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

EMS FOUNDATION A document prepared for CITES COP 17 | 1 Te abl of Contents

SMOKE AND MIRRORS: WILDLIFE POLICIES IN POST-APARTHEID SOUTH AFRICA 4 SOUTH AFRICA’S FALSE CLAIM OF EXCEPTIONALISM 5 Hunting for Official Answers 6

SERIOUSLY…YOU ARE KILLING ME: THE WILD LIFE TRADE 8 BACKGROUND 8 AN OVERVIEW OF THE ILLEGAL TRADE IN SOUTH AFRICA 10 RHINOS IN SOUTH AFRICA: AN EXAMPLE OF TRADING INTO EXTINCTION 12 Overview 12 South Africa’s - Pro-Trade Position 14 Legal Trade: A Cover for Illegal Trade 15 Statistics and Comparative Data 16 Recommendations 17

‘SUSTAINABLE USE’ IS LEADING TO THE EXTIRPATION OF AFRICA’S ELEPHANTS 19 Elephants are Africa’s Heritage 19 South Africa’s Elephant Population 20 Zimbabwe and Namibia’s Elephant Populations 21 South Africa and the Ivory Trade 22 Elephants Are Not Tyres: Why all Trade in Ivory Must End 22 AFRICAN GREY PARROTS 25

HUNTING FOR PROFITS: SOUTH AFRICA AND TROPHY HUNTING 27 THE ROLE OF NATIONAL AND PROVINCIAL PARKS 29 Turning a Blind Eye: ‘Sustainable Use’ Policies and Hunting in the Kruger National Park ‘Buffer Zones’ 29 Letaba Ranch 31 Makuya Nature Reserve (MNR) 32 Makulele Contract Park 33 Manyaleti, Andover and Mthethomusha Nature Reserves 33 Associated Private Nature Reserves (APNR) 33 ‘SUSTAINABLE USE’ ON STEROIDS: SOUTH AFRICA’S CANNED LION INDUSTRY 34 ”You can make as much money as you like”: Lion Hunting in South Africa 35 Inadequate Lion Hunting Statistics 35 Captive Breeding of Lions 35 South Africa’s Support for the Lion Bone Trade 36 CITES Cop 17 and South Africa’s Position on Lions 37

CONCLUDING REMARKS 38

REFERENCES 39

ENDNOTES 40

2 | A document prepared for CITES COP 17 EMS FOUNDATION ACRONYMS

AEC African Elephant Coalition APNR Association of Private Nature Reserves CITES Convention on International Trade in Endangered Species of Wild Fauna & Flora COP Conference of the Parties DCA “damage causing animals” DEA Department of Environmental Affairs DRC Democratic Republic of Congo EU European Union GDP Gross Domestic Product INTERPOL International Criminal Police Organization IUCN International Union for the Conservation of Nature KNP Kruger National Park LEDET Limpopo Department of Economic Development, Environment and Tourism MNR Makuya Nature Reserve MPTA Mpumalanga Tourism and Parks Authority NGO Non-Governmental organisation PAIA Promotion of Access to Information Act PASA Parrot Breeders Association of South Africa SANBI South African National Biodiversity Institute SADF South African Defence Force SADC Southern African Development Community SANParks South African National Parks SDGs Sustainable Development Goals SPCA Society for the Prevention of Cruelty to Animals UNEP United Nations Environment Programme UNITA National Union for the Total Independence of Angola VAT Value Added Tax

EMS FOUNDATION 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 even more of a target for trade and slaughter. The world where Africa’s animals are literally “Under Siege”. recasting of wild animals as disposable commodities without intrinsic value, is taking place as the Earth is We highlight an obvious pattern: legal trade in both reaching finite limits and “resource use” is intensifying ivory and rhino horn is part of the problem and as a consequence. should be prohibited, because it has been used to launder illegal ivory and rhino horn which in turn South Africa’s wildlife policies of “sustainable use” are has stimulated demand. Criminals, benefitting from not only leading to the extirpation of wild animals corrupt and inefficient administration in many parts of but are deliberately positioning people against them. the world, including in South Africa and other Southern When you add to the mix: the lack of fiscal resources African countries, have taken full advantage. As a result needed for effective institutional capacity and of these factors many wild animals are under siege and enforcement; private ownership; and corruption, it is facing extirpation. Numerous studies mentioned in the a lethal situation indeed. report present a large body of evidence supporting this view. Historically, South Africa has always taken a pro “consumptive use” stance in relation to wild animals. While Africa’s wild animals are becoming extinct in In the colonial and apartheid past it was so that a their natural habitats, on the other hand, in South few people could benefit and have private hunting Africa, they are being commercially bred purely grounds. In terms of whom benefits now, this still for the purposes of killing and naked profit. And holds true – it is a few greedy people who are making unacceptably, their endangeredness makes them short term profits, albeit located within the language of development and livelihoods.

In taking South Africa’s excessive wildlife policies have ushered in an extensive increase in the trade in animals and, a self-centred, what is essentially, the farming of wild animals. It is advocating endless exploitation, concealing ‘exceptionalism’ ethical issues and real suffering underneath this raw commercialism. The country’s position on ivory sales approach, and the growth of the hunting industry are examples South Africa is of its overt “consumptive use” conservation policies. Internationally, South Africa puts forward the image distancing itself that it is a “world leader” and should be respected when it comes to conservation, but in reality this from other African is not the case. Its increasingly hard line approach to the “consumptive use” of wild animals, regularly countries, displaying a puts the accumulation of profits ahead of ethics, livelihoods, the interests of other African nations or disregard for the the well-being, protection and conservation of the rest of the continent earth’s wild animals. South Africa is advocating the sale of ivory despite and placing Africa’s a compelling body of evidence to the contrary, the decimation of Africa’s elephants and the opposition of at wild animals least 70% of the 37 African elephant range states and other.

in danger. 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

4 | A document prepared for CITES COP 17 EMS FOUNDATION exportation of large quantities of lion bones for the A FALSE CLAIM OF EXCEPTIONALISM traditional medicine market in Asia. Far from trying to The nationalist, exceptionalism narrative that southern improve the country’s image as a responsible custodian African countries, such as South Africa, Zimbabwe, of nature and natural heritage, the Government now and Namibia, have “successful conservation practices” chooses to support this “reprehensible practice,” and should therefore be treated differently to the as it was once described by former Minister of rest of the Continent is not only spurious but cleverly Environmental Affairs Martinus van Schalkwyk. and carefully crafted to obfuscate real problems in relation to their own policies and the consequences South Africa has the largest hunting industry in sub- they are having for wild animals. Moreover, all of these Saharan Africa. It is Africa’s most popular destination countries have serious problems with corruption, for foreigners wishing to kill anything from elephants enforcement and the illegal trade. and buffalo to tiny antelope. South Africa remains the worlds’ top destination for the hunting of captive The South African exceptionalism position, with raised lions and is also the premier market for those increasing support from Zimbabwe, continuously wishing to shoot rhinos. distances itself from other African countries on issues related to elephants and displays a disregard for the Over the past 30 years South Africa has regularly rest of the Continent. promoted the sale of rhino horn despite evidence that sales fuel the killing of rhinos which increased South Africa’s promotion of ivory sales and its by 7,000% between 2007 and 2013 alone. As this support of the canned lion hunting industry are document shows, it is clear that the rhino hunting but two examples of putting profits before ethics permitting system, internal legal trade and poor and the needs of other African countries. There is a enforcement have all contributed to promoting the considerable body of academic work which shows global illegal trade in rhino horn. Legal hunting merely that the 2008 “once off’ sale of ivory contributed paved the way for the laundering of illegal horn. directly to an increase in elephant poaching and a wide range of people, even including professional South Africa has for decades lobbied for the opening and amateur hunters in South Africa, oppose canned of trade in rhino horn, although in early 2016, on lion hunting on ethical grounds. advice from the Committee of Inquiry established to deliberate on rhino poaching and matters relating Legal trade is also used as a cover to launder illegally to its effects, the government had no choice but to gathered ivory, rhino horn, abalone, etc. into the decide against making a request for sales. Although a market. Poor administration and control of trade is full explanation for this decision has never been made easily exploited by criminal networks. Nonetheless, public, South Africa has declined to destroy stockpiles, South Africa promotes both trade and canned obviously in the expectation that they may be used at hunting because it argues that elephants and lions some time in the future. in South Africa are “well managed” and that ivory sales and captive lion hunting will not threaten local South Africa also allows the breeding of a wide range of populations of these animals. This attitude shows a colour variant wild animals. This in the face of widespread lack of concern for what is happening with lions and evidence that it is of no conservation value, counter to elephants elsewhere in Africa, the circumstances of the protecting biodiversity and unethical. Through selective country’s whose views on these subjects differ and the breeding wildlife ranchers have developed a highly detrimental affect South Africa’s position is having on lucrative industry breeding animals (for which they have Africa’s wildlife. created names) such as Golden wildebeest, Black impala, Copper blesbuck, Golden oryx and others. South Africa’s spin and apparent belief that because it manages its wild animals “well” - a view that is contested The country is one of the leading exporters of Africa’s by many - it should be able to do as it pleases at the wild animals to zoos and so-called “safari parks” all expense of other African countries, emphasises a false over the world. It is also often used as a conduit for the sense of exceptionalism, a belief that it is somehow smuggling of wildlife including gorillas, chimpanzees, justified to impose its view. In adopting these and African grey parrots and abalone as well as reptiles and similar positions South Africa is increasingly isolating birds from Madagascar and elsewhere. itself from world opinion on wildlife conservation and from its own citizens. Although South Africa regularly states its virulent support for the concept of the “sustainable use of natural This trend also needs to be looked at in the context resources”, and it is included in all its environmental of political developments over the past year which policies, it has no effective monitoring mechanisms, indicates a hardening of attitudes amongst senior such as a central database where information relating to government representatives, including the President, trade and hunting can be sourced, let alone monitored with regard to South Africa’s international image. and interrogated by civil society organisations.

EMS FOUNDATION A document prepared for CITES COP 17 | 5 In March 2015 the South African government flouted Some Southern Africa countries, notably Zimbabwe, an international convention, an International Criminal Namibia and Swaziland are also adopting increasing Court warrant of arrest for al-Bashir and a South nationalist positions with regard to wildlife “utilisation” African High Court order. South Africa refused to arrest (Botswana is the exception, and has banned trophy Sudanese leader Omar al-Bashir who is wanted for hunting). Supported by strong hunting and wildlife war crimes and was invited to South Africa. Instead of ranching lobby groups they argue that as sovereign arresting him the government gave him safe passage nations they have a right to propose sales and other out of the country. utilisation as they believe this will not impact on wildlife in their countries. The South African Supreme Court of Appeal found that the government should have arrested al-Bashir and Members of the Southern African Development this decision was later confirmed by the Constitutional Community (SADC) have been the primary drivers of Court. Despite the decisions of the courts, the flouting requests for ivory sales since 1997 and according to of an international convention and widespread Swaziland, also agreed at a meeting earlier this year to international criticism no action has been taken against support proposals to open trade in rhino horn, again those who ignored the requirements of South African with the exception of Botswana. and international law. The comments by Human Rights Watch that South Human Rights Watch, an NGO that monitors human Africa should “base its positions on an objective rights abuse around the world, notes that in 2014 South evaluation of the needs of victims and the international Africa abstained on votes at the United Nations Human obligations of the government concerned” has Rights Council dealing with human rights abuses in direct relevance to the position with wildlife. The Burma, North Korea and Zimbabwe yet supported widespread slaughter of elephants across Africa, the the votes against abuses in the OPTs (occupied Arab surge in rhino killing in South Africa, and elsewhere territories). It also did not support motion on abuses in and the decline of lion populations to their lowest Bahrain and Egypt. levels in history are all issues of relevance to the entire continent and anyone in the world who cares about According to Human Rights Watch, “The contrast the environment and wildlife. between South Africa’s votes on the resolutions on the OPT’s and its votes on all other situations raises serious In taking a self-centred approach South Africa ignores questions about double standards and selectivity in its commitment to wildlife elsewhere and the need its approach to the Council…South Africa should base to coordinate action to ensure its survival. Decisions its positions on an objective evaluation of the needs made in Southern Africa can, and do, influence wildlife of victims and the international obligations of the elsewhere in the Continent and the world. Sales of government concerned.” African ivory and rhino horns have impacts in Asia too.

In March 2016 South Africa supported Saudi Arabia in Hunting for Official Answers opposing the establishment of a UN body to look into Record keeping by the Department of Environmental the issues relating to the surveillance of citizens and in Affairs and provincial conservation authorities is, as July abstained on a vote to create an expert position on pointed out numerous times in this Report, notoriously sexual identity and discrimination. poor. There is no centralised database and some

6 | A document prepared for CITES COP 17 EMS FOUNDATION provinces still have to contact various sub-offices by phone or email to gather information which should South Africa’s be easily available. Even data on rhino poaching was not kept centrally until 2009, only after the poaching wildlife ‘sustainable crisis had intensified. At one point the Department of Environmental Affairs released rhino poaching figures use’ policies are on a regular basis but this is no longer the case. leading to the According to a 2010 Animal Rights Africa Report, Seeking the Path of Least Disclosure, “It is very difficult extirpation of to understand how the Ministry and the Department of Environmental Affairs can make informed decisions wild animals about the management of South Africa’s wildlife when the information they use, and provide to the public, and positioning is frequently inadequate. It also raises doubts, of the accuracy of information provided to international people against bodies such as CITES and is exemplified by the information demands on international treaties, such wildlife. as CITES and the Convention on Biological Diversity, to which South Africa is signatory. Conservation offcials in some provincial head offices All too often doors are closed in the face of researchers often have to contact sub-offices by phone or mail wishing to get clarity on a wide range of issues. requesting information, some of which is kept in hard Officials in some provinces are particularly poor in copy only, if at all, because no central database exists. this regard. Even officials from the Department of A centralised database system, funded by donor Environmental Affairs sometimes struggle to get money, was developed as early as 2000, but nothing access to accurate and up to date information from has yet been implemented. some provincial officials”. During a CITES stakeholder meeting organised by Unfortunately, all too often, this is still the case. the Department of Environmental Affairs in July 2016, officials promised that a centralised system would be Problems with access to information and the in place before the beginning of CITES COP 17 on 24 permitting structure were also flagged as a problem September but at time of writing (September 2016) by TRAFFIC, the wildlife trade monitoring network, nothing further had been heard on whether or not this in 2015 in their Rhino Horn Trade: An Update Report. would happen. “Understanding South Africa’s wildlife trade remains clouded by delays, abuse and miscommunication A 2014 Department of Environment Affairs report within the current permitting structure, providing entitled, The viability of legalizing rhino horn trade in loopholes and opportunities for illegal trade or South Africa, concluded that due to inefficient record- unintended activities for many species and wildlife keeping and the subsequent submission of statistics products to proliferate.” to CITES “it is impossible to determine exactly how many [rhino] trophies were exported legally out of Reliable statistics relating to the hunting and killing of South Africa.” That this is the case with such a well- so-called “damage causing animals” (DCA), including studied animal during one the worst poaching crises in high profile animals such as leopards is poor. The South decades is nothing short of shocking. African Scientific Authority, the South African National Biodiversity Institute, in a 2015 document examining Some provincial officials are unwilling to provide circumstance surrounding the hunting of leopards, also information to journalists or researchers and often noted that “record-keeping is generally poor amongst insist that an application be made in terms of PAIA the provinces.” SANBI also noted that “some provinces (Promotion of Access to information Act, 2 of 2000) record the numbers of DCA permits awarded but few legislation before information will be released. This is actually note whether putative DCAs were successfully a lengthy procedure that allows officials a month to removed (translocated or killed)”. gather information or, alternatively provide reasons as to why it should not be released. In the latter instance It is unclear why there is such a reluctance to improve those requesting have the option of talking the matter record-keeping with regards to South Africa’s to court, an expensive time consuming process. In wildlife. Without accurate information it is difficult to some instances the information has simply not been understand how responsible decisions can be made recorded or has been done so in a way that makes and also questions South Africa’s credibility when it very difficult for anyone, including conservation submitting reports to organisations like CITES. officials themselves, to access.

EMS FOUNDATION A document prepared for CITES COP 17 | 7 SERIOUSLY…YOU ARE KILLING ME: THE WILD LIFE TRADE

BACKGROUND while the Department of Environmental Affairs (DEA) in The violent geography of the trade in Africa’s wild its Rhino Issue Management Report stated that “banning animals is extensive, lucrative and ever expanding. The of the rhino horn trade by CITES and the concomitant international trade (legal and illegal) involves millions of moratorium on domestic trade by South Africa has had animals every year and is one of the key drivers of species the unintended consequence of increasing poaching extinction, population decline, suffering, abuse and of live animals as there is no other horn available.”2 death. The trade in African mammals, birds and reptiles has grown dramatically since the early 1990s. Profit- The tenet of the pro-trade argument is that trade bans motivated dealers and middlemen, and a seemingly produce high prices and scarcity leading to higher bottomless market, drive this trade. And it all takes place illegal trading and that this can be eliminated by a flow as a direct consequence of the vague, misused and of legal supply through captive breeding (farming), misinterpreted concept of “sustainable use”. sales of stockpiles, “culling” etc. In this way they believe they will be able to out-compete the illegal suppliers Many countries, South Africa being one of them, base and drives prices down thus making “poaching” their pro wild animal trade policy formulation on a false unprofitable while ensuring high returns for the legal premise that trade is a conservation solution for so- market. Private ownership and business enterprise is called “endangered species” and that legal markets are key to this argument, and implicit is the development a panacea for the illegal trade. For example, in relation of expanding demand. to the trade in rhino horn, in March 2013, the South African Minister of Environmental Affairs, Edna Molewa, A pivotal study by Nadal and Aguayo reviewed the stated that she believes the legalisation of the trade analytical economic arguments3 used to support the is the right direction to take to curb rhino poaching,1 legal market framework. It powerfully shows that “the literature advocating trade as a conservation solution for endangered species relies on models that Many countries, are based on simplistic and/or extremely restrictive assumptions. In most cases, these models also rely base their pro-trade on conceptual tools that have been theoretically discredited.” (Nadal & Aguayo 1:2014) They argue policies on a false that the belief that markets behave as self-regulating mechanisms that lead to equilibrium and greater premise that trade is a efficiency cannot be substantiated and that “the economic analysis of wildlife trade…appears to conservation solution have been trapped in the backwaters of textbook economics” (3:2014) resulting in “incongruities and for “endangered misleading conclusions” (4:2014). species” and that legal A major contradiction is the separation of the illegal trade (trafficking) from the legal trade, despite the fact markets are a panacea that the two are naturally, and obviously, intertwined and part of the same continuum. Allowing a market for the illegal trade. 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 EMS FOUNDATION animals. In addition, the term “wildlife” often includes The European Commission argues that “wildlife charcoal, plants and timber, making it impossible to get trafficking” is one most profitable organised crimes in accurate information in relation to wild animals only. the world with the illegal elephant ivory trade having So, uncovering the mystery of the amount of profits more than doubled since 2007 and rhino poaching generated from trading in wild animals and their body increasing by 7,000% in South Africa between 2007 parts as a legally and regulated ‘‘commodity” is elusive. and 2013, “endangering the very survival of this species”. (European Union Action Plan against Wildlife According to TRAFFIC during the years 2005 to 2009, Trafficking: 2016). CITES recorded an annual average of more than 317,000 live birds, just over two million live reptiles, 2.5 million In 2013 the United States government estimated that crocodilian skins, 1.5 million lizard skins, and 2.1 million the monetary value from the illegal trade in “wildlife” snake skins. In terms of hunting trophies, CITES data was between USD $45 billion to $120 billion each year shows that 10,000 lions were legally trophy hunted with the illegal trade in “endangered wildlife products” between 2003 and 2013, while between 2003 and 2013, (including elephant ivory, rhino horns, and turtle shells) 15,518 African elephants were killed for trophies.4 worth at least an estimated $7 billion to $10 billion annually (Wyler & Sheikh:2013). These numbers are a low estimate because most of the countries from where the animals traded originate, are There are thousands of species of wild animals who fall poor record-keepers and corruption is common. The outside of so-called “regulated” international trade yet exotic pet trade industry is one of the key drivers of the they are “legally” traded internationally and accompanied trade in wild animals. Countries involved in the exotic by the appropriate permits and official documents. pet trade – both exporters and importers - do not According to the United Nations, permits for about compile reliable data on the extent but nonetheless, in 900,000 legal shipments of protected “wildlife products” 2005 Karesh et al suggested that the magnitude of the are issued annually. (UNEP Interpol Report, 2016:10) global trade for the exotic pet trade involves over 350 million live animals a year, including primates, birds, These animals are often obtained illegally but reptiles and fish. laundered through the legal regulatory framework, including trophy hunting, live sales, “wildlife” farming Written evidence submitted by TRAFFIC to a 2012 and ranching, breeding and captive operations, United Kingdom House of Commons Environmental including zoos. According to a June 2015 CITES press Audit Committee on Wildlife Crime claims that in release their trade database had exceeded 15 million the early 1990s the estimated value of legal wildlife records of trade since the mid-1970s – this would mean products imported globally was around USD160 billion, many millions more animals as each record usually while in 2009 it was over USD323 billion. TRAFFIC also represents more than one individual being.8 estimated the legal trade of “wildlife products” into the EU alone was worth an estimated €93 billion in 2005 A recent study which analysed CITES wild animal trade and that this increased to nearly €100 billion in 2009. records for Appendix I and II species exported out of (Ev88:18 October 2012). Africa (involving 2,337 species), between the years 2003 to 2012 found that 90% of the records contained While in 2013, Hübschle valued the global legal trade discrepancies across almost every type, including 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 CITES- listed 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 SOUTH AFRICA IS According to a recently published UNEP/INTERPOL Report7 environmental crime (which includes the AN IMPORTANT illegal trade in wild animals) is growing two to three times faster than global GDP, dwarfing the illegal trade TARGET FOR in small arms and is the world’s fourth largest criminal enterprise after drug smuggling, counterfeiting and WILDLIFE human trafficking. At the same time, the Report concedes that “given this level of volatility in both the TRAFFICKERS. 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).

EMS FOUNDATION A document prepared for CITES COP 17 | 9 quantity, appendix, origin, purpose, source, term, year Pet shop and domestic pet breeders are also sometimes etc. and that records missing an import quantity were involved in illegal trade. The internet is also often used the most frequent type of discrepancy, occurring in as a means of marketing illegal wildlife sales but because 63% of all trade records. It also found that the 50 African the global nature of the internet, and sometime the countries included in the study were involved in data anonymity of people who post the adverts, it is often discrepancies with Appendix 1 species having more difficult to prosecute sellers. divergences than the other appendices. (Russo: 2015) Without the end users the illegal trade would not exist The specific use of desensitised and detached language but use of wildlife, alive or dead, is deeply interlinked used to refer to Africa’s wild animals by governments with traditional beliefs, perceived status (as in the use and bodies such as CITES - such as “game,” “wildlife of rhino horn based medicine), ignorance, vanity (as products,” “wildlife production,” “off-takes,” “quotas,” in the creation of private zoos), financial greed and “harvest,” “high value natural resource,” “wild sourced sometime desperation (subsistence “poaching” for inputs,” “specimens,” “derivatives” and “derived food) driven by poverty. A key component of reducing products” - plays an important role in legitimising and the illegal and legal wildlife trade is educating end sanitising the unspeakable. The main actors - the very users about the need to protect wild animals and beings who are traded and killed - and the holocaust suggesting alternatives. that is unleashed on them, is deliberately obscured through trade and commercial activities. South Africa is one of the most biologically diverse countries in the world and this, coupled AN OVERVIEW OF THE ILLEGAL TRADE IN with poor border controls, weak record-keeping, SOUTH AFRICA poor administrative skills, lack of resources and corruption has made it an important target for Corrupt officials and politicians also play an important illegal wildlife traffickers. The examples below form role in illegal wildlife trade by helping poachers but a small illustration of the illegal trade in wildlife and traffickers evade law enforcement agencies. in South Africa. Wildlife traffickers also exploit inefficiencies in law • South Africa is the epicentre of the world rhino enforcement, insufficient conservation staffing and/ “poaching” crises. or incompetent or poorly trained officials. Poor record- • Elephant tusks believed to be worth more than keeping and limited access to information also works in R17 million were seized by police at a business favour of those involved in illegal trade. premises in Pretoria on 3 March 2016. In 2015 Kruger National Park announced that 19 elephants Illegal trade is sometimes also undertaken by zoos, had been killed for ivory in the Park.. In several of wildlife breeders and wildlife traders using legal trade these cases poachers laced carcasses with poison as a cover. South Africa has a large, well developed and a result more than 100 vultures and other wildlife industry and hundreds of thousands of animals species have been killed. are legally traded annually. A trade criminals sometimes • South Africa is one of the world’s largest sources of use as a screen for their activities. Taxidermists, a key illegal abalone for use in the Far East. component of the hunting industry, have also been • South Africa has 37 cycad species, 26 of which are involved in illegal trade. endemic. The illegal trade in cycads has resulted five endemic species becoming extinct in the wild

10 | A document prepared for CITES COP 17 EMS FOUNDATION in the last seven years. According to the South African National Biodiversity Institute cycads worth South Africa is at R11 billion have been illegally traded over the past 15 years. the epicentre of the • In 2014 Northern Cape Nature conservation officials estimated that at least 1,000 snakes, tortoises and rhino horn trade. The lizards are smuggled out of South Africa every month. These animals are all destined for the trade in rhino body international pet trade. • According to Rowan Martin, Director of the World parts, specifically their Parrot Trust, many illegally caught wild parrots are used in the captive breeding industry in South horns, has meant that Africa and that it relies heavily on wild birds as breeding stocks. In 2011 750 grey parrots died on more rhinos have a flight to Durban. They were part of a consignment of 1650 parrots imported from the Democratic been killed illegally republic of Congo. At the time authorities said the parrots had been legally imported. in South Africa since • In August 2014 eight sitatunga antelope had to be euthanized at OR Tambo International Airport 2008 than at any after arriving in shocking condition on a flight from Europe. They were destined for the Johannesburg other time in the last Zoo and a private person. • Six South Africans and a Zimbabwean were arrested 90 years. 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 Many factors contribute to the prevalence and Western Cape were found with 2,000 rare succulents scale of wildlife crime. Poverty, corruption, greed, they intended to ship to Spain. exploitative attitudes towards wildlife, (including • About 240 frogs including 180 rains frogs and 80 the neoliberal concept of the “sustainable utilisation bull frogs destined for Vietnam were confiscated at of natural resources”), regional conflict, traditional OR Tambo International Airport in January 2016. beliefs (food and medicine) and many other issues • . Although the Department of Environmental Affairs influence “poaching” and trafficking. The South African state that “bushmeat” it is not a serious problem in government has enacted laws which provide for the South Africa landowners and various environmental criminal prosecution of those accused of wildlife groups across South Africa report that snaring crimes and various sets of regulations and norms and and the illegal killing of wild animals for food is a standards also specify how wildlife and environmental widespread problem. policy is managed. Wildlife conservation issues are • There is a thriving internet pet trade in birds and overseen by the Department of Environmental Affairs, reptiles. Many of the species are South African but powers to manage wildlife administration are although exotic species are also imported into devolved to each of the nine provinces. South Africa. Some of this trade is legal but a large amount is illegal. Some exotic species, such as corn The country has one of the largest economies in Africa, snake, are released into the wild which has adverse and by far the best infrastructure, and a significant effects on biodiversity. amount of state funds are spent on countering • There are many traditional “medicine” markets “poaching” and illegal trade annually. Large amounts that sell both plant and animal based products. of money are also regularly received from NGOs Large numbers of species are part of this trade, and other donors as contributions towards funding body parts from vultures, pangolins, African rock “anti-poaching” efforts and a range of other wildlife/ pythons, spotted hyena, owls, and many other environmental programmes. species are openly sold. Authorities have done little to curb this trade, which includes Red Data Why then, given such widespread effort, is there Book or CITES Appendix I or Appendix II listed very limited data available about the scale of wildlife species. crime in South Africa, and why are attempts to • South Africa is often used as a transit hub illegal curtail “poaching” and subsequent trade, apparently wildlife trafficking from Madagascar, (particularly floundering. Civil society organisations regularly reptiles and birds for the pet industry), the struggle to access accurate and comprehensive Democratic Republic of Congo, and (Grey parrots information from the Department of Environmental – pet industry) Mozambique (birds – pet industry) Affairs head office and particularly from provincial and other countries. environmental agencies.

EMS FOUNDATION A document prepared for CITES COP 17 | 11 Government officials acknowledge that poor record- slaughtered on an industrial scale to meet demand keeping feeds into the illegal trade problem. In October for rhino horn in newly affluent Asian countries. South 2015 South African Revenue Service Commissioner, Tom Africa is at the epicentre of the rhino horn trade. The Moyane, encapsulated many of the difficulties when war on rhinos is also being fed by private ownership told a government meeting that “In our sub-region and there also seems to be a relationship between the [Southern Africa] we are confronted by the challenges rise in the proportion of rhino horn entering the illegal of cross border illicit trade, VAT fraud, contraband trade and the increase in some private ownership. cigarettes, money laundering, smuggling in alcohol, The State, through its environmental agencies, cash economy and illegal trade in wildlife. Another of has purposefully transformed private wildlife the serious scourges confronting our administration ownership into a full-blown agricultural activity. Its is the rampant scourge of corruption which continues conceptualisation of “conservation” as utilisation and to retard our progress. This flourishes where weak commodification is also actively encouraging and institutions, poor governance and under resourced legitimising criminal and unethical activities. customs services and police forces stationed in our porous borders are difficult to control. “ According to World WISE, in order of importance, South Africa, Mozambique, Zimbabwe and Kenya are the The Minister of Environmental Affairs and other senior main sources of seized shipments of rhino horn. The government official regularly point out that wildlife United Arab Emirates and European countries (including crime and other forms or of crime often go hand-in-hand. Slovakia, the Czech Republic, Belgium, Italy and Germany) are indicated as transit countries. In order of importance, RHINOS IN SOUTH AFRICA: AN EXAMPLE OF Vietnam, China, Ireland, Czech Republic, United States TRADING INTO EXTINCTION and Thailand are indicated as destination countries (UN 71:2016). Europe is currently a destination market and a Overview hub for trafficking in transit to other regions. (EU Action Trade and trophy hunting has driven rhinos in Africa Plan against Wildlife Trafficking 2016). to the edge of extinction. In the 1960s there were approximately 100,000 rhinos but in 2015 the IUCN The killing of rhinos in South Africa has reached the provisionally estimated the number of white rhinos highest levels since the 19th century and in the past to be between 19,682 and 21,077 and black rhinos 16 years at least 7 853 rhinos have been killed for their estimated at between 5,042 and 5,455.9 horns, a figure, far high than government records show.

South Africa currently holds 79% of Africa’s rhinos10 The South African government says at least 5,162 rhinos and the fact that its population is currently the largest were killed illegally by “poachers” from 2001-2015 and in the world has perversely meant that this perceived the CITES trade database records a further 2,691 (2001- “population success” has been used as a justification, 2014) animals killed for their “horns” and “trophies” particularly in a country where greed and poverty which were imported from South Africa by a number intersect, for their exploitation, commodification and of other countries around the world.11 According to the killing, through trophy hunting, local auctions, live Department of Environmental Affairs and the South international sales, and consumption of their horns. Not African National Parks (SANParks), 1,492 permits were surprisingly, and in tandem, the illegal killing of rhinos issued from 2001 to 2015 - a discrepancy of 1,199 (about is also growing exponentially and rhinos are being 80%) if compared against the official CITES figure.

12 | A document prepared for CITES COP 17 EMS FOUNDATION The origins of the surge in rhino killings in South Africa are complex but in part are linked to poor control There is of the hunting and rhino farming industry which enabled so-called “rogue” elements in this sector overwhelming to launder horn into illegal market which helped stimulate demand. Organised crime syndicates took evidence to full advantage of the situation. show that The illegal trade in rhino horn, and elephant ivory, has been exacerbated by corruption and official the 2008 sale inefficiency in Africa but also across the globe. South Africa is by no means exempt from this. The same of ivory by syndicates that smuggle horn or ivory also become involved in other forms of crime including the drug South Africa, trade, money laundering and human trafficking. Botswana and A number of reports published in the mid-2000s identified major weaknesses in South Africa’s ability Namibia helped to control and monitor illegal activities but authorities responded slowly and in some instances these issues stimulate the remain unresolved today, a decade later. current wave Successive South African governments have regularly promoted trade in both rhino horn and ivory. Although of elephant killings. 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 Between 1995 and 2014 South Africa exported 1,096 permitting system.12 live rhinos, of which 35% went to countries in the East, mainly China, Vietnam and Thailand.15 What is interesting In line with their pro-hunting position, and despite to note is that the number of live rhino export sales, the unconscionable number of rhinos that are dying particularly to the East, increased from 2010, as the rhino as a result of the rhino horn trade, South Africa is also “poaching” statistics were increasing, the public outcry the premier market for those wishing to shoot rhinos grew ever louder and the government gave assurances legally for trophies.13 that it was trying to address the problem.16

Using the CITES legal regulatory framework, and Within South Africa and elsewhere hundreds of people therefore with full knowledge of the South African have been charged with rhino poaching offences government and the CITES Secretariat, the movement and include wildlife ranchers, professional hunters, and sale of rhino horns (as trophies) and live rhinos to veterinarians, employees of national and provincial overseas destinations (including those who consume parks as well as farmworkers, career criminals and rhino horn such as Vietnam and China) constitutes sometimes residents from communities living near not only a convergence of the legal and illegal trade wildlife areas. Nearly 500 Mozambicans have been but also a conscious stimulation of the trade and the killed by anti-poaching teams in the Kruger National resultant massive killing of rhinos in South Africa for Park since 2010.17 the so-called illegal trade. Large numbers of live rhinos have also been According to CITES the total number of rhino trophies exported from South Africa to reserves and zoos all that were exported from South Africa from 2001 to over the world. Between 2001 and 2014, South Africa 2014 was 2,693 with 24% of these going directly to exported 986 live rhino with about one quarter being countries in the East, mainly Vietnam.14 sold to countries in the Far East, the primary market for most rhino horn.

EMS FOUNDATION A document prepared for CITES COP 17 | 13 Photographer Jennifer Bruce

South Africa’s - Pro-Trade Position to have their rhino population down-listed to Appendix Although the international trade in rhino horn was II. In 1992 South Africa went to CITES and proposed that banned in 1977, South Africa has consistently refused the trade in rhino horn be allowed. to destroy its rhino horn stockpiles. Although this was not accepted by the Parties, two- The 1977 ban meant that rhinos were listed as Appendix years later in 1994 (COP 09), not only was South Africa’s 1, although they could still be trophy hunted “for non- proposal to down-list their population adopted, but commercial purposes.” The ban failed to include stockpiled Resolution Conf. 6.10 was repealed (Conf.9.14), opening horns or the destruction of stockpiles and this provided a the way for the amassing and privatisation of rhino horn major loophole for the pushing of continued trade. with the end game being trade. Part of their rationale for trade was that it would “benefit rhino conservation… In 1987 (Resolution conf.6.10) CITES acknowledged [and that it] results in improved intelligence, as the legal that trade was the “primary factor responsible for entrepreneur informs on the black market activities, and the destruction of rhinos populations” and urged that a dependable supply of products depresses black all Parties to destroy their stockpiles of rhino horn. market prices. In addition, private land-owners will be Domestic trade was also outlawed. It is extremely encouraged to invest in rhino populations and protect unlikely that South Africa heeded this call, particularly them as utilisable, economic assets.” because deeply woven into the fabric of South Africa’s Apartheid history is the killing of, and profiting, from In 1994, at South Africa’s behest, the white rhino was wild animals, whose fates were closely bound to the down-listed to Appendix II. This meant that some internal use of State sanctioned violence. trade, the exportation of horns as hunting trophies and stockpiling of horns by private individuals was allowed. The Apartheid State was deeply involved in slaughtering The official 1994 CITES annotation down-listing the tens of thousands elephants and in the sustained white rhino to Appendix II stated that the change in smuggling of ivory, rhino horn drugs and diamonds status was “ For the exclusive purpose of allowing through South Africa for resale internationally, to international trade in live animals to appropriate and support its war machine in Africa in the 1970s and 1980s. acceptable destinations and hunting trophies.”18

The smuggling trade in wild animal body parts was not Currently South Africa’s rhino horn stockpile in the only allied to the South African security apparatus but hands of government is said to be approximately protected by them and as a result their networks and 21 tonnes19 (representing 5,250 dead rhinos). The private reach grew unimpeded and into the post-apartheid industry is said to have a stockpile of approximately era. (Humphreys & Smith 2014:803). After the demise 6 tonnes20 (representing 1,500 rhinos). But these of the Apartheid State and the dawn of democracy figures may not be accurate because authorities have in 1990, when the social and political landscape was struggled to confirm the amount in private hands. being recast and reimagined, the official approach Poor stockpile management practices of ivory and towards wild animals remained seamlessly callous rhino horn in South Africa has encouraged leakage into and inhumane. illicit markets.

Post-1990, South Africa actively began to lobby CITES for Despite an alarming increase in rhino killings, the the trade to be legalised. The first step in this process was Private Rhino Owners Association (PROA) and Wildlife

14 | A document prepared for CITES COP 17 EMS FOUNDATION Ranching South Africa (WRSA), have pursued a strident rejected the claim that it had agreed to make a joint campaign calling for the opening of “controlled trade” submission on trade. Officials would not say if South in rhino horn. In 1993 there were 650 rhinos in private Africa will support the Swaziland proposal.27 hands and there are now 6,200 owned privately.21 Legal Trade: A Cover for Illegal Trade South Africa’s deliberate promotion of the The trophy hunting permitting system in South Africa, commodification of rhinos and their ownership by internal legal trade and poor enforcement by the private individuals has not only grown the trade (both State have all contributed to promoting the global legally and illegally) in, and trophy hunting of, rhinos illegal trade in rhino horn and the killing of rhinos. The but has also meant that they are being bred and farmed information below shows how South Africa, through as agricultural products so that they can be cruelly and lax control of rhino hunting, rhino farming and internal continuously de-horned. trade, promoted demand for rhino horn.

Rhino farmer John Hume, who is essentially factory Rhinos bought directly from the Kruger National Park farming rhinos currently owns approximately 1,200 and KwaZulu-Natal Wildlife auctions are known to rhinos and is the largest rhino breeder in South Africa have been shot soon afterwards under “put and take” (and the world). According to Hume he “harvests” rhino circumstances so that the horns could be removed horn to save them.22 Hume also bought hundreds of and sold (“put and take” means that the animal is shot rhinos directly from the Kruger National Park. The under circumstances where it has no chance of escape fact that SANParks has chosen to sell so many rhinos - it is the same as “canned hunting”).28 to one single buyer, particularly given the increase in the illegal killing of rhinos and the stockpiling of horns In other instances rhino horn from private stockpiles by private individuals, reveals much about the State was sold within South Africa but later laundered into position. According to Hume he has five tonnes of rhino the illegal medicinal medicine market. Hunting permits horn stockpiled and he harvests a tonne every year.23 were also issued, allowing rhino horn to flow into the Izak du Toit, John Hume’s lawyer is quoted as saying: illegal international trade. “We would sell to the poachers to prevent them from killing rhinos,”24 so it seems that breeders such as Hume As stated above, internal trade in rhino horn became may have no problem with selling their stockpiles off to legal in South Africa after CITES down-listed the local transnational criminal smuggling networks. population to Appendix II in 1994 and remained so until 2008 when the government placed a moratorium In anticipation of CITES COP17 and because of civil society on trade. Rhino owners successfully won a High Court pressure, the Minister of Environmental Affairs convened Appeal in 2015 which rejected the moratorium. Although a Committee of Inquiry in 2015 tasked with investigating the Department of Environmental Affairs appealed the issue. The Committee advised against requesting this decision in the Supreme Court of Appeal in May CITES COP 17 for an opening of trade, advice accepted 2016 they again lost the case but in June 2016 filed an by the Cabinet, although it said that South Africa would application for leave to appeal to the Constitutional not destroy any rhino horn stockpiles. The full findings Court. The moratorium on internal trade will remain in of the committee have never been made public despite place until the Constitutional Court has made a decision. numerous requests for copies of its report. The Department of Environmental Affairs record Following the Cabinets’ decision, Swaziland keeping has been poor with regard to all wild animals, subsequently submitted a trade proposal to CITES and and even in 2016 it is still unclear how much rhino horn in official documentation accused South Africa of is in private hands or has left the country. reneging on a pro-trade agreement made during an earlier meeting between 12 Southern Africa According to a 2015 TRAFFIC Report29, “ironically the Development Association (SADC) nations.25 source of many illegal horns to date has been from poorly documented private horn stockpiles and the continuing According to documents submitted by Swaziland there poor management will simply continue to undermine was a consensus (with the exception of Botswana) at conservation efforts and any attempt to legalise trade.” the meeting in favour of rhino trade and it was agreed that South Africa would make a trade proposal this They further make the point that “understanding South year. “Swaziland was expecting South Africa to submit Africa’s wildlife trade remains clouded by delays, abuse a rhino horn trade proposal to CoP17 and was ready and miscommunication within the current permitting to support it. However, Swaziland was informed on structure, providing loopholes and opportunities 21st April, 2016 that this was not going to happen” the for illegal trade or unintended activities for many Swaziland submission to CITES stated. “That decision species and wildlife products to proliferate…This issue gave rise to this proposal by Swaziland at the 11th remains unresolved with many wildlife professionals, hour.”26 The Department of Environmental Affairs including professional hunters, hunting outfitters, confirmed South Africa had attended the meeting but wildlife veterinarians and wildlife capture operators,

EMS FOUNDATION A document prepared for CITES COP 17 | 15 arrested in conjunction with rhino crime still operating described by one provincial government official as “... buy within the industry. So far self-regulating private sector rhino, kill it, replace it, kill it...[sic]” (Hübschle, 2016:197). structures have been insufficient to prevent unethical practices…There are many examples where legal and And the South Africa State seemed not to be concerned illegal trades end up co-existing in parallel without about what happened to the wild animals once they reducing illegal off-take for the affected species: South left their national parks or who they sold them to. Africa’s abalone trade is a classic example, with illegal Several of the buyers are known criminals or have harvest swamping the legal quota system to the point been formally charged with crimes, including illegal of collapse of the wild resource.” activities relating to wild animals. For example, since 2004 SANParks, through the Kruger National Park, sold The significant scale of the use of legal trophy hunting 120 rhinos, “at a massively reduced fee,” to white-lion permits to move rhino horn to unknown destinations canned hunter Alexander Steyn a notorious “outfitter” was raised in official CITES documents as early as 2007.30 for various Vietnamese rhino hunts.34 Perversely the authorities claim that revenue from sales goes “back Other research undertaken at the same time noted into conservation,” and these include anti-poaching that during this period Vietnamese hunters, using legal activities, research, land acquisition and community permits, began to hunt rhinos in order to use their horn beneficiation projects.35 for medicinal purposes, rather than as hunting trophies. SANParks said that once sold the fate of rhinos became According to Hall-Martin, Du Toit, Hitchens and Knight, the responsibility of the provinces which issued permits. “During 2005 the first legal white rhino hunts with The ARA report added that “SANParks statement such as Vietnamese clients were conducted in South Africa. ...the sale of rhinoceroses to sources outside of national These hunts were legal as a trophy hunt but there can parks is governed by the provincial conservation be little doubt that the trophy became medicine on permits,’ ring hollow because they have not put a policy its way to the East and we have therefore referred to in place relating to the sale of wild caught rhinoceroses these hunts as medicinal hunts. It was also reported into captivity or to hunting destinations. that several clients purchased multiple rhino hunts whereas traditional trophy hunters would generally SANParks also appears to be abdicating its national only take one rhino trophy on a hunt. The impact of responsibility when it claims that because the permits these medicinal hunts on the rhino industry was huge, are issued by the provinces this precludes them from with an estimated income between 2005 and 2008 having such a policy. In terms of the South African of R121,050,000.”31 Constitution, responsibility for the Environment is a shared and concurrent competency between the According to a 2009 Animal Rights Africa Report, (Under national government and the provinces and therefore, Siege: Rhinos in South Africa) despite selling hundreds surely, SANParks and the provincial authorities have of live rhinos, sometime to known hunting concerns, a close working arrangement and the terms of the SANParks said they had no responsibility to monitor permits can be jointly agreed upon.” what happened with the animals after the sale. “One buyer [of rhinos from a KNP auction] also told the Statistics and Comparative Data Sunday Independent [newspaper] that he dehorned CITES trade data is drawn from information submitted rhinoceroses once they arrived on his farms. He said by members of CITES. The CITES Trade Database does he was stockpiling the horns so he could sell them not differentiate between rhino “horns” and rhino if the market was re-opened,” ARA reported. “This “trophies” but since no legal trade in horns, except also brings into question whether or not SANParks’ for hunting trophies, a has been allowed since 1977 it recent auction of white rhinoceroses from the Kruger is assumed that all horns listed are the result of legal National Park could be contributing to the exploitation rhino hunting. In South Africa the Department of of legal trophy hunting by those involved in the rhino Environmental Affairs submits data to CITES. horn trade. As previously stated, SANParks does not see a conflict with selling the rhinoceroses to trophy According to the CITES Trade Database, the total number hunters, claiming that the animals are no longer their of rhino horns/trophies imported from South Africa responsibility after the sale”.32 from 2001 to 2014 was 2,691 and the total number of live rhinos imported from South Africa for the same period In relation to rhino sales in 2014, SANParks spokesperson was 922. The total number of rhino hunting permits said that they “had transactions with several businesses issued from 2001 to 2015 was 1,492. The official number and were not at liberty to divulge who they were doing of rhinos “poached” from 2001 to 2015 is 5,162. business with.”33 There have been several reports of rhinos that had been bought from the State being shot In a 2014 Department of Environmental Affairs Report, almost immediately, some even in their crates for their The Viability of Legalizing Rhino Horn Trade in South Africa rhino horn, or for trophies in canned (so-called “put is conceded that government itself cannot provide and take”) “hunts” which in relation to rhinos have been accurate trophy hunting exports and attributes this to

16 | A document prepared for CITES COP 17 EMS FOUNDATION 1400 NumberLive of horns/trophies rhino imports from South Africa*** imported from SA* 1200 NumberReported of rhino hunting poaching (nationally)*** 1000 permits issued** Number of rhino hunting permits issued** Reported poaching 800 (nationally)*** Number of horns/trophies imported from SA* 600 Live rhino imports from South Africa****

400

200

0 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

*Source: CITES Trade Database **Source: T he 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 ****Source: CITES Trade Database

problems associated with the CITES reporting system as Protecting rhinos for who they are is not on South well as internal inadequacies in the collection of statistics Africa’s agenda, but rather it is the disembodied rhino in South Africa as the primary reasons for this failure. as a highly profitable commodity which has some owners (both government and the private industry) According to the Report trophy hunting data obtained incentivised by the black market value of rhino horn, from the CITES database has limitations that affect even if this means accelerating the poaching crisis, accuracy. “Each party to CITES designates a management causing pain and suffering and threatening the very authority to issue permits and compile annual reports existence of rhinos as a species.37 that are entered into the database. Although there are guidelines for the preparation of these reports many As Hübschle has noted, “regulatory breaches and Parties do not follow them completely resulting in the exploitation of legal and regulatory loopholes, inconsistencies…As a result of these limitation, when including illegal hunting and dehorning of rhinos, import and export permit counts for rhino trophies do as well as the stockpiling and laundering of illegally not match up on the CITES database it is impossible to harvested rhino horn into legal trade flows constitute determine exactly how many trophies were exported modes of ‘production’”. What renders these flows legally out of South Africa.”36 particularly efficient and safe is the early stage conversion of an essentially illegal good to legal status Recommendations (the laundering of illegally harvested horn into legal The South African government’s pro-use, pro-abuse, trade flows), and contrariwise, the conversion of a legal pro-trade and pro-private ownership stance towards product (the hunting trophy) into an illegally traded rhinos, particularly because they are stockpiling rhino good in consumer markets.” (Hübschle 2016:292) horn and encourage private owners to do the same, means they are actively not limiting supply and in so While the United Nations Office on Drugs and Crime, doing are spurring on the proliferation of rhino deaths, has shown that “case studies show that when illegally playing a role in stimulating demand and pushing up traded wildlife is introduced into legal commercial the price and perceived value for dead rhinos and their streams, criminals have access to a much larger source body parts (both legally and illegally). Rhinos have of demand than they would have had on the black become the victims of financial speculation. market alone.” (2016:10).

EMS FOUNDATION A document prepared for CITES COP 17 | 17 Photographer Jennifer Bruce

The irregularities in the South African rhino hunting Despite the very high levels of illegal trade in rhino and breeding industry that were noticed in the early horn the South African government, supported by 2000s were, according to Annette Hübschle in her PHD. rhino farmers, hunters and others in the wildlife Thesis, A Game of Horns: Transnational Flows of Rhino industry have regularly promoted rhino hunting, Horn published in 2016, a clear driver of demand which trade in horn and the trade in live rhinos. Very little stimulated the rhino poaching that surged in 2008. has been done by these parties to contribute in any Hübschle argues that a “gray” trade was created where significant way to campaigns aimed at reducing rhino it became difficult to distinguish between legal and horn trade in Asia. illegal rhino horn. “A key feature of these gray flows is the exploitation of legal and regulatory loopholes as South Africa’s position and that of some private actors ride on the edge of legality”. owners of rhino, hunters and supporters of the concept of the “sustainable use of natural resources” Hübschle interviewed 360 people and found that, ”South is clearly aimed at generating profits without African wildlife professionals and rhino breeders who consideration to the fate of rhinos in South Africa form part of the country’s white economic elite are the or elsewhere. principal actors” and that “the significant role of wildlife industry players in rhino extinction (as opposed to rhino “We find that a legal trade will increase profitability, conservation) is noteworthy. While public attention has but not the conservation of the rhino population,” been drawn to rhino poaching in public parks, rogue economists Dr Douglas Crookes and Professor James elements within the wildlife industry were the catalyst for Blignaut state in a paper entitled “Debunking the myth poaching to increase in national and provincial parks.”38 that a legal trade will solve the rhino crises: A system dynamics for market demand” which was published in Hübschle’s findings may help explain to some degree the Journal for Nature Conservation in June 2015. “It is why, Hall-Martin, du Toit, Hitchins & Knight, found only through education in consumer nations that this unwillingness, from some in the wildlife industry, trend [in rhino poaching] could be reversed. to assist in them in their research. “The level of cooperation afforded by many individual owners In their 2009 report Under Siege: Rhinos in South Africa,39 of white rhinoceros, their managers, the provincial Animal Rights Africa called for the following steps to be and national authorities and various elements of taken to effectively counter the killing of rhinos: the organized game ranchers associations has • Improve data collection at both provincial and been disappointing. The professional hunters and national level; individuals involved with hunting were particularly • Re-examine the permit system under which unhelpful,” they noted. “Much of the official government sellers of rhinoceros abrogate their cooperation was grudging at best and many owners responsibility with regard to what happens to the and management authority officials refused outright animal once it has been sold; to provide information when requested. Indeed, • End all rhinoceros hunting in South Africa because the diffusion of effort, and even chaos, in managing it has been proven to be as great a problem as wildlife and the associated trade in many species in poaching; South Africa that was addressed by Bodasing and • Re-examine the entire CITES reporting procedure Milluken (1996) appear to be as great a problem now because it is quite clear that limited and often as it was more than a decade ago.” inaccurate information is submitted;

18 | A document prepared for CITES COP 17 EMS FOUNDATION • Open the policy of ‘sustainable use’ and trophy hunting to public debate; “Today’s elephant • Publicly publish through websites up-to-date applications for hunting permits and hunting populations are statistics. suffering from a form Now, seven years and thousands of dead rhinos later the EMS Foundation calls for the same steps. Will the of chronic stress, a… proponents of killing rhino and selling their horns finally put rhinos before profits and change their views? species-wide trauma. History and the facts listed above insist they should. Decades of poaching ‘SUSTAINABLE USE’ IS LEADING TO THE EXTIRPATION OF AFRICA’S ELEPHANTS and culling and Elephants are Africa’s Heritage habitat loss…have so As a direct result of the trade in elephant ivory (both legal and illegal) and ‘sustainable use’ policies elephant disrupted the intricate populations across Africa have been catastrophically decimated. Alarmingly in the last seven years alone web of familial and more than a third of Africa’s elephants have been savagely killed. Add to the mix the effects of widespread societal relations… and proliferating trophy hunting and the live trade in elephants to overseas zoos and the very existence that what we are now of Africa’s elephants hang in the balance. CITES COP members have the power to save them by taking a stand witnessing is nothing to protect elephants. less than a precipitous Statistics from the Great Elephant Census released on 1 September 2016 show that the savannah elephant collapse of elephant population has dropped to about 350,000 with forest elephant numbers as low as 70,000.40 To put this figure culture.” in perspective, approximately 1.3 million elephants inhabited Africa in the 1970s. The pace of the slaughter varies from region to region. Charles Siebert An Elephant Crackup, New York Times 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 trade, granted two previous “once off sales” of ivory, Mozambique dropped from about 20,000 in 2009 both subsequently linked to increases in poaching. to 13,000 in 2013, a decline of about 35% in just five These countries are also strong supporters of “killing years. Both these countries are strong proponents of animals to save them” thinking and all have thriving ‘sustainable use’ including of course trophy hunting. but poorly managed trophy hunting industries.

Despite this cataclysmic decline three countries, South According to a 2016 International Fund for Animal Africa, Zimbabwe and Namibia, will ask CITES COP 17 for Welfare Report, 10,294 African elephant “trophies” were permission to sell ivory stocks, a direct rejection of the exported from the continent between 2004 and 2014. pleas made by 29 African nations (the African Elephant IFAW notes that these records may not be complete. 43 Coalition)41 for all trade to be stopped and for ivory During the same period South Africa exported 1,740 stockpiles to be destroyed. There is overwhelming elephant “trophies”. evidence to show that a sale of ivory by South Africa Botswana and Namibia in 2008 helped stimulated the Trophy hunters argue that their presence deters current wave of elephant killing. 42 poaching but this theory has imploded with the massive slaughter of elephants in and around hunting South Africa, Zimbabwe and Namibia are amongst the concessions in Tanzania and Mozambique. foremost supporters of trade in ivory and rhino horn and have for years gone against the majority of global The Selous Reserve complex in Tanzania, an area opinion that trade bans must be enforced without of some 80,000 square kilometres, is divided into exception. CITES has, despite their 1989 ban on ivory 47 operating blocks of which only four are devoted

EMS FOUNDATION A document prepared for CITES COP 17 | 19 to tourism, the rest being reserved as hunting boundaries with the park. The remaining elephants concessions. Despite the preponderance of hunting occur in much smaller national, provincial, and concessions the elephant population has dramatically some private parks and reserves. The South African plummeted.44 A similar situation exists in the Ruaha- Department of Environmental Affairs has published Rungwa Complex in Tanzania and the Niassa Reserve a set of National Norms and Standards for the and surrounding concessions in Mozambique, both Management of Elephants in South Africa (2008) but sought after hunting areas. these may be reviewed in 2017.46

In 2015 CITES granted Zimbabwe the right to export South Africa has also seen an increase in elephants 1,000 trophy tusks (effectively 500 elephants), being killed for their body parts, with at least 54 killed South Africa 300 tusks, Tanzania 200, Mozambique in the Kruger National Park in the last 18 months. Park 200, Namibia 180 and Zambia 160. CITES has given officials have expressed their extreme concern by this Zimbabwe the right to kill 500 elephants annually sudden increase in elephant killings and fear that it and export their tusks although the country faces a could mirror the pattern of rhino killing, which has plethora of economic sanctions imposed in an attempt soared since 2008. to force the reform of its undemocratic and corrupt government. Zimbabwe has no currency of its own, (it To keep the numbers of elephants high so as to ‘harvest’ uses the U.S Dollar) and is regularly unable to pay its their tusks for the ivory trade, South Africa used the civil servant or soldiers. farming practice of so-called “culling”. Between 1967 and 1997 a total of 14,629 elephants were killed in this In 2012 four baby elephants were exported but three way in the Kruger National Park.47 died within months of the export. It is reported that Zimbabwe was paid US$60,000 for each calf. This cruel practice, which severely and negatively Zimbabwe has said it sold of the animals because it impacted the elephant survivors, was discontinued as a needs the money sales would raise. In 2015 Zimbabwe result of a local civil society campaign which successfully also captured at least 34 young elephants for sale to challenged the scientific and ethical reasons for this zoos in China, an action widely condemned as cruel. unjustifiable tradition and ultimately brought about a change in thinking by SANParks scientists. South Africa’s Elephant Population South Africa has an elephant population of about In 2014, SANParks, large mammal ecologist, Dr Sam 20,500 and differs from other African elephant range Ferreira said that the elephant population growth rate states in that all of these animals occur within fenced during the period when “culling” took place was about reserves.45 The vast majority, about 17,500 occur, in 6.5% but under a different management regime which the Kruger National Park and neighbouring private included the closing of various artificial water holes and provincial “buffer reserves” which share unfenced and dams the growth rate dropped to just over 2%.

South Africa also developed a terrible and inhumane The capture industry from the elephants they deliberately orphaned though culling, namely the elephant-back safari industry. and export of Over and above the “cull orphans” other young elephants were allowed to be deliberately abducted and kidnapped young elephants from their mothers and families for use by the industry. is exceptionally Further emphasising the idea that elephants must be part of “sustainable utilisation” and that they have to “pay cruel, is driven their way”. South Africa has the largest elephant back riding/elephant interaction industry in Africa with more by profit and has no than 100 animals held in captivity for these purposes. conservation value. A strong trend is developing to move away from this exploitative and cruel practice and at least 2 elephant- back 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 Elephant scientists and long-term and detailed scientific in the North West province. Shambala has established research has clearly shown that the capture and removal a scientific programme to monitor the animals as of young elephants disrupts social groups and causes they become accustomed to their new lives. A third intense distress in the captives and those left behind. operator, Camp Jabulani at the Kapama Reserve has stopped elephant back rides but will still allow their For example, in October 2014, Zimbabwe captured 35 14 elephants to interact with humans. At least one elephant calves from wild herds in Hwange National other private reserve, the Gondwana Private Reserve Park for export to China. Although the capture and in the Western Cape has also allowed former captive export was widely condemned as cruel and without elephants to become free ranging animals again.48 any conservation value the Zimbabwean Government argued that it needed to raise funds and selling Despite its Apartheid past, South Africa remains wedded elephant calf was a legitimate use of “natural resources”. to the concept of “sustainable se” of so-called “natural resources”. It therefore actively drives the trophy In September 2015 National Geographic reported that hunting of elephants. In 2015 CITES gave permission for the elephants that went to China were being mistreated the export a total of 300 tusks as hunting trophies (150 and were slipping into poor health. In 2012, Zimbabwe animals). Similar quotas were granted in previous years. exported eight elephants to China. Only four survived the journey. Another three died shortly after arriving in The killing does not stop there. Elephants are also shot China, leaving only one surviving elephant. as so-called “damage causing animals” (DCA) in some provinces. These are animals that have crossed through Elephants, nor any other animals, should be kept in zoos. fences surrounding parks and strayed into communal A 2012 Seattle Times special report found that elephant or agricultural areas. A culture of killing is the preferred births in U.S. zoos have failed to offset deaths, which solution. Tusks from these animals are supposed to will lead to the demographic extinction of the country’s be marked, catalogued and stored in government zoo elephants in the next 50 years. Half the elephants storeroom or other safe places. documented in the study were dead by age 23, about a third of their expected life span in the wild of 50 to Between 2010 and 2015 Mpumalanga Tourism and 60. The report noted that the infant mortality rate for Parks Authority (MTPA) conservation officials permitted elephants in zoos is 40 percent, nearly triple the natural the killing 153 elephants as DCAs. Most of these rate in the wild in Asia and Africa. Most had died from elephants came from the Kruger National Park. During injury or disease associated with their captive conditions: the same period Limpopo’s Department of Economic foot and joint disease, reproductive disorders, infertility, Development, Environment and Tourism (LEDET) aberrant behaviours such as infanticide.50 conservation officials killed 69 elephants as DCAs.49 Namibia has an elephant population of approximately Zimbabwe and Namibia’s Elephant 19,500 elephants, most of which occur in the north of Populations the country close to the borders of Angola, Botswana According to the 2016 Great Elephant Census, and Zambia. Poaching of elephants and rhinos has Zimbabwe has an elephant of population of about increased, and from 1 Jan 2015 to July 2016 at least 80 82,000 which has declined by 6% since it was last elephants were killed by poachers and approximately reliably surveyed. CITES has for several years awarded 167 rhinos. Namibia is also popular destination for Zimbabwe a trophy hunting quota of 1000 tusks (500 foreign hunters. 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.

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 and that in 1979 alone fraudulent import permits for The global ivory trade has existed for centuries and at least 3,922 elephant tusks and 700 rhino horns had as weapons become more advanced the slaughter been issued at Rundu on the Angolan border within of elephants across Africa and Asia increased South West Africa (now Namibia). The Commission correspondingly. Continued demand for ivory, was told that SADF soldiers assisted UNITA in killing promoted by both legal and illegal sales, has ensured elephants and rhino. The ivory and rhino horn was that elephants continue to be killed for their tusks. transported through areas controlled by the SADF and then smuggled through South Africa and other According to information obtained through a countries. Some private individuals within the SADF Promotion of Access to Information Act (PAIA) request also benefitted from sales. by the Centre for Environmental Rights from the Department of Environmental Affairs in August 2016, Elephants Are Not Tyres: the total weight of the national ivory stockpile held Why all Trade in Ivory Must End by South Africa National Parks and other national In an attempt to quell the elephant poaching which and provincial governmental and parastatal bodies in swept Africa in the 1980s CITES finally imposed a ban South Africa is 65,043.48 Kg. on international trade in ivory in 1989 (International commercial trade in rhino horn was banned in 1979). The total number of ivory pieces that form part of this Elephant poaching declined to relatively low levels stockpile consists of 76,354 pieces (raw and worked). for the next decade but researchers noted a marked 50,171.60 Kg is sourced from, “damage causing animals”, increase in the poaching of forest elephants in the early natural mortality, and donations and 14,871.89 Kg 2000s followed by dramatic surge beginning in 2008. from confiscations (ivory from criminal activities. The current stockpile does not include ivory from so-called Despite the international ban various Southern African “culling, i.e. obtained prior to 1997 as the ivory was sold nations have nevertheless persistently campaigned for in the CITES COP approved once-off sales in 2008. the right to sell ivory since 1997: • In 1997 CITES agreed to allow Namibia, Zimbabwe South Africa too has a long history of trading in ivory, and Botswana a “once off” sale of 49 tons of ivory to rhino horn and the skins and horns of other wild Japan. This sale took place in 1999. animals. By the end of the 19th century most of the • In 2002 CITES approved requests by South Africa, elephants and rhinos that had been found in what Botswana and Namibia for another “once off” sale, comprises modern South Africa had been shot and this time agreeing to the sale of 60 tons of ivory killed with only small isolated populations surviving. from government stockpiles. This only took place Colonial records show that between 1844 and 1904 in 2008 but CITES raised the amount 108 tons, all (60 years) at least 883,491 kg of elephant ivory was of which was sold to China and Japan. (In this sale exported from the port of Durban alone. During the South Africa sold 47,356 kg of ivory for US$ 6,703, same period 19, 246 rhino horns and 2, 015, 246 skins of 000; Botswana sold 43,153 kg for US$7 093 550; various animals were also exported.51 Namibia 7,226 kg for US$ 1, 862,60 and Zimbabwe 3,700 kg for US500,000. The average price per kg Conservation efforts over the next century ensured was $157). that wildlife populations recovered in South Africa. • In 2010 Tanzania requested permission for a once The country was spared the rampant killing of off sale but this was rejected by CITES. elephants and rhinos that took place elsewhere in Africa during the 1980s partly because of the intense In 2016 prior to CITES COP 17 South Africa, Zimbabwe military and police activity aimed at crushing political and Namibia again submitted proposals to CITES dissent secured the country’s borders during the last for further sales. Namibia and Zimbabwe have also years of apartheid and also because of international requested that their elephant populations be delisted trade embargoes which isolated country from formal altogether an action which would allow them to sell global commerce. ivory by auction. Approval for this proposal requires a two thirds majority vote. During the 1970s and 1980s senior members of the South African Defence Force (SADF) participated in The African Elephant Coalition (AEC) persuasively the in the almost total destruction of the elephant argues that if African nations are serious about and rhino populations in southern Angola as part of a stopping poaching they should support proposals scheme to sell ivory and rhino horn rhino to fund the that all ivory stockpiles should be destroyed and that UNITA rebel movement. no legal trade should be permitted. Currently most Southern African elephant populations are listed In 1995 the Kumleben Commission of Inquiry into on CITES Appendix II which allows trade in special the Alleged Smuggling and Illegal Trade in Ivory and circumstances, such as the special “once off” sales. Rhinoceros Horn was told that the SADF had created (http://www.africanelephantcoalition.org) a front company to transport ivory and rhino horn

22 | A document prepared for CITES COP 17 EMS FOUNDATION “The current listing of southern African elephants in about profits from future trade and acts as an incentive Appendix II – allowing trade – has stimulated poaching for legal and illegal traders and processors to remain in and smuggling of ivory,” the AEC states “Elephant business. They also say that selling of stockpiles can lead populations are declining significantly across most to new investments and new market-related institutions of Africa. A universal listing in Appendix I will outlaw that lock-in society into a trajectory of more, not less, the ivory trade, simplify enforcement and send a clear ivory trade. The synergies between legal and illegal trade message to the world of a global determination to halt may very well be strengthened (2016:Vol.57). the extinction of African elephants”. The view that no further ivory sales should be permitted Since the ban on open trade was imposed in 1989 at is also strongly supported in a peer-reviewed paper least 14 countries have burnt ivory stockpiles In March published in June 2016 by Solomon Hsiang and Nitin 2016 Kenya, supported by other AEC members and a Sekar. According to their findings, the 2008 “once off” wide range of global and local conservation NGOs sale by South Africa, Namibia and Botswana stimulated burnt a 105 ton ivory stockpile thereby emphasising the huge spike in poaching.53 their rejection of any trade in ivory, legal or illegal. South Africa, Zimbabwe, Namibia and Botswana have Their research has shown that “the international all rejected the destruction of stockpiles. announcement of the legal ivory sale corresponds with an abrupt 66% increase in illegal ivory production At a ceremony held in Nairobi where the ivory was across two continents, and a possible ten-fold increase burnt Kenyan President Uhuru Kenyatta said that “No- in its trend” and that “an estimated 71% increase in one, and I repeat no-one, has any business in trading in ivory smuggling out of Africa corroborates this finding, ivory, for this trade means death of our elephants and while corresponding patterns are absent from natural death of our natural heritage.”52 mortality and alternative explanatory variables. These data suggest the widely documented recent increase The view that ivory sales promote usage and thus the in elephant poaching likely originated with the legal killing of elephants is supported by economists Nadal sale.” Their results “are most consistent with the theory and Aguayo In the science journal Pachyderm they that the legal sale of ivory triggered an increase in argue that ivory stockpiles should be destroyed because black market ivory production by increasing consumer keeping stockpiles in place supports expectations about demand and/or reducing the cost of supplying future supply and the establishment of an international black market ivory, and these effects dominated any legal market and that this consolidates expectations 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 The report noted that the Minister said this amount dedicated hunter, also surprisingly voiced support of money “could turnaround the fortunes of the for a ban on all ivory sales “ One-off sales of African country should a ban on ivory trade be lifted.”56 countries’ stores of confiscated ivory in the past two This figure is wildly inflated and makes the assumption decades - which were permitted under the assumption that Zimbabwe’s stockpile if is worth about US$94,791 that they would drive down the price of ivory - instead a kilogram. The Hong Kong Tourism and Natural appear to have had the opposite effect … Poached Resources Minister, Professor Jumanne Maghembe ivory looks nearly identical to legal ivory, enabling vast said in September the average wholesale price of ivory amounts of illicit material to be laundered and sold in Hong king’s was $150 a kg.57 openly- further driving trafficking and the poaching of elephants. It is time to end all ivory sales worldwide”.54 In a formal document submitted to CITES Zimbabwe argues that “The proposed move by the proponents A wide range of NGOs including the EMS Foundation, essentially infringes upon Zimbabwe’s sovereignty to The WWF, IFAW, the Environmental Investigation make decisions over its wildlife resources, for the benefit Agency (EIA), Amboseli Trust for Elephants, Big Life of its economy and its citizens without interference.”58 Foundation, the Born Free Foundation, the David Sheldrick Wildlife Trust, the David Shepherd Wildlife The same Minister concedes that Zimbabwe has Foundation, Elephant Action League and others have been unable to stop theft from its ivory stockpiles. opposed the current application by South Africa, Commenting on a theft of ivory from stockrooms at Zimbabwe and Namibia for trade. TRAFFIC, the global the Hwange National Park in April 2016, the Minister wildlife trade monitoring network, has also rejected said “...the investigations we have conducted since the sales proposals. late last year prove that there was indeed a lot of ivory theft from within the parks authority itself,” and that SADC Members have been the primary drivers of the “markets included Chinese people, some of whom requests for ivory sales since 1997. Public comments sometimes buy ivory legally from government sales.”59 from senior officials and politicians in South Africa, Zimbabwe and Namibia reveal that raising funds Namibia’s position is similar that that of Zimbabwe. irrespective of the plight of elephants elsewhere in “We will get a lot of money and the proceeds will go to Africa is the primary driver of their position. state coffers to alleviate poverty” Namibia’s Minister of Environmental and Tourism, Lobamba Shifeta, told South Africa has taken a strong line in differentiating the New Era newspaper in 2015. The Minister also between management policy relating to elephants in said the burring of ivory stockpiles would be waste of southern Africa and elsewhere in Africa, often refusing potential revenue.60 to acknowledge that decisions on trade could have Continental, or global, implications. They are also In demanding another “once off sale,” if granted it often victims of their own ideological position and would be the third since 1989, South Africa, Namibia spin-doctoring, seemingly deliberately ignoring the and Zimbabwe have clearly taken a stand to lobby for mounting evidence, analysis and research as well as their own economic gain at the expense of elephant large-scale seizures of ivory which have more than populations in other African nations. None of these doubled since 2009. SADC countries has produced any evidence to show that sales will not jeopardise elephants elsewhere in Edna Molewa, the South African Minister of Environmental Africa, or Asia, despite considerable evidence that this Affairs, told an audience during the signing of a rhino is likely. anti-poaching agreement with Mozambique in April 2014 that selling rhino horn might help reduce poaching In arguing that it is their sovereign right to make as had been learnt from “South Africa’s ivory sale”. “… decisions about how to manage their wildlife resources just taking the lesson we have learn from ivory. We did they fail to acknowledge that these rights must be a once-off sale and elephant poaching has not been a exercised in a way that does not impinge on the problem since…”55 sovereignty of others. The decisions taken by South Africa, Zimbabwe and Namibia will clearly have an Zimbabwe, which is in a political crisis, with its economy impact on elephants throughout Africa. in ruins and massive unemployment, has made it clear that it wants to sell ivory purely for the money. The The South African government’s current position in Minister of Environment Water and Climate, Oppah relation to ivory sales and stockpiling is mercenary and Muchinguri-Kashiri told the Zimbabwean National counter-intuitive and it is holding the rest of the continent Assembly in July 2016“ We have 96 tons of ivory and to ransom. South Africa is misguidedly following a “South if we sell it, we will realize about $9,1 billion,” Minister African exceptionalism” position, which continuously was quoted as saying in the state controlled Herald distances itself from other African countries and displays newspaper in Harare. a disregard for the rest of the continent.

24 | A document prepared for CITES COP 17 EMS FOUNDATION All three countries were signatories to the CITES landlocked” and that “the poached abalone enters the African Elephant Action plan signed in 2010 by 37 general market stream in which it instantly becomes African elephant range states in Africa. The signatories indistinguishable from the legal equivalent. agreed that “the African elephant range States shall continue their constructive elephant dialogue aiming This is the case with ivory too. End users cannot to develop joint conservation policies and exchange easily distinguish between what is legal and what of management experience in order to improve the is illegal meaning that legal sales simply fuel trade. management of elephant populations,”, the proposal The transnational criminal syndicates involved easily submitted to CITES in March 2010 stated, adding that move between species depending on the profitability. “African countries have progressively strengthened Rhino smugglers easily become elephant or pangolin understanding and cooperation within and amongst smugglers, people smugglers or drug merchants. elephant range state on numerous social, economic and environmental issue of mutual interest and concern.”61 Promoting legal trade in ivory, or rhino horn, sends a signal that it is acceptable to use these animal parts. The “constructive dialogue” has clearly broken down In proposing trade when wild animal populations and in the proposal to CITES Zimbabwe perhaps in unprecedented decline South Africa, Namibia explains the stance of the three pro-sale nation’s and Zimbabwe are setting themselves above the most clearly. “Zimbabwe would oppose any moves interests of the rest of Africa and other countries that that seek to prescribe an umbrella approach to the are determined to ensure that elephants survive and management of African elephants particularly to continue share the planet with humans. range states that have proven to manage thriving elephant populations through successful conservation AFRICAN GREY PARROTS practices,” the country states in a document submitted to CITES supporting the appeal to trade. “The proposed South Africa is one of the largest exporters of move by the proponents essentially infringes upon Africa grey parrots in the world. Zimbabwe’s sovereignty to make decisions over its Although African Grey Parrots do not occur naturally wildlife resources, for the benefit of its economy and its in South Africa, tens of thousands have been imported citizens without interference”. into South Africa from other African states, notably the Democratic Republic of Congo and very large numbers This shows little commitment to a continent-wide are also bred in captivity for sale into the global pet coordinated approach to reducing poaching. The trade and to provide breeding stock for commercial focus on revenue generation through increased trade breeders.62 According to the Parrot Breeders in ivory is counter to widespread calls for demand Association of South Africa (PASA), South Africa has reduction programmes in user countries. 1,632 breeding facilities which hold 97,928 African grey parrots (48,964 pairs). South Africa, Zimbabwe and Namibia seldom enter into meaningful discussions about demand reduction African grey parrots are experiencing significant for ivory or rhino horn although South Africa recently population declines in the wild due to the capture of declined to lodge a request to sell rhino horn because birds for the pet trade and habitat loss. Mortality rates it was felt that it was unclear whether sales under the are very high amongst captured birds. present conditions would stimulate poaching. This is a concern clearly not felt with regard to ivory and the The World Parrot Trust says that only about 560,000 of circumstances of elephants elsewhere in Africa. the birds may be left in the wild and that “Over 1.3 million wild-caught individuals of mostly P. erithacus (African The killing of elephants is fuelled by corruption, grey parrot) entered international trade in four decades. poor administration, demand for wildlife “products” Taking into account a mortality rate of 40-60% the true and many other socio economic issues. Legal trade number trapped could be upwards of 3 million.”63 in wildlife is widely used as a cover for illegal trade. South Africa, for example, allows a limited amount of A motion requesting that the protection of Grey legal abalone (perlemoen) trade and also maintains a parrots be improved by listing the population to CITES number of abalone aquaculture projects but poaching Appendix I will be made at COP 17 by Angola, Chad, still continues unabated and illicit trade far outweighs the European Union, Gabon, Guinea, Nigeria, Senegal, the legal trade. Togo and the United States of America. They argue that placing the African grey on appendix I is essential As the Report on South Africa’s illicit abalone trade; an because “the African Grey parrot has experienced updated review and knowledge gap analysis states, “The marked population declines throughout its range. In legal trade is regularly used as a cover by poachers June 2012 it was re-categorised as Vulnerable on the and the smuggling syndicates to move abalone IUCN Red List of Threatened Species on the basis that through neighbouring countries, some of which are “the extent of the annual harvest for international

EMS FOUNDATION A document prepared for CITES COP 17 | 25 trade, in combination with the rate of ongoing habitat if this an average figure). loss, means it is now suspected to be undergoing rapid • The global demand for African grey parrots in 2014 declines over three generations (47 years).”64 was 97,706 birds of wild, captive and unknown origin. Of these 82% were captive bred in different This document also points out that in many instances parts of the world. trade figures for African grey imports by South Africa • Of the captive bred birds traded 96% came from do not match export documents from the Democratic South Africa. Republic of Congo and that fake or falsified permits have been used to launder illegally caught birds into PASA opposes the submission requesting African grey the legal trade. “In 2009, 2010 and 2012, reported parrots be placed on CITES Appendix I on the grounds imports by the Republic of South Africa from the that the listing will not assist in protecting wild parrots. Democratic Republic of Congo exceeded their annual “Left on Appendix II South Africa can play a vital role to export quota and the exports reported to CITES in supply enough aviary bred birds to satisfy the global each of these years…The Republic of South Africa is demand,” Meiring stated in his presentation. the largest exporter of captive-bred birds to the global market and in 2012 exported over 42,000 specimens As with South Africa’s position on trade in ivory, lion under CITES code C…Currently commercial-scale bones, abalone and other animals and plants PASA breeders in the Republic of South Africa import high stance places trade above conservation of wildlife. volumes of wild caught birds as inexpensive breeding CITES notes considerable irregularities in the trade of stock. Reported imports from the Democratic Republic wild birds and it is clear that this trade is deeply linked of Congo alone have regularly exceeded that country’s to severe population declines amongst wild African export quota in recent years.”65 grey parrots. Trade, both legal and illegal, is clearly contributing to the decimation of the planets’ wildlife In response to questions in the South African and plants. Parliament the Department of Environmental Affairs said that 4,100 African grey parrots were imported from In a submission made to the Department of the Democratic Republic of Congo in 2009.66 In 2011 Environmental Affairs in July regarding various at least 750 African grey parrots, part of an order of proposals regarding CITES listing EMS Foundation 1,650 wild caught birds from the Democratic Republic noted: “It was clear from the… stakeholder meeting Congo, died on an aircraft between Johannesburg held in June that parrot breeders in South Africa have and Durban.67 been trading in wild-caught parrots. This is supported by statistics in the CITES trade database. Again it is a In July 2016 the Vice Chairman of PASA, Antonie case of a dual market and a legal trade providing a cover Meiring, told a South African CITES stakeholder for illegal trade. The EMS Foundation totally supports meeting that the commercial breeding of African grey the position taken by the World Parrot Trust, Africa parrots had increased exponentially in South Africa Conservation Programme as presented by Dr Lynn since the 1990s. He said that the latest available figure Jackson and we concur that the rates of decline are gathered by his organisation showed that: consistent with CITES guidelines for Appendix I listing.” • 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 EMS FOUNDATION HUNTING FOR PROFITS: SOUTH AFRICA AND TROPHY HUNTING

The proponents of “trophy hunting as a conservation by the lack of serious economic analysis on market tool” contention are primarily trophy hunting advocacy structures and price formation dynamics in markets for organisations, like PHASA, CHASA, SAPA, Safari Club so-called wildlife ‘products’ (including, of course, ivory, International etc. These organisations often cite two rhino horn, lion and tiger bones and skins, etc.). interrelated documents as alleged “proof” that trophy hunting can be a “useful tool” to conservationists: the They argue that advocates of trophy hunting and IUCN SSC Guiding Principles on Sport-hunting as a deregulated trade of these ‘products’ have been Tool for Creating Conservation Incentives (09 August navigating in oceans of ignorance, both in terms of the 2012) and CITES Resolution Conf. 2.11 (regarding trade theoretical tools that are used as well as the superficial in hunting trophies of species listed in Appendix I). analyses of real world (existing) markets. This means that assertions concerning the movement of prices The primary theory for promoting trophy hunting as and the amount of resources that are supposed to be a conservation tool behind the IUCN Principles and ‘ploughed back’ into conservation are in reality just the CITES’s Resolution is that hunting can: incentivise empty statements. governments in developing countries to generate conservation programmes and directly raise funding South Africa has the largest hunting industry in for on the ground conservation efforts in counties with sub-Saharan Africa and it is Africa’s most popular otherwise limited resources. destination for foreigners wishing to kill anything from elephants and buffalo to the 4.5 kilogram blue Supporters of trophy hunting based conservation duiker and 1.6 kilogram genet. South Africa also has a increasingly ignore that these so-called benefits of large domestic recreational (“biltong” or South African trophy hunting have not overcome the long-term dried “meat”) hunting industry. In addition, so-call negative effect of hunting - namely the allowance subsistence or “bushmeat” hunting, usually referred for legalised killing of these animals continues to to as “poaching” (with all its cruel implications), takes decrease their overall chance of survivability as a place in many parts of the country. Levels of “poaching” species in the wild. are high in South Africa because it that coincides with poverty, joblessness and market-driven “wildlife” trade In fact, development economists conducted a study and policies. on illegal trade of wildlife and found that “the literature advocating trade as a conservation solution for The hunting industry is far from under control with endangered species relies on models that are based canned hunting officially endorsed and supported on simplistic and/or extremely restrictive assumptions. by the State. The reality is that most trophy hunting The study went on to explain that in most cases these in South Africa is essentially canned to a greater or models rely on conceptual tools that have been lesser extent. South Africa remains the worlds’ top theoretically discredited. destination for the hunting of captive raised lions and according to the Department of Environmental Affairs Indeed, many objective scientific studies and in the field there are approximately 6,000 lions in captivity (at any observations that are not directly supported by trophy given time) held in about 200 facilities.68 hunting organisations have repeatedly concluded that trophy hunting endangered or threatened species, Sixty eight percent of Africa’s wild animals that were even if well managed, is one of the primary factors killed by American trophy hunters between 2005 and driving the illegal trade of these species in the black 2014 came from South Africa, i.e., of the 565,558 African market. These findings show that the legal and illegal animals killed during this period, 383,982 came from markets are intertwined in a complex manner and that South Africa.69 A Humane Society International report their interactions create a dual market that is impossible for the same period showed that out of a total of 5,587 to regulate. lion trophies 3,999 came from South Africa. 70

Development Economists such as Nadal and Aguayo Although the situation with regards to lion and rhino who ironically are also supported by South African hunting has attracted widespread attention and programmes driven by the Department of Trade criticism, both locally and abroad, the killing of all and Industry (DTI) and the Industrial Development species of wild animals has increased significantly over Corporation (IDC), for example through the African the past ten years. It is worrying that in a country which Programme on Rethinking Development Economies is aggressively advocating and allowing the killing of (APORDE). These economists are extremely concerned other animals for profit that many hunting regulations

EMS FOUNDATION A document prepared for CITES COP 17 | 27 are poorly enforced and provincial and national Societal injustice, subjugation, the proliferation of officials do not collect and collate the relevant data - a violence and exploitation frame the indifferent wildlife failing which draws into question the basis on which industry. And it is with individual, community and many decisions in relation to wild animals are taken. ultimately global silence that these fundamentally cruel practices continue to grow, fester, are camouflaged and Many officials, by the governments’ own admission, ultimately feed upon themselves. This has particular either misunderstand or fail to apply national resonance in South Africa because of the serious environmental regulations such as the Threatened problem of violence the country has faced and is facing and Protected Species regulations (TOPS). In addition, and the tools required to combat it. despite the scale of the industry, the Department of Environmental Affairs does not have an electronic permit A recent study analysed trophy hunting in six system that allows it to collate the numbers of hunting African countries - South Africa, Zimbabwe, Zambia, permits issued nationally. If it requires information it has Mozambique, Namibia and Tanzania - where trophy to contact the nine provinces individually and they too hunting has touted by the industry and governments do not have electronic permit systems. as “an effective conservation tool,” unsurprisingly showed that in reality: trophy hunting is causing The consequence of this is that it “does not have decline in wild animal numbers, having negative information on the number of hunting permits issued impacts on wild populations and causing the loss of for a particular species across the country”71 nor “does healthy individuals that are key for reproduction and not keep a national register of professional hunters and social cohesion; there is also an extremely close link there is no limit to the number of hunters permitted.” between legal hunting and poaching; that trophy The trophy hunting industry in South Africa is not only hunting is fuelling corruption; and that trophy hunting growing but is also extremely difficult to monitor or encourages the unfair redistribution of the wealth police and official control is poor at best. The national generated (Cruise:2016). and provincial hunting permit systems have been inefficiently administered and a national permitting The so-called “new” conservation paradigms that database does not exist. So for the hunting and include notions of: the well-heeled legal white hunter “wildlife” industry it is virtually a case of carte blanche. versus the illegal impoverished black “poacher;” the intense privatisation, and commodification of wild animals; and livelihoods and benefit-sharing, further Instead of a excluding and entrenching antagonistic views of, and alienation from, wild animals by local communities. The precautionary relationship between communities and wild animals is therefore fixed within the construct of “human-wildlife approach, conflict”, leading to loss of agency and exploitation of South Africa is both humans and wild animals. Private ownership is at the core of the “new conservation” facilitating the discourse and thus there is state-capital collusion and “State capture” by the hunting industry when it trophy hunting of comes to wild animals. The post-apartheid State has played a significant role in supporting and privileging wild animals from the privatisation of wild animals for profit by passing enabling legislation to assure private ownership of wild their protected areas animals, selling them off from national and provincial protected areas and parks at lower prices and poor through live sales institutional enforcement and corruption. This has made it complicit in the growth of the lucrative, unrestrained and by allowing and reprobate wildlife industry. hunting along the There is asymmetry and an ideological convergence between the State and the contentious wildlife Kruger National industry. This is particularly problematic given that it is about much more than mere issues of enforcement Park’s ever-increasing and regulation, it is about perverted states and power porous borders. 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

28 | A document prepared for CITES COP 17 EMS FOUNDATION is organising politically and using its muscle and have big horns and large tusks. The internet is littered resources to influence government policy, importantly with boasts of hunters from Europe and the USA in ways that exclude dissenting voices. who seem to get a perverse thrill from killing “Kruger animals,” from what they often offensively refer to as An example of this is the establishment of the Wildlife the “Dark Continent,” and sticking them on their walls Forum in 2005. It deliberately excludes labour, animal as symbols of domination and prowess. welfare and civil society stakeholders. “When asked why these stakeholders were absent, an industry So, on the one hand, SANParks says it goes totally member commented: ‘No, no, they are not real against their mandate and legislative regulations to stakeholders. They don’t own anything; it’s [that they allow hunting in the national parks, but on the other are] not hunters, not landowners’” (Snijders 178:2014). hand, they appear to be smoothing the way and encouraging trophy hunting and the killing of the very The Forum, which works hand-in-glove with Safari beings that are supposed to be under their protection. Club International, promotes a discourse alliance that endorses both government’s conservation interests Wild animals living in the Kruger National Park (where and industry’s development interests. Thus, in line hunting is not allowed) are moving across unfenced with neoliberalism, the development of “wildlife” boundaries on the Park’s western border into the policy in South Africa reveals a strong alliance Associated Private Nature Reserves (APNR) and on the between the state and capital (in this case the hunting Park’s Eastern border into Mozambique where they industry) by means of deregulation and public-private are commercially trophy hunted by foreign trophy partnerships. (Snijders 2014). hunters for exorbitant sums. The Protected Areas Act75 prohibits certain “extractive activities” in national THE ROLE OF NATIONAL AND PROVINCIAL PARKS parks, including hunting. Nonetheless, hunting is The African National Congress government, through taking place in the areas which share open boundaries SANParks, a Public Entity of the Department of with the Kruger National Park. Environmental Affairs, operates at a profit and generates 75% of its operating revenue.72 This includes Turning a Blind Eye: ‘Sustainable Use’ Policies revenue from the sale of “wild animals,” which from and Hunting in the Kruger National Park 2011 to 2014 amounted to R134,248,173.73 ‘Buffer Zones’ The Kruger National Park, South Africa’s premier In this same period the sale of rhinos made up the conservation area, shares it’s western, northern, and largest percentage: between January 2010 and June southern boundaries with a number of provincial and 2014, 354 rhinos were sold and 6 “given away” for private nature reserves. Many of these boundaries are R81,060,538.74 These figures exclude the number of unfenced and wild animals cross back and forth at will. rhinos (and profit made) by provincial conservation authorities. Thus, at the same time that rhinos are Hunting is permitted in some of the provincial and being killed at an accelerated rate, the State is not only private parks and animals crossing from the Kruger actively stimulating the trade in rhinos but making a National Park are sometimes killed by hunters. This profit as part of the bargain. issue has been hotly debated with some arguing that

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 TRADE AND TROPHY trophies but rather they should only be translocated in order to expand the range of the species. Instead of HUNTING HAS this precautionary approach. DRIVEN RHINOS IN SANParks appears to prefer to rather promote and actively facilitate the trophy hunting of wild animals AFRICA TO THE EDGE (which they supposedly hold in custody and care on behalf of all South Africans) not only through live sales OF EXTINCTION. but also by allowing hunting along the Kruger National Park’s ever-increasing porous borders.

Trophy hunters are salivating to kill individuals who originate from the Kruger National Park because they

EMS FOUNDATION A document prepared for CITES COP 17 | 29 hunting outfitters operating in these areas are simply pointed out the lack of capacity was evident in the few utilising the Park as a source area for target animals, rangers, their aging profile, the need to recruit skilled including elephant and buffalos. trackers, interpreters, specialised investigators and environmental management investigators and analysts. In addition number of reports and studies, as well as visits Some provincial reserves have also been the subject to a number of reserves by EMS Foundation researchers, of land claims and community groups have in some show that many of the provincial reserves have a shortage instances become embroiled in disputes over land of skilled staff, lack adequate financial resources and claims and even when land claims have been settled experience high levels of “poaching”. Compounding the (for example Mala Mala private reserve) many issues management issues is the fact that some of these parks remain unresolved. In some areas serious disputes have not been formally declared (gazetted). This hinders have developed over access to hunting rights. efficient management of these areas. In terms of South Africa’s wildlife management policies The provincial and private parks that form buffer these reserves are considered “buffer zones” which, zones along the Kruger National Park are important according to the 2013 Biodiversity Policy and Strategy conservation areas that play a key role in enhancing for South Africa: Strategy on Buffer Zones for National and supporting the conservation goals of the Park. Parks “includes the immediate setting of the national It is of critical importance that the various official park and attributes that are functionally important as a stakeholders act as a matter of urgency to improve support to the national park and its protection.” the management of provincial reserves and to ensure that private reserves are managed in an open and Despite the importance of these areas South Africa has transparent manner. Although they are privately been slow to resolve management issues and to co- owned they form part of the greater Kruger National ordinate management plans. In some private reserves Park, which means they form part of the Great Limpopo managers have to deal with both the SANParks and Transfrontier Park. provincial officials in the formulation management plans and hunting quotas. The Kruger National Park is managed by SANParks on behalf of the citizens of South Africa. The issue of hunting In the case of some provincial parks the situation is even in both provincial and private reserves also needs to be more cumbersome and provincial officials, SANParks the subject of public debate and consultation. Hunting and community representatives/or concessionaires are in these areas has a direct impact on the Kruger National sometimes all involved. In many instances there is a Park and is a matter of public concern. breakdown in communications between these parties resulting in weakened management processes. Minutes of a Department of Environmental Affairs Briefing to the Parliamentary Portfolio Committee Many of the provincial reserves are seen as a component on the Environment entitled “Provincial conservation of the Great Limpopo Transfrontier Park which is shared challenges and programs” held on 11 November 2014, by South Africa, Zimbabwe and Mozambique. recorded a wide range of problems facing provincial reserves. Many of these “challenges” remain unresolved. The situation in Mozambique is also of concern with a number of private reserves which border the These minutes state that the Department briefed the south eastern boundary of the Kruger National Park Committee on: “the support, resources, challenges and and which allow elephant, lion, buffalo and leopard constraints in relation to the provincial conservation hunting, In some areas animals from the Kruger authorities when implementing the conservation National Park regularly cross the border. mandate, particularly around the compliance and enforcement of biodiversity legislation.” The provincial reserves which share borders the Kruger National Park include: The Department told the meeting that “the • Makuleke Contractual Park, unfenced border, concurrent competence issue (environment and managed jointly between the concessionaire and nature conservation) between the national and the Kruger National Park. provincial departments did cause some complications”, • Makuya Nature Reserve, unfenced border, and it was “concerned to bring all role players managed by Limpopo Province. together to agree upon common priorities and • Letaba Ranch Nature Reserve, unfenced border, enforcement mechanisms.” managed by Limpopo Province. • Mthimkhulu Nature Reserve, unfenced border, The meeting also noted that “the main challenges to joint management between Limpopo Province and maintaining a stable biodiversity related to funding, the concessionaire. lack of capacity and operational issues. The basic • Manyaleti Game Reserve, unfenced border, allocations were inadequate and there was a need to managed by Mpumalanga Province. find a proper funding model and focus”. It was also • Andover Nature Reserve, fenced and shares

30 | A document prepared for CITES COP 17 EMS FOUNDATION boundaries with the Timbavati and Manyaleti Game • Contestations over land claims and hunting Reserves, both of which are open to the Kruger concessions. National Park, managed by Mpumalanga Province. • Illegal logging and mining within the reserve. • Mthethomusha Game Reserve, fenced border with the Kruger National Park, managed by Mpumalanga Past and current employees of the Kruger National Park Province. (names withheld at the request of the interviewees) • The Marietta Buffer area (which includes the confirm that Letaba Ranch, has for years prior to 1994, Mahumani, Ndindani, Mahlathi, Muyexe and been used for trophy hunting and the controls were lax. Mhinga areas, Kruger National Park boundary fence in place. The area is not formally included in the According to a former Kruger official with more than Kruger National Park or provincial reserves. 30 years’ experience “If you knew the right people in those days you could have done pretty much as Private reserves which share unfenced boundaries with you wanted...These days not too much has changed, the Kruger National Park include: it is still a case of who you know and good money is • The Associated Private Nature Reserves (APNR) paid. Lots of money changes hands…In recent years are privately owned and managed in consultation the hunting has been a closed shop but it is heavily with Kruger National Park. The APNR includes the contested now. Some of the local communities, not all, Timbavati, Klaserie, Umbabat and Balule Private want to start making money too, so the competition Nature Reserves. All share open boundaries with is getting hot.” the Kruger National Park. • Sabi Sands is privately owned and a draft agreement The official said that trophy hunters often waited for is in place with the Kruger National Park. elephants and buffalo move along the banks of the • Mala Mala (owned by successful land claimants Letaba River, and the Klein Letaba further north, to and privately managed) also shares an unfenced select a trophy. “Some of the elephant bulls … spend boundary with the Kruger National Park. lots of time in Kruger and make the mistake of crossing • Mjejane Private Game Reserve, unfenced border, an unmarked border with fatal results...There have also private management in agreement with local been cases of baiting of lions from Kruger here and communities. future north…In some instances hunting permits have been used several times over as few people check up Some of the provincial reserves have still not been on what is happening.” formally declared which has a direct impact on co- management of these areas. These include Letaba In November 2015 the Letaba Herald, a newspaper Ranch, Makuya and Mthimkhulu. based in the nearby town of Phalaborwa, reported that they had evidence of widespread corruption linked to Letaba Ranch hunting in Letaba Ranch. In a story headlined “Letaba The Letaba Ranch covers approximately 42,000 Ranch: a nest of corruption the newspaper said that “For hectares and incorporates the Mthimkhulu Nature decades rumours have been flying around regarding Reserve (6,349 hectares). Trophy hunting takes place illegal hunting and poaching in this reserve. What on at Letaba Ranch. It is run by the Limpopo provinces makes the illegal hunts even worse is that there is no LEDET Department (Limpopo Department Economic fence between Letaba ranch and the Kruger National Development, Environment and Tourism) and shares Park. In effect this means that KNP’s animals are being an unfenced boundary with the Kruger National Park. hunted illegally. Documents and sound recordings which have come into the Herald’s possession expose A 2013 five-year strategic management plan for Letaba a trail off illegalities in the hunting industry.” Ranch has also not been implemented because: • The reserve is not officially proclaimed as a nature The story then gives details of various people alleged reserve and therefore does not fall under the legal to be involved in dubious deals, including bribery, to protection of Protected Areas Act. secure hunting permits. This included hunting operators, • Ageing staff component and shortage of staff. wealthy people from Phalaborwa and factions within • Centralised budget, and de-capacitated reserve the local rural communities. The Herald story also states management. that various local communities are working against each • Lack of resources. other to get hunting rights. This involves disputes over • Lack of communication/co-operation between land claims and which groups have the rightful claim to management and stakeholders. some of the land in Letaba Ranch. • Very little scientific data available as a result of a lack of research and monitoring. The City Press newspaper also reported at the same • Ineffective management. time that a hunting concession holder was ejected • Hunting activities are not sustainable as it is not from the area because the community felt he had been backed by good scientific data. cheating them. The newspaper pointed out that a • “Poaching” is a serious problem in the reserve. number of people were involved in the dispute.

EMS FOUNDATION A document prepared for CITES COP 17 | 31 Makuya Nature Reserve (MNR) The unregulatable This reserve is also run by the Limpopo provinces LEDET Department (Limpopo Economic Development, cannot be regulated. 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 EMS Foundation has in its possession a variety of The Levubu River form the boundary between the documents which confirm the turmoil. A visit to area parks and animals regularly cross between the two, and interviews with a number of people involved in particularly in the dry season when the water levels the disputes also reveal that provincial authorities are low. are either powerless to resolve matters or actively involved in the infighting. “We see that many people Trophy hunting takes place in the reserve with make money from the place (Letaba Ranch) but we elephants, buffalo and antelope being targeted. An are always left out,” one man who lives on the border EMS Foundation researcher has watched elephants of the reserve told the EMS Foundation. “We are the and buffalo move to and from the Kruger National people who live here but the money goes elsewhere. Park. “Poaching” is also a serious problem. Who can blame people for poaching when all we want to do is get our share.” A draft management plan “Five year strategic management plan for the Makuya Nature Reserve, Conservationists working in the region report that Limpopo Province [2012]” also never been implemented the setting of snares for antelope and even buffalo is because, amongst other issues: common on Letaba Ranch. “You can go there at any • The reserve is not officially proclaimed as a time and find snares, particularly along the river,” a protected area. (This is still the case) ranger with 15 years’ experience in the region said. • The co-management agreement between the “There is also some hunting with dogs and illegal management of the MNR and the Kruger National shooting and nobody seems to report it or do much Park cannot be located and relations are sometimes about it”. strained. • The management authority is ineffective and He added that the illegal cutting down of trees was a incapacitated by internal political issues. common problem and that. “poaching” in Letaba Ranch • High levels of corruption in the government was poorly controlled. “The authorities seem to turn a institutions of the area impact on management. blind eye. Animals are snared or killed by dogs all the • There is a considerable conflict among communities time at Letaba ranch,” he said. that have a land stake in the reserve, particularly with regard to the division of reserve benefits. Newspaper reports record a number of major • Many of the MNR’s internal roads are only accessible “poaching” incidents in recent years. via 4x4 vehicles - this makes management difficult • In November 2015 when at least 22 white backed and increases wear and tear on equipment and vultures died after feeding on two poisoned buffalo vehicles. carcasses. The head and intestines of the vultures had • Water and electricity supply received from mining been removed for use in the traditional medicine. infrastructure on the reserve may end when mining • In 2012 at least two rhinos, one an endangered activities conclude. black rhino were shot for their horns. • Reserve staff has limited capacity. • In 2010 the remains of at least 17 rhinos, killed two or • Ageing staff complement. three years previously, were found at Letaba Ranch. • The management authority is ineffective and Conservation authorities could not explain how so incapacitated by internal political issues many rhino carcasses had remained undiscovered • Institutional financial constraints and a lack of a for so long. dedicated budget for the reserve as a cost • “Poaching” from surrounding communities. A mine has also been constructed within the reserve • High levels of corruption in the government but despite strenuous opposition was allowed to institutions of the area impact on management. continue working. • There is a considerable conflict among communities that have a land stake in the reserve, particularly From the above it can be seen management of the area with regard to the division of reserve benefits. is weak at best. It is clear that far from being a buffer zone that is ‘’functionally important as a support to According to the consultants employed to draft the national park and its protection.” Letaba Ranch the management plan (NCC),“the co-management (including Mthimkhulu) is anything but that. Rather it agreement between the management of the is a problem area that needs to be put right as a matter MNR and KNP cannot be located and relations are of urgency. sometimes strained”.

32 | A document prepared for CITES COP 17 EMS FOUNDATION Regular visits to Makuya by an EMS Foundation buffalo, leopard, rhino and other species have been researcher reveal that infrastructure is in poor hunted. This fact is carefully shielded from tourists condition. People in conservation and tourism projects visiting expensive tourist lodges in the area. The 1996 in the area report that “poaching” in the area have agreement makes no reference to commercial trophy increased in the past 18 months. “There is lots of hunting. snaring but I have seen spotlights at night and heard shots as poacher work along the river (which forms Many private landowners and some lodges owners the border with Kruger National Park),”he said (again and managers are opposed to hunting but have been he asked not to be identified for this report because outvoted by those who support the practice. There of potential repercussions.” Nobody in the park does has been widespread debate about hunting in these anything about it. They often don’t have fuel for their APNR with many arguing that animals from the Kruger vehicles and those are often broken-down too.” National Park, which SANParks looks after on behalf of the citizens of South Africa, are being killed. Makulele Contract Park Hunting was briefly permitted within the Makuleke Satellite tracking of elephants by researchers shows Contract Park run by the Makuleke community who that some bulls spend long periods in the Park. Buffalo, won a land claim in the 19 842 hectare ‘‘Pafuri Triangle’‘ lions and other animals or also known to cross the which runs from the Limpopo to the Luvuvhu River unmarked boundaries regularly. along the north eastern border of the Kruger National Park. Hunting commenced in 2000 and two elephants The money raised by trophy hunting is, according and two buffalo were killed by foreign hunters. The to representatives of the reserves that make up quota had increased to five elephants and seven the APNR, used for anti-poaching operations, local buffalo by 2003 but hunting was discontinued in favour community development and maintaining the of non-consumptive tourism. biodiversity of the APNR. Critics argue that the money is also used to boost the commercial operations and Manyaleti, Andover and Mthethomusha to reduce levies. They also argue that they invested Nature Reserves in the area as a Reserve where, as in the Kruger Manyaleti and Mthethomusha have both been the National Park, hunting should not be allowed and subject of land claims. The land claims on Manyaleti that while hunting earns much needed revenue have not been fully resolved and members of the funding for the maintenance of the reserves should be nearby communities are at loggerheads over who found elsewhere. should benefit from any development of the park. Local tour operators report snaring in the area and anti- The APNR has a high density of artificial and natural poaching specialists spoken to by the EMS Foundation water holes. This contrasts markedly to the Kruger say the park is often used by poachers entering or National Park where a large number of artificial exiting the Kruger National Park. water points have been closed. This makes the APNR particular attractive to water dependent large animals One tour operator, who previously worked for the such as elephant, buffalo and rhino. 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 WHEN IT COMES TO Associated Private Nature Reserves (APNR) The APNR consists of Timbavati, Balule, Klaserie and WILD ANIMALS THERE Umbabat. The removal of fences between the APNR and the Kruger National Park began in 1993. According IS “STATE CAPTURE” to a 1996 agreement the purpose of dropping the fences was according that “the premise and objective BY THE HUNTING of this agreement is the extension and creation of ecological unity between the APNR adjoining and INDUSTRY. proximate to the KNP and the KNP itself”.

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 APNR APPROVED HUNTING “QUOTAS”76 Elephant Buffalo Impala Zebra Kudu Lion White Rhino Hippo Leopard Waterbuck Giraffe Warthog

2009 55 144 5003 7 19 2 7 3 1 4 6

2015 30 153* 4720 1 27 1 1* 5 - 7 1 26

2016 33 223 46481 26 1 1* 3 - 9 1 23

*Please note that: • 20 buffalos erew 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 Appetite for profit seems to propel this industry and AFRICA’S CANNED LION INDUSTRY it fits comfortably within the current South African More than 9,100 lions have been killed in South Africa’s wildlife ideology of “sustainable use”, which is based canned lion hunting industry over the past fourteen on attaching an economic value to a sentient being. As years. Nearly all of the animals killed were raised in in the commercial farming of domestic animals, birth South Africa’s approximately 200 captive breeding rates are maximised at the lowest costs possible. In facilities and those intended as trophies were shot order to increase production of lions, an extra oestrus after being released on private land where they had no cycle is induced, as with farm animals, and the cubs are chance of escape. Some animals are also killed to the removed from their mothers and hand-reared in small lion bone trade in the Far East. cages. Male lions are sought-after trophies, and as a consequence are more profitable. Most of the female The South African government fully supports the industry cubs are therefore killed. as a form of “sustainable use of natural resources” despite widespread opposition to the practice which The hunting of captive raised lions in South Africa, is considered cruel, killing for fun and run by operators although an activity that had been taking place for purely for financial gain. decades, first drew international attention after the release of the Cook Report in 1997, which exposed Canned hunting is the ‘put and take’ practice of offering canned lion practices in South Africa. As a consequence a captive, and often tame, animal, which usually has there was huge public outcry about canned hunting nowhere to run, commonly to a rich overseas trophy and its damaging ethical, ecological and biological hunter who wants to mount its head on a wall. The animals implications. South African public opinion favours an used for canned hunts in South Africa include indigenous outright ban of this industry. and exotic cats (such as Bengal tigers and jaguars).

34 | A document prepared for CITES COP 17 EMS FOUNDATION The general public, both locally and internationally, sustainable utilisation of natural resources. This applies cannot be criticised for thinking that canned hunting to the export of lion bone and skeletons too. in South African is a thing of the past. But nothing can be further from the truth. Far from being controlled, At least 9,147 lions were killed in the canned lion industry the canned hunting industry, with active support from between 2003 and 2015. Figures sourced from Lion most of the provincial governments, is growing. It is Aid (www.lionaid.org ) show that from 2003 and 2013 not only confined to the hunting of large predators - some 7,487 lion trophies were exported from South elephants, rhinos, buffaloes and antelope species are Africa. CITES records show that a further 1,150 trophies also hunted and killed in this way. were exported in 2014. Figures provided by North West province’s Department of Rural Environment and About 6,000 lions are held in captive breeding facilities Agricultural Development, in answer to questions from in the country and about 3,100 wild lions, most the EMS Foundation, show that a further 510 permits occurring in the Kruger National Park and surrounding were issued in 2015. reserves as well as the Kgalagadi Transfrontier Reserve (about 2,300 lions occur in these two populations). According to these statistics South Africa kills five times About 800 lions have been introduced to 45 smaller more lions than Tanzania, the next largest exporter of lion reserves over the past three decades.77 It is estimated trophies. (South Africa differs from all other lion hunting that the lion populations across Africa has dropped countries in that more than 99% of the lions killed are by about 43% over the past 21 years and only about captive raised and very few wild lions are hunted). 20,000 remain. With the exception of South Africa all the figures below The captive breeding of large numbers of lions is of no refer to wild lions. Source: http://lionalert.org/ conservation value and has also led to inbreeding and consequent genetic defects. Although most captive Country Exported Lion Trophies 2003-2013 breeding facilities were started with the sole intention South Africa 7487 of providing animals to be shot as trophies or for other forms of entertainment, in the mid-2000s the industry Tanzania 1408 expanded into supplying the lion bone trade to the Far East where the bones are used for medicinal purposes.78 Zimbabwe 688

”You can make as much money as you like”: Zambia 635 Lion Hunting in South Africa Mozambique 219 Most wild lions live National Parks or provincial reserves where trophy hunting is not allowed and consequently Namibia 185 vast majority of lions that are killed are captive raised animals placed on private land. Inadequate Lion Hunting Statistics In 2007 the then Department of Environmental Affairs South African record keeping with regard to lion and Tourism (now the Department of Environmental hunting is poor. Hunting permits are issued by the Affairs) attempted to impose new regulations which provinces and details are meant to be submitted to would have closed down much of the canned hunting officials in Pretoria who compile CITES reports but industry but these were rejected by the courts after reports are often incomplete or inaccurate, failing legal action by the South African Predator Breeders regularly noted by researchers. Association. According to a 2015 Joint WILDCRU and TRAFFIC Report, The Department of Environmental Affairs has taken no “…when one compares the number of Lions hunted action against the industry despite the former Minister (indicated by the hunting register) with the number of Marthinus van Schalkwyk calling the practice of canned trophies exported (indicated by CITES permits) between hunting a “cancer” which had to be stopped. “We are 2004 and 2010, there is a large discrepancy in that 1,138 putting an end, once and for all, to the reprehensible more trophies were apparently exported than Lions practice of canned lion hunting,” the minister told hunted…There may be various legitimate reasons for reporters in 2007. “South Africa has a long-standing this discrepancy, but ultimately the accuracy of the reputation as a global leader on conservation issue. We hunting register is called into question.”80 cannot allow our achievements to be undermined by rogue practices such as canned hunting.”79 Captive Breeding of Lions The captive breeding of lions commenced in earnest This view appears to have been abandoned by in the 1990s and by 1999 there were about 1000 subsequent Ministers who have promoted the hunting lions in breeding centres. This has now swelled of captive raised predators as an acceptable form of to over 6,000.81 Although the numbers of lions in

EMS FOUNDATION A document prepared for CITES COP 17 | 35 captivity far outnumber wild lions they serve little source cubs from breeders. Tourists are unaware of the or no conservation purpose. According to the Bones fate of the cubs once they grow to a size suitable for of Contention Report “The prevailing view amongst hunting and the practice has been widely opposed as carnivore specialists is that captive-bred Lions do being unethical. not contribute to the conservation of the species, especially for population restoration purposes, since “The captive keeping and breeding of carnivores inbreeding is known to occur and thus compromises for touch programmes does not contribute to genetic integrity and provenance.” conservation, presents serious ethical and welfare issues, and is routinely linked to exploitation and Other carnivores such as tigers, leopards, cheetahs and canned hunting“, the Endangered Wildlife Trust, one of wild dogs are also kept at many of the lion breeding South Africa’s largest wildlife NGOs states in its position facilities and exported to breeders and private zoos on the issue.83 locally, where there fate is unknown. Although this is of major concern, permits are still regularly issued for South Africa’s Support for the Lion the export of these animals. Bone Trade South Africa began issuing lion bone export permits in The breeding of large numbers of lions has significant 2008 and from the outset, as with much other record welfare issues and although were raised by a number of keeping relating to wildlife, mistakes were made in the South African NGOs as long ago as March 2009 - these permit as to the quantity and destination. have yet to be addressed by Government. A National Council of SPCA Report, Lions in Captivity and Lion According to the Bones of Contention Report, “In July Hunting in South Africa – an update,82 called for urgent 2008 South Africa issued its first permit to export action to be taken against the industry and expressed Lion skeletons obtained from captive bred animals concerns about, amongst other issues: to Southeast Asia…The destination of the cargo was • The quality of life of the animals while they are mistakenly recorded as Vietnam instead of Lao PDR growing to a size suitable for shooting. (Lao People’s Democratic Republic) and the quantity • The quality of life of lions kept in enclosures as recorded as 35 Lion “bones” instead of the “bones of 35 tourist attractions. Lions…Another permit issued in 2008 authorised the • The fate of animals not suitable for hunting. export of 50 skeletons and by 2011 permits for at least • The practice of removing cubs from their mothers 573 skeletons were issued. while very young in order to trigger oestrous in the adult female so she can breed again as soon as The Bones of Contention Report shows that between possible. 2008 and 2011 CITES permits were granted for the • The use of growth stimulants and genetic exportation of 1,160 skeletons which the researchers manipulation to try and increase the size of calculated would weigh in the region of 10.8 metric captive lions. tons. “Lao PDR was the primary recipient of the bones • The manner in which animals fed to the lions (85%), followed by Vietnam (13%)…Permits issued are killed. to Thailand and China were only reported in 2011…If the mean mass of a Lion skeleton is ± 9.28 kg then the Some breeding facilities also offer tourists the exports are equivalent to 10,765 kg – over 10.8 tons in opportunity to “pet” cubs and petting farms sometimes four years”.84

36 | A document prepared for CITES COP 17 EMS FOUNDATION There is also concern that the lion bone trade is being While Africa’s wild used to launder Tiger bones into the medicinal market. A number of lion breeders in South Africa also breed animals are becoming Tigers and there is concern that Tiger bones from South Africa may be laundered as Lion bones using extinct in their CITES Appendix II (instead of Appendix I) permits. The Bones of Contention Report has argued, “Limitations in natural habitats, on the South African legislation applying to endangered exotic animals have made it possible for an unregulated the other hand, in domestic trade in Tigers”. South Africa, they are CITES Cop 17 and South Africa’s Position on Lions being commercially Canned lion hunting will be an important issue at COP 17 with nine African proposing that lions require bred purely for the further protection and should be removed from CITES Appendix II and placed on CITES Appendix I. purposes of killing These countries , Chad, Côte d’Ivoire, Gabon, Guinea, and naked profit. 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.

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 Captive breeding and canned lion hunting is or registered facilities whose document mandate is a undertaken purely for profit, the self-gratification of recognised, registered conservation process,”. Adding those who kill the animals, and has no conservation that, South Africa should also “legally prohibit the value. EMS strongly believes that the mass breeding hunting of captive bred lions under any conditions.”85 of lions, the shooting of captive raised lions and the exports of lion bones should be prohibited. In response, South Africa’s Department of Environmental Affairs said that “while South Africa does not support The South African government actively approved some of the aspects of this motion it will however the breeding and subsequent hunting of lions as consider the implications associated with this motion”. well as the export of bones, again, as it has in supporting Their press release added that, ”South Africa, cautions trade in ivory, elevating profit making above against assumptions that the adoption of this motion conservation or ethics. will result in the shutting down of facilities. As is known, biodiversity contributes to the achievement In supporting the breeding of lions for hunting South of Sustainable Development Goals (SDGs). Existing Africa has also created major welfare crises for the legislative tools and frameworks therefore regulate this more than 6,000 lions held in captivity and should act sector including the aspects of captive keeping and urgently to end what it once officially referred to as to hunting of lion in South Africa in a manner that ensures “the reprehensible practice of canned lion hunting”. a balanced approach to its overriding developmental priorities and challenges.”86

EMS FOUNDATION A document prepared for CITES COP 17 | 37 CONCLUDING REMARKS South Africa’s official instrumentalist approach to practices are rooted in respect and consideration for conservation of “sustainable and consumptive use” the welfare of the wild animals under their protection is not only contradictory but it is bound to fail. In this and custodianship. interpretation, wild animals only matter to the extent that they are useful to humans, and conservation is only about Treating living animals as commodities and ensuring there will be wild animals in the future so they “consumptive use” practices such as trophy hunting can be exploited for profit. This view will not convince which promotes and sanctions violence against highly people that wild animals should be conserved.87 Instead sentient creatures essentially accepts and normalises what it is doing is: deliberately positioning people against violence more generally in society. Disrespect towards them; not benefitting livelihoods; ensuring massive nonhuman animals cannot be neatly pigeonholed, it is suffering; and leading to extirpation. part of a continuum of other human behaviours.

One cannot conserve species without respecting In South Africa, research is showing that the hunting the individuals who comprise those species. By this industry continues to maintain highly racialized and approach the species will always be protected and discriminatory practices and perpetuate apartheid-era preserved. South Africa’s, and Africa’s, rich wild life property and land relations. These findings show that heritage is imperilled unless they move away from their there is an intimate relationship between disrespectful current interpretation of “sustainable use”. Instead, treatment of wild animals and similar behaviour they need to ensure that their conservation policies and towards humans.88 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 REFERENCES Brandt, F. and Spierenburg, M. (2014). “Game Fences in the Karoo: Reconfiguring Spatial and Social Relations”. Journal of Contemporary African Society, 32:2, 1-18.

Cruise, A. (2016). “The effects of trophy hunting on five of Africa’s iconic wild animal populations in six countries”. http:// conservationaction.co.za/resources/reports/effects-trophy-hunting-five-africas-iconic-wild-animal- populationssix-countries-analysis/

Commission to the European Parliament, The Council, The European Economic and Social Committee and the Committee of the Regions. (2016). “European Union Action Plan Against Wildlife Trafficking”. https://ec.europa. eu/transparency/regdoc/rep/1/2016/EN/1-2016-87-EN-F1-1.PDF

Hübschle, AM. (2016). “A Game of Horns Transnational Flows of Rhino Horn”. Phd. IMPRS-SPCE, http://imprs.mpifg.de

Hübschle AM., (2014). “Of bogus hunters, queenpins and mules: the varied roles of women in transnational organized crime in Southern Africa”. Trends in Organized Crime, 17:31–51.

Humphreys, J. and Smith MLR. (2014). “The ‘rhinofication’ of South African security”. International Affairs 90: 4, 795-818.

Mkhize, N. (2014). “Game Farm Conversions and the Land Question: Unpacking Present Contradictions and Historical Continuities in Farm Dwellers’ Tenure Insecurity in Cradock”. Journal of Contemporary African Society, 32:2, 207-219.

Nadal, A. and Aguayo, F. (2014) “Leonardo’s Sailors. A Review of the Economic Analysis of Wildlife Trade”. LCSV Working Paper Series No.6. The Leverhulme Centre for the Study of Value, School of Environment, Education and Development, University of Manchester.

Nellemann, C., Henriksen, R., Kreilhuber, A., Stewart, D., Kotsovou, M., Raxter, P., Mrema, E., and Barrat, S. (Eds). (2016). “The Rise of Environmental Crime – A Growing Threat to Natural Resources Peace, Development and Security”. A UNEP-INTERPOL Rapid Response Assessment. United Nations Environment Programme and RHIPTO Rapid Response–Norwegian Center for Global Analyses, www.rhipto.org

Russo, A. (2015). “The prevalence of documentation discrepancies in CITES (Convention on the International Trade in Endangered Species of Wild Fauna and Flora) trade data for Appendix I and II species exported out of Africa between the years 2003 and 2012”.. Thesis. Percy FitzPatrick Institute of African Ornithology, University of Cape Town.

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EMS FOUNDATION A document prepared for CITES COP 17 | 39 ENDNOTES 1 Rademeyer, J. SA pushes for legal trade in rhino horn‘ Mail & Guardian, 22 March 2013. 2 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 Sas- rolfes (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_poach- ing_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/2015- 02-10-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-rhino- farmer-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-own- ers/#.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 31 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. 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-no- victory-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/killing- trophies-report-analyzes-trophy-hunting-around-world

40 | A document prepared for CITES COP 17 EMS FOUNDATION 44 https://cmsdata.iucn.org/downloads/2010_tz_plan_final.pdf 45 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-11e6- 96c0-37533479f3f5_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-populations- of-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. Ac- cessed 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 80 William, V., Newton, D., Loveridge, A. and Macdonald, D. 2015. Bones of contention: An assessment of the South African Trade in lion, 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-captive- breeding-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).

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