate the numbers of hunting
permits issued nationally. If it requires information it has
to contact the nine provinces individually and they too
do not have electronic permit systems.
The consequence of this is that it “does not have
information on the number of hunting permits issued
for a particular species across the country”71 nor “does
not keep a national register of professional hunters and
there is no limit to the number of hunters permitted.”
The trophy hunting industry in South Africa is not only
growing but is also extremely difficult to monitor or
police and official control is poor at best. The national
and provincial hunting permit systems have been
inefficiently administered and a national permitting
database does not exist. So for the hunting and
“wildlife” industry it is virtually a case of carte blanche.
Instead of a
precautionary
approach,
South Africa is
facilitating the
trophy hunting of
wild animals from
their protected areas
through live sales
and by allowing
hunting along the
Kruger National
Park’s ever-increasing
porous borders.
28 | A document prepared for CITES COP 17
Societal injustice, subjugation, the proliferation of
violence and exploitation frame the indifferent wildlife
industry. And it is with individual, community and
ultimately global silence that these fundamentally cruel
practices continue to grow, fester, are camouflaged and
ultimately feed upon themselves. This has particular
resonance in South Africa because of the serious
problem of violence the country has faced and is facing
and the tools required to combat it.
A recent study analysed trophy hunting in six
African countries - South Africa, Zimbabwe, Zambia,
Mozambique, Namibia and Tanzania - where trophy
hunting has touted by the industry and governments
as “an effective conservation tool,” unsurprisingly
showed that in reality: trophy hunting is causing
decline in wild animal numbers, having negative
impacts on wild populations and causing the loss of
healthy individuals that are key for reproduction and
social cohesion; there is also an extremely close link
between legal hunting and poaching; that trophy
hunting is fuelling corruption; and that trophy hunting
encourages the unfair redistribution of the wealth
generated (Cruise:2016).
The so-called “new” conservation paradigms that
include notions of: the well-heeled legal white hunter
versus the illegal impoverished black “poacher;” the
intense privatisation, and commodification of wild
animals; and livelihoods and benefit-sharing, further
excluding and entrenching antagonistic views of, and
alienation from, wild animals by local communities. The
relationship between communities and wild animals is
therefore fixed within the construct of “human-wildlife
conflict”, leading to loss of agency and exploitation of
both humans and wild animals.
Private ownership is at the core of the “new conservation”
discourse and thus there is state-capital collusion
and “State capture” by the hunting industry when it
comes to wild animals. The post-apartheid State has
played a significant role in supporting and privileging
the privatisation of wild animals for profit by passing
enabling legislation to assure private ownership of wild
animals, selling them off from national and provincial
protected areas and parks at lower prices and poor
institutional enforcement and corruption. This has made
it complicit in the growth of the lucrative, unrestrained
and reprobate wildlife industry.
There is asymmetry and an ideological convergence
between the State and the contentious wildlife
industry. This is particularly problematic given that it
is about much more than mere issues of enforcement
and regulation, it is about perverted states and power
arrangements within the state system.
Approximately one-sixth of South Africa’s total land has
been fenced and converted for private “wildlife-based
production.” Snijders shows that the wildlife industry
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is organising politically and using its muscle and
resources to influence government policy, importantly
in ways that exclude dissenting voices.
An example of this is the establishment of the Wildlife
Forum in 2005. It deliberately excludes labour, animal
welfare and civil society stakeholders. “When asked
why these stakeholders were absent, an industry
member commented: ‘No, no, they are not real
stakeholders. They don’t own anything; it’s [that they
are] not hunters, not landowners’” (Snijders 178:2014).
The Forum, which works hand-in-glove with Safari
Club International, promotes a discourse alliance that
endorses both government’s conservation interests
and industry’s development interests. Thus, in line
with neoliberalism, the development of “wildlife”
policy in South Africa reveals a strong alliance
between the state and capital (in this case the hunting
industry) by means of deregulation and public-private
partnerships. (Snijders 2014).
THE ROLE OF NATIONAL AND PROVINCIAL PARKS
The African National Congress government, through
SANParks, a Public Entity of the Department of
Environmental Affairs, operates at a profit and
generates 75% of its operating revenue.72 This includes
revenue from the sale of “wild animals,” which from
2011 to 2014 amounted to R134,248,173.73
In this same period the sale of rhinos made up the
largest percentage: between January 2010 and June
2014, 354 rhinos were sold and 6 “given away” for
R81,060,538.74 These figures exclude the number of
rhinos (and profit made) by provincial conservation
authorities. Thus, at the same time that rhinos are
being killed at an accelerated rate, the State is not only
actively stimulating the trade in rhinos but making a
profit as part of the bargain.
National and provincial parks see wild animals as
lucrative assets and sell them to local private operators
and dealers, including for trophy hunting purposes,
for onward sale via private auctions, and to overseas
destinations such as zoos and other captive facilities.
To ensure the protection and survival of wild animals
they should not be sold off to be killed as hunting
trophies but rather they should only be translocated
in order to expand the range of the species. Instead of
this precautionary approach.
SANParks appears to prefer to rather promote and
actively facilitate the trophy hunting of wild animals
(which they supposedly hold in custody and care on
behalf of all South Africans) not only through live sales
but also by allowing hunting along the Kruger National
Park’s ever-increasing porous borders.
have big horns and large tusks. The internet is littered
with boasts of hunters from Europe and the USA
who seem to get a perverse thrill from killing “Kruger
animals,” from what they often offensively refer to as
the “Dark Continent,” and sticking them on their walls
as symbols of domination and prowess.
So, on the one hand, SANParks says it goes totally
against their mandate and legislative regulations to
allow hunting in the national parks, but on the other
hand, they appear to be smoothing the way and
encouraging trophy hunting and the killing of the very
beings that are supposed to be under their protection.
Wild animals living in the Kruger National Park (where
hunting is not allowed) are moving across unfenced
boundaries on the Park’s western border into the
Associated Private Nature Reserves (APNR) and on the
Park’s Eastern border into Mozambique where they
are commercially trophy hunted by foreign trophy
hunters for exorbitant sums. The Protected Areas Act75
prohibits certain “extractive activities” in national
parks, including hunting. Nonetheless, hunting is
taking place in the areas which share open boundaries
with the Kruger National Park.
Turning a Blind Eye: ‘Sustainable Use’ Policies
and Hunting in the Kruger National Park
‘Buffer Zones’
The Kruger National Park, South Africa’s premier
conservation area, shares it’s western, northern, and
southern boundaries with a number of provincial and
private nature reserves. Many of these boundaries are
unfenced and wild animals cross back and forth at will.
Hunting is permitted in some of the provincial and
private parks and animals crossing from the Kruger
National Park are sometimes killed by hunters. This
issue has been hotly debated with some arguing that
TRADE AND TROPHY
HUNTING HAS
DRIVEN RHINOS IN
AFRICA TO THE EDGE
OF EXTINCTION.
Trophy hunters are salivating to kill individuals who
originate from the Kruger National Park because they
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A document prepared for CITES COP 17 | 29
hunting outfitters operating in these areas are simply
utilising the Park as a source area for target animals,
including elephant and buffalos.
In addition number of reports and studies, as well as visits
to a number of reserves by EMS Foundation researchers,
show that many of the provincial reserves have a shortage
of skilled staff, lack adequate financial resources and
experience high levels of “poaching”. Compounding the
management issues is the fact that some of these parks
have not been formally declared (gazetted). This hinders
efficient management of these areas.
The provincial and private parks that form buffer
zones along the Kruger National Park are important
conservation areas that play a key role in enhancing
and supporting the conservation goals of the Park.
It is of critical importance that the various official
stakeholders act as a matter of urgency to improve
the management of provincial reserves and to ensure
that private reserves are managed in an open and
transparent manner. Although they are privately
owned they form part of the greater Kruger National
Park, which means they form part of the Great Limpopo
Transfrontier Park.
The Kruger National Park is managed by SANParks on
behalf of the citizens of South Africa. The issue of hunting
in both provincial and private reserves also needs to be
the subject of public debate and consultation. Hunting
in these areas has a direct impact on the Kruger National
Park and is a matter of public concern.
Minutes of a Department of Environmental Affairs
Briefing to the Parliamentary Portfolio Committee
on the Environment entitled “Provincial conservation
challenges and programs” held on 11 November 2014,
recorded a wide range of problems facing provincial
reserves. Many of these “challenges” remain unresolved.
These minutes state that the Department briefed the
Committee on: “the support, resources, challenges and
constraints in relation to the provincial conservation
authorities when implementing the conservation
mandate, particularly around the compliance and
enforcement of biodiversity legislation.”
The Department told the meeting that “the
concurrent competence issue (environment and
nature conservation) between the national and
provincial departments did cause some complications”,
and it was “concerned to bring all role players
together to agree upon common priorities and
enforcement mechanisms.”
The meeting also noted that “the main challenges to
maintaining a stable biodiversity related to funding,
lack of capacity and operational issues. The basic
allocations were inadequate and there was a need to
find a proper funding model and focus”. It was also
30 | A document prepared for CITES COP 17
pointed out the lack of capacity was evident in the few
rangers, their aging profile, the need to recruit skilled
trackers, interpreters, specialised investigators and
environmental management investigators and analysts.
Some provincial reserves have also been the subject
of land claims and community groups have in some
instances become embroiled in disputes over land
claims and even when land claims have been settled
(for example Mala Mala private reserve) many issues
remain unresolved. In some areas serious disputes
have developed over access to hunting rights.
In terms of South Africa’s wildlife management policies
these reserves are considered “buffer zones” which,
according to the 2013 Biodiversity Policy and Strategy
for South Africa: Strategy on Buffer Zones for National
Parks “includes the immediate setting of the national
park and attributes that are functionally important as a
support to the national park and its protection.”
Despite the importance of these areas South Africa has
been slow to resolve management issues and to coordinate management plans. In some private reserves
managers have to deal with both the SANParks and
provincial officials in the formulation management
plans and hunting quotas.
In the case of some provincial parks the situation is even
more cumbersome and provincial officials, SANParks
and community representatives/or concessionaires are
sometimes all involved. In many instances there is a
breakdown in communications between these parties
resulting in weakened management processes.
Many of the provincial reserves are seen as a component
of the Great Limpopo Transfrontier Park which is shared
by South Africa, Zimbabwe and Mozambique.
The situation in Mozambique is also of concern
with a number of private reserves which border the
south eastern boundary of the Kruger National Park
and which allow elephant, lion, buffalo and leopard
hunting, In some areas animals from the Kruger
National Park regularly cross the border.
The provincial reserves which share borders the Kruger
National Park include:
• Makuleke Contractual Park, unfenced border,
managed jointly between the concessionaire and
the Kruger National Park.
• Makuya Nature Reserve, unfenced border,
managed by Limpopo Province.
• Letaba Ranch Nature Reserve, unfenced border,
managed by Limpopo Province.
• Mthimkhulu Nature Reserve, unfenced border,
joint management between Limpopo Province and
the concessionaire.
• Manyaleti Game Reserve, unfenced border,
managed by Mpumalanga Province.
• Andover Nature Reserve, fenced and shares
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boundaries with the Timbavati and Manyaleti Game
Reserves, both of which are open to the Kruger
National Park, managed by Mpumalanga Province.
• Mthethomusha Game Reserve, fenced border with
the Kruger National Park, managed by Mpumalanga
Province.
• The Marietta Buffer area (which includes the
Mahumani, Ndindani, Mahlathi, Muyexe and
Mhinga areas, Kruger National Park boundary fence
in place. The area is not formally included in the
Kruger National Park or provincial reserves.
Private reserves which share unfenced boundaries with
the Kruger National Park include:
• The Associated Private Nature Reserves (APNR)
are privately owned and managed in consultation
with Kruger National Park. The APNR includes the
Timbavati, Klaserie, Umbabat and Balule Private
Nature Reserves. All share open boundaries with
the Kruger National Park.
• Sabi Sands is privately owned and a draft agreement
is in place with the Kruger National Park.
• Mala Mala (owned by successful land claimants
and privately managed) also shares an unfenced
boundary with the Kruger National Park.
• Mjejane Private Game Reserve, unfenced border,
private management in agreement with local
communities.
Some of the provincial reserves have still not been
formally declared which has a direct impact on comanagement of these areas. These include Letaba
Ranch, Makuya and Mthimkhulu.
Letaba Ranch
The Letaba Ranch covers approximately 42,000
hectares and incorporates the Mthimkhulu Nature
Reserve (6,349 hectares). Trophy hunting takes place
on at Letaba Ranch. It is run by the Limpopo provinces
LEDET Department (Limpopo Department Economic
Development, Environment and Tourism) and shares
an unfenced boundary with the Kruger National Park.
A 2013 five-year strategic management plan for Letaba
Ranch has also not been implemented because:
• The reserve is not officially proclaimed as a nature
reserve and therefore does not fall under the legal
protection of Protected Areas Act.
• Ageing staff component and shortage of staff.
• Centralised budget, and de-capacitated reserve
management.
• Lack of resources.
• Lack of communication/co-operation between
management and stakeholders.
• Very little scientific data available as a result of a
lack of research and monitoring.
• Ineffective management.
• Hunting activities are not sustainable as it is not
backed by good scientific data.
• “Poaching” is a serious problem in the reserve.
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• Contestations over land claims and hunting
concessions.
• Illegal logging and mining within the reserve.
Past and current employees of the Kruger National Park
(names withheld at the request of the interviewees)
confirm that Letaba Ranch, has for years prior to 1994,
been used for trophy hunting and the controls were lax.
According to a former Kruger official with more than
30 years’ experience “If you knew the right people
in those days you could have done pretty much as
you wanted...These days not too much has changed,
it is still a case of who you know and good money is
paid. Lots of money changes hands…In recent years
the hunting has been a closed shop but it is heavily
contested now. Some of the local communities, not all,
want to start making money too, so the competition
is getting hot.”
The official said that trophy hunters often waited for
elephants and buffalo move along the banks of the
Letaba River, and the Klein Letaba further north, to
select a trophy. “Some of the elephant bulls … spend
lots of time in Kruger and make the mistake of crossing
an unmarked border with fatal results...There have also
been cases of baiting of lions from Kruger here and
future north…In some instances hunting permits have
been used several times over as few people check up
on what is happening.”
In November 2015 the Letaba Herald, a newspaper
based in the nearby town of Phalaborwa, reported that
they had evidence of widespread corruption linked to
hunting in Letaba Ranch. In a story headlined “Letaba
Ranch: a nest of corruption the newspaper said that “For
decades rumours have been flying around regarding
illegal hunting and poaching in this reserve. What
makes the illegal hunts even worse is that there is no
fence between Letaba ranch and the Kruger National
Park. In effect this means that KNP’s animals are being
hunted illegally. Documents and sound recordings
which have come into the Herald’s possession expose
a trail off illegalities in the hunting industry.”
The story then gives details of various people alleged
to be involved in dubious deals, including bribery, to
secure hunting permits. This included hunting operators,
wealthy people from Phalaborwa and factions within
the local rural communities. The Herald story also states
that various local communities are working against each
other to get hunting rights. This involves disputes over
land claims and which groups have the rightful claim to
some of the land in Letaba Ranch.
The City Press newspaper also reported at the same
time that a hunting concession holder was ejected
from the area because the community felt he had been
cheating them. The newspaper pointed out that a
number of people were involved in the dispute.
A document prepared for CITES COP 17 | 31
The unregulatable
cannot be regulated.
The EMS Foundation has in its possession a variety of
documents which confirm the turmoil. A visit to area
and interviews with a number of people involved in
the disputes also reveal that provincial authorities
are either powerless to resolve matters or actively
involved in the infighting. “We see that many people
make money from the place (Letaba Ranch) but we
are always left out,” one man who lives on the border
of the reserve told the EMS Foundation. “We are the
people who live here but the money goes elsewhere.
Who can blame people for poaching when all we want
to do is get our share.”
Conservationists working in the region report that
the setting of snares for antelope and even buffalo is
common on Letaba Ranch. “You can go there at any
time and find snares, particularly along the river,” a
ranger with 15 years’ experience in the region said.
“There is also some hunting with dogs and illegal
shooting and nobody seems to report it or do much
about it”.
He added that the illegal cutting down of trees was a
common problem and that. “poaching” in Letaba Ranch
was poorly controlled. “The authorities seem to turn a
blind eye. Animals are snared or killed by dogs all the
time at Letaba ranch,” he said.
Newspaper reports record a number of major
“poaching” incidents in recent years.
• In November 2015 when at least 22 white backed
vultures died after feeding on two poisoned buffalo
carcasses. The head and intestines of the vultures had
been removed for use in the traditional medicine.
• In 2012 at least two rhinos, one an endangered
black rhino were shot for their horns.
• In 2010 the remains of at least 17 rhinos, killed two or
three years previously, were found at Letaba Ranch.
Conservation authorities could not explain how so
many rhino carcasses had remained undiscovered
for so long.
A mine has also been constructed within the reserve
but despite strenuous opposition was allowed to
continue working.
From the above it can be seen management of the area
is weak at best. It is clear that far from being a buffer
zone that is ‘’functionally important as a support to
the national park and its protection.” Letaba Ranch
(including Mthimkhulu) is anything but that. Rather it
is a problem area that needs to be put right as a matter
of urgency.
32 | A document prepared for CITES COP 17
Makuya Nature Reserve (MNR)
This reserve is also run by the Limpopo provinces
LEDET Department (Limpopo Economic Development,
Environment and Tourism). It borders on the far north
western boundary of the Kruger National Park, north
of the Punda Maria gate and South of the Pafuri Gate.
The Levubu River form the boundary between the
parks and animals regularly cross between the two,
particularly in the dry season when the water levels
are low.
Trophy hunting takes place in the reserve with
elephants, buffalo and antelope being targeted. An
EMS Foundation researcher has watched elephants
and buffalo move to and from the Kruger National
Park. “Poaching” is also a serious problem.
A draft management plan “Five year strategic
management plan for the Makuya Nature Reserve,
Limpopo Province [2012]” also never been implemented
because, amongst other issues:
• The reserve is not officially proclaimed as a
protected area. (This is still the case)
• The co-management agreement between the
management of the MNR and the Kruger National
Park cannot be located and relations are sometimes
strained.
• The management authority is ineffective and
incapacitated by internal political issues.
• High levels of corruption in the government
institutions of the area impact on management.
• There is a considerable conflict among communities
that have a land stake in the reserve, particularly
with regard to the division of reserve benefits.
• Many of the MNR’s internal roads are only accessible
via 4x4 vehicles - this makes management difficult
and increases wear and tear on equipment and
vehicles.
• Water and electricity supply received from mining
infrastructure on the reserve may end when mining
activities conclude.
• Reserve staff has limited capacity.
• Ageing staff complement.
• The management authority is ineffective and
incapacitated by internal political issues
• Institutional financial constraints and a lack of a
dedicated budget for the reserve as a cost
• “Poaching” from surrounding communities.
• High levels of corruption in the government
institutions of the area impact on management.
• There is a considerable conflict among communities
that have a land stake in the reserve, particularly
with regard to the division of reserve benefits.
According to the consultants employed to draft
the management plan (NCC),“the co-management
agreement between the management of the
MNR and KNP cannot be located and relations are
sometimes strained”.
EMS FOUNDATION
Regular visits to Makuya by an EMS Foundation
researcher reveal that infrastructure is in poor
condition. People in conservation and tourism projects
in the area report that “poaching” in the area have
increased in the past 18 months. “There is lots of
snaring but I have seen spotlights at night and heard
shots as poacher work along the river (which forms
the border with Kruger National Park),”he said (again
he asked not to be identified for this report because
of potential repercussions.” Nobody in the park does
anything about it. They often don’t have fuel for their
vehicles and those are often broken-down too.”
Makulele Contract Park
Hunting was briefly permitted within the Makuleke
Contract Park run by the Makuleke community who
won a land claim in the 19 842 hectare ‘‘Pafuri Triangle’‘
which runs from the Limpopo to the Luvuvhu River
along the north eastern border of the Kruger National
Park. Hunting commenced in 2000 and two elephants
and two buffalo were killed by foreign hunters. The
quota had increased to five elephants and seven
buffalo by 2003 but hunting was discontinued in favour
of non-consumptive tourism.
Manyaleti, Andover and Mthethomusha
Nature Reserves
Manyaleti and Mthethomusha have both been the
subject of land claims. The land claims on Manyaleti
have not been fully resolved and members of the
nearby communities are at loggerheads over who
should benefit from any development of the park.
Local tour operators report snaring in the area and antipoaching specialists spoken to by the EMS Foundation
say the park is often used by poachers entering or
exiting the Kruger National Park.
One tour operator, who previously worked for the
government, spoken to by EMS Foundation claimed
that buffalo were sometimes removed from the park by
corrupt officials who then claimed this was necessary
for “scientific purposes” but in realty were selling the
animals to hunters. The Andover Reserve, although
it does not border directly on the Park (it borders on
the Timbavati which is part of the APNR and Manyaleti
which borders on the Park) is also reported
Associated Private Nature Reserves (APNR)
The APNR consists of Timbavati, Balule, Klaserie and
Umbabat. The removal of fences between the APNR
and the Kruger National Park began in 1993. According
to a 1996 agreement the purpose of dropping the
fences was according that “the premise and objective
of this agreement is the extension and creation of
ecological unity between the APNR adjoining and
proximate to the KNP and the KNP itself”.
buffalo, leopard, rhino and other species have been
hunted. This fact is carefully shielded from tourists
visiting expensive tourist lodges in the area. The 1996
agreement makes no reference to commercial trophy
hunting.
Many private landowners and some lodges owners
and managers are opposed to hunting but have been
outvoted by those who support the practice. There
has been widespread debate about hunting in these
APNR with many arguing that animals from the Kruger
National Park, which SANParks looks after on behalf of
the citizens of South Africa, are being killed.
Satellite tracking of elephants by researchers shows
that some bulls spend long periods in the Park. Buffalo,
lions and other animals or also known to cross the
unmarked boundaries regularly.
The money raised by trophy hunting is, according
to representatives of the reserves that make up
the APNR, used for anti-poaching operations, local
community development and maintaining the
biodiversity of the APNR. Critics argue that the money
is also used to boost the commercial operations and
to reduce levies. They also argue that they invested
in the area as a Reserve where, as in the Kruger
National Park, hunting should not be allowed and
that while hunting earns much needed revenue
funding for the maintenance of the reserves should be
found elsewhere.
The APNR has a high density of artificial and natural
water holes. This contrasts markedly to the Kruger
National Park where a large number of artificial
water points have been closed. This makes the APNR
particular attractive to water dependent large animals
such as elephant, buffalo and rhino.
WHEN IT COMES TO
WILD ANIMALS THERE
IS “STATE CAPTURE”
BY THE HUNTING
INDUSTRY.
The APNR comprises top tourism lodges and privately
owned properties. Trophy hunting takes place in the
APNR and over the past twenty years elephant, lions,
EMS FOUNDATION
A document prepared for CITES COP 17 | 33
Impala
Zebra
Kudu
Lion
White Rhino
Hippo
Leopard
Waterbuck
55
144
5003
7
19
2
7
3
1
4
2015
30
153*
4720
1
27
1
1*
5
-
7
1
26
2016
33
223
4648
1
26
1
1*
3
-
9
1
23
Warthog
Buffalo
2009
Giraffe
Elephant
APNR APPROVED HUNTING “QUOTAS”76
6
*Please note that:
• 20 buffalos were also approved for live sales in 2015
• 43 white rhinos were also approved for live sales and relocations in 2015
• 19 white rhinos were also approved for live sales in 2016
‘SUSTAINABLE USE’ ON STEROIDS: SOUTH
AFRICA’S CANNED LION INDUSTRY
More than 9,100 lions have been killed in South Africa’s
canned lion hunting industry over the past fourteen
years. Nearly all of the animals killed were raised in
South Africa’s approximately 200 captive breeding
facilities and those intended as trophies were shot
after being released on private land where they had no
chance of escape. Some animals are also killed to the
lion bone trade in the Far East.
The South African government fully supports the industry
as a form of “sustainable use of natural resources”
despite widespread opposition to the practice which
is considered cruel, killing for fun and run by operators
purely for financial gain.
Canned hunting is the ‘put and take’ practice of offering
a captive, and often tame, animal, which usually has
nowhere to run, commonly to a rich overseas trophy
hunter who wants to mount its head on a wall. The animals
used for canned hunts in South Africa include indigenous
and exotic cats (such as Bengal tigers and jaguars).
34 | A document prepared for CITES COP 17
Appetite for profit seems to propel this industry and
it fits comfortably within the current South African
wildlife ideology of “sustainable use”, which is based
on attaching an economic value to a sentient being. As
in the commercial farming of domestic animals, birth
rates are maximised at the lowest costs possible. In
order to increase production of lions, an extra oestrus
cycle is induced, as with farm animals, and the cubs are
removed from their mothers and hand-reared in small
cages. Male lions are sought-after trophies, and as a
consequence are more profitable. Most of the female
cubs are therefore killed.
The hunting of captive raised lions in South Africa,
although an activity that had been taking place for
decades, first drew international attention after the
release of the Cook Report in 1997, which exposed
canned lion practices in South Africa. As a consequence
there was huge public outcry about canned hunting
and its damaging ethical, ecological and biological
implications. South African public opinion favours an
outright ban of this industry.
EMS FOUNDATION
The general public, both locally and internationally,
cannot be criticised for thinking that canned hunting
in South African is a thing of the past. But nothing can
be further from the truth. Far from being controlled,
the canned hunting industry, with active support from
most of the provincial governments, is growing. It is
not only confined to the hunting of large predators elephants, rhinos, buffaloes and antelope species are
also hunted and killed in this way.
About 6,000 lions are held in captive breeding facilities
in the country and about 3,100 wild lions, most
occurring in the Kruger National Park and surrounding
reserves as well as the Kgalagadi Transfrontier Reserve
(about 2,300 lions occur in these two populations).
About 800 lions have been introduced to 45 smaller
reserves over the past three decades.77 It is estimated
that the lion populations across Africa has dropped
by about 43% over the past 21 years and only about
20,000 remain.
The captive breeding of large numbers of lions is of no
conservation value and has also led to inbreeding and
consequent genetic defects. Although most captive
breeding facilities were started with the sole intention
of providing animals to be shot as trophies or for other
forms of entertainment, in the mid-2000s the industry
expanded into supplying the lion bone trade to the Far
East where the bones are used for medicinal purposes.78
”You can make as much money as you like”:
Lion Hunting in South Africa
Most wild lions live National Parks or provincial reserves
where trophy hunting is not allowed and consequently
vast majority of lions that are killed are captive raised
animals placed on private land.
In 2007 the then Department of Environmental Affairs
and Tourism (now the Department of Environmental
Affairs) attempted to impose new regulations which
would have closed down much of the canned hunting
industry but these were rejected by the courts after
legal action by the South African Predator Breeders
Association.
The Department of Environmental Affairs has taken no
action against the industry despite the former Minister
Marthinus van Schalkwyk calling the practice of canned
hunting a “cancer” which had to be stopped. “We are
putting an end, once and for all, to the reprehensible
practice of canned lion hunting,” the minister told
reporters in 2007. “South Africa has a long-standing
reputation as a global leader on conservation issue. We
cannot allow our achievements to be undermined by
rogue practices such as canned hunting.”79
This view appears to have been abandoned by
subsequent Ministers who have promoted the hunting
of captive raised predators as an acceptable form of
EMS FOUNDATION
sustainable utilisation of natural resources. This applies
to the export of lion bone and skeletons too.
At least 9,147 lions were killed in the canned lion industry
between 2003 and 2015. Figures sourced from Lion
Aid (www.lionaid.org ) show that from 2003 and 2013
some 7,487 lion trophies were exported from South
Africa. CITES records show that a further 1,150 trophies
were exported in 2014. Figures provided by North
West province’s Department of Rural Environment and
Agricultural Development, in answer to questions from
the EMS Foundation, show that a further 510 permits
were issued in 2015.
According to these statistics South Africa kills five times
more lions than Tanzania, the next largest exporter of lion
trophies. (South Africa differs from all other lion hunting
countries in that more than 99% of the lions killed are
captive raised and very few wild lions are hunted).
With the exception of South Africa all the figures below
refer to wild lions. Source: http://lionalert.org/
Country
Exported Lion Trophies 2003-2013
South Africa
7487
Tanzania
1408
Zimbabwe
688
Zambia
635
Mozambique
219
Namibia
185
Inadequate Lion Hunting Statistics
South African record keeping with regard to lion
hunting is poor. Hunting permits are issued by the
provinces and details are meant to be submitted to
officials in Pretoria who compile CITES reports but
reports are often incomplete or inaccurate, failing
regularly noted by researchers.
According to a 2015 Joint WILDCRU and TRAFFIC Report,
“…when one compares the number of Lions hunted
(indicated by the hunting register) with the number of
trophies exported (indicated by CITES permits) between
2004 and 2010, there is a large discrepancy in that 1,138
more trophies were apparently exported than Lions
hunted…There may be various legitimate reasons for
this discrepancy, but ultimately the accuracy of the
hunting register is called into question.”80
Captive Breeding of Lions
The captive breeding of lions commenced in earnest
in the 1990s and by 1999 there were about 1000
lions in breeding centres. This has now swelled
to over 6,000.81 Although the numbers of lions in
A document prepared for CITES COP 17 | 35
captivity far outnumber wild lions they serve little
or no conservation purpose. According to the Bones
of Contention Report “The prevailing view amongst
carnivore specialists is that captive-bred Lions do
not contribute to the conservation of the species,
especially for population restoration purposes, since
inbreeding is known to occur and thus compromises
genetic integrity and provenance.”
Other carnivores such as tigers, leopards, cheetahs and
wild dogs are also kept at many of the lion breeding
facilities and exported to breeders and private zoos
locally, where there fate is unknown. Although this is
of major concern, permits are still regularly issued for
the export of these animals.
The breeding of large numbers of lions has significant
welfare issues and although were raised by a number of
South African NGOs as long ago as March 2009 - these
have yet to be addressed by Government. A National
Council of SPCA Report, Lions in Captivity and Lion
Hunting in South Africa – an update,82 called for urgent
action to be taken against the industry and expressed
concerns about, amongst other issues:
• The quality of life of the animals while they are
growing to a size suitable for shooting.
• The quality of life of lions kept in enclosures as
tourist attractions.
• The fate of animals not suitable for hunting.
• The practice of removing cubs from their mothers
while very young in order to trigger oestrous in
the adult female so she can breed again as soon as
possible.
• The use of growth stimulants and genetic
manipulation to try and increase the size of
captive lions.
• The manner in which animals fed to the lions
are killed.
Some breeding facilities also offer tourists the
opportunity to “pet” cubs and petting farms sometimes
36 | A document prepared for CITES COP 17
source cubs from breeders. Tourists are unaware of the
fate of the cubs once they grow to a size suitable for
hunting and the practice has been widely opposed as
being unethical.
“The captive keeping and breeding of carnivores
for touch programmes does not contribute to
conservation, presents serious ethical and welfare
issues, and is routinely linked to exploitation and
canned hunting“, the Endangered Wildlife Trust, one of
South Africa’s largest wildlife NGOs states in its position
on the issue.83
South Africa’s Support for the Lion
Bone Trade
South Africa began issuing lion bone export permits in
2008 and from the outset, as with much other record
keeping relating to wildlife, mistakes were made in the
permit as to the quantity and destination.
According to the Bones of Contention Report, “In July
2008 South Africa issued its first permit to export
Lion skeletons obtained from captive bred animals
to Southeast Asia…The destination of the cargo was
mistakenly recorded as Vietnam instead of Lao PDR
(Lao People’s Democratic Republic) and the quantity
recorded as 35 Lion “bones” instead of the “bones of 35
Lions…Another permit issued in 2008 authorised the
export of 50 skeletons and by 2011 permits for at least
573 skeletons were issued.
The Bones of Contention Report shows that between
2008 and 2011 CITES permits were granted for the
exportation of 1,160 skeletons which the researchers
calculated would weigh in the region of 10.8 metric
tons. “Lao PDR was the primary recipient of the bones
(85%), followed by Vietnam (13%)…Permits issued
to Thailand and China were only reported in 2011…If
the mean mass of a Lion skeleton is ± 9.28 kg then the
exports are equivalent to 10,765 kg – over 10.8 tons in
four years”.84
EMS FOUNDATION
There is also concern that the lion bone trade is being
used to launder Tiger bones into the medicinal market.
A number of lion breeders in South Africa also breed
Tigers and there is concern that Tiger bones from
South Africa may be laundered as Lion bones using
CITES Appendix II (instead of Appendix I) permits. The
Bones of Contention Report has argued, “Limitations in
the South African legislation applying to endangered
exotic animals have made it possible for an unregulated
domestic trade in Tigers”.
CITES Cop 17 and South Africa’s Position
on Lions
Canned lion hunting will be an important issue at
COP 17 with nine African proposing that lions require
further protection and should be removed from CITES
Appendix II and placed on CITES Appendix I.
These countries , Chad, Côte d’Ivoire, Gabon, Guinea,
Mali, Mauritania, Niger, Nigeria and Togo believe that
while lions populations are in serious decline, trade
in trophies and lion products has actually increased,
placing populations under further threat. It is likely that
South Africa, Namibia and Zimbabwe will oppose such
a proposal.
While Africa’s wild
animals are becoming
extinct in their
natural habitats, on
the other hand, in
South Africa, they are
being commercially
bred purely for the
purposes of killing
and naked profit.
Adding to the mounting criticism of lion breeding
and canned hunting seven South African based NGOs
presented a motion to the IUCN World Conservation
Congress (WCC) held in Hawaii in early September
calling for ending of the breeding of lions in captivity
for the purpose of hunting.
The proposal requested the IUCN and other African
countries to pressurise the South African government
into agreeing to: “terminate the practice of breeding
lions in captivity for the purpose of canned hunting’
through a structured time bound process and to
restrict captive breeding of lions to registered zoos
or registered facilities whose document mandate is a
recognised, registered conservation process,”. Adding
that, South Africa should also “legally prohibit the
hunting of captive bred lions under any conditions.”85
In response, South Africa’s Department of Environmental
Affairs said that “while South Africa does not support
some of the aspects of this motion it will however
consider the implications associated with this motion”.
Their press release added that, ”South Africa, cautions
against assumptions that the adoption of this motion
will result in the shutting down of facilities. As is
known, biodiversity contributes to the achievement
of Sustainable Development Goals (SDGs). Existing
legislative tools and frameworks therefore regulate this
sector including the aspects of captive keeping and
hunting of lion in South Africa in a manner that ensures
a balanced approach to its overriding developmental
priorities and challenges.”86
EMS FOUNDATION
Captive breeding and canned lion hunting is
undertaken purely for profit, the self-gratification of
those who kill the animals, and has no conservation
value. EMS strongly believes that the mass breeding
of lions, the shooting of captive raised lions and the
exports of lion bones should be prohibited.
The South African government actively approved
the breeding and subsequent hunting of lions as
well
as the export of bones, again, as it has in supporting
trade in ivory, elevating profit making above
conservation or ethics.
In supporting the breeding of lions for hunting South
Africa has also created major welfare crises for the
more than 6,000 lions held in captivity and should act
urgently to end what it once officially referred to as to
“the reprehensible practice of canned lion hunting”.
A document prepared for CITES COP 17 | 37
CONCLUDING REMARKS
South Africa’s official instrumentalist approach to
conservation of “sustainable and consumptive use”
is not only contradictory but it is bound to fail. In this
interpretation, wild animals only matter to the extent that
they are useful to humans, and conservation is only about
ensuring there will be wild animals in the future so they
can be exploited for profit. This view will not convince
people that wild animals should be conserved.87 Instead
what it is doing is: deliberately positioning people against
them; not benefitting livelihoods; ensuring massive
suffering; and leading to extirpation.
practices are rooted in respect and consideration for
the welfare of the wild animals under their protection
and custodianship.
One cannot conserve species without respecting
the individuals who comprise those species. By this
approach the species will always be protected and
preserved. South Africa’s, and Africa’s, rich wild life
heritage is imperilled unless they move away from their
current interpretation of “sustainable use”. Instead,
they need to ensure that their conservation policies and
In South Africa, research is showing that the hunting
industry continues to maintain highly racialized and
discriminatory practices and perpetuate apartheid-era
property and land relations. These findings show that
there is an intimate relationship between disrespectful
treatment of wild animals and similar behaviour
towards humans.88
Treating living animals as commodities and
“consumptive use” practices such as trophy hunting
which promotes and sanctions violence against highly
sentient creatures essentially accepts and normalises
violence more generally in society. Disrespect towards
nonhuman animals cannot be neatly pigeonholed, it is
part of a continuum of other human behaviours.
Currently, anthropocentrism dominates our
world, disconnecting many from the wonder
and pain of the other than human animal
world and leading instead to its exploitation
and consumption.
38 | A document prepared for CITES COP 17
EMS FOUNDATION
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A document prepared for CITES COP 17 | 39
ENDNOTES
Rademeyer, J. SA pushes for legal trade in rhino horn‘ Mail & Guardian, 22 March 2013.
The Department of Environmental Affairs _Rhino Issue Management Report July 2013, https://www.environment.gov.za/
sites/default/files/docs/rhinoissue_managementreport.pdf
accessed on 2 February 2016
3
For examples see Biggs et al (2013, Conrad (2012), Eustace (2012), Lockwood (2011), Martin (2011), Moyle (2007, 2013), ‘t Sasrolfes (2012) and Loon (2012).
4
http://abcnews.go.com/US/cecil-lion-trophy-hunting-industry-africa-explained/story?id=32785057
5
Convention on International Trade in Endangered Species of Wild Fauna and Flora
6
www.cites.org/common/docs/Recent-trends-in-international-trade-in-Appendix-II-listed-species.pdf
7
The Rise of Environmental Crime Report, UNEP and INTERPOL, 2016 unep.org/documents/itw/environmental_crimes.pdf
8
https://cites.org/eng/cites_trade_db_passes_15million_records
9
https://www.iucn.org/content/iucn-reports-deepening-rhino-poaching-crisis-africa
10
Data compiled by the International Union for Conservation of Nature (IUCN) Species Survival Commission’s African Rhino
Specialist Group (AfRSG) https://www.savetherhino.org/latest_news/news/1462_iucn_reports_deepening_rhino_poaching_crisis_in_africa
11
http://trade.cites.org/
12
http://www.rhinoresourcecenter.com/pdf_files/118/1181373723.pdf
13
Of the 317 white rhinos killed by American hunters between 2005 and 2014, 308 came from South Africa (HSI Report:2016)
14
CITES Trade Database
15
CITES Trade Database
16
2001 – 2009: 440 and 2010 – 2014: 546
17
http://ewn.co.za/2015/09/22/Nearly-500-Mozambican-poachers-killed-in-South-Africa-s-Kruger-since-2010-former-leader
18
https://www.savetherhino.org/assets/0000/7437/TRAFFICSAVietnamRhinoHornReport1208.pdf
19
Edna Molewa, Minister of Environmental Affairs, quoted in Mail & Guardian, 10 February 2015 http://mg.co.za/article/201502-10-stockpiled-rhino-horns-sale-decision-will-be-made-in-2016
20
According to the Private Rhino Owners Association estimates its members have about 6 tonnes - http://uk.reuters.com/
article/uk-safrica-rhinos-idUKKCN0X1178
21
http://uk.reuters.com/article/uk-safrica-rhinos-idUKKCN0X1178)
22
http://news.nationalgeographic.com/2016/01/160122-Hume-South-Africa-rhino-farm/
23
http://www.telegraph.co.uk/news/worldnews/africaandindianocean/southafrica/12173750/Why-the-worlds-largest-rhinofarmer-is-cutting-off-their-horns.html
24
http://www.dailymaverick.co.za/opinionista/2015-12-01-lifting-the-ban-on-rhino-horn-trade-is-no-victory-for-rhino-owners/#.V0cD3DX5j4Y)
25
http://conservationaction.co.za/media-articles/swaziland-accuses-sa-backtracking-rhino-horn-trade/
26
https://cites.org/sites/default/files/eng/cop/17/prop/SW_Rhino.pdf
27
http://conservationaction.co.za/media-articles/swaziland-accuses-sa-backtracking-rhino-horn-trade/
28
http://www.rhinoresourcecenter.com/pdf_files/125/1255419687.pdf
29
Newton, D and Milliken. 2015. Rhino Horn Trade: An Update. TRAFFIC
30
Quoted in Rhino-related crimes in Africa: An overview of poaching, seizure and stockpile data for the period 2000-2005, http://
www.rhinoresourcecenter.com/pdf_files/118/1181373723.pdf
1
2
all-Martin, AJ, du Toit, JG, Hitchens PM and Knight, MH. 2008. Survey of White rhinoceros, Ceratotherium simum simum on
H
private land in South Africa. Unpublished Report. See: http://www.rhinoresourcecenter.com/pdf_files/146/1465289401.pdf
32
http://www.rhinoresourcecenter.com/pdf_files/125/1255419687.pdf
33
http://www.iol.co.za/scitech/science/environment/questions-raised-over-rhino-sale-1743202
34
http://city-press.news24.com/News/Rhinos-sold-to-canned-hunter-20150627
35
Edna Molewa, Minister of Environmental Affairs in response to parliamentary question, no. 786, August 2014
36
https://www.environment.gov.za/sites/default/files/docs/rhinohorntrade_southafrica_legalisingreport.pdf
37
White rhinos have the heaviest front horns, weighing on average 4.0 kilograms. In 2015 a kilogram of rhino horn was said to
be worth USD65 000 (http://www.dailymaverick.co.za/opinionista/2015-12-01-lifting-the-ban-on-rhino-horn-trade-is-novictory-for-rhino-owners/#.V0cD3DX5j4Y)
38
http://kups.ub.uni-koeln.de/6685//
39
http://www.rhinoresourcecenter.com/pdf_files/125/1255419687.pdf
40
A project led by Elephants Without Borders - http://www.greatelephantcensus.com
41
http://www.africanelephantcoalition.org
42
http://www.nber.org/papers/w22314.pdf
43
This figure refers to individual tusks and may also refer to “heads”). See:http://www.ifaw.org/united-states/news/killingtrophies-report-analyzes-trophy-hunting-around-world
31
40 | A document prepared for CITES COP 17
EMS FOUNDATION
https://cmsdata.iucn.org/downloads/2010_tz_plan_final.pdf
See http://www.elephantdatabase.org
46
https://www.environment.gov.za/sites/default/files/gazetted_notices/nemba_elephantsinsa_g30833gon251.pdf
47
Elephant Management: A Scientific Assessment for South Africa Edited by R J Scholes and K G Mennell
48
The EMS Foundation has produced an extensive report on the Captive Elephant Industry in South Africa and can be obtained
from us on request.
49
Figures supplied by the MTPA and LEDET in response to PAIA requests from the EMS Foundation.
50
http://old.seattletimes.com/html/nationworld/2019809167_elephants02m.html
51
McCracken, D. Saving the Zululand Wilderness - An Early Struggle through Conservation, Jacana Press, 2008.
52
http://www.bbc.com/news/world-africa-36176756
53
http://www.nber.org/papers/w22314.pdf
54 https://www.washingtonpost.com/opinions/global-opinions/end-all-ivory-sales-worldwide/2016/08/19/ad4149cc-631e-11e696c0-37533479f3f5_story.html?utm_term=.1f25c20a230f
55
http://www.sabreakingnews.co.za/2014/05/05/edna-molewa-has-got-it-wrong-on-ivory-trade
56
http://allafrica.com/stories/201607291035.html
57
http://allafrica.com/stories/201609010118.html
58 http://zimparks.org/index.php/mc/260-zimbabwe-s-position-on-the-proposal-to-transfer-the-african-elephant-populationsof-botswana-namibia-south-africa-and-zimbabwe-from-appendix-ii-to-appendix-i
59
http://oxpeckers.org/2016/04/how-to-steal-an-ivory-stockpile/
60
https://www.newera.com.na/2015/07/15/namibia-burn-ivory-rhino-horns-shifeta/
61
https://cites.org/common/cop/15/inf/E15i-68.pdf
62
https://cites.org/sites/default/files/eng/cop/17/prop/060216/E-CoP17-Prop-19.pdf
63
https://www.parrots.org/projects/grey-parrot
64
https://cites.org/sites/default/files/eng/cop/17/prop/060216/E-CoP17-Prop-19.pdf
65
https://cites.org/sites/default/files/eng/cop/17/prop/060216/E-CoP17-Prop-19.pdf
66
https://www.environment.gov.za/sites/default/files/parliamentary_updates/question573.pdf
67
http://www.news24.com/SouthAfrica/News/750-African-Greys-die-on-Durban-flight-20110113
68
Department of Environmental Affairs Biodiversity Management Plan for the Lion (Panthera leo) in South Africa, 2014:1. https://
www.environment.gov.za/sites/default/files/gazetted_notices/nemba_africanlion_managementplan_gn351g38706.pdf. Accessed on 5 February 2016.
69
http://news.nationalgeographic.com/2016/02/160206-American-trophy-hunting-wildlife-conservation/
70
Trophy Hunting by the Numbers: The United States’ Role in Global Trophy Hunting, HSI February 2016
71
Parliamentary Question No. 305, 3 July 2009. Still remains the situation in 2016.
72
https://www.sanparks.org/about/history.php
73
Hübschle 2016:204 citing SANParks
74
Edna Molewa, Minister of Environmental Affairs in response to parliamentary question, no. 786, August 2014
75
Act 57 of 2003 (as amended by Act 31 of 2004)
76
Interview with EMS Researcher 2016
77 https://www.environment.gov.za/sites/default/files/gazetted_notices/nemba_africanlion_managementplan_gn351g38706.pdf
78 https://www.researchgate.net/publication/280875397_Bones_of_Contention_An_Assessment_of_the_South_African_Trade_
in_African_Lion_Panthera_leo_Bones_and_Other_Body_Parts
79
http://mg.co.za/article/2007-03-07-net-closes-on-sas-canned-hunting-industry
44
45
illiam, V., Newton, D., Loveridge, A. and Macdonald, D. 2015. Bones of contention: An assessment of the South African Trade in lion,
W
Panthera leo, bones and other body parts. Joint WILDCRU and TRAFFIC Report
https://www.researchgate.net/publication/280875397_Bones_of_Contention_An_Assessment_of_the_South_African_Trade_
in_African_Lion_Panthera_leo_Bones_and_Other_Body_Parts
81
http://www.bloodlions.org/blood-lions-exposing-dark-underbelly-canned-hunting-screen-sydney/
82
http://www.nspca.co.za/wp-content/uploads/2016/05/lions_in_captivity_hunting_sa.pdf
83
https://www.ewt.org.za/scientific%20publications/position%20statements/EWT%20position%20Statement%20Petting%20
Zoos%20FINAL.pdf
84
https://www.researchgate.net/publication/257201401_Urgent_and_comprehensive_reform_needed_in_sport_hunting_of_
African_lions
85
http://conservationaction.co.za/resources/reports/terminating-hunting-captive-bred-lions-panthera-leo-predators-captivebreeding-commercial-non-conservation-purposes/
86
https://www.environment.gov.za/
87
Bilchitz, D. 2016. Can the Environmental Rights in the South African Constitution Offer Protection for the Interests of Animals? Paper
Prepared for Harvard Conference on Animals and the Constitution.
88
See: Mkhize, N (2014) and Brandt F and Spierenburg, M. (.2014).
80
EMS FOUNDATION
A document prepared for CITES COP 17 | 41
NOTES
42 | A document prepared for CITES COP 17
EMS FOUNDATION
NOTES
EMS FOUNDATION
A document prepared for CITES COP 17 | 43
NOTES
44 | A document prepared for CITES COP 17
EMS FOUNDATION