Kruger National Park Stakeholder Participation Report

The

Kruger

National

Park

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MANAGEME

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NATIONAL

Stakeholder participation KRUGER report

2018

Table of contents

No. Index Page Prelude 4 Executive summary 5 1 Introduction 6

2 Stakeholder participation strategy 6

2.1 Stakeholder engagement objectives 6 2.2 Approach 6 3 Stakeholder engagement process 7 4 Stakeholder identification, registration and meetings 8

4.1 Media platforms used to invite stakeholders to register and participate 10

4.2 Documentation dissemination 12 4.3 Public information sessions on Draft Management Plan 13 5 Stakeholder comments / inputs 30

Figures Description Page 1 The KNP Management Plan review process, as was presented to 7 stakeholders. 2 The role of the desired state process within the broader context of the 13 relationship between SANParks and public interests. 3 Public meetings were held in 11 localities within the immediate KNP 14 vicinity for both the “desired state” and draft Management Plan presentations and 4 in main metros (not shown).

4 The adaptive planning process as presented at meetings, leading to the 15

articulation of the desired state. The vision is informed by the operating

principles and values, the context within which the Park is nested, and

its vital attributes. Together, these form the basis for the articulation of

high level objectives for the Park.

5 Summary of the key issues identified during the desired state 15 workshops, clustered into key themes and high-level objectives. 6 Graph of the key issues identified (more than 25 mentions) during the 16 Desired state workshops. 7 Graph of the issues identified (less than 25 mentions) during the Desired 20 state workshops. 8 Graph of the issues identified during the public meeting workshops. 26

9 Word cloud of main themes and related issues, as discussed during the 176

Staff information sessions, desired state phase (2017).

10 Word cloud of the Vital attributes, as discussed during the Staff 177 information sessions, Desired State phase (2017).

Tables Description Page 1 The various organisations that were identified to participate in the Park 9 management plan process. The government departments are at national, provincial and local level. The intention is to illustrate SANParks’ commitment in terms of the spirit of co-operative governance. 2 The various media platforms used to inform stakeholders of the revision 11 of desired state public meetings (2017) and the draft KNP Management Plan presentation (2018).

Tables Description Page

3 Public venues where members of the public could view the draft Park 12 Management Plan. 4 Desired state workshops attendance. 13 5 A brief description of the issues raised during the Desired state 16 workshops, for issues mentioned more than 25 times. 6 A brief description of the issues raised during the Desired state 21 workshops, for issues mentioned less than 25 times.

7 A summary of the focus/interest group meetings where inputs into the 24

draft Management Plan were received/presented throughout the review

process.

8 A broad summary of inputs received on the KNP draft Management Plan, 25 categorised according to broad themes, very often overlapping between the respective KNP Management Plan sections/themes. 483 inputs were received (public meetings and written inputs). 9 A broad summary of inputs received on the KNP draft Management Plan, 27 categorised according to broad themes, very often overlapping between

the respective KNP Management Plan sections/themes. 483 inputs were received (public meetings and written inputs). 10 Register of inputs received during the draft KNP Management Plan public 30

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meetings (February 2018), showing comments per relevant KNP N Management Plan section.

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An Acronymn list is caputed in the KNP Management Plan –

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Prelude

This report is the accompanying stakeholder participation report to the revised Park management plan of the Kruger National Park (KNP).

The report includes the comments received from stakeholders during the “Desired State” public participation phase (April – May 2017), and on the draft Park management plan released for public comment on 30 January 2018.

This report is submitted with the revised KNP Management Plan to the Department of Environmental Affairs (DEA) for technical review.

EXECUTIVE SUMMARY

In compliance with National Environmental Management: Protected Areas Act (Act No. 57 of 2003) (NEM: PAA), SANParks has initiated a process to revise the KNP Management Plan.

The management plan was formulated over a period of 12 months following extensive consultation through 54 public and focus group meetings with the public and with interested groups. The management plan will guide the Park’s strategic direction and operations in relation to broader regional land use for the next ten years. The management plan has been aligned with national and international legislation and agreements. The plan furthermore seeks alignment with the National Development Plan and the Ministerial Delivery Outcomes.

A total of 3,465 stakeholders participated in the desired state meeting (2017), which provided the strategic direction for the KNP for the next 10 years. A total of 2,297 stakeholders attended the second round of public meetings (2018), during which the draft management plan was presented. 483 inputs were received during the meetings and in written format.

Issues raised by the public during development of the plan include, but are not limited to, job creation, business partnerships, opportunities to participate in the wildlife economy and tourism, better communication and feedback, the state of basic services, crime and its impact, damage-causing

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animals, increased community access to the Park, increased environmental education and awareness N programmes, opportunities for inclusion, partnerships with Mozambique and Zimbabwe, concerns about the impact of commercial developments on wilderness areas, and clarification on resource use

The KNP Management Plan will be guided by eight high-level objectives and operationalised through

30 implementation plans. The plan will focus on various programmes such as regional integration with MANAGEME

other sectors and land uses, socio-economic development such as the Land Claimant and Wildlife –

Economy Programmes, Tourism, Cultural Heritage, Stakeholder Engagement, Wilderness, and Effective Park Management. The latter will focus on financial sustainability, safety and security, human wildlife conflict management, human capital management and research programmes. PARK

The Park recognises that a holistic approach is required to ensure strategic alignment, sustainability and transformation of the conservation sector, in line with the SANParks Vision: “A sustainable National Park System connecting society”. Implementation will therefore require a multi-institutional and

NATIONAL sectoral approach that engenders co-operation and collaboration with a range of sectors, communities and strategic partners within the fields of environmental management, rural development and livelihoods, food security and land reform, local government and human settlements, safety and security, education and health, spatial planning and infrastructure development. KRUGER

Introduction

1. Background

Section 39(3) of NEM: PAA stipulates that all persons who may be interested or affected by a management plan for a protected area be given the opportunity to participate in, or comment on the plan. Section 41(2e) of NEM: PAA states that a management plan for a protected area must contain at least procedures for public participation, including participation by the owner (if applicable), any local community or other interested party.

The stakeholder engagement strategy was developed in line with the requirements of SANParks guidelines for stakeholder engagement and Chapter 5 of the National Environmental Management Act No. 107 of 1998 (NEMA).

SANParks follows the adaptive planning process that involves stakeholder participation as an integral part of the revision of the management plan for any National Park. The commitment to the incorporation of public opinion into park management is rooted in the recognition that (a) parks must serve a conservation-oriented subset of societal values and that (b) parks are inevitably situated within a broader landscape and context, which it influences and is influenced by.

The parks’ management activities are therefore geared towards promoting conservation values (and society’s connection with those values) and promoting this goal, in part, by engaging the broader context in which the park is situated. The adaptive planning process that was followed was designed to (a) help stakeholders express opinions and values in a structured way, (b) to use the opinions and expressed values to revise the existing mission for KNP, and (c) to translate the mission into management objectives and implementation plans that reflect the values as expressed by stakeholders.

This report is submitted as a record of the formal comments received from stakeholders on the draft KNP Management Plan. This includes a summary of the ‘desired state’ public meetings’ feedback, summary of focus group meetings’ feedback, the draft management plan public meetings’ responses, and written responses received.

2. Stakeholder participation strategy

2.1 Stakeholder engagement objectives

The objectives of the stakeholder participation process are to:

 Create a channel for the accurate and timely dissemination of information to interested and affected stakeholders;  Create the opportunity for communication between SANParks and the public;  Promote opportunities for the building of understanding between different parties;  Provide the opportunity for stakeholders to give meaningful input into the decision-making processes that drive the development of the Park Management Plan.

2.2 Approach

The approach to the stakeholder participation process is based on the principles embodied in the following legal framework:

 The Constitution of the Republic of South Africa Act No. 108 of 1996;  The NEMA; and  The NEM: PAA as amended by the National Environmental Management: Protected Areas Act No.31 of 2004, Act No. 15 of 2009 and Act 21 of 2014.

In addition to the above legal framework, the stakeholder process was developed with the Guiding Principles for SANParks stakeholder participation as a basis. SANParks thus undertakes to:

 Seek to notify stakeholders of participation processes through appropriate mechanisms;  Ensure that the process provides the opportunity for input from all stakeholders within reasonable timeframes, emphasising the sharing of information, joint learning and capacity building;  Promote participation by stakeholders through timeous and full disclosure of all relevant and appropriate information;  Provide feedback on the outcome of the process to stakeholders and demonstrate how their inputs have been considered in the decision-making process;  Ensure that methodologies accommodate the context of the issue at hand and the availability of resources (people, time, money) and do not conflict with these guiding principles; and  Give particular attention to ensuring participation by marginalised communities, communities with specific concerns, or communities that have contractual rights in the National Park.

3. The stakeholder engagement process

The stakeholder engagement process took the form of a wide-reaching open process where comments and / or input on the draft sections were collected, considered and responded to. The ‘call for comments’ to participate and comment on the draft sections was advertised in national and local newspapers, on the SANParks website, at local government and Traditional Authority offices. Email invites were also

distributed to organisations and parties listed within the database (see portfolio of evidence). At the public T PLAN information sessions, stakeholders were given a chance to directly interact with park management. N

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Figure 1. The KNP Management Plan review process, as was presented to stakeholders.

4. Stakeholder identification, registration and meetings

An initial stakeholder profiling process was used to list and classify stakeholders according to guiding principles in various categories, requiring different engagement approaches during the review of the KNP Management Plan (KNP Stakeholder Engagement Plan, 2017). The KNP Stakeholder Engagement Plan provides a means of describing a broader, more inclusive and continuous engagement process between the Park and those potentially impacted, affected and having an interest in the business and development of the Park. This process takes the circumstances and needs of KNP into account, enables informed decision making sensitive to stakeholder needs and values, while ensuring that the legislative requirements are met.

The stakeholder engagement and associated communication process is summarised as follows:

1. Identify the stakeholders (WHO)

Why are they important? What do they care about?

2.1 Stakeholder analysis / profiles

What are the guiding principles to "Power"/importance pertaining to What are their interest/main themes? "categorise" stakeholders? management issues?

2.2 This informs the following with the Stakeholder profiling proDcess Stakeholder Deparment"leading" Stakeholder profile Stakeholder map Stakeholder register influence/interest stakeholder groups

3. Stakeholder profile

Strategic Partner Focus group General stakeholder

4. Planning the engagements (HOW, WHEN) Communications Plan: Who leads Range of invites within structured enagement, when, key messages, Key messages for respective groups process and channels

5. Engaging stakeholders (DO) General Feedback on Stakeholders kept "Desired state" Key thematic issues engagement specific issues informed

6. Measuring effectiveness (Results/Impact)

How well are we engaging? What difference does engagement make?

7. Have the stakeholders changed? Does the stakeholder and communication plans require revising?

Review stakeholder analysis and Review stakeholder groups profiles Review communications plan

To agree on the desired state, stakeholders were invited to register and attend public meetings (2017) within 11 areas adjacent to the KNP and within four key metros. Invites were mainly advertised in national and local newspapers, through the internet, via email invites, through radio and through targeted focus groups to specific forums/organisations. Stakeholders were then invited to provide inputs into the draft KNP Management Plan during the February 2018 public meetings held in the same 15 localities as the

desired state public meetings. Continuous engagement with thematic focus groups also took place on an T PLAN ongoing basis during the review of the KNP Management Plan. N

Stakeholders from the following types of institutions were invited to attend:

Local government; district municipalities; provincial government; national government; international

MANAGEME government; traditional authorities; Park Forum; community forums; visitors to the park; local

– residents/neighbours – including landowners, communities/land rights holders; organised agriculture; land claimants; community based organisations; local business; business associations; media; researchers; GLTP-GLTFCA; education institutions; conservation organisations; NGOs; tourism associations; tour operators; water committees; SANParks Honorary Rangers; conservation and protected area PARK representatives; UNESCO Man and Biosphere: Kruger to Canyons (K2C) and Vhembe Biospheres; Wild Card holders, thematic focus/interest groups and the KNP staff (see Table 1).

Table 1. The various organisations that were identified to participate in the Park Management Plan

NATIONAL process, inclusive of government departments at national, provincial and local level. The intention is to illustrate SANParks’ commitment in terms of the spirit of co-operative governance.

International Great Limpopo Transfrontier Conservation Area Joint Management Board,

KRUGER Administraçăo Nacional das Ȧreas de Conservaçăo National government / institutions Departments of Environmental Affairs; Agriculture, Forestry and Fisheries; Water and Sanitation; South African National Defence Force; South African Police Service; South African National Biodiversity Institute; South African Heritage Resources Agency Provincial government Mpumalanga and Limpopo Departments of Health; Social Development; Finance; Home Affairs; Sports Arts and Culture; Education; Agriculture and Rural Development and Land Administration; Agriculture, Forestry and Fisheries; Water and Sanitation; Co-operative Governance and Traditional Affairs Provincial conservation authorities Mpumalanga Tourism and Parks Agency, Limpopo Department of Economic Development, Environment & Tourism District government Ehlanzeni District Municipality, Mopani District Municipality, Vhembe District Municipality Local government Mbombela Municipality, Nkomazi Municipality, Greater Giyani Municipality, Bushbuckridge Municipality, Ba-Phalaborwa Municipality, Thulamela Municipality, Collins Chabane Municipality, Musina Municipality Community fora Hlanganani, Lubambiswano, Mahlambandlopfu, Makuya, Nkomazi, Ntirhisano, Phalaborwa Traditional authorities All traditional authorities bordering the Park

Land claimants Land claimants as per National Land Claims Commissioner settlement process Local resident Rural communities, conservation areas, agricultural sector, river fora, /neighbours/businesses biospheres, concessions, tourism sector, local business, Chamber of Commerce, business associations, environmental consultants, taxi associations Broader sector partners Forestry: SAPPI, York, Komatiland, Inkomati Usuthu Catchment Management Agency; Mining: Foskor, Ba-Phalaborwa complex (including Palabora Mining Company); Rand Water; Irrigation Boards Community based organisations Womens’ groups, Mothers’ Union, stokvels, youth groups Media Print and electronic media at local and national level including social media NGOs general Endangered Wildlife Trust, Earthlife Africa, Wildlife and Environment Society of South Africa, SANParks support group, World Wide Fund for Nature, Kruger2Canyons, Conservation South Africa, Vhembe Biosphere, Association and Water and Rural Development, Greater Kruger Environmental Protection Forum, South African Institute for Aquatic Biodiversity, Birdlife SA, Conservation Outcomes Conservation areas bordering KNP Mjejane, Marloth Park, Mala Mala, Sabi Sand Wildtuin, Manyeleti (MTPA), Association of Private Nature Reserves (Timbavati, Balule, Umbabat, Klaserie), Kapama, Thornybush, Selati, Letaba Ranch complex (LEDET), Makuya (LEDET), Makuleke Contractual Park, Limpopo National Park, Greater Limpopo Conservancy Lifestyle estates bordering the Park Sabie Park (western boundary), Elephant Point, Lisbon, Leopard Creek, Selonque etc. Research and tertiary institutions Savanna Network Research database - local and international research partners; all major universities and other tertiary institutions in SA, and entities such as South African Wildlife College, Wits Rural Facility, South African Environmental Observation Network, Agricultural Research Council, University of Pretoria, Hans Hoheisen Wildlife Research Station Tourist associations SATSA, Lowveld Tourism, MISA Tour operators Untamed, Siyabona Travels, Thomson Indaba, Safaris Direct, Elephant Herd, Sefapane Lodge, Open Safari Vehicle operators Staff Information sessions across all KNP regions with all departments SANParks support groups SANParks Honorary Rangers Visitors to the KNP Wildcard holders, broader public invited to public meetings Key Focus / Interest groups (these  Conservation Areas open and adjacent to KNP are groups that have been  GLTFCA specifically approached for  Technical Focus Groups specialised input)  Water River Fora / Committees  Savanna Network Meeting and Research Institutions  Animal Health  Tourism fora (Mpumalanga Independent Safari Association, South African Tourism Services Association, Lowveld Tourism)  Safety and security clusters: National Joint Operational and Intelligence Structure (NATJOINTS), Limpopo and Mpumalanga Provincial Commissioners, Mozambique Security cluster  Mpumalanga House of Traditional Leaders  Limpopo House of Traditional Leaders

4.1 Media platforms used to invite stakeholders to register and participate

A range of media platforms (Table 2) were used to engage stakeholders to inform them of the revision of the Park Management Plan and to invite stakeholders to participate in the desired state meetings (2017) and the draft KNP Management Plan public meetings.

Table 2. The various media platforms used to inform stakeholders of the revision of desired state public meetings (2017) and the draft KNP Management Plan presentation (2018). Media Description 1. Direct e-mail All the stakeholders that were registered during the 2008 management plan development were informed about the revision process. Emails were sent to all stakeholders/organisation representatives captured in the updated KNP stakeholder database (updated in 2016/2017/2018) covering all functionalities. Focus/interest group and other stakeholder representatives of strategic partners/organisations were personally invited to attend the public sessions as well as thematic discussion groups. 2. National media Advertisements to inform interested and affected parties to attend and advertisements comment on the draft Park Management Plan were placed in the following national newspapers/media:

Desired state meetings, 2017:  Media 24/City press: 26/05/2017, 27/05/2017, 8/05/2017  Sunday Times: 26/03/2017  Business Times: 14/05/2017  Independent Newspaper 29/05/2017, 31/05/2017, 02/06/2017

Draft KNP Management Plan meetings, 2018:  Media 24: 28/01/2018 (City Press)  Sunday Times, Rapport

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 Traveller24: 02/02/2018 N 3. Local media advertisements An English advert was placed in the following local newspapers (direct placements, as well as shared in other media):

Desired state meetings, 2017:  News Horn: 12/04/2018

MANAGEME  Lowveld Media: 26/05/2017

–  Phalaborwa Herald: 28/04/2017  Kruger 2 Canyons: 05/05/2017

Draft KNP Management Plan meetings, 2018: PARK  Lowvelder: 30/01/2018  Media 24: 28/01/2018  Phalaborwa Herald: 01/02/2018  Limpopo Mirror: 02/02/2018

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4. Internet Stakeholders were able to access the SANParks website to gain information regarding the revision process.

Stakeholder were also invited to the public meetings through adverts (and

further shared by the media) on the following online media sites: KRUGER  Travel 24: – 15 /05/2017  Africa Geographic: 15/05/2017  Eyethu News: 10/04/2017  Overport Rising Sun: 10/04/2017  Estcourt & Midlands News: 10/04/2017  GPS News: 11/04/2017; 16/05/2017  Northern Natal Courier: 10/04/2017 5. Radio Stakeholders were informed about public meetings through national and local radio stations.

Desired state meetings:  SAFM: 24/05/2017  Rise FM: 10/04/2017

Draft KNP Management Plan:  SABC news – 02/02/2018  Bushbuckridge FM: 06/02/2018  RSG: 06/02/2018  Talk Radio 702: 06/02/2018  Mala FM : 08/02/2018  Giyani FM : 08/02/2018  Univen FM : 09/02/2018

Media Description 5. Radio Draft KNP Management Plan:  Phalaborwa FM : 09/02/2018  SABC: 12/02/2018  RFM : 15/02/2018  SABC SA FM : 15/02/2018

General  Talk Radio 702  RSG  Munghana Lonene FM  Ligwalagwala FM 6. Registration at meetings Participants were also able to register at the desired state workshops and the draft Park Management Plan meetings: 7. Public information Official invites were sent out and notices placed at Traditional Authority notices/offices offices and at local municipalities (see detailed list attached) 8. Invites to Focus/Interest Official invites were sent to members of the following Focus/Interest groups Groups:  Conservation Areas open and adjacent to KNP  GLTFCA  Technical Focus Groups  Water River Fora / Committees  Savanna Network Meeting and Research Institutions  Animal Health  Tourism fora (MISA, SATSA, Lowveld Tourism)  Safety and security clusters: NATJOINTS, Limpopo and Mpumalanga Provincial Commissioners, Mozambique Security cluster  Mpumalanga House of Traditional leaders  Limpopo House of Traditional leaders

4.2 Documentation dissemination

The draft Park Management Plan was made available at public venues such as Traditional Authority offices and Local Municipal Offices as listed in Table 2.

Table 3. Public venues where members of the public could view the draft Park Management Plan.

Item Action Date Draft document for January and Refer to Table 10 for a summary of the inputs that were comment – copies given to February 2018 received. Feedback will also be given to each all Traditional Authorities community forum, based on the comments received at and Local Government that area. office Draft document for https://www.sanparks.org/conservation/park_man/ 30 January 2018 comment placed on SANParks Website. Revised draft document and The documents were made available on SANParks comments and response Website. They were made available to registered N/A report available to stakeholders by email and internet link. stakeholders. Dissemination of finalised The documents will be available on theSANParks document and comments Website once approved by the Minister. They will be N/A and responses document. made available to registered stakeholders by email and internet link.

4.3 “Desired state” workshops

Table 4. Desired state workshops attendance

Activities Description Attendance The meetings were well attended by representatives from: local communities, Traditional Authorities, conservation area representatives, Local Government, tourism operators, NGOs, research institutions, sector partners such as DAFF, DARDLEA, LEDET, MTPA, river fora, media, SANParks Honorary Rangers, businesses, tourism operators and associations, SAPS, environmental consultants, life-style areas bordering KNP, GLTFCA parties, DEA, DWS, SAHRA etc. Desired State workshop Meetings were held in 15 local and metropolitan areas as shown below. Venue Date Number of stakeholders that attended Mutale 18 April 2017 310 Maphophe 19 April 2017 335 Malamulele 20 April 2017 499 Giyani 21 April 2017 390 Ba-Phalaborwa 24 April 2017 226 Hoedspruit 25 April 2017 40

Acornhoek 26 April 2017 353 Hazyview 02 May 2017 350 KaBokweni 03 May 2017 434 Kwa-Mhlushwa 04 May 2017 411 Cape Town 24 May 2017 9 T PLAN

N Pretoria 25 May 2017 22 Johannesburg 26 May 2017 9 White River 27 May 2017 55 Durban 03 June 2017 22 Total number 3,465

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– The purpose of the adaptive planning process is to source and incorporate stakeholder input into a more technical planning process. Moreover, this purpose is part of a broader context of forming and sustaining relationships with the public to secure mutual understanding and ongoing support and

PARK legitimacy. This notion is described in Figure 2. The desired state process reported on here is therefore an event in an ongoing, dynamic public engagement process.

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Figure 2. The role of the desired state process within the broader context of the relationship between SANParks and public interests.

SANParks has a mandate to conserve biodiversity and to promote the associated conservation values (the green arrows in Figure 2). Stakeholders also have an interest in the park and how it affects the surrounding and interested community and their activities (blue arrow). It is acknowledged that the sustained vibrancy and legitimacy of the park depend upon stakeholder understanding, support and involvement. For this reason, the park management wished to engage the public in an ongoing manner (the red arrow). This will also influence the SANParks mandate and thereforeinvesting in public participation (the pink arrow) is key.

Figure 3. Public meetings were held in 11 localities within the immediate KNP vicinity for both the “desired state” and draft Management Plan presentations and four in main metros/cities (not shown).

The following three questions formed the content for the “desired state” workshops:

1. What are the new emerging issues in this context which you think are important to consider in the development of KNP Management Plan? Stakeholders were asked to list their top five. 2. What are the special features (uniqueness) of KNP and its surrounds that we should consider in the future management plan. Again, stakeholders were asked to list their top five. 3. For each of these special features what can we do to sustain it … what makes them possible (drivers) and what threats are associated with these?

Feedback from each individual workshop was captured in workshop specific reports. This report consolidates the feedback using the three standard questions asked at all fifteen workshops as the framework to avoid bias towards individual workshops. Categories have further been used to align issues emerging across all fifteen workshops to ensure consistency in reporting and fair representation of discussions across a diverse group of stakeholders.

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Figure 4. The adaptive planning process as presented at meetings, leading to the articulation of the

– desired state. The vision is informed by the operating principles and values, the context within which the park is nested, and its vital attributes. Together, these form the basis for the articulation of high- level objectives for the park. PARK

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Figure 5. Summary of the key issues identified during the desired state workshops, clustered into key themes and high-level objectives. 15

The issues that were mentioned 25 times or more across the 15 desired state workshops are summarised in Figure 6 below.

>25 mentions 300

250

200

150

100

Gates

Youth

Fence

Buffer

Safety

Water

CBNRM

Poverty

Tourism

Poaching

Bursaries

Localjobs

Community…

Infrastructure

More Rangers More

ClimateChange

SustainableUse LegacyEquity &

HealthMalaria &

KNP Management KNP

Community Access Community

Community Projects Community

Access & Benefit Sharing Benefit & Access

Damage CausingAnimals Damage

Environmental Education Environmental Education & Learnerships& Education Biodiversity & Conservation & Biodiversity

Figure 6. Graph of the key issues identified (more than 25 mentions) during the desired state workshops.

A description is given in Table 5 below of the issues that were mentioned 25 times or more across the 15 desired state workshops.

Table 5. A brief description of the issues raised during the desired state workshops, for issues mentioned more than 25 times.

Category Summary of the issues raised # Mentions Comment Local jobs Local jobs were raised as a concern for all stakeholders – both in terms of 270 Addressed in the ensuring that more local people are employed in existing positions (target Management of 50% of KNP staff being local was raised); as well as the creation of new Plan, primarily employment within the tourism, anti-poaching and environmental within Sections management sectors. Numerous suggestions were made regarding 10:7, 10.8, 10.9.4, improvements for the advertisement of available positions to local 10.9.9 communities. Suggestions were also made regarding ways to expand the Expanded Public Works programmes in terms of both natural resource management and infrastructure management. Stakeholders recognised the park as an important employer for local communities but noted that more can be done to create additional jobs and to ensure that local communities are appropriately skilled and qualified to take up jobs that are available.

Category Summary of the issues raised # Mentions Comment Community Stakeholders noted the importance of ongoing communication between 150 Addressed in the communication the park and all its stakeholders. Stakeholders noted the significance of Management the workshops and praised the park for including them in the Plan, primarily management plan review, however it was noted that communicating within Sections every ten years, or even annually, was not sufficient. Stakeholders 10.8, 10.9.9 noted that the existing Park Forums are not as effective as they could be, and other existing mechanisms for communication are not meeting their needs in terms of regular, consistent, and informed communication between the park and its neighbours. Stakeholders requested additional efforts be made to improve communication and accountability on both sides of the fence. Infrastructure Infrastructure was raised repeatedly as a source of pride, concern and 147 Addressed in the job creation within the park. Key themes emerging under infrastructure Management included the need to improve roads within the park and in neighbouring Plan, primarily communities; the need for additional tourism infrastructure (within the within Sections park and in neighbouring communities) and for existing tourism 10:7, 10.8, infrastructure to be repaired. Water infrastructure, sports infrastructure, 10.9.4, 10.9.9 security infrastructure and lighting in the communities were also raised as significant concerns for neighbouring communities. The park was

noted has having the best infrastructure in the region, but the lack of public infrastructure in the neighbouring communities was noted as being an ongoing concern that needs to be recognised and addressed. The need for additional toilet stops for visitors within the park was also

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raised. N Damage Stakeholders raised ongoing concerns regarding the presence of 146 Addressed in the causing animals damage causing animals that escape through the fence. Concern was Management raised regarding compensation for loss of life and livestock (particular Plan, primarily emphasis on loss of livestock), on the spread of diseases, and on the within Section general safety of people living adjacent to the park. It was noted that 10.9.10

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the current policies on damage causing animals are an improvement on

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the past, but stakeholders wanted more information on how to report damage causing animals; some training on how to handle damage causing animals in the absence of an immediate response from the Park; and more information on the length and structure of the PARK compensation process. Tourism Stakeholders recognised the significance of tourism in the area as an 104 Addressed in the economic driver and the means to continue the conservation of Management biodiversity. Additional opportunities were identified by stakeholders to Plan, primarily

promote further economic activities from tourism, including cultural within Sections NATIONAL

tourism, the creation of additional accommodation (within the park and 10.5, 10.7 within neighbouring communities). Tourism was noted as a driver for job creation and empowerment in the region and the only negative sentiment regarding tourism was that it does not currently reach the communities in any significant way if they are not directly employed by KRUGER the park and more could be done to expand the tourism offerings of the region. Safety Stakeholders raised concerns about the safety of everyone visiting the 84 Addressed in the park or living near it. They raised concern about the safety of staff and Management rangers working within the park, and the safety of tourists – particularly Plan, primarily in relation to swimming pools. Additional issues were raised regarding within Section new criminal networks that are entering the area attracted by poaching 10.9.7 and the side effects of this on community safety and visitor safety. Suggestions were made to improve safety in the park and raise awareness with visitors about safety related issues. Community Stakeholders raised concerns regarding the cost of entering the park – 79 Addressed in the access to the especially for neighbouring communities and Traditional Authorities. Management park Stakeholders recognised the significance of the free access on Heritage Plan, primarily Day and in September but requested additional mechanisms for access within Section throughout the year. Stakeholders also noted that access should not be 10.8.3 in the form of paper slips, they also want WildCards with preloaded access.

Category Summary of the issues raised # Mentions Comment Poaching Stakeholders raised concerns about future generations being able to 78 Addressed in the enjoy the biodiversity of the park in the same way that they are able to Management now due to poaching. Stakeholders noted this as a serious concern for Plan, primarily all and requested opportunities to assist more in anti-poaching activities. within Sections Stakeholders noted the connection between poaching and poverty, and 10.9.7, 10.8, 10.7 lack of environmental education. Stakeholders also noted the impact of poaching on community relations with the park – particularly regarding community members being killed or jailed for poaching related incidents. Fence Stakeholders raised concerns about the strength of the fence of the park 77 Addressed in the and the need for its ongoing repair, maintenance and security. This was Management noted as a threat to both communities and animals, and it was noted as Plan, primarily an opportunity for local job creation. The fence issue was raised within Section repeatedly over and above the issue of damage causing animals. 10.9.6, 10.7, 10.9.10 Environmental Stakeholders noted the value of environmental education activities by the 74 Addressed in the education Kruger staff, but requested more opportunities for these engagements as Management they found them very valuable. Stakeholders also noted the relationship Plan, primarily between environmental education local jobs, and environmental within Sections education and opportunities to support anti-poaching activities. 10.7, 10.8.1 Gates Stakeholders noted that there needs to be a clear way forward regarding 63 Addressed in the the creation of new gates, the reopening of old gates and any unresolved Management gate related issues. Stakeholders felt that gates bring tourism and Plan, primarily opportunity to communities and they noted the significance of access to within Sections a gate for each community. Stakeholders noted frustrations regarding 10.8.3, 10.2.2 lack of clarity on certain gate related discussions that had started and were then not been resolved. Community Stakeholders noted the importance of looking after the environment 56 Addressed in the based natural outside of the park and requested further assistance through the Management resource Biodiversity Social Programmes and other mechanisms to support Plan, primarily management community based natural resource management in the buffer. Specific within Sections issues raised related to the management of bush encroachment, erosion, 10.2, 10.3.9. protection of the rivers, management of grazing areas, limiting of 10.3.2 deforestation and cutting down of trees, and the growing of medicinal plants. Bursaries Stakeholders requested that the park support neighbouring communities 50 Addressed in the with bursaries and access to tertiary education opportunities – Management specifically regarding conservation and within disciplines that would allow Plan, primarily local community members to gain the skills needed to get jobs within the within Section park beyond non-skilled labour. 10.9.4 Sustainable use Stakeholders felt it was important that the park recognise the culture and 49 Addressed in the traditions of local people, especially regarding their use of natural Management resources (Mopani Worms, Marula, Hunting, Grass, and Wood). Plan, primarily Stakeholders raised the need for additional opportunities to be made within Section available for sustainable resource use within the park. 10.3.9 Poverty It was noted that the park is located within a broad context of poverty, 44 Addressed in the specifically one in which there are many orphans and vulnerable people Management (people with disabilities, pensioners) who need assistance. It was noted Plan, primarily that while Kruger may not be able to resolve all issues relating to poverty, within Sections it is important to recognise the context of poverty within South Africa and 10.2, 10.7, 10.9.4 on the borders of the park. Water The lack of clean drinking water outside of the park was raised as a 42 Addressed in the significant issue affecting the broader socio-economic context and the Management quality of life of communities living next to the park. Access to water Plan, primarily related infrastructure such as dams (for livestock), drinking water and within Sections sanitation facilities were highlighted as an urgent need. 10.2.3, 10.3.4, 10.7

Category Summary of the issues raised # Mentions Comment Buffer Stakeholders noted the significance of the park buffer zone and 40 Addressed in requested additional support and information to assist in the collaborative the management of the buffer zone. Management Plan, primarily within Sections 10.2, 10.7, 10.8, 10.9.9 Legacy & equity Stakeholders raised concerns regarding the resolution of land claims as 40 Addressed in they pertain to the park. It was noted that the land claim process has the been concluded, but it was noted that only a limited number of claims Management were settled. Stakeholders also raised broader concerns regarding equity Plan, primarily and the addressing of historical issues relating to the park. Questions within Sections were also raised about accessibility for disabled people and general 10.7, 10.8 issues of equity within the park. Biodiversity & Stakeholders recognised the importance of the conservation of 37 Addressed in conservation biodiversity in the continuance of the park and the benefits it brings to the the region. Stakeholders praised SANParks for their management of Management biodiversity within the park and noted the ongoing conservation of the Plan, primarily area as being important beyond just tourism. Stakeholders noted the within Sections sense of identity and peacefulness associated with animals and plants in 10.3, 10.4 the area.

More rangers Stakeholders regularly raised the importance of more rangers to support 35 Addressed in T PLAN

job creation and ensure safety and security within the park. Stakeholders the N also raised issues regarding the quality of life of rangers living within the Management park, particularly in relation to security concerns, and health concerns. Plan, primarily within Sections 10.9.7, 10.9.4 Youth Stakeholders noted the significance of local populations being made up 34 Addressed in

MANAGEME predominantly of youth (<35 years) and requested that SANParks the

– recognise this, and develop strategies to positively engage with youth in Management the area. Youth were noted as being restless and a potentially Plan, primarily destructive force in the area if not properly engaged. within Section 10.9.4, 10.7, PARK 10.8 KNP Questions were raised by stakeholders regarding the appropriate 30 Addressed in management management of the park. In particular, stakeholders requested more the information regarding how the park is managed so that management can Management

NATIONAL

be held accountable for their actions and stakeholders have a better Plan, primarily understanding of the management framework. within Sections 10.8, 10.9.9 Climate change Climate change was raised by stakeholders as an increasingly significant 29 Addressed in issue needing to be addressed – both in terms of disaster risk the

KRUGER management and understanding the implications of droughts and floods Management on the current protected area system. Stakeholders also noted the Plan, primarily importance of buffer zone management, and community based natural within Sections resource management in relation to climate change related threats and 10.2, 10.9.13 opportunities. Community Stakeholders noted the need for development and support for 28 Addressed in projects communities living adjacent to the park. The requested that the park the implement a system for reviewing community projects and assisting with Management cash and in-kind donations. Stakeholders particularly requested that old Plan, primarily and unused equipment, furniture and other items belonging to SANParks within Sections that are no longer in use be donated to charitable causes in neighbouring 10.7, 10.9.4 communities. Access & Stakeholders noted the collection of a community levy by SANParks and 28 Addressed in benefit sharing wanted this to be formally recognised and accounted for to neighbouring the communities. Stakeholders indicated that there needs to be Management accountability and transparency regarding how the levy is used and who Plan, primarily benefits from it. There was a strong need for access and benefit sharing within Section to be recognised more formally within the context of the park, and 10.7, 10.8 additional mechanisms to be put in place to assist communities to clarify whom (specifically) the levy intends to benefit. Stakeholders also felt that they should be included in decisions regarding how the levy is spent if it is not handed over as a direct compensation / levy.

Category Summary of the issues raised # Mentions Comment Health & Stakeholders noted the government’s poor service delivery in this regard 27 Addressed in malaria and specifically requested that SANParks investigate opening clinics the within the park (or near the gates) to service staff and tourists. Additional Management health issues were raised concerning neighbouring communities, such Plan, primarily as HIV, malaria and other context specific diseases. within Section 10.9.4 Education Stakeholders noted the poor quality of schools and the lack of access to 26 Addressed in tertiary education for communities living near the park. Requests were the made for SANParks to continue to assist neighbouring schools and to Management focus explicitly on the role of the park in supporting education in the area. Plan, primarily within Sections 10.7, 10.8, 10.9.4

Issues raised 25 times or more were discussed in all workshops and remain the most significant issues raised according to stakeholder rankings. However, important issues were also raised that did not reach the 25, including service delivery, crime, population growth, litter, corruption, equity, schools, tenders and donations.

The following issues were mentioned between five and 24 times:

5 - 24 Mentions 30 25 20 15 10 5

Fire

Skills

Litter

Crime

Rivers

Equity

Legacy Legacy

Budget

Protest

Culture

Schools

Malaria

Pension

Tenders

Disability

Traditional…

Population…

Corruption

Volunteers

Immigrants

KNP service KNP

Biodiversity

Learnership

Park Expand Park

Social Media Social

Collaboration

PeopleParks &

HealthAnimal - Service delivery Service DonationsNGO /

Figure 7. Graph of the issues identified (less than 25 mentions) during the desired state workshops.

The issues that were mentioned less than 25 times across the 15 desired state workshops is summarised in Table 6 below.

Table 6. A brief description of the issues raised during the desired state workshops, for issues mentioned less than 25 times.

Category Summary of the issues raised # Mentions Comment Service delivery Stakeholders raised the need for additional service delivery in 24 Addressed in the neighbouring communities and requested local offices in each Management village to support with the implementation of service delivery. Plan, primarily Stakeholders recognised this as being beyond the mandate of within Section 10.8 SANParks but requested assistance in liaising with and co- ordinating service delivery with the relevant government departments. Crime Stakeholders called for support in reducing the rising tide of 23 Addressed in the crime outside the park – both in relation to poaching and general Management crime. Stakeholders noted a steady increase in crime in the Plan, primarily area that was affecting tourism and day to day life in within Section communities. The link between rhino poaching, poverty and 10.9.7 increases in crime were noted. Population growth Stakeholders noted the increasing pressure on the park from the 22 Addressed in the urbanisation of previously rural communities due to population Management growth. The impacts of urbanisation on land use and Plan, primarily development were noted as being important contextual issues within Sections to consider in the management of the park. 10.2, 10.8 Litter Stakeholders raised concerns about litter within and outside the 21 Addressed in the park. Specifically, stakeholders requested assistance (also Management

mentioned under Infrastructure) with recycling and other waste Plan, primarily T PLAN related infrastructure. It was noted that litter (or the absence within Sections N thereof) is a significant issue in attracting tourists to the park and 10.2, 10.7 they wanted to make sure the park remains free of litter at all times (requests were made for litter bags to be handed out) and that neighbouring communities can be kept clean as well. A critical issue raised about litter in the communities is nappies

MANAGEME and their appropriate disposal.

– Collaboration Stakeholders raised questions regarding how treasury 19 Addressed in the regulations work, and an emphasis was put on the need to work Management together to unlock opportunities and facilitate new investment in Plan, primarily the contractual parks. within Sections PARK 10.2, 10.7 Corruption Stakeholders raised concerns about the integrity of staff within 18 Addressed in the the park, especially about the perception of ongoing nepotism. Management Concerns were also raised about the involvement of KNP staff Plan, primarily

NATIONAL

in poaching. within Sections 10.9.7, 10.9.4 Schools Stakeholders requested support for local schools, as well as for 18 Addressed in the the consideration of opening up schools within the park for Management

community children. Plan, primarily KRUGER within Sections 10.7. 10.8.1, 10.9.4 Tenders Stakeholders raised questions regarding how the tender 16 Addressed in the process works and complained that local companies often do Management not qualify. It was noted that treasury regulations need to be Plan, primarily followed, but requests were also made for more information and within Section support in ensuring local companies are compliant. 10.9.3 Donations Stakeholders requested the park to recognise that multiple 15 Addressed in the Non-Governmental Organisations and Community Based Management Organisations in the area are assisted with donations of old Plan, primarily equipment, uniforms, furniture and other goods from the park within Sections that are no longer used. Cash donations were also requested, 10.8, 10.9.3 but the focus was on the donations of goods. Donations were also requested for small businesses. KNP service Stakeholders raised concerns about the treatment of local 14 Addressed in the visitors to the park, and double standards by staff within the park Management towards international tourists and local tourists. Stakeholders Plan, primarily requested consistency in how all guests are treated when within Section 10.5 entering the park.

Category Summary of the issues raised # Mentions Comment Skills development In addition to environmental education and job creation, 12 Addressed in the stakeholder highlighted the need for skills development in Management Plan, neighbouring communities. primarily within Sections 10.7, 10.9.4 Social Media Stakeholders noted the increasing significance of social media 10 Addressed in the and the potential that unpopular conservation decision making Management Plan, may result in negative social media reporting by animal rights primarily within activists. This was noted as a new contextual issue that should Sections 10.8, 10.9 be taken into consideration with regards to general media strategies and engagement with the public. Budgets Stakeholders raised concerns regarding there being sufficient 9 Addressed in the budget available to manage the park, and made suggestions Management Plan, regarding fundraising and donations. primarily within Section 10.9.3 Animal health Stakeholders noted concerns regarding the ongoing 9 Addressed in the management and prevention of Foot and Mouth Disease and the Management Plan, general well-being of their cattle. Requests were made for primarily within additional support to reduce the vulnerability of livestock to Sections 10.2, damage causing animals and droughts. The significance of 10.9.12, 10.9.10 livestock and the threat the Park poses for them was also raised under damage causing animals in relation to compensation for predator losses, but this category refers specifically to animal health related issues. Park expansion Stakeholders on neighbouring reserves noted the importance of 9 Addressed in the the National Protected Areas Expansion Strategy for the ongoing Management Plan, management of the park. Stakeholders noted the need for primarily within ongoing information in this regard, and opportunities to Sections 8, 10.2 participate in expansion planning and buffer zone planning. Traditional Over and above the need for improved communication with 8 Addressed in the Authorities communities neighbouring the park, and the need for increased Management Plan, access to the Park, stakeholders noted the importance of primarily within recognising the Traditional Authorities located on the park’s Sections 10.6, 10.8 boundary. Traditional Authorities were noted for their role in communicating with the broader community, their historical and cultural associations with important burial sites within the park, and their role in the ongoing governance of the region. Immigrants Concerns were raised regarding immigrants who use the park to 7 Addressed in the illegally cross borders. Stakeholders noted concern both for the Management Plan, safety of immigrants attempting to walk across the park, but also primarily within 10.9.7 for illegal activities often associated with illegal immigrants. Stakeholders also raised concerns about Protocols regarding border crossing through the park and asked for more information in this regard. Pension Stakeholders asked SANParks to make special consideration for 7 Addressed in the pensioners in the area – both in terms of accessing the park, and Management Plan, in terms of providing material support for pensioners within their primarily within communities. Section 10.9.4 People and parks Stakeholders asked questions about the People and Parks 7 Addressed in the programme to clarify its role and intended beneficiaries of the Management Plan, programme. primarily within Sections 10.7, 10.8 Protest Stakeholders noted the increasing occurrence of civil unrest in 7 Addressed in the communities surrounding the park and its impact on tourists Management Plan, trying to access the park and on the safety of communities. primarily within Section 10.8

Category Summary of the issues raised # Mentions Comment Rivers Stakeholders noted the importance of rivers inside and outside 6 Addressed in the the park. Stakeholders noted the importance of managing rivers Management under the category “community based natural resource Plan, primarily management”, this category refers more generally to the health within Sections and significance of rivers in the area. 10.2.3, 10.3.4, 10.3.9 Volunteers Stakeholders raised questions about the volunteer programmes 6 Addressed in the around the park – requesting support with stipends for Management volunteers who had been on the programme for a long time, as Plan, primarily well as requesting additional opportunities for skills within Section development through volunteer opportunities. 10.9.4 Culture Beyond cultural tourism and issues of legacy and equity, 5 Addressed in the stakeholders noted the importance of recognising local cultures Management and the impact of local culture on the context within which the Plan, primarily park is managed. within Section 10.6 Fire Stakeholders raised concerns about ongoing fire management 5 Addressed in the – specifically in relation to communal rangelands. Management Plan, primarily within Sections 10.3.7, 10.2

Lastly, several issues were raised less than five times that are nonetheless significant issues to be considered in the revision of the Management Plan.

T PLAN Most stakeholders attending the workshops were residents of local communities neighbouring the Park, N reflecting a bias in issues towards social justice and economic development.

Other important issues that were raised less than five times include:

MANAGEME  National Environmental Management: Protected Areas Act;

–  Wilderness;  Community basic needs;

 Image of the park; PARK  Invasive species;  Sport;  Workers;  Ecosystem services;

NATIONAL  Gender;  The iconic nature of Kruger National Park;  Livestock;  Traffic;  Size; and KRUGER  Technology.

Inputs on the Mission statement highlighted the following:

 Tourism and its impact on human well-being needs to be highlighted;  The Transfrontier nature of Kruger National Park needs to be highlighted;  Recreational opportunities for visitors and communities need to be added to the mission;  The mission statement should emphasize the importance of there being harmony between people and nature; and  The use of words like preserve versus conserve need to be thought about carefully.

Following further consultation with other stakeholders as well as an internal workshop the following version of the mission statement was agreed on:

KNP Mission

To conserve, protect and manage biodiversity, wilderness qualities and cultural resources, provide a diverse and responsible visitor experience, contributing towards social, ecological and economic resilience and well-being whilst strengthening constituency within a unique regional landscape.

4.4 Focus group meetings

Several thematic focus group/interest group meetings provided inputs into the desired state process, as well as the development of the LLPs. At the focus group meetings, the following questions were asked:

 Define / reflect on the current collaboration between yourself and KNP.  What were the key issues addressed through the current Management Plan (programmes) which is relevant to you as focus/interest group partner?  What are the current key challenges/gaps/threats?  What are the opportunities to be considered in the KNP Management Plan review?  What would you suggest that the KNP need to consider/amend e.g. in terms of the focus, approach, actions, prioritisation etc. for the development of the KNP Management Plan/lower level plans?  What will your actual involvement/interest be in terms of participating and contributing to the lower level/operational plans and what are the relevant engagement structures with respect to the Conservation area that you represent?  What are the current governance arrangements within your specific area, within the broader area of co-operation, and what would be necessary to enhance/promote co-operation at this broader scale and with the KNP?

Table 7. A summary of the focus/interest group meetings where inputs into the draft Management Plan were received/presented throughout the review process, are as follows:

High level objective Focus/Interest Group Dates Phase in which inputs were considered Regional integration GLTFCA programme – Conservation areas 10 May 2017 Desired State Regional integration GLTFCA programme - GLTFCA 23 June 2017 Desired State Regional integration GLTFCA programme – Greater Kruger Living 12-13 July 2017 LLP with Wildlife multi-sector workshop Regional integration GLTFCA programme – Greater Kruger 7 September 2017 LLP, Implementation stakeholders Regional integration GLTFCA programme – GLTFCA JMC 23 October 2017 LLP, Implementation Regional integration GLTFCA programme – GLTFCA JMC 29 January 2018 Implementation Regional integration GLTFCA programme –GLTFCA JMB 30 January 2018 Implementation Regional integration Integrated land use programme-Zonation and 8 November 2016 Zonation and buffer buffer delineation – conservation partners delineation Regional integration GLTFCA programme – Conservation areas 10 May 2017 Desired State Regional integration GLTFCA programme - GLTFCA 23 June 2017 Desired State Regional integration GLTFCA programme – Greater Kruger Living 12-13 July 2017 LLP with Wildlife multi-sector workshop Regional integration GLTFCA programme – Greater Kruger 7 September 2017 LLP, Implementation stakeholders

High level objective Focus/Interest Group Dates Phase in which inputs were considered Regional integration GLTFCA programme – GLTFCA JMC 23 October 2017 LLP, Implementation Regional integration GLTFCA programme – GLTFCA JMC 29 January 2018 Implementation Regional integration GLTFCA programme –GLTFCA JMB 30 January 2018 Implementation Regional integration Integrated land use programme- 8 November 2016 Zonation and buffer Zonation and buffer delineation – delineation conservation partners Regional integration Integrated land use programme – 28 January 2017 Buffer delineation, LLP, buffer and municipal meeting Implementation Regional integration Integrated land use programme – 28 February 2017 Buffer delineation, LLP, buffer delineation external partners Implementation Regional integration Integrated land use – zonation and 4 April 2017, 12 April Integrated land use buffer mechanisms – mostly internal 2017, 1 June 2017 mechanisms and LLP, partners zonation Regional integration Integrated land use meeting 16 September 2017 LLP development, implementation Regional integration Integrated land use meeting 9-10 October 2017 LLP – spatial product use, buffer zonation Regional integration Integrated land use – spatial, buffer 5-7 September 2018 Implementation Regional integration Integrated land use programme – 6 July 2017 LLP

Biospheres Regional integration Integrated water resource 30 June 2017 LLP management programme – Crocodile River Forum

T PLAN

Regional integration Integrated water resource 19 June 2017 LLP N management programme- Sabie River forum Regional integration Integrated water resource November 2017 LLP management programme – Focus group meeting

MANAGEME Responsible Tourism Responsible Tourism – MISA 9 May 2017 LLP

– Responsible Tourism Responsible Tourism – Lowveld 10 May 2017 LLP Tourism Responsible Tourism Responsible Tourism – SATSA 11 May 2017 LLP Responsible Tourism Visitor Management Several workshops LLP PARK during November 2017 Effective park management Infrastructure Development May 2017, LLP Polokwane

NATIONAL

Effective park management Infrastructure Development May 2017, Nelspruit LLP Effective park management Safety and Security – NATJOINTS 6 April 2017 LLP, Implementation Effective park management Safety and Security – Provincial 14 April 2017 Desired State, LLP, Commissioner Limpopo Implementation

Effective park management Safety and Security – Provincial 13 April 2017 Desired State, LLP, KRUGER Commissioner Mpumalanga Implementation Effective park management Veterinary Wildlife Support 15 June 2017 LLP Effective park management Research Programme - Savanna 17 March 2017 LLP Network meeting

4.5 Public information sessions on the draft KNP Management Plan

During the second round of public meetings during February 2018, the draft Park Management Plan was discussed specifically to give feedback on progress but also to illustrate how comments from the first round of meetings were incorporated in the plan. Park management prepared a formal presentation addressing the draft Park Management Plan. For all 15 advertised public information sessions, (Table 3) stakeholders had an opportunity to engage directly with Park management.

Table 8. Public information session attendance, 2018.

Venue Date Number of stakeholders that attended Mutale 13 February 2018 95 Malamulele 14 February 2018 182 Maphophe 15 February 2018 166 Giyani 16 February 2018 366

Venue Date Number of stakeholders that attended Phalaborwa 13 February 2018 244 Hoedspruit 14 February 2018 20 Acornhoek 15 February 2018 249 Hazyview 13 February 2018 224 KaBokweni 14 February 2018 302 KwaMhlushwa 15 February 2018 392 White River 16 February 2018 33 Durban 12 February 2018 2 Cape Town 13 February 2018 2 Pretoria 14 February 2018 8 Johannesburg 15 February 2018 12 Total number 2,297

5. Stakeholder comments on the draft Management Plan

All comments received (February – March 2018) on the draft Park Management Plan are listed in Table 9. In total 483 comments were received. General, verbal responses were given to the commentators at the various meetings. SANParks has formulated final responses to all the comments / input received, including comments received via email.

# Mentions - 2018 Public meetings 60

SED

Costing

Addenda

Research

Diseases

Consultation

Rehabilitaton Legal Status

nfrastructure

BD-Herbivory

Resource use Resource

Communication,

Cultural Heritage Cultural

Fire management Fire

urpose andVision urpose

Riskmanagement

Promoting access Promoting

Generalcomments

Safety and Security Safety

Executive summary Executive Biodiversity Biodiversity general

Access and facilities Access

Zoning and Concept… Zoning

Responsible Responsible Tourism

Invasive alien species Invasivealien

Predation programme Predation

Human Wildlife Human Conflict…

Freshwater ecosystems…

Wilderness management Wilderness

Information management Information

Regional Integrated water… RegionalIntegrated

Stakeholder engagement Stakeholder

Educationand awareness Educationand

Monitoring and evaluation Monitoring

Disaster Risk Management Risk Disaster

Species of Special Concern Special Speciesof

Climate Change programme Change Climate

Human Capital Management Human

GLTFCA Conservation areas GLTFCAConservation

Coordinated Policy framework Policy Coordinated

Regional integration- Integrated… integration- Regional Park expansion and consolidation and expansion Park

Figure 8. Graph of the issues identified during the Public meeting workshops.

Table 9. A broad summary of inputs received on the KNP draft Management Plan, categorised according to broad themes, very often overlapping between the respective KNP Management Plan sections/themes. 483 inputs were received (public meetings and written inputs).

Key theme / LLP / Section Number of Key issues mentions Herbivory – KNP Management 57 Elephant TPCs; Elephant MP signed off?; concerns about landscape of Plan, Section 10.3 fear, and if open for consultation; public consultation; concerns about population size; do not kill elephants; landscape of fear vs awareness; mismatch of scales; contradiction to Elephant Norms and Standards queries around water gradients; ethic matters; broader management philosophies, etc. Stakeholder engagement – KNP 35 Need to improve communication, don’t wait for so long; concerns about Management Plan, Section 10.7 community forums not being constituted; communication not transparent and inclusive; KNP did not inform parties in advance of meetings; communication on proposed Shangoni gate required Socio-economic development – 31 Job opportunities, SMMEs, wildlife economy, support through KNP Management Plan, Section infrastructure programmes, youth programmes, update land claim 10.7 processes, concern that expectations are created and that programmes are not going to be sustainable, tender processes, why are service providers outside the local area being appointed?

Responsible Tourism – KNP 31 Concern about visitor management, concern about further Management Plan, Section 10.5 developments, concerns about OSVs, off-road rules and practices, update on Selati restaurant, is concession management successful?, models of off-road driving regulation, cumulative impact of developments,

T PLAN

maintain aesthetics N General comments 30 Different views on Management approach, Vision, typos, incorrect numbering, LLPs not made available Effective Park Management – 29 Concerns about compensation process, concerns about fence Human Wildlife Conflict maintenance, responses to incidents too slow, confusion in terms of Management - KNP reporting, KNP to take back wild animals

MANAGEME Management Plan, Section

– 10.9.10 Effective Park Management – 24 Job opportunities concerns about nepotism and corruption, internships Human Capital Management – and learnerships, improved communication about vacancies, positions KNP Management Plan, Section for rangers PARK 10.9.4 Cultural Heritage – KNP 19 Management of cultural heritages, compliance with SAHRA, more Management Plan, Section 10.6 cultural opportunities and access to communities, training courses available, update on theft of Thulamela gold, current staffing structure

NATIONAL

Section 5 - Purpose and Vision 18 Suggestions for clarification, corrections, improvement regarding contextual background. Agreement that actions should be linked to all aspects of Vital attributes (determinants, challenges). Effective Park Management – 18 Crime in communities, costs of security, corruption, collaboration with Safety and Security – KNP SAPS and communities to address crime, snaring, concern about

KRUGER Management Plan, Section poisoning, will more air strips be developed, concern that persons 10.9.7 working in one position may become corrupt, EWT have officer in Hoedspruit to assist with poison related matters Biodiversity Species of Special 15 Focus on indicator species such as birds, smalls species such as oribi, Concern – KNP Management Vultures, add sub-objectives to deal with poisoning Plan, Section 10.3.5 Section 2 - Legal Status 14 Suggestions for clarification, corrections, improvement regarding contextual background. Biodiversity Resource use – 14 Community requests for Warburgia trees, need to understand rules for KNP Management Plan, Section Mopani harvesting, may communities collect elephant bones, where can 10.3.9 communities get more access to broader resource use, Concerns about resource use - when is KNP going to stop to supply protein -how can KNP sustain it, concerns about KNP image on social media, does the legal framework allow for wildlife sales, Protocols guiding resource use?, more opportunities requested by communities; confusion with the meaning of "tissue". Sections 6, 9 - Zoning and 13 Concerns about zonation and implications for development, incorrect Concept development interpretation of zonation, peripheral alignment opportunities for traversing with co-operative conservation areas, concerns about certain potential activities in wilderness zones such as sport, GLC labelling as conservation areas vs formally protected area, concerns about quality of current products and now new products are already presented, delineation of riparian zones essential

Key theme / LLP / Section Number of Key issues mentions Stakeholder engagement: 11 More education and awareness opportunities requested, diversity education and awareness – products and approaches, collaboration with the Depart of Education, KNP Management Plan, Section opportunities to collaborate 10.8.1 Effective Park Management - 9 Very little about wildlife management, very impressed with the new Research – KNP Management management plan, too much attention of academic aspects, concerns Plan, Section 10.9.14 about elephant research and synthesis, ecological management is deficient, how is co-learning practised - KNP could lead on this Regional Integrated water 11 Assistance to water forums regarding water quality, concern about resource management – KNP water waste, interest in groundwater monitoring results, details of LLPs, Management Plan, Section concerns that water use is too high. 10.2.3 Addenda 10 Concerns about perceived permissible activities, suggestions for improvements on Addenda

Effective Park Management- 10 Shangoni gate - when is land claim finished, concern about lack of Infrastructure – KNP feedback, when will the position of the gate be finalised, concerns about Management Plan, Section visibility of infrastructure e.g. at Tshokwane and Skukuza; roads require 10.9.6 maintenance Section 7 - Access and facilities 8 Queries on access opportunities with Mozambique, SAHRA requirements, servitudes, commercial activities, position against mining.

Regional integration- Integrated 8 Waste management, mining, recycling, scenario planning, climate land use – KNP Management change, , strategic partnerships, mining issues, DCA concerns linked to Plan, Section 10.2.1 other sectors, support and relationships with other sectors, concerns about hunting in neighbouring areas such as the APNR Regional integration – GLTFCA 8 Model for TFCA areas, difference between contractual and co-operative Conservation areas – KNP arrangements; land inclusion and "buffer areas"; concerns about Management Plan, Section hunting, programmes focussing on snaring, clarify roles and 10.2.2 responsibilities between MTPA and KNP, further community areas for inclusion, EMS submission, interpretation of buffer regarding Table 22 Biodiversity- Diseases – KNP 8 Certain minor amendments made, and further inputs will be considered Management Plan, 10.3.8 during the first work plan review

Biodiversity – Freshwater 7 Collaboration with water forums, water saving measures, concern about ecosystems management– KNP pampers, interest in groundwater issues, understand changes in bird Management Plan, Section species as result of water changes, delineate riparian buffers and 10.3.4 protect, create artificial wetlands Biodiversity Fire management – 7 Inform when fires are conducted in KNP, fire awareness in KNP Management Plan, Section communities, support for fire management in rangelands, maintain 10.3.7 networks, maintain safety and security, conservation to drive fire management Stakeholder promoting access – 7 More gate access, access for disabled, half entry and free access, KNP Management Plan, Section better communication with traditional authorities, sports events, access 10.8.3 for resource use Biodiversity Rehabilitation – 5 How rehabilitation is done, concerns about destruction of dams, focus KNP Management Plan, Section on upstream catchments 10.8.3 Wilderness management – KNP 5 Status or road network, net loss of wilderness areas, development of Management Plan, Section 10.4 auditing systems function of conservation management

Section 8 - Park expansion and 3 Include Manyeleti, consider cultural heritage aspects, roles and consolidation responsibilities with MTPA

Section 3 – Coordinated Policy 2 Minor suggestions for clarification / improvement framework

Biodiversity Predation 2 Rewrite of section; correction of reference cited programme – KNP Management Plan, Section 10.3.6

Key theme / LLP / Section Number of Key issues mentions Biodiversity general – KNP 2 Why is TPCs not reflected? Anthropogenic threat to vultures - EWT Management Plan, Section 10.3 willing to provide support.

Effective Park Management- 2 Compliance with SAHRA and ICS requirements? Disaster Risk Management – KNP Management Plan, Section 10.9.2 Monitoring and evaluation – 2 Is the implementation tracked and staff being held accountable, at what KNP Management Plan, Section level will progress be measured? 10.10 Executive summary 1 Concerns about inadequacies of document; include market related matters

Section 4 - Consultation 1 Comment for noting

Effective Park Management - 1 Scenario planning Climate Change programme – KNP Management Plan, Section 10.9.13 Biodiversity – Invasive alien 1 Impact of clearing on cultural sites species – KNP Management Plan, Section 10.3.3

Effective Park Management - 1 SAHRA requirements for information management T PLAN

Information management – KNP N Management Plan, Section 10.9.5 Effective Park Management- 1 Include risks around electrical infrastructure and implications for birds Risk management, KNP Management Plan, Section

MANAGEME 10.9.2

– Effective Park Management – 1 Valuable, but requires expert monitoring and management Communication, KNP Management Plan, Section 10.9.9 PARK Section 11 - Costing 1 Financial sustainability, political buy in, appointments not based on merit; budget self-generated?

NATIONAL

KRUGER

Table 10. Register of inputs received during the Draft KNP Management Plan Public meetings (February 2018), showing comments per relevant KNP Management Plan Section:

483 inputs were received during the public meetings, and through written inputs. A total of 32 stakeholders submitted written inputs (Annexure 4). A template was provided for the written inputs and inputs that were submitted in the requested format, were considered for responses.

EXECUTIVE SUMMARY

No. Comment / Input Comment Reference Official response ator/s 1 In response to the Executive summary concerning GMFER Written Input, 9 The focus on distant market forces (traditions of trade, inelastic demand, high profit the “inadequacies” (in the face of “continually March 2018 potential) as drivers of poaching is beyond the jurisdiction of SANParks. Instead, changing society”) of the previous management plan SANParks focus on the local drivers (inadequate law enforcement, unclear property for 2008 – 2018: rights and ownership of wildlife, and human-wildlife conflict disincentives). This document, as it was drafted in 2007 and accepted in 2008, could not have anticipated the result of the sell offs of the ivory inventory to Japan, and then to China and the resulting explosion of the ivory market, which has been met to an enormous level by black market ivory acquired through poaching and illegal sales.

Some of the most profound “inadequacies” of the 2008-2018 management plan document, rest principally on the crises facing at-risk elephant and rhino populations resulting from the illegal market as well as the corruption enabling it. Climate change and shifting weather patterns are also factors. However, the crashing of the rhino populations (with repeated incursions into Kruger), as well as the precipitous decline in elephant populations continent-wide and now also in South Africa itself, are principally due to illegal market factors and demand for ivory and horn products, both domestically and abroad. Therefore, the market must also be addressed and demand for these “products” lessened and eliminated.

GENERAL COMMENTS

No Comment / Input Commentator/s Reference Official response 2 There is a spelling error throughout the document when Ms Lindie Botha Written inputs, 9 March Noted and addressed. referring to NEMPAA (NEM: PAA) 2018 3 Page 58. Top corner of table, the photo obscures the Ms Lindie Botha Written inputs, 9 March Noted and addressed. text. 2018 4 Ms Lindie Botha Written inputs, 9 March This will be made available on the SANParks website. We look forward to seeing the Stakeholder 2018 Consultation Report (Appendix 2) once it is completed. It would be very useful to see how the Stakeholder engagement process influenced the content of the management plan, specifically the high-level objectives. 5 There is a sense that communities are perceived as Ms Lindie Botha Written inputs, 9 March SANParks has since 1996 included the issue of people and passive beneficiaries of conservation/KNP, instead of 2018 conservation as part of its mandate and various programmes that making them the critical focus of ensuring the long- are aimed at benefiting neighbouring communities have been term conservation of the Greater Kruger and Kruger implemented since then and continue to be implement up to now. National Park itself. This means a clear recognition that land reformation issues, including land claims on the Park, are central to ensuring biodiversity conservation is framed in the political reality of South Africa. All of us need to move away from a conservation ideology that is framed by external conservation values and priorities. This is not to "throw the baby out with the bathwater" but are we really moving towards a new paradigm? Along the same vein, the “private sector” is often framed as the solution to all our conservation problems. This perception needs to be questioned, as it is an approach that might not be well suited to the current political environment. Kruger’s alliance with private land-owners cannot come at the expense of alliances with communities. This will not be sustainable, even the short-term. Greater emphasis can be placed on neighbouring communities and trans-border collaboration. This is no easy task, but there is a cost to be paid for past expropriations if our intent is to see a conservation landscape that is of benefit to all. What is the Quid Pro Quo? 6 The definition of “Responsible Tourism” in the glossary Dr. Audrey Delsink Written inputs, 9 March Please refer to Section 10.5 where the Responsible Tourism should be expanded to include the definition in the 2018 programme and principles are addressed. Norms and Standards for Responsible Tourism (Responsible Tourism Requirements - SANS 1162:2011) to read “Tourism that takes responsibility to protect and conserve the natural environment,

maximises benefits to local communities, minimises negative social or environmental impacts, and helps local people conserve fragile cultures, habitats and species whilst maintaining the world’s biodiversity”. The current definition does not place enough emphasis on the protection and conservation of the natural environment and maintenance of biodiversity, which should take precedence in a protected area. 7 DCA (Damage Causing Animal(s)) and HWC Dr. Brandon Anthony Submitted via email on The Acronyms and Abbreviations lists have been updated. (Human Wildlife Conflict) should be included in the n 20 Feb. 2018 Acronyms and Abbreviations.

8 Page numbers should be provided for all items in Dr. Brandon Anthony Submitted via email on Lists of figures, tables and appendices have been included in the Lists of figures, tables and appendices 09 Feb. 2018 contents section and page numbers has been provided for these

items. 9 Replace ‘2.10’ with ‘8.14’ for sub-objective heading Research,Dr. Brandon Anthony Submitted via email on The numbering has been corrected. evaluation, and co-learning. 11 Feb. 2018

10 Heading numbering is inconsistent. Heading 10.8.1 Dr. Brandon Anthony Submitted via email on The heading numbering has been corrected. (p. 164) is followed by 10.6.2. on p. 166. This 10.6. 11 Feb. 2018 numbering continues through page 194, which then follows with 10.7…. (which was already used from pp. 152-164).

11 Regarding section 10.6.8. In last paragraph above Dr. Brandon Anthony Submitted via email on The numbering has been corrected. Table, the text reads, “This programme links with 20 Feb. 2018 high-level objective 8 and objective 8.14 on page 49.” Please note that there is no objective 8.14 (see No. 3 above), and that, should it occur, it would be on page 52 (or elsewhere if text is changed).

12 Regarding section 10.3.5. Typos: Par. 2, last line Dr. Victor W Meyer Submitted via email on Typos have been corrected. should read “... and are context-[,] person- and Park 11 Feb. 2018 [-]specific.” [INS comma and hyphen].

13 Typos: Minter et al. (2004) should read “... Frogs of Dr. Victor W Meyer Submitted via email on Typos have been corrected. South Africa, Lesoth[o] and Swaziland...” [INS 'o']; “... 11 Feb. 2018 Wa[s]hington...” [INS ‘s’]

14 Section 7.2, page 70. “veterinarian gates” should be Dr Ben du Plessis Submitted via email This has been corrected. “veterinary gates” 15 SANParks Board Members and Executive Ms Lisbeth Scalabrini, Written inputs, 4 March We acknowledge your opinion, which is part of a range of opinions Management, Africa Wild 2018 expressed by stakeholders. Viewpoints range from aggressive reduction in elephant numbers through culling, to calls for no We are once again concerned that a plan of this intervention at all. SANParks embrace several lessons and incredible magnitude and global importance has been scientific findings that help to inform management. The role that released very quietly, with no media release and elephants play in socio-economic-ecological systems does not request for stakeholder feedback other than for existing primarily associate with how many elephants there are, but rather participants. with how elephants use landscapes. Impacts that elephants have

on conservation values associate with how intense they use the Upon review, it is of concern that the main priority of landscape – for instance feeding year in and year out in the same Kruger remains commercial in nature, followed by area result in little time for some tree species to recover from such political. Conservation comes in a poor third or fourth, herbivory. The best science available highlights that what with the maintenance of biodiversity first being determines where elephants spend time are firstly, essential mentioned on page 56 as a primary function. resources like water, then high quality food. A third factor that becomes important, particularly in the dry season, is shade and We utterly dispute that moneymaking should be a water to control body temperatures. A fourth factor is how primary concern of Kruger. Similarly, socio-political elephants perceive undesirable features of the landscape such as upliftment and the addressing of land claims are people that are present. In such cases, elephants will have higher political issues beyond the ambit of SANParks, an vigilance, avoid such areas at the appropriate time, or avoid these organisation established for conservation purposes. areas entirely if it is hard for elephants to predict when undesirable There are huge National Departments that deal with features of the landscape will be present. In this sense humans these issues, and it is entirely unwaranted for used to be an ecosystem driver, which is now absent or limited. conservationists to be spuriously tasked with the SANParks thus seek to restore the ecological process that above. generates gradients in these resources. To achieve this, the approved elephant management plan of KNP seeks to restore In the same vein, we find the gist of the preamble to the natural gradients of water availability, hence the closing of places Plan to be sanctimonious and condescending where authorities provided additional water. SANParks are also regarding the Mission and Vision of SANParks, and reconnecting areas through partnerships with neighbours and the thereby Kruger. Basically it is a case of 243 pages of lifting of fences that allow elephants to respond spatially to gradients stating what has been decided and that is how it will be. of food and comfort (e.g. shade) resources. A key challenge is to We are under no illusions, from past experience, that create the variable levels of perceptions that elephants may have this public participation process will be a rubber-stamp about undesirable features, often associated with humans, in the affair, as little mention is made of concerns raised at landscape. It is for this reason why SANParks seek to make use of high levels over the previous ten years other then them various passive and active techniques to disturb elephants and being incorporated in a pre-concluded fashion. “create local zones of high vigilance”. The term “landscapes of fear” used previously provides potential for misinterpretation. Culling in The Strategic Adaptive Management approach that has the traditional sense and meaning are therefore only considered in been taken is fundamentally flawed here in the sense the above context. This approach allows SANParks to responsibly that the outcomes have been pre-ordained, thereby manage the benefits and risks associated with elephants. pre-empting the consultation process. Telling is the fact that existing planned improvements will continue and The review of the KNP Management Plan followed the legal no new ones after that in the Southern Section. Said framework and SANParks Policy framework. Stakeholder inputs improvements are truly massive in scale and warrant a forms one of the aspects that has to be considered. SANParks has ten-year expansion programme on their own. a dual mission which includes conservation and tourism. Note that less than 1% of the current Kruger footprint is developed for tourism. Furthermore, while offensive terms such as "purist", "fortress conservation" and "Western Noses" (foreign Please refer to the Executive summary. opinions on Kruger management) are thankfully absent in the Mission, the general attitude of certain stakeholders' interests being elevated above those of others patently remains, apparently on a racial basis. This is unacceptable given the fact that despite various initiatives, and for various reasons, Kruger's source of 33

income largely remains the reliable middle class white tourist. It is a simple fact.

More importantly, in the current climate of rampant corruption in South Africa, coupled with economic failure, we find continued investment of taxpayers' money (be it by SANParks or Ministries) into various extremely expensive capital ventures in Kruger to be extremely imprudent to say the least. We conservatively estimate the cost of said ventures to be in the range of R2 000 000 000, with little scientifically- researched justification and little chance of recoupment within the 10-year framework given. While projects such as the R260 000 000 Skukuza Conference Lodge are in progress and have been approved, that does not mean that they do not set a very serious precedent for the future, especially regarding privatisation of taxpayer assets, an acknowledged possible outcome.

Similarly, financial red flags are raised regarding the implementation of an 11.3% increase in Conservation Levy due to rhino poaching, and generally dubious financial statements indicating a shortfall in budget while a profit is simultaneously claimed.

More specifically regarding conservation, there is a lack of significant appraisal of the elephant overpopulation question. This is the most important problem faced by Kruger regarding biodiversity, and is being ignored for anthropomorphic reasons. It is ironic that sustained culling of elephant would arguably solve the protein deficiency needs of all impoverished communities in the Kruger area, if not the subcontinent, thereby fulfilling all the socio-political mandates that SANParks have ascribed to themselves. In the short term we request that all tourist infrastructure development in Kruger Park, both current and future, be placed on hold pending Parliamentary Scrutiny. 16 MANAGEMENT PLAN REVIEW – KRUGER PARK Ms Penny Legg Written inputs, 3 March The issues raised are noted. We are confident that the 54 2018 workshops have provided a basis to understand the range of values MANDATE and opinions of stakeholders. The Management plan will address It would be hoped that the SanParks role in maintaining these, and annual feedback will be provided to the full range of the biodiversity of such a magnificent World Heritage stakeholders to keep parties abreast of emerging issues, and how

Site (which should be declared) such as the Kruger these matters are being addressed. See also the reply to comment National Park should be excercised using total 15. transparency and accountability. Sadly many South Africans feel that this has not been the case. Please note that the inputs were not received in the requested It would appear that there has been a lack of political template format. will in many spheres to uphold the ethos of KNP as a place to be trodden on lightly and great respect for the tremendous biodiversity should in the same vein not be taken lightly. This requires extreme environmental conscience and when one gets the perception that commercialisation (money above everything else) becomes the driving force then one has to believe that it is a matter of time before this would be tantamount to killing the goose that lays the golden egg. Is conservation bowing to commercialisation? There is a plethora of information that there are virtually no legal guarantees that will safeguard the ethos of our Parks and stop them from being over developed. The Kruger National Park’s Mission Statement is “To maintain biodiversity in all its natural facets and fluxes and to provide human benefits in keeping with the mission of the SANP in a manner which detracts as little as possible from the wilderness qualities of the KNP”. This is fully covered by NEMA. SANParks are bound by the Environment Conservation Acrt (ECA) No. 73 of 1989 as well as the EIA Regulations and Guidelines pertaining to the ECA, and the National Water Act (NWA) (NO. 36 of 1998) AND the National Environmental Management act (NEMA) (No. 107 of 1998 and the National Parks Act (NPA) No. 52 of 1976 and the Principles and Procedures of Integrated Environmental Management (IEM) under NEMA.

This mandate has, in many people’s opinion, been irrevocably changed in complete conflict with itself by the granting of the concessions, the continued barrage of new developments in the form of HUBS, hotels, allowing the culling of buffalo and hippo to show goodwill to communities, all sorts of hair brained schemes from tented camps to the erection of tents to private companies within camps for glamping, to new tarred roads that appear to be forging ahead despite the fact that an initial BAR has not even been completed, to allowing Kruger to be used as a thoroughfare without jurisdiction, to the complete abuse 35

of gates and roads throughout the night, to the labour dispute now playing itself out with a franchise holder who is still operating in KNP but not under the franchise banner, to the protection of wildlife – with specific regard to rhino and elephant.

NEW REGIME How will the possibility of a totally new government structure in the very near foreseeable future affect SANParks ability to guarantee that the Kruger National Park is kept in as pristine a condition as possible for future generations?

EXCESS ACCOMMODATION AND MAINTENANCE How will SANParks deal with all of the accommodation that they will, within the time frame of this management plan, find reverting to them. Please note in this regard that it was legislated at the time of the granting of the concessions that they would only last for 20 years and that there was also no right to renew or right of first refusal. Please also remember that at the time the esteemed Dr. Ian Player believed that these concessions were ill conceived and had grave doubts as to their role in making KNP accessible to ALL South Africans as they were aimed at an elite and extremely upmarket overseas clientele. Much of the accommodation in Kruger Park is in desperate need of constant maintenance not emergency repairs and sadly the pricing structure of the current SANParks accommodation has put it beyond the realm of most for an affordable bush holiday.

PUBLIC INPUT This should not be perceived by SANParks as a token gesture and nor should they see the meetings currently being held as having met due process and that they were now entitled to rubber stamp all commercial planned activities having supposedly followed due process. Given that this due process was NOT followed in the case of the concessions, must we believe that SANParks will now not take into account the chance for the public as well as specialists in their fields to contest these processes. After an extremely limited and small public participation process the concessions were granted as is and passed with the

public hardly being aware that in excess of 100 000 hectares had been signed away to concession holders.

POACHING There is not a single person in the world who is conservation minded, nor in the hearts of most South Africans, that does not abhor poaching and the relentless killing of our wildlife. This is a scourge that must be fought with full political will and the added commercialisation of the KNP will simply add to this scourge. Already, the usage of gates and the abuse of them and roads throughout the night by concession holders and staff is a major cause for concern. It is doubtful whether SANParks is in full control as to who is staying in their staff villages, who is driving armed and with dubious intent through their gates and who is setting the thousands of shameful snares that are to be found throughout the Park. The baiting and luring of big cats is a major problem and if not tackled this will damage the integrity of SANParks as many see the hunting alongside original Park boundaries in the Timbavati and APNR as well as the Greater Frontier Park on the Eastern boundary as nothing more than legal poaching. This has to be stopped. The Park needs to be cleansed from the inside out and SANParks needs to be at the forefront of doing this whether it be in the form of increased boots on the ground, cutting cell phone signals, lifestyle audits, lie detector tests, sniffer dogs that are utilised in staff camps in surprise raids and any other tool in their armoury. This is a war that has to be won!!!!!

FINALLY – OUR FINANCIAL STAKE Not only are we concerned stakeholders but many of us who have been loyal to SANParks have spent in excess of HALF A MILLION RAND, some way more, others less, over our lifetimes to avail ourselves of the spiritual renewal and awakening that Kruger affords everyone.

Please do not let South Africans down in your endeavour to commercialise KNP – it’s the most tranquil place on earth according to the civet!

IS LIFE TRANQUIL ASKS THE CIVET? 37

ALL DEPENDS ON HOW YOU LIVE IT! AND TO THIS RHETORIC QUESTION, I MUST POSE YOU A SUGGESTION! THOUGH THE QUESTION IS ABSORBING, SO THE ANSWER IS REWARDING! TO BE TRANQUIL IS NOT EASY! LIFES’ NOT ALWAYS BRIGHT AND BREEZY! TRY TO LIVE IT LIKE THE CIVET TRY TO LOVE IT AND TO LIVE IT! 17 Figure 1 is quite blurry. Suggest a higher resolution Mr David Marnewick, Written inputs. 9 March Noted and addressed. copy is inserted in the final plan. EWT 2018 18 (Appendix 4) should be (Appendix 5). Appendix 4 is the Mr David Marnewick, Written inputs. 9 March Noted and addressed. land types. EWT 2018 19 10.1. Should the LLPs be added as addenda to the Mr David Marnewick, Written inputs. 9 March The below extraction indicates the various designations based on plan? The LLP for the “Species of Special Concern EWT 2018 SANParks’ Species of Special Concern monitoring programme and Programme” should be made available to assess the policies: rationale for certain species being listed as SSCs. Species of Special Concern is largely an administrative designation or grouping. These include (i) red list taxa from local to regional scales; (ii) taxa without a formal conservation status assessment or with insufficient data; (iii) listed in the NEM: BA Threatened or Protected species regulations (TOPS) Regulations on CITES appendices; (iv) species which is subject to a Biodiversity Management Plan as per NEM: BA and NEM: PAA; (v) endemic taxa that has >80% of range confined to a Park; (vi) reintroduced taxa that were extinct or threatened or indigenous species recently introduced and (vii) locally threatened populations. These categories also include species with a data deficient status especially invertebrates such as the green ducetia Ducetia chelocerca, Rentz's ambush katydid Peringueyella rentzi and the Jambila seedpod shieldback Thoracistus jambila. Some of these species have no records inside the Park but were collected near the Park. Apart from these principal definitions, species may also be of special concern if (i) threatened taxa were monitored in the past, but the conservation status has improved; (ii) taxa are functionally important or key species; (iii) taxa are selected or common species; (iv) species with social or cultural value; (v) taxa that are subject to resource use and legitimate sustainable harvesting; (vi) species listed under relevant international

conventions other than CITES. These above designations that can make-up species of special concern, pose some key challenges in defining a list for the Park largely because species of special concern can nearly be any kind of species and are context- person- and Park specific 20 Appendices should include TPCs for all species Mr David Marnewick, Written inputs. 9 March For most species there are no defined TPCs. This is largely (especially those listed as SSC in KNP). EWT 2018 because it is a hard concept to define ecologically and transparently.

Though TPCs have proven very useful in less complex programmes such as alien biota, macroinvertebrate monitoring and fire management where management and intervention thresholds are fixed, they have proven less useful in more complex environments, where mechanisms approaches are preferred. This is the very nature of adaptive management and learning by doing. 21 EWT is committed to assisting SANParks with the Mr David Marnewick, Written inputs. 9 March Thank you. SANParks is committed to strengthen relationships with implementation of this management plan across a EWT 2018 co-operative partners. range of objectives and would be happy to discuss 22 Effective Park Management: Correct numbering of Ms Kim Da Ribeira, Written inputs, 10 Noted and addressed. LLPs OSCAP March 2018 23 Kruger National Park Management Authority has a GMFER Written inputs, 9 March We take note of your opinion. KNP has consulted with a broad once in a decade opportunity to put a plan into place 2018 range of stakeholders through 54 public and focus group meetings. that utilizes best conservation and eco tourism We are confident that the Management Plan represents the management practices. Unfortunately for the elephants mandate of SANParks, whilst also addressing the broader and other wildlife residing in and around KNP, this is stakeholder values, interests and the required responsiveness to not that plan. Instead it harkens back to Kruger's late emerging drivers within the broader landscape. KNP will provide 19th and early 20th century roots and colonial annual feedback on progress made to ensure that stakeholders are sensibilities of the deluxe safaris and all the appropriately informed. exploitations that those practices entailed. This plan could and should reflect a South Africa that is independent and forward looking: a model for conservation and responsible tourism for the entire African content, and, indeed, the rest of the world. 24 SUMMARY: GMFER Written inputs, 9 March Thank you for your concern and input. Your views are part of a 2018 range of views with regards to elephant management. Please see As far as elephant conservation is concerned, this draft also the reply to comment 15 in this regard for further details. document is a miscarriage of conservation philosophy and practice rather than a serious conservation endeavor seeking serious and considered input. As such, its finalization should be delayed for at least one calendar month until the stakeholders envisioned in Sections 39, 40, and 41 in NEM: PAA (of 2003) per mandate, can read, research, and properly respond to this plan.

Wildlife in Kruger are its inhabitants and should be seen as primary stakeholders. Elephants are not “inventory” to be distributed and disposed of according to the interests of ambiguous motives affected by pecuniary interests and DEAT preferences for usage in amenities planned for Kruger. 25 Conclusion: GMFER Written inputs, 9 March We thank you for your opinion on the science basis of herbivore This draft for the Management Plan of 2018-2028 does 2018 management. SANParks embrace all science to provide the not fulfill the primary mission of Kruger National Park. framework guiding management. Please see also the reply to The draft plan does not use highest scientific research comment 15 in this regard for further details. standards for conservation, most particularly regarding elephants and the “Herbivory” section. This report is also incomplete. There are blank sections that need oversight by law. It cannot be left to adding Stakeholder input after the management plan is officially approved. The entire report must be available for all critiques from all legally mandated stakeholders—as it stands there is a lack of transparency. Therefore, this report cannot be finalized and authorized as stands without oversight by all stakeholders and appropriate governmental and non- governmental agencies. Commenting Period SHOULD BE EXTENDED, Conservation Scientists consulted, and appropriate changes to the draft made. 26 CONCERNS: LEGAL AND OTHER ISSUES ARISING GMFER Written inputs, 9 March Stakeholders are defined as per the legal definition in the National FROM THIS DOCUMENT 2018 Environmental Management: Biodiversity Act as the National Choices for stakeholders and the legal definition of Environmental Management: Protected Areas Act does not have a them; internal inconsistencies in terminologies and in definition for stakeholders. We hope that after revising the draft with logic within the document; poor and incomprehensible the input received from stakeholders that all inconsistencies drafting; incompleteness of research and composition regarding terminology and logic wil have been rectified. Research of draft document; inappropriate goals in opposition to will never be complete and we acknowledge that we do not know “responsible tourism” for Kruger National Park; no everything; this is the departure point of Strategic Adaptive presentation of stakeholder input; failure to fulfill the Management. However, the plan is clear that research is an foundational mission of Kruger National Park important component and that this is supported on an ongoing basis. There will always be conflicting objectives, what is more importatnt is how it’s addressed. Ultimately the park might have to make certain trade-offs to ensure that the objectives are achieved. This is definately not the depature point but rather last option. The stakeholder input has been summarised in Appendix 2 in the draft management plan and discussed in detail in this report. The Mission has changed slightly in the new version and it is too early to state that park management has failed in the fulfillment of the Mission.

This success or failure will only become clear over the next couple of years. 27 The Authorization statement evades acknowledgement GMFER Written inputs, 9 March The format of the plan is in accordance to the DEA guidelines and of legally mandated management criteria. And the draft 2018 Section 40 of NEM: PAA. These aspects have been addressed in document does not fulfill it. the KNP Management Plan, Sections 2, 3, 5, and consultation (Section 4 of the Management Plan) has been in accordance to The Authorization statement evades acknowledgement Section 40 of NEM: PAA. of legally mandated management criteria. And the draft document does not fulfill it.

The Authorization Page mentions two items that are required for the plan to be authorized. These occur in the NEM: PAA concerning the Preparation of a Management Plan (section 39) and the Management Plan itself (section 41) and the format it should take.

NOT mentioned on this page is Section 40 of this same legal document, which concerns Management Criteria. The first provision of which is: 40. (1) The management authority must manage the area- (a) exclusively for the purpose for which it was declared (emphasis added) and (b) in accordance with- (i) the management plan for the area (emphasis added and in consideration of UNESCO requirements); (ii) this Act, the Biodiversity Act, the National Environmental Management Act and any other applicable national legislation; (iii) any applicable provincial legislation, in the case of a provincial protected area; and (iv) any applicable municipal by-laws, in the case of a local protected area. (2) The management authority may amend the management plan by agreement with the Minister or the MEC, as the case may be.

Unless Section 40 is specifically noted, and adhered to, this draft document DOES NOT FULFILL ITS FOUNDATIONAL MISSION as mandated by law.

Link: NEM:PAA https://www.environment.gov.za/…/l…/nema_amend ment_act57.pdf 28 The MTPA appreciates the opportunity to comment, Mr Johan Eksteen, Written inputs, 9 March The current format follows the DEA framework. Regarding the provide information and to express an opinion with MTPA 2018 LLPs: the summary of these plans were included in the 41

respect to the Draft Kruger National Park Management Management Plan, and the lower level plans could be requested. Plan. These will be reviewed on an annual basis as guided through the strategic adaptive management process. The format of the reviewed plan is different to the KNP Management Plan of 2008. It is noted that several programs in the reviewed plan are supported by detailed lower level plans, especially w.r.t. Biodiversity. The lower level plans are not included in the draft plan, and it is therefore not possible to comment on those programs.

29 Table 14: The list of priority IAS species refer. KNP Mr Johan Eksteen, Written inputs, 9 March This will be addressed within the operational implementation plans, should note that PomPom (Campuloclinium MTPA 2018 which seeks to prioritise IAS clearing in collaboration with the macrocephalum) is already present in the Crocodile Provincial WfW offices, focussing on areas and catchments Gorge Conservancy. Once it reaches the KNP, control external to KNP. The Biodiversity Social Projects team will monitor should be started asap. the situation closely and will liaise with the MTPA, Regional WfW and other interested parties to ensure an integrated catchment approach. 30 1. Ethics \AUCC Committee: whilst not listed in the Ms Karen Trendler, Written Input As part of SANParks due diligence, any animal interventions are Management Plan, many of the activities listed in the National Council of conducted within the ambits of the law and subject to approval by Plan need to be evaluated by an Ethics \ AUCC SPCAs the SANParks ethics committee. This is a constituted committee Committee. Apparently the establishment of or the and its TORs have recently been reviewed with new members inclusion of an NSPCA representative is on the cards, having been nominated for board approval, including a SPCA this is still and has been pending for an extended representative period. Would like to submit that this be implemented with immediate effect. 31 I would like to make an observation. There seems to Mr John Scutcher 12 February 2018, It is a fair observation and your concern is understandable. be a lot of questions on tourism, visitor management Durban SANParks have to generate 85 % of its own required budget, only and infrastructure but very little in the way of wildlife 15 % is provided by Government. The KNP provides the largest part management. I almost get the feeling that you cater of this income; hence, tourism is also a focus of KNP, to generate more for tourism and the enjoyment by tourist than for this income but especially to make Kruger accessible to the public. wildlife management. Stakeholders / tourists KNP management attempts to provide a range of experiences. experience and perception of the Park could be Unfortunately, the conservation emphasis is normally out of site affected by the state of infrastructure, while losing even though it is of international standard. Research has been going focus of the bigger picture, namely conservation. on since 1950 and currently there are about 200 active research projects in the Park, including many by non-SANParks national and international scientists. The annual Savanna Science Network Meeting brings together a range of researchers that share knowledge. Some of our conservation policies also change over time based on the knowledge that was gained. The fire policy was changed 6 times over the last 7 decades. During the recent drought, due to the improved water policy the Park was better off than during the droughts of the 1990s and none if its perennial rivers stopped flowing. We acknowledge that we need to improve communication between the Park and stakeholders / visitors.

During our initial public workshops in April and May 2017 one of the main issues raised were job creation. In fact the social aspect, in and around the Park, were by far the highest mentioned theme, while conservation matters were far lower down the list

SECTION 2

No. Comment / Input Commentator/s Reference Official response 32 The declaration of the Kruger National Park is Dr. Michael Brett Written input, 11 Feb. The section has been updated based on the land audit register and incomplete and does not include the 7 farms 2018 includes all farms that were donated by the Orpens. purchased by Eileen Orpen in the vicinity of Orpen from 1935 to 1944 and totalling 24,529 ha. 33 Section 2.12.6. Add to sentence: “populations. This Mr David Marnewick, Written Input, 9 March This has been incorporated. Sentence rephrased as follows: This together with the scant bird population data currently EWT 2018 means that efficient and relevant long-term monitoring of bird available for the Park means that efficient and relevant populations both inside and outside the park is essential for the long-term monitoring of bird populations both inside conservation of the Park’s avifaunal population. and outside the Park is essential to the conservation (Section 2.12.6) of the Park’s avifaunal population 34 Add to this sentence “Furthermore, several threats Mr David Marnewick, Written Input, 9 March The specific threats for the park is already incorporated facing the Park such as river system deterioration, loss EWT 2018 (Section 2.12.6) of riparian vegetation, bush thickening and encroachment and loss of large trees can have drastic effects on bird populations.” an additional significant threat is mortalities caused by electrical infrastructure. The Eskom/EWT partnership has recorded more than 7,200 mortalities on electrical infrastructure across South Africa, this includes close to 2,000 vulture related incidents. Seeing that vultures are mentioned in this section, we feel that this anthropogenic threat should be included here. 35 P28: ( humans) were an important ecosystem driver— Prof Van Helden Written inputs, 6 March The definition of a benchmark, which the comment implies, is a key 2018 challenge – hence the approach to manage in a way that allow Yes, I might agree, but only in relatively modern times. ecosystem processes an opportunity to play out. We acknowledge Modern of course needs a time statement, but I would the disturbance of modern day man. Man as an ecological driver define modern in terms of perhaps 2-20000 years. I in historic times, however, would have different spatial extents think this statement needs to be very carefully associated with key resources that humans needed. This is a driver managed and not lend itself to being overemphasized. that SANParks can only mimic and how to implement it will be the It depends on what “time slot” KNP wishes to be in. focus of science in the next decade or so. Today, human activities in the Park could be said to replace human pressure in the past. Just as one example, the current guest accommodation is about 8881 persons. In addition to that, there are many staff living in the Park, including SANParks staff and

concessionaires. Then there is a constant daily stream of “contract workers” and outside workers, e.g. supply truck drivers, as well as undesirables, such as poachers. These people drive, walk, camp, patrol, poach, utilise resources and cause fire. All those people have an impact on the landscape, and by their presence can create disturbances and generate a “landscape of fear”. In terms of ecosystem disturbances, this is not necessarily substantially different from human disturbances in “modern or past times”. To say that humans as a driver are no longer there is arguably wrong and might invite ideas of reoccupation.

36 “Primary threats for large and mega herbivores, as Mr David Marnewick, Written inputs, 9 March The sentence has been changed in the Management Plan as well as large carnivores are poaching for valuable EWT 2018 follows: wildlife products and non-sustainable contribution to The primary threats for large and mega-herbivores, as well as large the wildlife economy transformation initiatives in South carnivores currently is poaching for valuable wildlife products and Africa.” This sentence needs adding to as the threat of disease to some extent. The recent distemper outbreak in a pack disease is high for carnivore species. This is of wild dogs in KNP highlights that introduced or emerging diseases evidenced by the loss of the Lower Sabie pack of Wild can threaten rare species with localised extirpation. (Section Dogs in mid-2016 and further in South Africa, the 2.12.6) further loss of another two packs (25 individuals in total) in mid-2016 (Wild Dog Advisory Group of South Africa minutes, 2016). Additionally, the case of rabies in a pack of Wild Dogs in Blue Canyon Conservancy (part of K2C) also highlights the proximity of this disease to the Park. 37 Regarding section 2.12.6. A mere mention of termite Dr. Victor W Meyer Written inputs, 11 Feb. SANParks fully acknowledges the key role played by termites in fauna is not sufficient to direct the management of 2018 nutrient cycling and ecosystem engineering, however our natural resources, of which termites make out a ecosystem approach and landscape level management philosophy substantive part (see separate motivation). means that we manage and mitigate threats at a landscape level

and assume that this will create the landscapes for species to thrive. The termite ecosystem inside the park is thriving with no hostile anthropogenic activities detected that will harm termite species within the park. 38 Regarding section 2.12.6. The number of termite Dr. Victor W Meyer Written input, 11 Feb. Thank you, addressed. Species lists are also continuously being species found in Kruger are far more than 20, as 22 2018 updated as new species are discovered in the park. genera are known to occur (Coaton, 1962). At least 11 species of mound-building termites alone are mentioned in Meyer et al. (1999), of which five species belong to the genus Macrotermes.

39 Regarding section 2.12.6. New discovery of an isopod Dr. Victor W Meyer Written input, 11 Feb. Thanks for bringing it to our attention. Species lists are continuously species (woodlouse) – see below description. 2018 being updated as new species are discovered in the Park. This

record will be added. 40 Section 2.7, Page 17. The explanation of the highest Mr Frans (surname not Written inputs, 7 March The highest point in the park is Khandizwe hill at 839 m (2,751 feet) point and the Airspace is confusing. The highest point captured) 2018 above mean sea level (AMSL). The latter is of note, for the airspace is Khandizwe at 839 m (2,753 ft AMSL) above sea above the Park up to 2,500 feet above the highest point, as per level. The airspace 2500 ft (762m) above that is also legislation, is also deemed National Park (Appendix 7, Map 2a-b). deemed National Park. Thus the airspace from Thus, the Park’s airspace ranges from anywhere in the Park anywhere in the Park to an altitude of 1601 m (AMSL) (ground level) up to 1,601 m (5,252 feet) AMSL. or 5,253 feet (AMSL) is deemed National Park. 41 Section 2.11: Environmental Authorisations. Re the Ms Kim Ra Ribeira, Written inputs, 10 The gate has been requested by people living along the Park in that Shangoni Gate development and activity hub OSCAP OSCAP March 2018 area who have to travell more than 100 km to Phalaborwa or Punda comment: Questions have been asked in the past re Maria Gates in order to gain access to the Park which is just a stone the conservation-related justification for this project throw from their homes. SANParks have been considering this gate which have yet to be answered, will we be receiving for the past 2 decades and is currently in the EIA phase. an answer to this question/request? 42 2.12.6 Fauna. Re: ‘Although the poaching of white and Ms Kim Ra Ribeira, Written inputs, 10 As responsible managers, SANParks will identify key threats to black rhinoceroses is a key feature in the public OSCAP March 2018 achieving objectives. Logically if these associate with social domain, the legacy of social injustice remains as the injustices, then it becomes part of SANParks suite of options to primary challenge to address in order to ensure the manage threats. intactness of the Park’s mammal assemblages in future.’

OSCAP comment: Are addressing social injustices a mandate/responsibility that SANParks and DEA carry? 43 2.13 Archaeology and cultural heritage. Re: It is Ms Kim Ra Ribeira, Written inputs, 10 Thank you, your comment is noted. See also reply no 35 estimated that the human population in the Park may OSCAP March 2018 have peaked at 16,000 people, a number large enough to have had a significant influence on the ecosystem as an important ecosystem driver – a driver that is largely missing in the current context.

OSCAP comment: Surely the impact of tourism and permanent and temporary staff in KNP off-set this, the Park currently has capacity to accommodate 8,881 overnight guests? 44 2.15 Tourism. Re: During the previous financial year Ms Kim Ra Ribeira, Written inputs, 10 Visitor Management has been elevated as a function that is crucial (2016 / 2017) a record number of 1,817,724 guests OSCAP March 2018 in managing the increasing number of visitor to the Park and in entered Kruger access points particular managing the areas of potential overcrowding. Park management does not believe that thresholds alone will suffice in OSCAP comment: managing possible over-tourism but views visitor management • At what point will this figure be ‘capped’ surely the fulfilling an integrated function in managing possible over-tourism. Park is limited as to how many guests it can This would include components such as additional points for guests accommodate comfortably and still maintain Objective to alight from vehicles, closely monitoring key touchpoints e.g., 45

4.2 Diverse products and experiences objective: To traffic, ablutions, providing alternative transport solutions, co- grow income through tourism by providing visitors with ordinated law-enforcement, etc. an appropriate and a diverse range of products and services, whilst protecting the tranquillity and sense of place. • We are concerned that it is envisaged that there will be 2,2 million visitors per year in ten years’ time • Currently there is a lack of law enforcement capacity in the Park, the number of visitor transgressions bears testimony to this, we cannot expect that ‘ the tranquillity and sense of place’ will be maintained going forward if the Park places such a high emphasis on increasing tourist numbers. 45 Section 5.2.9.1. Mr Johan Eksteen, Written inputs, 9 March High-level meetings are in process with the MTPA, DEA, LEDET, MTPA 2018 GLTFCA Joint Management Board, conservation partners and The addition of Regional Integration as a High level sectors, as guided by the GLTP Treaty. The GLTFCA Co-operative objective is noted. This will result in ‘new’ interactions Agreement and GLTFCA Integrated land use/sectors agreement between KNP, MTPA and other role-players in the are in process, specifying envisaged outcomes, roles and region. We trust that these activities will be clarified responsibilities. This is linked to a joint implementation plan and and discussed as the plan approval and guided by consistent guidelines in pursue of co-operative implementation progress. outcomes, joint risk mitigation, incentives and efficient resourcing for the open conservation system, as well as adjacent land use practices. This is also a key step towards alignment with the municipal LUMS and SPLUMA, Bioregional plans and SDFs. Moving forward, a key focus will need to be on the institutional review, supported by stakeholder consultation, of the GLTFCA conservation network and enabling institutional environment. Several focus group workshops have been conducted in the past year, attended by conservation entities, MTPA, DEA, LEDET, GLTFCA partners in pursue of better aligned and consistent practices. This will be formalised through the afore-mentioned agreements and operationalised through respective entities management plans. An executive structure will provide oversight on the implementation, monitoring and evaluation. Charters/Terms of References are being co-developed to clarify roles and responsibilities, especially with respect to concurrent conservation functions (National vs. provincial legislation and mandates). Please refer to Section 10.2 for more detail.

SECTION 3

No. Comment / Input Commentator/s Reference Official response 46 Major threat: perceived economic opportunities will Prof Van Helden Written input, 6 March We thank you for your input. We would be interested in the attract more and more people to move into 2018 evidence-basis of your concern. communities next to Parks and create huge problems. This effect has been documented in other Parks in Africa.

47 Figure 2 – under the operationalise box, why only list Mr David Marneweck, Written Input Thank you for your input. It is not the TPCs that are listed but the TPCs? We suggest an additional point to implement EWT Management Options to implement once the TPC have been actions when TPCs reached. exceeded. (Section 3.2)

SECTION 4

No. Comment / Input Commentator/s Reference Official response 48 Section 4: threats: major problem is access to KNP via Prof Van Helden Written input, 6 March We thank you for your input, but do not agree with statements very poor roads outside Kruger, which run through 2018 made. Access roads to Kruger’s main gates are all national tar protest inclined, and crime-ridden communities, roads in fair to good condition. Access is rarely denied to visitors by making tourist access unsafe. demonstrating communities, however, it is a concern that this seems to be getting more frequent. We would be interested in the evidence-basis of your claims.

SECTION 5

No. Comment / Input Commentator/s Reference Official response 49 P41 section 5.2.7: could go to section 2? A major threat Prof Van Helden Written input, 6 March Section 2 states the status quo regarding certain aspects of the should include excessive visitor pressure creating 2018 KNP. Unfortunately, we cannot move section 5.2.7 to section 2 as pressure on the ecosystem. Not only that, but excessive this is a key component of the Desired State. The Desired State is visitors detract from visitor experience and enjoyment. made-up of the Mission, vital attributes (determinants and threats) (Simply noting the stream of complaints on social media and the hierarchy of objectives. about safari vehicles and excessive and poor tourist behaviour should be convincing enough for this last point:

50 Section 5.2.4. Dr Audrey Delsink Written inputs, 9 March We thank you for your comment and opinion. Note that we have 2018 adapted the text in the relevant section about herbivore Operating principles or values lists the following: management. Corporate values:

2. Be guided by environmental ethics in all we do;

Biodiversity values:

3. We can intervene in ecosystems responsibly and sustainably, but we focus management on complementing natural processes under a "minimum interference" philosophy; and

4. We accept with humility the mandate of custodianship of biodiversity for future generations while recognising that both natural and social systems change over time.

These values appear to be mismatched and challenged by the sub-objective to “establish a landscape of fear” under the higher-level objective as stated in the table “in such a manner as to conserve and restore its varied natural structure, function and composition over time and space, and its wilderness qualities”.

51 Section 5.2.8 Dr Audrey Delsink Written input, 9 March The definition cannot be included in figure 6. It has been included 2018 in the Glossary. Include the above definition of “Responsible Tourism” in the diagram.

52 P48: Herbivory objective: 2.1 and 2.2 could almost be Prof Van Helden Written input, 6 March Thank you, we have addressed this in the objectives and sub- seen in opposition, since 2.1 is to “establish”, whilst 2.2 2018 objectives. Please note that bioprospecting does not refer to is to “restore”. Should KNP be “establishing” in this mining, but to the responsible use of plant tissue, as guided by the context? Note that KNP is an ecosystem that is now legal framework on Bioprospecting. enclosed and limiting. We need to be careful with this point I think. Unfortunately, I have not come up with something better to suggest.

Wilderness High Level Objective: I am not convinced that one can have wilderness by means of “Park development’. Maybe by management, perhaps.

Socio-economics: 6.1: “facilitate transformation of the wildlife sector by land access”. This sounds to me like

“give land to people”. If so, then I cannot in any way agree to this point. Remove or drastically Rephrase.

6.2: likewise, bioprospecting should not be allowed. The next step is mineral or mining prospecting.

6.6: “support successful, (i.e. accredited and approved) land claims, not ANY land claim.

53 Comment on Page 39 Mr KN Written input, 8 March Stakeholder engagement and communication will enjoy a key focus MASWANGANYI. 2018. with the implementation of the management plan and is addressed Park management must ensure an integrated approach (ALTEIN CIVIC in Sections 10.8 and 10.9.9. is followed regarding the implementation of the CHAIRPERSON) SANParks Strategic Plan and the Management Plan The KNP Management plan will also place much more emphasis on the Cultural Heritage Programme (Section 10.6) and the Socio- Your planned integrated approach that may be uplifted economic Development Programme (Section 10.7) towards a by adjacent communities of Mtititi to the KNP is slightly holistic approach of better harmonising this with the conservation not marketed to the most relevant people who are focus. always treasuring the heritage site (KNP) by avoiding poaching and vandalizing its properties.

Closest consultation and general participation by KNP to communities such as Mtititi who are seldom visited (visitation is seen when there are problems within the Park) should be part of this management programme in order for the community to continue protect the Park with pride and ownership.

Regular visits shall instil a fruitful knowledge to Mtititi communities to begin to love the Park and avoid ill- treated behaviour to natural animals and trees treasured by the Park and the surrounding areas.

54 Vision: A sustainable national Park system connecting Mr KN Written input, 8 March Thank you, we take note of your comment. The SED department society. MASWANGANYI 2018. will engage with you with respect to the damage causing animals, (ALTEIN CIVIC as well as the compensation. The vision statement does not empower the residents of CHAIRPERSON) the adjacent community of Mtititi-Altein village. Numerous claims to the SANPARKS in relation to domestic animals killed by your dangerous wild cats stand unpaid to date.

The South African government is always educating communities about compensation to the affected parties in that regard.

55 Section 5.2.3. The following sentences sum up the fears Ms Lorinda Written inputs, 10 We take note of your opinion and sentiment. SANParks have taken most of your long standing, regular visitors have. Steenkamp March 2018 a balanced approach, based on the legal framework and informed Especially South African citizens that view Kruger as by the inputs received through 54 stakeholder workshops. part of our national heritage, a heritage to be preserved SANParks has a dual mission which includes conservation and for future generations: tourism, and currently less than 1% of Kruger is developed for “Kruger North does not have a potential to generate tourism. Large chunks of the remaining area is wilderness or in the income comparable with that of the South, and its process of being restored and officially declared as wilderness. cultural heritage value is slightly higher than that of the South. In other respects the two are similar.”…..” There is potential to generate surplus income over the next ten years.”

It is clear from this management plan that although conservation is mentioned (almost as an afterthought) the main focus is profit.

This is in direct contrast to the mandate of the Park.

One only needs to look at what has been happening in the private sector that is completely profit driven, to realize what grave danger this model will pose for our natural assets.

When senior management has profits as performance targets, there are no holy cows to preserve when aiming for performance bonuses. I can use the Steinhoff debacle as one example.

When profits drive decision making, managers will try and get out as much as they can, while they are still there, with no consideration to the state they will leave the organization in when they are gone. This a pure human nature, self-preservation.

Our National Parks are not supposed to make profits. The sole purpose should be to preserve as much as possible of our natural heritage for generations to come.

I often wonder if SANParks and DEA keep this in mind.

Only 6.71% of our country is classified as protected areas. A shameful figure. Any small fraction of this already small percentage utilized to generate current profit will impact what we leave behind.

Between the race for performance bonuses and the political pressures to reduce subsidies, does anyone even think about future generations? Our duty to them?

56 Section 5.2.7, pages 43-44. Mining in and outside the Mr Frans (surname Written inputs, 3 March These inputs were received during stakeholder workshops and KNP. Mining in the Park cannot be a threat because it is not captured) 2018 refer to broader regional impacts of mining. The desired state illegal, not probable unless there is corruption within the workshops specifically focussed on the broader and adjacent land top management structures. I still do not see that even uses, and how it might impact (positively or negatively) on the if fraudulent mining applications are approved by DMR values and objectives of the KNP. or that Park management were reluctant to object to it that the public nationally and internationally will not allow KNP is part of a larger open system in the GLTFCA, and certain any form of mining in a RSA National Park. The areas that either might be contractually incorporated or are part of Management plan has stated clearly that the whole area the co-operative system of the GLTP and ultimately the GLTFCA, has been proclaimed. The effects of mining outside the do face such potential threats. Once again, the desired state Park and maybe in the buffer might have a negative workshops referred to the broader GLTP and GLTFCA, with the impact such as water pollution but mining in the Park is KNP being the core to this. a no go option. There is no such a threat of mining inside the Park. Also refer to section 7.9 57 Pages 47, 50SANParks Kruger must investigate the Ms Natasha Higgit, Written inputs, 9 March The suggestions will be incorporated in the implementation of the establishment of a Heritage Unit at the Park in order to SAHRA 2018 Management Plan. SANParks will liaise closely with SAHRA in the facilitate the high-level objective of Cultural Heritage implementation of the Cultural Heritage Programme, which will and the implementation of the Lower Level Heritage receive key attention, also in terms of building the relevant capacity. Management Plan. -The inventory of the heritage sites and resources within the Park must be sent to SAHRA as per section 9 of the National Heritage Resources Act, Act 25 of 1999 (NHRA). -All heritage sites and collections to be recorded on the South African Heritage Resources Information System (SAHRIS). SANParks can contact the SAHRA National Inventory Unit for assistance in this regard. 58 5.2.3 SANParks corporate vision Ms Kim Da Ribeira, 10 March, 2018 The duplication has been removed and unclear text addressed. of the desired state OSCAP

Re: Thus, the following strategic direction for the Park has also informed the programmes of implementation (Section 10) of this management plan:

OSCAP comment: This line has been repeated.

Re: Kruger North does not have a potential to generate income comparable with that of the South, and its cultural heritage value is slightly higher than that of the South. In other respects, the two are similar.

Because of its transfrontier status, it has significance in the bioregional context. There is potential to generate surplus income over the next ten years. Socio-economic impact could improve through a post-land claim plan, which could generate economic benefits for communities. There is potential to set an example through the development of sustainable living practices. It is anticipated that the next 20 years will see an increased impact on biodiversity as a result of global environmental change. Risks to biodiversity are high, especially poaching, diminished water quantity and quality and impacts of development in the buffer zone.

OSCAP comment: There are sections of this paragraph that don’t make sense 59 5.2.7 Determinants and risks to the vital Ms Kim Da Ribeira, Written inputs, 10  SANParks realises that numbers cannot always grow, and the Attributes - Re: Lack of infrastructure to accommodate OSCAP March 2018 experience will in some stage be hampered by the volumes increasing visitor numbers  However, numbers only are not a true benchmark as other Parks (i.e. Parks in the USA) have more visitor numbers per 1. A flagship South African wildlife attraction and iconic month than what the KNP has per year but is better managed local experience. hence a combination of visitor numbers and management Threats methods / capability is integral to ensure an optimal Re: Lack of infrastructure to accommodate increasing experience. Other initiatives might include (as example): visitor numbers  Seasonal camps or increased visitation based on water supply – smaller camps in dry years and bigger ones in OSCAP comment: At what point will this figure be wet years ‘capped’ surely the Park is limited as to how many  In future, might decrease self-drive vehicles to guests it can accommodate comfortably and still accommodate more people on Open Safari Vehicles maintain Objective 4.2 Diverse products and  Finding the best balance between day visitors and experiences objective: To grow income through tourism overnight visitors to optimise revenue for conservation; by providing visitors with an appropriate and a diverse and range of products and services, whilst protecting the  Increase support infrastructure such as picnic sites (the tranquillity and sense of place. south a good example) to ensure a more evenly distribution of traffic with associated advantages from an experience point of view. 60 5.2.7 Determinants and risks to the vital Ms Kim Da Ribeira, Written inputs, 10 It is considered as part of the adaptive management decision- Attributes (listed all Vital attributes) OSCAP March 2018 making process

OSCAP comment: We believe all of the above to be vitally important factors that need to be considered in any and all decision making. 61 5.2.9. Unpacking the high-level objectives. Ms Kim Da Ribeira, Written inputs, 10 All natural resources that are sustainably and legally harvested in OSCAP March 2018 KNP are linked to a monitoring and evaluation program. This 2. Biodiversity high-level objective: ensures the sustainability of the resource in KNP and prevents the Re: 2.9 Natural resource use: To support, where illegal harvesting of such products in KNP. There are other possible, social, ecological and economic sustainability mechanisms that are addressing the issues around poaching. All of the greater Kruger Park system by promoting and our resource use projects are closely monitored in terms of their facilitating access to and sustainable use of a range of social, economic and ecological impact across various scales. One natural resource products within and adjacent to the of the goals of promoting sustainable resource use is to build Park. positive relationships locally with people living adjacent to the Park. In the long run we believe that having positive relationships with OSCAP comment: With the current level of poaching in neighbours could have a positive impact on illegal resource use. the Park how will this resource use be monitored and Resource use projects that involve external parties entering the policed to ensure that no other products/resources are Kruger Park are closely monitored from a security perspective by illegally harvested. armed field and section rangers, to both (1) ensure the safety of the participants and (2) to monitor the type, quantity and ways in which resources are being harvested towards sustainability of the Park system. 62 5.2.9. Unpacking the high-level objectives. Ms Kim Da Ribeira, Written inputs, 10 The Biodiversity Economy Strategy through its Wildlife Economy OSCAP March 2018 Programme objectives is to ensure participation of emerging 6. Socio-economic development high-level objective: farmers in the Wildlife Economy value chain, especially 5.2.9. Unpacking the high-level objectives. communities with land. To ensure sustainability, before any game can be donated, a rigorous site inspection is undertaken and a Re: 6.1 Wildlife economy objective: To facilitate the sustainability plan is to be submitted to the Wildlife Steering transformation of the wildlife sector through land access Committee for further scrutiny. The game donation criteria clearly and support programmes for new emerging black game stipulate that monitoring and evaluation will be done annually as farmers. well as game technical support to the beneficiaries. Further to the requirements no game should be harvested between year one to OSCAP comment: year three of donation. No emerging companies should sign • We are concerned about the long-term sustainability of agreement with communities with land during the donation phase, this/these project/s. a rigorous due diligence is undertaken to ensure communities • We are further concerned about the relocation of this companies legal status. wildlife, is wildlife donated to areas that are suitable insofar as habitat and resources are concerned? Or is the wildlife that is donated done so on the basis that it is the game that is available? 63 “Thus, the following strategic direction for the Park has Mr David Marnewick, Written Input The changes have been made. also informed the programmes of implementation EWT (Section 5.2.3) (Section 10) of this management plan:” is repeated from the 1st paragraph and as a standalone in the 2nd. Suggest to delete the 2nd mention. 64 Supporting objective 2.10 (Research, evaluation and Mr David Marnewick, Written Input The changes have been made. co-learning). This should be 8.14 to follow in sequence EWT (Section 5.2.9) 53

from the rest of the supporting objectives under high- level objective 8. 65 5.2.3 “Thus, the following strategic direction for the Park Mr David Marnewick, Written input, 9 March The duplication was removed. has also informed the programmes of implementation EWT 2018 (Section 10) of this management plan:” is repeated from the 1st paragraph and as a standalone in the 2nd. Suggest to delete the 2nd mention. 66 5.2.9 Supporting objective 2.10 (Research, evaluation Mr David Marnewick, Written input, 9 March The changes have been made. and co-learning). This should be 8.14 to follow in EWT 2018 sequence from the rest of the supporting objectives under high-level objective 8.

SECTION 6 CROSS-LINK TO SECTION 9

No. Comment / Input Commentator/s Reference Official response 67 6.6: Table 3. The cell of Wilderness and General Mr David Marnewick, Written inputs, 9 March Noted. characteristics is hard to read due to the photo in the EWT 2018 background. Suggest to remove the photo for this page. 68 Where will you stop with high intensity areas? Concern Ms Lorinda 16 February, White Gravel roads will redirect traffic. Recommendations by a visitor about some zonation areas. Steenkamp River management study will be implemented, and is available. Some areas were incorrectly zoned, and this has been corrected. The key focus through the zonation plan is to ensure that that important biodiversity areas and KNP at large are not detrimentally impacted. We can provide a map of the changes made, and you are welcome to contact the GIS Section. 69 P61: 6.6.2: remote zones: I completely support that Prof Van Helden Written Input, 6 March Noted and agreed. Access and use of the Wilderness and Remote there must be remote/wilderness zones. These zones 2018 zones are strictly controlled and will not be opened for should be visited only by ranger or research staff from indiscriminate activities. Uses of Wilderness or Remote zones for time to time, and possibly by teams doing alien races will be limited to the surrounding road network (which is zoned clearance for example, if needed. In my opinion, there Primitive). Allowing smaller scale activities, such as bicycle trails, must be NO OPTION FOR BICYCLE OR RUNNING OR may be considered with strict guidelines for size and suitable areas, OTHER SPORT ACTIVITES/RACES IN SUCH ZONES. but currently there are no plans for implementing such a product. It has been shown by researchers internationally that the presence of just 6 sporting persons can substantially Whilst it is noted that research into the effect of bicycles or trail alter rare animal behaviour and lead to population running has been undertaken, this research has been done in fairly decline. To allow sport in wilderness zones is to me high volume use areas in the northern hemisphere. More research completely unacceptable on how this translates into an African context is needed.

The Conservation Development Framework (CDF) that will be finalised in 2018 specifically deals with the number of people allowed in a Wilderness area at any one point and the guidelines for specific activities. The principles of maintaining the sense of place - Wildness, remoteness, and solitude - and “touch the earth lightly” will be adhered to in any guidelines put in place.

70 P98: 9.3: communication: I think to allow wifi/cell phone Prof Van Helden Written Input, 6 March There are very different views on the issue of WiFi. Several of the etc connections between camps will encourage 2018 guests feel that they are completely separated from the ‘living poaching and poor visitor behaviour. This should not be world’. The issue of WiFi was raised mainly by people doing repeat an option. Staff communication should be done by visits to the KNP and most of whom are business people. These dedicated and working radio systems, as there used to visitors wish to be able to communicate whilst on holiday and be in KNP. Commercial Safari vehicle radio business. The installation should however be done in a responsible manner, it will be restricted to certain rest camps and sometimes communication should not even be allowed. (refer to only certain areas within the rest camp, and impact will be extensive social media complaints about this). monitored. We do have the necessary systems in place to address the law enforcement aspect. Any installations will also be subject to all environmental assessments and further required research.

The OSV radio issue was attended to by SATSA saying they will monitor if this is abused by the guides. It must also be noted that the KNP did raise the issue with the OSV operators where the operators claimed that that is the only tool they have to communicate with guides for business of the following day not nescessarily for sightings. Hence their commitment to manage the issue. The KNP suggested a MoU in this regard, and this will be addressed accordingly. 71 Is the GLC correctly labelled on the map for the Park, is Dr Richard Davies Written inputs,3 March The Greater Lubombo Conservancy (GLC) is not formally it not formally proclaimed and not just 'Other proclaimed, and is correctly indicated as conservation area (no Conservation areas' see map link formal status). The GLC was the first privately managed area to be included as part of the Great Limpopo Transfrontier Conservation Area (TFCA) for all 3 countries that are members of the GLTP Treaty 72 I reject the entire zoning plan as presented in the Draft Ms Lorinda Written inputs, 10 The intention is not to develop the Tourism Orientated zones in their Management Plan and the accompanying Zoning Maps. Steenkamp March entirety. These zones are all much larger than the envisaged tourism footprint as they include not only the actual development The Zoning Maps are not a reflection of the Zoning Plan. footprint but also a buffer area around these developments. This is included to absorb the impacts of things such as light and noise pollution. The Zoning Maps only display the current Tourism Orientated Zones (Low and High Intensity Leisure). No To ensure that these zones are not developed to their full area there indication is given where the additional +- 2590% are a number of checks and balances in place; provisioned in the zoning plan is planned.  Firstly, there is legislation that sets the maximum extent developments can have in a national park. During the stakeholder’s information session on the  We also have zone guidelines that specifically set out Draft Management Plan a presentation was shown, the number of beds that may be contained in a showing that only 0.69% of the Park is currently utilized contiguous zone, the types of activities as well as the in the Tourism Orientated Zones. No detail was however scale of these activities. given on how this will be increased by approximately  There are further guidelines on the development 2590% to become the 18.59% provisioned in the actual nodes that specify the principles behind each type of zoning plan. development, their zone and size.

The Management Plan also provides no additional information on where this significant development will take place

This is deceitful and goes against the principle of transparency and stakeholder participation.

The zoning plan should not be accepted unless full detail has been made public on where and what developments are planned in the next 10 years. Stakeholders should also be allowed to give their input on this. But this can only happen if full disclosure is made public, which is currently not the case 73 Before embarking on expanding your tourism offering, I Ms Lorinda Written inputs, 10 A 10-year maintenance plan informs the high-level maintenance would suggest an intensive maintenance program of Steenkamp March programme and annual budget requirements. A detailed annual your current facilities. maintenance plan is compiled from the 10-year maintenance plan and is informed by the condition assessments and budget We mostly utilize the guesthouses and bush lodges in availability. Kruger, which is currently your top offering. The condition of most of these houses are shocking, to put it mildly. For the past few years we constantly had to contact the duty manager for everything from toilets not working (Melville) , no hot water in bathroom and kitchen (Boulders), kitchen sink mixer completely loose (Melville) , outside doors not opening in a room that has no windows, thus no fresh air (PJ Joubert), dirty facilities (Moni, Melville, Rudy Frankel) , dirty linen (Rudy Frankel), and the list goes on

Granted, every time we brought these issues to the attention of camp management, it was dealt with. However, there are no proactive maintenance projects in the camps and everyone waits till a customer complains.

It is clear to me, that senior management never go into these units to merely check what is being presented to customers.

Expanding your tourism offerings are going to be of no use if you are not able to provide quality service.

With the above in mind, I personally cannot see Kruger managing a 3-star hotel in Skukuza. 74 6.7.2, page 6.7. Riparian zones should be delineated Mr Frans (surname Written inputs, 3 March This is a valid point and is something that we are taking note of and protected from non- sustainable tourism not captured) 2018 going forward. Where infrastructure is damaged due to extreme developments and those developments that have events such as floods their viability and impact they have on the washed away during 1:50 and 1:100 year floods should environment is assessed before being rebuilt. For all new be closed and redesigned to adapt to climate change developments, green building principles are being implemented to and future threats. The Riparian zones do provide reduce their impact. In addition, infrastructure such as roads that crucial habitat during drought periods and has not only are found to negatively impact natural processes, are moved or a rich biodiversity of living organisms but also contribute closed where feasible. to the high aesthetical value and sense of place of the Park. - Remote Zone? Whilst riparian zones are not specifically zoned in the use zones map they have been afforded protection through the sensitivity layer on which development locations within use zones are selected.

The reasons for not affording them special protection within the use zones are twofold;  Most of the developments in KNP, many of which are in the riparian zones, were put in place many years ago before the use zones were implemented. To retroactively remove these developments to comply with a change of zone, would not only be costly, both in terms of direct costs but also due to lost revenue.  It was also felt that retaining these already disturbed sites would have less impact than relocating the infrastructure to currently undisturbed areas. 75 Please supply the methodology used to assign heritage Ms Natasha Higgit, Written inputs, 9 March The methodology of the creation of the various layers contributing sensitivity as part of the sensitivity analysis as an SAHRA 2018 to the final sensitivity analysis will be detailed in the final CDF due appendix or in the Lower Level Heritage Management by end 2018. Plan 76 While the map provided in this section is exclusively for Ms Natasha Higgit, Written inputs, 9 March The sensitivity analysis did not look only at biodiversity indicators. biodiversity, the sensitivity of heritage resources should SAHRA 2018 Additional inputs such as topography, hydrology, viewsheds and be taken into consideration. The sensitivity map will heritage sites were included. require continuous updating during the inventory of the heritage resources located within the Park By default, this sensitivity analysis will be redone at the next Park plan review (2028) to account for any changes to the input layers. However, where the review of the heritage resources requires a major change in the sensitivity or zonation of an area, an earlier update of the layer may be considered. 77 As stated above, any heritage site that is planned to be Ms Natasha Higgit, Written inputs, 9 March Noted. opened to the public, must have a Heritage Site SAHRA 2018 Management Plan developed. Additionally, any invasive activities or development will require a permit in terms of either section 27, 34, 35 or 36 of the NHRA. These permits must be applied for prior to any construction. If 57

a NHRA section 38 process is being undertaken i.e. a NEMA EA application or other development that triggers NHRA 38(1), permits may only be applied for after an EA is granted for the proposed development or if the relevant heritage resources authority provides a decision.

SANParks is urged to consult with SAHRA (or LIHRA/MPHRA for built environment) at the earliest stage of planning for development for guidance and comments. 78 Partnerships with local communities is relevant but Dr. Peta Thomas; Written inputs, 9 March The enterprise development strategy as well as enterprise and there are no details on any strategy on partnering with Prof. Llewellyn 2018 supplier guidelines approved by National Strategy, ensures stricter local communities or what work has been done. More Leonard, Prof. Robin process of partnering with local communities bordering the Park by details on the strategy and community / Park relations is Nunkoo ensuring that the communities sign a Community Public Private needed. Partnership with SANParks and due diligence is undertaken before the agreement is signed, to ensure the legality of the companies’ And commercial activities (9.5) directors and shareholders.

Items such as Sasol bird count not mentioned 79 The removal of the peripheral zones and the use of the Mr Johan Eksteen, Written inputs, 9 March Your concerns for the impacts a LIL zone next to Manyaleti’s more standard SANParks zonation scheme are noted. MTPA 2018 Primitive zone may have, is noted. The LIL zone referred to here is The MTPA manage two Protected Areas next to KNP, a legacy zone from the 2008 plan. This zone was retained in the and these are the focus in comments: 2018 review as a potential location for a low impact camp, most a) Manyeleti NR: The KNP zoning next to Manyeleti possibly a “touch the earth lightly” concept. The environmental are either LIL or Primitive zones. Please note that the conditions in this zone, such as water availability and soil types, limit whole MNR boundary area with KNP is zoned as the type and size of developments that can be considered here, and Primitive. The MTPA have specific concerns about the will be the final consideration to inform any possible products. LIL zone, and we would appreciate due consideration of the Manyeleti zoning wrt planning of developments The issues around traversing rights by neighbouring areas is in the KNP LIL zone. currently under discussion and formal talks will be taking place with b) Mthethomusha NR: We note the changes in the the relevant conservation areas in due course. The formalisation of KNP zoning, including the removal of the peripheral co-operative agreements will further facilitate possible traversing zoning to the north-east of Mthethomusha; and the and joint products. much narrower primitive zones directly to the east. In stakeholder meetings mention was made about the potential of traversing rights, and the MTPA is keen to find out more about the relevant process.

SECTION 7 – ACCESS AND FACILITIES

No. Comment / Input Commentator/s Reference Official response 80 Section 7.10 The statement “There are no servitudes in the Mr David Marnewick, Written inputs, 9 March There are not registered servitude agreements where ESKOM lines Park.” Should this be reconsidered as there are numerous EWT 2018. occur within the park. The Land audit programme (Regional land power lines traversing the Park where Eskom hold use lower level programme) will focus on all these matters through servitude rights? its implementation activities. 81 All heritage sites that have visitor access or plan to be Ms Natasha Higgit, Written inputs, 9 March The SANParks Cultural Heritage Policy and the Guideline for opened to visitors require Heritage Site Management SAHRA 2018 Development and Maintenance of Cultural Heritage Sites Plans (HSMPs). These plans should comply with the 2006 adequately provides for this as it complies with the SAHRA. SAHRA Guidelines for the development of plans for the management of heritage sites or places. -Please send all existing HSMPs to SAHRA for record purposes. All HSMPs that are to be developed must be submitted to SAHRA or LIHRA or MPHRA (the provincial PHRA’s for structures only) for comment. -Please note that some camps, accommodation, and other structures may be older than 60 years, and will require HSMPs for their continued use. Alternatively, a Historical Structures Policy could be developed. This would need to be sent to LIHRA or MPHRA for comment and to SAHRA for record purposes. All structures older than 60 years old require a permit in terms of section 34 the NHRA. 82 Promotion of access from Mozambique border posts is not Prof Leonard, Prof Written inputs, 9 March Thank you, noted. This aspect is covered by the GLTP Treaty and mentioned – this would help for tours that want to Nunkoo, Prof Thomas 2018 pursued through the Regional programme (Section 10.2.2, encompass more than South Africa/ Mozambique etc. GLTFCA Co-operative Arrangements for conservation areas), the Emphasise on cross-Park opportunities for instance - the Promoting Access programmes (Section 10.8.3) very short travel time and good roads to link from Kruger to Mapungubwe. 83 Very limited detail of existing PPP activities (7.6) For Prof Leonard, Prof Written inputs, 9 March Noted. example, SANParks needs to draw on more robustly the Nunkoo, Prof Thomas 2018 expertise and assistance from other NGOs and civil SANParks is actively doing Environmental Education and works society organisations dealing with education and closely with the Education Department. Please note that this section awareness of tourism/conservation issues and that are falls under our Social Economic Development (SED) Department creating awareness within schools and for teacher and hence tourism involvement is limited. education. This includes closing the gap that exists With reference to PPPs, SANParks is looking at outsourcing the between government departments working in silos. The Phabeni Education Centre to improve education through Public Gauteng Tourism Authority has in recent years undertaken Sector involvement. SANParks-KNP currently have very training of tourism teachers together with the University of successful PPPs with the Concessions. Johannesburg (See point 7.6.4 below for more information on PPPs). A strategy is needed to improve the South African people’s understanding of environmental/conservation issues and to change the perception of especially the previously marginalised groups that conservation is for the elite sectors of society. 59

All South Africans have a responsibility to protect and preserve the natural environment and for sustainable development. 84 7.6.Commercial activities Prof Leonard, Prof Written inputs, 9 March Many initiatives are initiated through the PPP’s and specifically Nunkoo, Prof Thomas 2018 through the private sector and are frequently overlooked and Administration and other activities underestimated. - Limited access to shops for tourism purchases (gifts, etc.) – there is potential for many more. PPP contracts include several BEE targets inclusive of but not - Can contracts with PPP accommodation not limited to the following: include a commitment for internship for one year of 1/ 2 - Ownership; qualified hospitality and tourism students at each of the - Strategic representation; PPP lodges? Students will gain exposure to the unique - Employment equity; tourism of Parks (while it is understood SANParks itself - Skills development; offers internships the opportunities could be greatly - Preferential procurement; extended through the PPP accommodations) - Enterprise development; and - Social development.

Under skills development the private company is required to outline the number of learnerships as a percentage of total employees, hence this is indeed happening. 85 7.6.4 Activities Prof Leonard, Prof Written inputs, 9 March In 2017 SANParks had its first investor conference. The objective The opportunity for new PPP are not considered: Nunkoo, Prof Thomas 2018 of the conference was twofold: - Geo-tourism/ cultural heritage trails as a new product possibility – preferably with a hop-on guide to 1. To link SANParks with investors and potential operators; provide specialist knowledge and prevent any vandalism and of sites 2. To showcase opportunities. - Jump on FGASA level 1 guides for private cars The conference was very successful and will be held more from communities just outside main gates frequently. Following a due diligence process some of the - Partnerships with professional conference and recommended projects might be showcased in due course. events NPOs such as SAACI (the Southern African These proposed projects are hence noted and might feature in the Association for the Conference Industry) and EXSA near future but wil still follow the guidelines as contained in the Park (Exhibition Association of Southern Africa) to promote Management Plan. exposure of the Park/ use of conferencing facilities, etc. - More conferencing facilities near main access gates? Conferencing is a very easy way to get corporate and international attention and business spend is generally much more than leisure spend - Building of more activities like sky walks that are charged for - Introduction of child play facilities at all camps – family friendly camps - Inclusion of more spa and wellness facilities – if not full spas then nail spas/ neck and shoulder massage only. Many community women could train very easily for these job opportunities. These spas will prove to be very

popular for conferencing / short time available guests. Such services are quick and financial cost of set up low. - More annual events (like golf) sold off as named events (SAACI and EXSA are useful for this)

Opportunity for much more University research work and support on tourism and hospitality related research – these are not mentioned in the plan.

WALOW is doing a fine job at grades 10 and 11 but there is a gap in communication with young millennials/ future job holders. Suggestions are as follows: - An annual double blind review tourism with special annual edition publication of Koodoe on Parks tourism and hospitality research from both nationally and internationally based academics - research on Parks internationally is coming to the forefront. The DHET commitments for South African researchers will be met and encourage much more awareness from up and coming graduates on the importance of Parks as tourism - Offer of annual free day pass to university students in one of the annual breaks (over and above the free annual week in Tourism month as many students do not know about the Parks) promoted with help from Universities. 86 The report is clear that mining poses a threat to the Prof Leonard, Prof Written inputs, 9 March Thank you. This is one key focus of the Regional Integration ecological integrity of the Park. Although it is further noted Nunkoo, Prof Thomas 2018 programme, in liaison with various co-operative partners (Section that there is currently no commercial mining taking place 10.2), focussing on the broader catchments and adjacent land use, in the Park. No mining rights / permits have been issued and subsequent impacts (positive and negative) of mining and other on Park property, there is also the future threat of mining land use practices. becoming operational outside the Parks’ boundaries and which will still pose a threat and cause damage to the Park. The KNP is putting substantial effort into delineating the buffer into These include the dangers of acid mine drainage, noise the municipal SDFs, LUMS, and bioregional plans (based on critical pollution and blasting disturbing wildlife and the peace and biodiversity areas and ecological support areas, also considering tranquillity of the area, include causing visual pollution. the socio-economic environment), whilst also securing adjacent With mining there is a very high possibility of corruption conservation areas under formal protected area status. and poor governance surrounding mining, including the issues of loss of tourism jobs. Recent reports on mining A key focus of the KNP is to have a broader integrated development and the impact on tourism conservation sites, including plan approach, promoting compatible land use practices, delivering issues of environmental impact assessments and on the National Development Plan, Provincial Growth Development governance has been a concern for conservation/tourism strategy and associated socio-economic outcomes, whilst ensuring areas in Dullstroom, Mpumalanga and St Lucia, KwaZulu- that the conservation values of the KNP and adjacent land use is Natal. More information may be found from the following secured but also provides important ecosystem services in support papers: of human well-being. This requires sound co-operative 61

partnerships and sector approaches, and multiple institutional • Leonard, L. (2018) Environmental Impact arrangements which will be pursued through the implementation Assessments and public participation: The case of programmes, outlined in Section 10.2, 10.7 and 10.8 environmental justice and mining development in Dullstroom, Mpumalanga, Environmental Assessment Policy and Management - DOI: http://dx.doi.org/10.1142/S1464333217500028 • Leonard, L., and Lebogang, T. (2017) Exploring the Impacts of Mining on Tourism Growth and Local Sustainability: The Case of Mapungubwe Heritage Site, Limpopo, South Africa. Sust. Dev., doi: 10.1002/sd.1695. • Leonard, L. (2017) Governance, participation and mining development, Politikon, Volume 44(2), 327-345, https://www.tandfonline.com/doi/abs/10.1080/02589346.2 016.1245526?journalCode=cpsa20 • L. Leonard. (2016) Mining and/or tourism development for job creation and sustainability in Dullstroom, Mpumalanga, Local Economy, Volume 31(1- 2), 249-263 - http://journals.sagepub.com/doi/abs/10.1177/0269094215 621875?journalCode=leca • L. Leonard. and Langton, A. (2016) Challenges facing tourist attractions due to acid mine drainage in the West Rand, Gauteng, AJHTL, Volume 4(1), 1-8 - http://www.ajhtl.com/uploads/7/1/6/3/7163688/article_5_v ol_5__1___2016.pdf

SANParks should have a clear position against mining development, which is absent in the document. This must also include education and awareness of local communities on potential threats of mining and mining causing divisions within the local community, include the benefits of tourism jobs over any mining development jobs. This is increasing important considering that the Department of Minerals and Resources has been spearheading mining development in conservation areas. 87 Map 2b. The Satara flight corridor over the northern parts Mr Johan Eksteen, Written inputs, 9 March Your comments are noted. of Manyeleti NR is noted. According to the Manyeleti NR MTPA 2018 zoning that area has a primitive zoning. According to the SANParks definition of a Primitive zone, this zone does allow for access by motorised transportation, which includes overflight by aircraft, on a controlled basis, and as per KNP Protocols and SOPs. KNP will engage with the MTPA with respect to the current flight path concerns.

SECTION 8 – PARK EXPANSION AND CONSOLIDATION

No. Comment / Input Commentator/s Reference Official response 88 Section 8. Include Manyeleti Game Reserve. Mr Frans (surname Written inputs, 3 March This has been included. not captured) 2018. 89 Any expansion / consolidation must consider the heritage SAHRA Written inputs, 9 March This is one of the key criteria included in the KNP Land Inclusion resources located on properties to be included as part of 2018 Protocol. this exercise. There may be a considerable amount of heritage resources within these properties that will need to be managed by SAN Parks. 90 With respect to the MTPA protected areas it is noted that Mr Johan Eksteen, Written inputs, 9 March The KNP Land Inclusion Protocol and GLTFCA Co-operative Manyeleti is included in the ‘Co-operative Areas open to MTPA 2018 Agreement will guide the inclusion of areas based on multi-criteria. the KNP’; whilst Andover NR, Mthethomusha NR and A range of different contractual and co-operative models, guided by portions of Blyde Canyon NR are included in the the legal framework, is considered. ‘Expansion / Consolidation Footprint’. It is also noted that the primary focus for expansion will be on protection and the unlocking of associated sustainable socio-economic benefits of integrated biodiversity areas in Mpumalanga areas that include Blyde River corridors and Croc-River gorge (linking to Barberton Mountainlands region) corridor (Inkomati: Crocodile River system).

SECTION 10.1 - REGIONAL INTEGRATION HIGH LEVEL OBJECTIVE – INTEGRATED LAND USE

No. Comment / Input Commentator/s Reference Official response 91 Timeframe of animals killed by lions and hit by trains, how Mr Elvis Sambo - 13 February, Hazyview SANParks is not aware of this need, so Mr Sambo must contact The long does it take to react? They want to have a camp Salubindza SED: People and Conservation officers who will assist. The fencing where their cattle is safe. Can KNP help? Wants a grazing around KNP is controlled and maintained by government (DAFF) camp. Not an overnight camp as far as I understand but I and not KNP. KNP does assist where they can. There is a specific may be wrong. They have human resources but Park can Protocol to be followed when cattle are taken by lions in order to help to build camp. He has application in for the camp. qualify for compensation. There are also forum representatives and they must report it when livestock has been lost. It must be reported to the Park’s Forum so that they can report to the Park. 92 In the Regional Integration programme, does this provide Mr M Grover 14 February, Acornhoek The Regional Integration and SED programmes will follow a a platform about communicating SMME opportunities and process of updating the existing database, including a synthesis of partnerships? Who are the contact persons? external partner SMME opportunities. Other aspects such as skills audit, and strategic partnerships and community opportunities will be supported. This will form part of the Year 1 work plan activities. 93 There is no support to assist in waste removal e.g. Community member 15 February, The community could collaborate with other communities on Pampers, etc. No transportation. Malumulele projects, pending feasibility studies, and pending sufficient bulk. A Project Manager could visit to provide initial recommendations. However, this is a key function of local government, and KNP will engage with local government to address the matter.

94 Regarding climate change. I see that is has been Mr. Sven Kramer 15 February, The Climate Change Programme in section 10 of the document is addressed to some degree however, I’m still concerned, it Johannesburg supported by a detailed lower level plan. It focusses on monitoring seems that no scenario planning has been incorporated in and mitigation. Our 2017/18 Annual Performance Plan states the the plan. reduction of electricity and water usage as a key objective. We are already monitoring consumption on a monthly basis and telemetry systems provide us with the necessary data. This matter has been included in the Key Performance Areas of Managers to ensure compliance. The Climate Change programme do not specifically mention scenario planning but it has been covered in the regional land use planning LLP, which addresses scenarios inside and outside KNP. The Savanna areas will not be as negatively impacted as compared to the Succulent Karoo areas. The Science Learning Centre in Skukuza is experimenting with a couple of technologies regarding how to deal with this and other issues better. If it proves to be successful then it can be rolled roll it out to the rest of the infrastructure. 95 What is SANParks’ response ito in mining and exploration Mr Jansen-Davies 16 February, White SANParks will take a high-level approach through engaging at a licences – not indicated in the Management Plan? River high level with the relevant intergovernmental platforms.

However, the KNP “buffer” has now been delineated according to SPLUMA and within certain SDFs, giving it a stronger legal mandate to respond to mining and prospecting applications.

We have amended the plan to make the necessary reference to this. 96 Requests for injections for his cattle. Mr Elijah Mnisi – 14 February, Ka- This is a function of DAFF (state vets), and we will provide your Phabeni bokweni details to them. 97 Section 10.2, page 103. The implementation of the listed Mr Frans (surname Written inputs, 3 March Noted. Implementation will be in accordance to Environmental land use integration objectives are crucial to align it with not captured) 2018. legislation. Environmental Legislation. 98 10.2.1 Integrated land use and regional planning and Ms Kim Da Ribeira, Written inputs, 10 It is important to note that that these areas are not owned or management programme OSCAP March 2018 managed by KNP and that the animals on those areas are not SANParks’ jurisdiction. Re: Develop, formalise and periodically review overarching co-operative guidelines and Protocols guiding However, the SANParks Policy framework provides for co-operative resource use in shared systems, e.g. hunting and animal arrangements with conservation areas and contractual Parks, of off-takes. which SANParks is not the landowner, to have sustainable resource use in accordance to their Management Plans, as guided by the OSCAP comment: We have in the past expressed our legal framework. The condition for this is that Protocols and co- concern about the fact that the animals hunted on the operative arrangements are in place. This is monitored by the reserves bordering on Kruger can be seen to be part of competent authorities, but also within a broader system to ensure the national heard yet these hunts provide an income ethical and sustainable practices. source for the private reserves?

Further, note that the legal framework does allow for such practices, and that this is a critical element of financial sustainability for the conservation estate, as long as it can be demonstrated in accordance to the Management Plans and associated audits.

SECTION 10.2 - REGIONAL INTEGRATION HIGH LEVEL OBJECTIVE – GLTFCA CO-OPERATIVE CONSERVATION ARRANGEMENTS

No. Comment / Input Commentator/s Reference Official response 99 Is there a programme dealing with snaring? Does the NGO representative 13 February, The GLTFCA includes the KNP. It includes programmes within GLTFCA include the KNP? Hoedspruit Safety and security, Biodiversity Social Projects and other programmes, some focussing on snaring.

The Safety and Security Programme also addresses this, and this will be reviewed on an ongoing basis.

However, SANParks will reflect more pertinently on this issue and interlink between GLTFCA programme, Biodiversity-Predation Programme (mentioned here) and the Effective Park Management: Safety and security programme. The Biodiversity Social projects will in future focus on deploying such team in the “buffer” 100 Contractual arrangements versus co-operative Mr. Sven Kramer 15 February, It is a co-operative agreement and it is based on principles and arrangements. Is a co-operative arrangement a legally Johannesburg incentives. If it is not working then we will have to discuss the issues binding agreement? at hand. The only penalty would be to stop the co-operative agreement i.e. putting the fence up again.

Co-operative agreements are institutional arrangements with a range of co-operative partners and/or sectors to contribute to common outcomes and collective impact, as guided by overarching principles and criteria, Norms and Standards, “best practice guidelines”, Protocols, standard operation procedures.

Contractual National Park and associated agreements: An area which has been declared as National Park through the Minister and which contributes to the objectives of a National Park, but of which SANParks is not the landowner. Contractual National Park agreements and/or co-management agreements are signed, and SANParks may be assigned to be part of a joint management authority through a range of possible institutional arrangements.

A co-management arrangement will mostly apply within Contractual Park arrangements (for National Parks) but are not always entered into. KNP has signed a Co-management agreement (NEM: PAA, Section 42) with the Makuleke Contractual Park: The management authority may enter into an agreement with 65

another organ of state, a local community, an individual or other party for (i) the co-management of the area by the parties; or (ii) the regulation of human activities that affect the environment in the area. 101 What is the current status of possible hunting in the north Mr M Pieterse 14 February, Pretoria There is no hunting taking place in the KNP and none is planned. of the Park? What is planned and how will it be controlled? SANParks policy framework indicates that no hunting will take place in a National Park, but that is possible in Contractual Parks (e.g. Makuleke Contractual Park) and in conservation areas open to National Parks. The necessary Protocols and agreements need to be in place to guide ethical and sustainable resource use practices such as hunting. The necessary ecological surveys, scientific studies, off-take records etc. need to be submitted to support such off-takes. The provincial conservation agencies regulate and authorises permits for the co-operative areas open to KNP.

Certain areas that are open to the Park i.e. the Associated Private Nature Reserves, Letaba Ranch and Makuya allow hunting. In the north (Makuleke area), hunting was included as an option in the treaty settlement. There are financial benefits that warrant the hunting of e.g. a certain number of animals. The concessions stated that they do not want hunting to take place and prefer photographic safaris. 102 Mahlathi community started a wildlife initiative (Mahlathi Community member 16 February, Giyani SANParks acknowledge awareness of this initiative. Mahlathi GR Game Reserve) but needs conservation education and management should approach SANParks with a formal request financial assistance. Is KNP able to assist with training, and present their plan. SANParks will be able to give advice on education, funds, etc.? habitat, animal stocking rates etc.

103 Can SANParks develop a model for Co-operative Mr Jansen-Davies 16 February, White There is already a framework and protocol developed based on Conservation areas, that will deal with mixed land tenure, River land use, land tenure, governance, socio-economic, conservation, land use status, land claims, tourism etc. that could be safety and security through the current KNP Land Inclusion used nationally? Protocol and GLFTCA Co-operative Agreement

We have been in discussion with recently launched Tourism Conservation fund that could provide support for such an integrated model. 104 INTEGRATED LAND USE AND REGIONAL PLANNING Ms Michele Pickover Written inputs, 9 March Please see the reply to issue no 98 AND MANAGEMENT PROGRAMME Develop, formalise 2018 and periodically review overarching co-operative guidelines and Protocols guiding resource use in shared systems, e.g. hunting and animal off-takes.

The EMS Foundation is aware that the KNP has given permission for the hunting of 4400 animals in the APNR

during 2018. It includes 53 elephants, 17 of them 40lb+ and one over 50 years old. There is no scientific basis for this and it is ethically it is reprehensible. What animals have been selected? On what basis? What role do these individual animals play in their own communities? Unless the KNP can provide solid answers to these questions hunting of animals from the KNP should be stopped immediately. Moreover, our legislation prevents hunting in the KNP. On what legal basis is the KNP allowing our animals to be hunted? The EMS Foundation is alarmed at the general tone of the Draft Plan when it comes to the disregard of the interests of the animals under the control of the KNP on behalf of the nation. In many ways the Draft Plan is retrogressive and out of step with pressing global concerns. The Draft Plan is pushing a one-sided, pro-hunting view of the wildlife economy. There are many other ways in which sustainable livelihood can be achieved without hunting or exploitation. The Draft Plan is misinterpreting the Constitution and the notion of ‘sustainable use’/’resource utilisation’. Wild animals are under siege, and as their world is diminished so is our own. As a country we need to develop a culture that abandons the celebration and romanticising of trophies and ‘products’ that require the slaughter of animals. There is a direct connection between the violence of our society and the fact that SANParks encourages and props up a hunting industry designed to satisfy the blood lust of those who kill for sport. These are not the values South Africans endorse. 105 These two sections, 10.3.1 and Table 22 are taken GMFER Written inputs, 9 March The Municipal SDF and LUMS ultimately govern what activities together for a commentary registering an objection to 2018 may take place in the KNP buffer. activities deemed “appropriate” for Kruger National Park or the buffer zones. These sections together address Table 22 states a range of multi-sector activities occurring in the problems for elephant conservation in and around KNP. landscape, and then specifically which activities might be supported or not by KNP.

The necessary planning processes as per legal framework to delineate the KNP buffer into the municipal SDFs and LUMS are well underway. 106 The increased focus on the GLTFCA in the reviewed KNP Mr Johan Eksteen, Written inputs, 9 March The MTPA will be a party to the GLTFCA Co-operative plan is noted. MTPA 2018 Arrangements, and a meeting on 23 April 2018 confirmed this This will also require inputs from the MTPA, wrt Manyeleti direction and support. NR as well as several Private Nature Reserves that are open with KNP. 67

In this regard it is noted that a meeting has been arranged between the KNP and MTPA CEOs to discuss relevant matters.

SECTION 10.2.3 - REGIONAL INTEGRATION – INTEGRATED WATER RESOURCE MANAGEMENT

No. Comment / Input Commentator/s Reference Official response 107 P115: allowance for water useage of 250l per capita per Prof Van Helden Written input, 6 March The comment is justified and we are grateful for this. Please note day seems very high. I think the aspiration should be to 2018 however that the 250L per capita is a new benchmark that never lower that limit. For example, to allow and arrange car existed before for the KNP. This allocation includes all uses such washes for visitors in KNP is unacceptable to me. KNP is as the industrial load (laundry and other uses) as well as limited supposed to be a bush/outdoor/wilderness experience irrigation water (grey water for irrigation included). Furthermore, all after all. new or refurbished infrastructure developments have this as their upper threshold where modern appropriate technologies will be included to bring this down further, such as dry sanitation systems. 108 What is KNP doing to assist farmers regarding water Mr Dumisani 13 February, Mutale The KNP has a major implementation programme on the integrated quality/quantity? water resource management, which involves all the rivers flowing Aquatic Water systems. No mention of water forums in the through the KNP. This programme focuses on several aspects, presentation. such as reserve management (water quality and quantity), developmental water management, and water auditing. This includes close collaboration with the water forums, catchment management agency, DWS, Irrigation Boards/Water User Associations NGOs, and transboundary programmes with Mozambique.

With KNP being downstream it acts as the ‘’watchdog’’ for water quantity & quality. In the five major rivers in KNP, we have equipment along these rivers to monitor water quality and quantity. When we see that there is not enough water coming downstream, we contact relevant sectors outside to increase water flow and/or upstream user restrict their abstraction i.e. call dam management upstream to release more water so that farmers & communities below the dams receive water. e.g. during the 2015-16 drought we kept the river running during the big drought because of communication, the first instance in modern times that all 5 rivers kept flowing during a serious drought.

The KNP is presently embarking on beneficial water management projects with emerging farmers on the Parks periphery, commencing in the Sabie catchment. 109 Concern about wasting water at Kruger Gate and animals Mr Hendrik (surname 13 February, Hazyview KNP has an integrated water resource management plan, which are dying. not captured) addressed compliance with water use, and this will be a major focus internal and with external stakeholders to improve responsible practices, including awareness. Please provide us with more

information on the water waste at Kruger Gate, so that the matter can be investigated and addressed. 110 I see that you’ve been monitoring ground water since 2007 Mr. Sven Kramer 15 February, You are more than welcome to contact the Water Resource and I’m interested in the results. If the current drought, as Johannesburg Managers, Dr Eddie Riddell and Mr Robin Petersen to get the currently being experienced in the Cape, becomes a information. widespread factor then groundwater monitoring becomes critical. 111 Regarding section 6.7.2. The national context of water Mr Gavin Snow Written inputs, 20 Feb. The KNP actively monitors and manages according to the gazetted management is quite vague and should be expanded on. 2018 Management Class and Resource Quality Objectives for the As defined by the National Water Act (36 of 1998) there Inkomati-Usuthu and Olifants WMAs. These were gazetted in 2016 are nine Water Management Areas in South Africa. The for flow, quality and eco-specs. Prior to this, the KNP has utilised its relevant ones here include the Olifants and the Inkomathi- own set of TPCs for this purpose. Thus, the Crocodile, Sabie, Usuthu. It is also not clear which rivers have had Olifants and Letaba now have legal environmental protections for Resource Directed Measures studies conducted on them flow and quality and the KNP works tirelessly with upstream (i.e. what is the required water quality and quantity of partners and institutions to achieve these targets. Only the Luvuvhu water for the large rivers that traverse the Park and their catchment is presently without this protection, however the KNP has associated Ecospecs?). This information is key to the requested DWS to elevate this matter, and a full classification effective management of those rivers that have their system will commence in 2018/19. catchments outside the Parks boundaries. 112 Section 10.2.3. Improve the management of the Aquatic Mr Frans (surname Written inputs, 3 March All ‘development’ activities within KNP have to abide by the impact buffer zones that forms part of the Riparian buffer not captured) 2018 conditions of Section 21 of the National Water Act (1998) and zones by relooking at the current tourism facilities and therefore care is exercised to ensure that the riparian zone is not access roads that are negatively impacting on the river impacted within the 1:100 year flood line. systems, (siltation, trampling of root systems, pollution and sewerage contamination of soil and underground water. 113 10.3.2 The investigation of the creation of artificial Mr Frans (surname Written inputs, 3 March The integrity of wetlands systems “Ecological Infrastructure” is a wetlands in the river systems before it enters the Park in not captured 2018 catchment wide process that requires wetland system to be order to buffer out heavy metals and plastics are needed. protected or restored to perform the desired ecosystem services. For this reason, creating artificial wetlands on the KNP will not necessarily remedy the problem 114 10.3.4 Creation of Artificial wetlands to restore the Mr Frans (surname Written inputs, 3 March Please see comment to issue no 113. ecosystems not captured) 2018 115 Re: The Park has to provide water services according to Ms Kim Da Ribeira, Written inputs, March Please see comment to issue no 107. the Water Services Act No. 108 of 1997, to staff, OSCAP 2018 contractors and its guests. The Park is thereby also Sufficient water exists in the river systems for the biota through the mandated to provide sanitation services necessary to implementation of the ecological reserve (environmental water secure sufficient water and an environment not harmful to requirements) and international flows. human health and / or wellbeing. In order to supply water to staff and tourists, as well for irrigation (gardens, Skukuza golf course, indigenous nursery) the Park abstracts water from the perennial rivers and / or groundwater and must thereby also comply with the NWA. The Park presently has 14 registered water uses for river abstraction, 11 for groundwater abstraction, 69

and 10 for storage (dams). It is imperative that the Park continues to maintain sound monitoring of its abstraction data, so that it does not over abstract especially as this relates to the irrigation allocation. Furthermore, where restrictions are placed on irrigation during times of drought the Park must continue to adhere to these restrictions as would any other user in the catchments. Furthermore, soft approaches to increase the per capita water savings for water users include further refinements to the present 5 tier progressive tariff for potable water, including a drought tariff structure. The aim is that within 5 years the Park’s per capita water use is within 250 l per person per day.

OSCAP comment: • The allocation of 250l of water per person per day is high, if one considers what has been achieved in Cape Town. • Is there any monitoring of the effect of water abstraction during periods of drought and the effect this has on the wildlife, this paragraph only deals with the Parks obligations to staff contractors and guests? • Is grey water currently used to irrigate? 116 With the limited information under the section headings, Mr Johan Eksteen, Written inputs, 9 March The detailed lower level plans could be provided on request. These and the references to the detailed lower level plans that MTPA 2018 implementation plans are reviewed on an annual basis according to are not included in the reviewed draft, it is not possible to the strategic adaptive management approach, and in consultation get clarity on the actual actions that will be undertaken. with relevant stakeholders. 117 Table 14: The list of priority IAS species refer. KNP should Mr Johan Eksteen, Written inputs, 9 March We are concerned about the threat of Campuloclinium note that PomPom (Campuloclinium macrocephalum) is MTPA 2018 macrocephalum and this comment will assist our surveillance and already present in the Crocodile Gorge Conservancy. rapid response control programme. Once it reaches the KNP, control should be started asap.

SECTION 10.3 - BIODIVERSITY HIGH LEVEL OBJECTIVE

No. Comment / Input Commentator/s Reference Official response 118 Why are TPCs not really reflected? Mr Grant Beverly, 13 February 2018, Though TPCs have proven very useful in less complex programmes EWT Hoedspruit such as alien biota, macroinvertebrate monitoring and fire management where management and intervention thresholds are fixed, they have proven less useful in more complex environments, where mechanism approaches are preferred. This is the very nature of adaptive management and learning by doing. Thanks for the enquiry; we have made amendments in the plan. 119 Add to this sentence “Furthermore, several threats facing Mr David Marneweck, Written Input, 9 March The specific threats for the Park is already incorporated the Park such as river system deterioration, loss of riparian EWT 2018 (Section 2.12.6) vegetation, bush thickening and encroachment and loss of large trees can have drastic effects on bird populations.” an additional significant threat is mortalities caused by

electrical infrastructure. The Eskom/EWT partnership has recorded more than 7,200 mortalities on electrical infrastructure across South Africa, this includes close to 2,000 vulture related incidents. Seeing that vultures are mentioned in this section, we feel that this anthropogenic threat should be included here.

SECTION 10.3.1 - HERBIVORY

No. Comment / Input Commentator/s Reference Official response 120 Regarding section 10.3.1. I recommend that you add Dr. Victor W Meyer Submitted via email on We thank you for your comment. Such detail is part of the annual the following: Frequent termite monitoring (mound 11 Feb. 2018 implementation plans outside the scope of the management plan counts), as described below, should be added to par. 3 and/or par. 6, which has bearing on the last category of The termite ecosystem inside the Kruger national Park is stable with the table (p.119): To monitor and evaluate impact of no known hostile anthropogenic activities detected that will harm management. termite species within the Park. SANParks is therefore using its

limited resources to monitor other organisms/ecosystems that are relatively more vulnerable to anthropogenic activities. 121 More emphasis on infrastructure etc. than on biodiversity Stakeholder that 16 February 2018, The LLPs have more detail. management. What happens if elephant populations attended meeting White River We are addressing system functions including missing drivers. The increases above 80% of biomass? And what happened to elephant population is high, but poaching is also increasing. TPCs? Though TPCs have proven very useful in less complex programmes such as alien biota, macroinvertebrate monitoring and fire management where management and intervention thresholds are fixed, they have proven less useful in more complex environments, where mechanisms approaches are preferred. This is the very nature of adaptive management and learning by doing. Thanks for the enquiry. 122 Has the Elephant Management plan been signed off and Stakeholder that 16 February 2018, SANParks seek to restore the ecological process that generates what is the “stopping point” for elephant populations, attended meeting White River gradients in resources. To achieve this, the approved elephant before it gets too late? management plan of Kruger National Park seeks to restore natural gradients of water availability, hence the closing of places where authorities provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients of food and comfort (e.g. shade) resources. A key challenge is to create the variable levels of perceptions that elephants may have about undesirable features, often associated with humans, in the landscape. It is for this reason why SANParks seek to make use of various passive and active techniques to disturb elephants and “create local zones of high vigilance”. The term “landscapes of fear” used previously provides potential for misinterpretation. Culling in the traditional sense and meaning are therefore only considered in the above context.

This approach allows SANParks to responsibly manage the benefits and risks associated with elephants. 123 How does the LLP link to the review of elephant Dr Michele Henley 13 February 2018, Implementation of elephant management embedded in the management plan? Including creating a landscape of fear. Hoedspruit Herbivory Lower Level Plan is linked to the Approved Elephant Is this open for consultation? Management Plan, which is on a cycle that does not align fully with the Park Management Plan cycle. SANParks therefore prepare and implement an annual elephant management implementation plan, which allows regular review of operations and changing context and challenges. The implementation plan is do not require consultation. 124 Are there public consultation processes with regard to the Dr Michele Henley & 13 February 2018, Annual implementation plans do not require a public consultation human presence approach i.t.o. elephant management? Robyn Hoedspruit process. The existing elephant management plan provides several actions linking to a variety of responses that allows various techniques to change how elephants use landscapes. All these techniques are options that SANParks can use to disturb elephants at local scales or areas of concern as specified in the present elephant management plan 125 What is the current status of the Eephant Management Mr. Riaan Potgieter 14 February 2018, SANParks have an approved elephant management plan and it is plan? Pretoria being implemented. In reality, the public wants to know when we will be starting the culling process again. When we start again we would not be doing it as was done in the past. We will now focus on disturbance culling that mimics the role that humans played historically. The current elephant Norms and Standards do not allow us to do this. We are in a process with DEA of amending the Norms and Standards to experiment with different management techniques to address elephant numbers, but also the impact on specific areas. The drought did not have much of an impact on the numbers. The number of calves might be lower but the population is still increasing. Poaching may have an impact in future. 126 Landscapes of fear Ms Karen Trendler, Written inputs, 9 March Please see comment to issue 122 Whilst we understand the principle and conservation SPCA 2018 needs\ benefits of managing habitat utilization by different species, we would like to ensure that techniques used for deterring wildlife are: • Humane • Do not cause injury or distress • Are not in contravention of the Animals Protection Act no 71 of 1962 • These techniques are submitted to the SANParks or any other relevant Ethics Committee for evaluation prior to implementing. Only techniques approved by an Ethics Committee should be utilized. 127 More specifically regarding conservation, there is a lack of Written inputs We acknowledge your opinion, which is part of a range of opinions significant appraisal of the elephant overpopulation expressed by stakeholders. Viewpoints range from aggressive question. This is the most important problem faced by reduction in elephant numbers through culling, to calls for no Kruger regarding biodiversity, and is being ignored for intervention at all. SANParks embrace several lessons and scientific

anthropomorphic reasons. It is ironic that sustained culling findings that help to inform management. The role that elephants of elephant would arguably solve the protein deficiency play in socio-economic-ecological systems does not primarily needs of all impoverished communities in the Kruger area, associate with how many elephants there are, but rather with how if not the subcontinent, thereby fulfilling all the socio- elephants use landscapes. Impacts that elephants have on political mandates that SANParks have ascribed to conservation values associate with how intense they use the themselves landscape – for instance feeding year in and year out in the same area result in little time for some tree species to recover from such herbivory. The best science available highlights that what determines where elephants spend time are firstly, essential resources like water, then high quality food. A third factor that becomes important, particularly in the dry season, is shade and water to control body temperatures. A fourth factor is how elephants perceive undesirable features of the landscape such as people that are present. In such cases, elephants will have higher vigilance, avoid such areas at the appropriate time, or avoid these areas entirely if it is hard for elephants to predict when undesirable features of the landscape will be present. SANParks thus seek to restore the ecological process that generates gradients in these resources. To achieve this, the approved elephant management plan of Kruger National Park seeks to restore natural gradients of water availability, hence the closing of places where authorities provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients of food and comfort (e.g. shade) resources. A key challenge is to create the variable levels of perceptions that elephants may have about undesirable features, often associated with humans, in the landscape. It is for this reason why SANParks seek to make use of various passive and active techniques to disturb elephants and “create local zones of high vigilance”. The term “landscapes of fear” use previously provides potential for misinterpretation. This approach allows SANParks to responsibly manage the benefits and risks associated with elephants. 128 I am writing in regard to the Elephant Management plan Ms Patricia Vineski Written inputs, 7 March Please see comment to issue 127. and the possibility of resuming culling of elephants in 2018 Kruger National Park. As per Dr Sam Ferreira, SANParks’ large mammal ecologist "Managing the effects of elephants is not about controlling populations. It is about letting natural processes influence where elephants spend time and what they do when they are in particular places' (2014). The Elephant Management Plan also concurs that "Culling did not work for managing elephant impacts, admits the Kruger’s Elephant Management Plan, and the new method

of imitating natural processes appears to be doing a much better job" (2014) If the priority of SANS Parks is as stated " for the conservation of biodiversity...that the Park could act as a nature-based tourism destination of choice, thereby constituting an economically and culturally valuable asset to the region in which it occurs" it seems a more viable option, ecologically and economically to continue with the imitating of natural processes and avoid culling. Responsible tourism is about conserving the wildlife people come to see, which, in this case, is elephants. I intend to travel in the near future, but to areas where elephants are respected for the intelligent, sentient beings they are and conserved and preserved in a manner consistent with this view. By your own admission, culling is not effective. Therefore, I respectfully suggest that culling should not be an option. We, and you, can do better than that. 129 I am writing to implore you not to kill our Elephants! They Ms Wendy King Written inputs, 7 March Please see comment to issue 127. are the largest Land mammal on our Earth and we destroy 2018 them, constantly, we enslave them, cage them in Zoos, they are murdered simply for an Ivory Trinket, used and abused in China, cruel Circus, they are thrashed to perform, hurt by bullhooks, starved, even murdered for their skins, killed mercilessly in Human conflicts, used as slaves, Human rides, and all the time these sentient Elephants need and want to only be with their family members whom they stay with forever! They evolved here and they are as important as us, It is their home too! Males leave the family re new genes, but Elephants gather regulary for a chat, they mourn for the dead, they are so like us and our loving families! If we cannot save the majestic, sentient, caring, amazing, gentle giants, what can we save? I weep for them and for us all, too . . . Thank You! 130 A Landscape of Fear versus Global Awareness and Ms Judy Malone, Written inputs, 9 March The use of the term “Landscape of Fear” provides a potential mis- Attitudes Tourists against 2018 interpretation. Animals in the wild will typically be vigilant about the This is a brief statement from an international coalition of trophy hunting environment and evolve mechanisms to respond to undesirable conservationists, scientists, journalists, activists, travel elements and stress as and when these occur. SANParks recognize agents and tourists. We are 'Tourists Against Trophy this as a key mechanism in how individual animals cope in ever Hunting', and we are responding to key areas of concern changing environments with different threats and challenges. It is in the SANParks 2018-2028 draft management plan. As this aspect that SANParks seek to use and thus want to create “local your managers know of the sound scientific and ethical zones of increased vigilance” which allows individual animals to challenges to historical culling, and persist with the threat make choices to respond to perceptions they have about the of it anyway, we will remind you of one differentiating environment. As part of SANParks due diligence, any intervention

factor. This is 2018, and a very different global landscape are conducted within the ambits of the law and SANParks make use of public awareness. of an ethics committee to evaluate and approve animal The plan references on Page 119 a strategic tactic of interventions. maintaining a 'landscape of fear', and the specific tactic for elephants references the existing Elephant Management Please see comment to issue 127. Plan. It would appear that "evaluation" of short-to long- term reactive culling is once again being seriously considered. We also take exception to the ongoing funnelling of KNP wildlife to trophy hunt concessions outside Park borders and beyond the dropped fences. The claim of elephant overpopulation is this area is a controversial one, and the quoted numbers are not supported by data. But no one questions the virtual confinement of elephants and the inability to range. Elephant culling in KNP was suspended in 1995, mostly because of international and local pressure, and the compelling science. If there is a decision to reintroduce even a "limited" cull by whatever method, ostensibly to discourage other elephants from an area, global condemnation will be intense. Much has been written of the failure of culling. Ecosystems are complex, and growth of large trees for example is influenced by such factors as seedling recruitment rates, fire burning policies, insect attack following bark stripping and obviously, climate change.There is no demonstrated linear relationship between elephant numbers and tree survival rates. Even then, ecologists were offering evidence that elephants never were the problem. Rather, it was the repeated burning or human-induced fires in the dry season (from slash- and-burn/swiddenagricultural methods) that was causing desertification. A recent study tracked differences in the Chobe savanna across 30 years, and provided information to improve dryland management strategies in the region and elsewhere. The findings show "little support for notions that elephants are to blame, while human-caused fires are high on the list of reasons." Rather than an overpopulation of elephants in the Park, the elephants are unable to move. Historically in these regions there were vast numbers of grazing animals and pack hunting predators as integral parts of the biological system. Their diminished numbers and/or absence has resulted in imbalances, along with artificial management, and has exacerbated biodiversity loss and land degradation. Alternative options to encourage movement, 75

even as elephants stand wrongly accused of causing biodiversity loss, when in fact they enhance it, have not been appropriately explored. These include the creation of cross-boundary/border Parks and/or viable migration corridors between Parks and countries in southern Africa, allowing elephants to both range and self-regulate their numbers as they would naturally do. Manipulating access to water sources, wire net protections and the presence of honeybees have been very effective, as have translocation of males and family units, and use of immuno-contraception in certain areas of the Park. Meanwhile the ongoing sacrifice of wildlife individuals to trophy hunters waiting beyond protected areas is allowed to continue, with impact on both reproductive and social species dynamics. Ecotourists are becoming increasingly aware of and uncomfortable with the killing that occurs alongside non-hunting reserves and lodges. We do not view the hunt tourism industry as compatible with wildlife viewing. Culling and trophy hunting of elephants is cruel, unethical and completely unacceptable in 2018. Their complex intelligence and social lives parallel our own. Studies have shown that elephants’ decision-making abilities were left impaired by culling that ended decades ago. Elephant herds that lost adults to culls in the 1970s and 1980s were less able to respond appropriately to other elephant calls, and suffered severe post-traumatic stress. Trophy hunting also causes herd stress, removes individuals in their prime, and is simply unsupportable from any perspective. We trust this statement will remind you that with modern super highways of communications, it is next to impossible to go off road with a program to slaughter elephants. In 2010 Dr. David Mbumba said "In conclusion we are not planning a post 2010 FIFA World Cup elephant bloodbath nor a trigger-happy willy-nilly extermination of elephants as if we are possessed. Culling will come one day as and when it becomes necessary and will be informed by scientific research, management imperatives and prevalent trends as an option of last resort." In 2014 Dr Sam Ferreira, SANParks’ large mammal ecologist said "There will be no further culling of elephants in Kruger National Park for population control because the new, “natural”, methods of managing them have severely curtailed the population growth rate, bringing it down to

just 2%, from a high of 6,5% when culling was stopped in 1994." In June 2017, Dr. Izak Smit (SANParks ecologist) on whether Kruger officials believed there was a need to resume elephant culling at some point in the future, said there were no immediate plans to cull, and that decisions would be guided by the Park’s elephant management plan. In conclusion, we ask for immediate clarification of the draft management plan. Culling not an option today, and the continued trophy hunting of so-called “problem animals” and endangered wildlife passing through dropped fences must stop. We include on our list of concerns the bizarre plans for clay pigeon hunting, elephant back rides (boycotted by all responsible tourism agencies) and golf courses: all of it incongruent with needs of the wildlife we come to your country to view. 131 The sub-objective is stated “to establish a landscape of Dr Audrey Delsink Written inputs, 9 March You are correct in that elephant responses are mismatched. fear” with concentrated efforts in the 28 defined areas of 2018 SANParks concern, however, is not the mismatch of elephant concern (KNP EMP 2013 – 2022, pages 56-58, Map 8). responses, but the mismatch of consequences of elephants at a There is a major challenge with the spatial and temporal local scale. Impact is at a local scale and it is the time they are scale of thinking contained within the current KNP spending and what they are doing at that area of concern that is the Elephant Management Plan. We have demonstrated the key requirement. Please see responses above to clarify the change mismatch in scale in that the elephants operate at a much of the “landscape of fear” to “Local areas of high vigilance” to avoid larger spatial and finer temporal scale than the planning miss-interpretation. The actions in the Lower Level Plans focus on scale for local areas of concern in terms of elephants defining the likely mechanism on how elephants are impacting (Delsink, AK, AT Vanak, SM Ferreira and R Slotow. values at these areas of concern as defined in the approved "Biologically Relevant Scales in Large Mammal Elephant Management Plan of Kruger. Interventions are a site of Management Policies." Biological Conservation 167, passive, active, static and mobile interventions that generate (2013): 116-126). We conclude that any proposed local disturbances to chance the vigilance and responses of elephants at effect management intervention will have a cascade effect that local scale. A specific response depends on the identified likely across the Park and into the adjacent reserves. This may mechanism. Implementation is associated with evaluating whether result in extreme and long-lasting negative effects and the predictions of that mechanism realized – this is adaptive unintended consequences because the management management in practice. approach does not make use of scales of assessment biologically relevant for management of elephant (Delsink et al. 2013). 132 The sub-objective is stated “to establish a landscape of Dr Audrey Delsink Written inputs, 9 March We agree and the detail components informing the lower level plan fear” with concentrated efforts in the 28 defined areas of 2018 have exactly those elements included. concern (KNP EMP 2013 – 2022, pages 56-58, Map 8) i.e. across a large-scale in order “to create gradients of resource use by keystone species… to actively deter species from certain areas where animals have been kept historically at low levels by anthropogenic activities.” The real measure of robust management is through an understanding of behaviour of herds occupying target 77

zones, as opposed to simply targeting the local population in general to achieve a localised effect (Delsink et al. 2013). 133 The sub-objective is stated “to establish a landscape of GMFER Written inputs, 9 March We acknowledge the opinion and prediction. This forms part of fear” with concentrated efforts in the 28 defined areas of 2018 assessing options. SANParks make explicitly use of risk-benefit concern (KNP EMP 2013 – 2022, pages 56-58, Map 8). assessments to evaluate any time of mammal interventions. It forms As we have learnt from previous management part of the adaptive management approach that SANParks interventions such as repopulating reserves with cull embraced. orphans in the absence of mature bulls (Slotow, R, G van Dyk, J Poole, B Page and A Klocke. "Older Bull Elephants Control Young Males." Nature 408, (2000): 425-426; Slotow, R and G van Dyk. "Role of Delinquent Young “Orphan” Male Elephants in High Mortality of White Rhinos in Pilanesberg National Park." Koedoe, no. 44 (2001): 85- 94; Slotow, R and G van Dyk. "Ranging of Older Male Elephants Introduced to an Existing Small Population without Older Males: Pilanesberg National Park." Koedoe 47, (2004): 91-104 and), there is a risk in creating a “landscape of fear” involving the unintended consequences that the proposed management interventions will create that may directly contribute to increased/pronounced human-elephant conflict, inter- species-wildlife conflict and tourism. With tourism being a high-level objective with the sub-objective “To improve tourist viewing and safety” (page 119 KNP Draft Management Plan), any threats to this must be carefully considered. Further, the risks and consequences of lethal management have been robustly assessed (Slotow, R, I Whyte, M Hofmeyr, GHI Kerley, T Conway and RJ Scholes. "Lethal Management of Elephant." In Elephant Management: A Scientific Assessment of South Africa, edited by RJ Scholes and KG Mennell, 370-405. Johannesburg: Wits University Press, 2008), concluding that “behavioural consequences are uncertain, but this assessment indicates they are potentially substantial”. 134 The sub-objective is stated “to establish a landscape of Dr Audrey Delsink Written inputs, 9 March SANParks adhere to national policies, Norms, and Standards. The fear” and refers to the KNP EMP 2013 – 2022 and lists the 2018 interpretation of disturbances not being allowed is debatable as proposed and preferred non-lethal and lethal management commented on here. Closing water is also a disturbance! SANParks options ranging from relatively benign to increasingly engage with several authorities when making mammal aggressive (e.g. noise disturbance to pitfalls to lethal management decisions to ensure that SANParks comply with the shooting - KNP EMP 2013 – 2022, pages 56-58, Map 8). relevant legislation and policies The National Norms and Standards (N&S) of Elephant Management in SA (DEAT. No 251 National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004): National Norms and Standards for the

Management of Elephants in South Africa 2008. pt. No 30833) and the Threatened or Protected Species (TOPS) Regulations (DEAT. National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004): Threatened or Protected Species Regulations, 2007), are the prevailing legislation. Both the KNP Elephant Management Plan and The Management Plan of Kruger Park should be informed and constrained by the N&S and TOPS. The Guiding Principles in the N&S state that: Guiding Principles 3. Any person executing a function or exercising a power or carrying out an activity that relates, directly or indirectly, to an elephant must do so with regard to the following further principles: (a) elephants are intelligent, have strong family bonds and operate within highly socialised groups and unnecessary disruption of these groups by human intervention should be minimised; (b) while it is necessary to recognise the charismatic and iconic status of elephants and the strong local and international support for their protection, proper regard must be given to the impacts of elephants on biodiversity or people living in proximity to elephants; (c) elephants are recognised engineers of habitat change and their presence or absence has a critical effect on the way in which ecosystems function; (g) measures to manage elephants must be informed by the best available scientific information and, where the available scientific information is insufficient, adaptive management forms the cornerstone of the management of elephants and adaptive decision-making tools must be adopted; (h) management interventions must, wherever practicable, be based on scientific knowledge or management experience regarding elephant populations and must - (i) take into account the social structure of elephants; (ii) be based on measures to avoid stress and disturbance to elephants; (i) where lethal measures are necessary to manage an elephant or group of elephants or to manage the size of elephant populations, these should be undertaken with caution and after all other alternatives have been considered; (j) while efforts should be made to ensure that elephants continue to play an important role in an already well- 79

established nature-based tourism sector this should not occur in an inappropriate, inhumane or unethical form or manner; (k) in the context of objective-based management of complex ecological systems elephants should not be accorded preference over other elements of biodiversity; (l) every effort must be made to safeguard elephants from abuse and neglect; and (m) elephant population in the wild should be managed in the context of objective-based management of the complex ecosystem in which they occur.

Thus, the current N&S specifically exclude disturbance as a management intervention to change the way in which elephants utilise the landscape, and further, some of the management interventions proposed do not fall within the listed criteria e.g. being ethical, humane and safeguarding elephants from abuse and neglect. 135 One of the actions listed under the landscape of fear sub- Dr Audrey Delsink Written inputs, 9 March DEA is currently reviewing the Elephant Norms and Standards objective is “Advocate through participation in the review 2018 following experiences of various challenges with the implementation of the Elephant Norms and Standards appropriate of the specific Norms and Standards. SANParks are participating in management responses”. As above, the KNP Elephant that process and will continue to advocate changes that emanate Management Plan and The Management Plan of Kruger from lessons learned while managing elephants. This action allows Park should be informed and governed by the prevailing that process to continue. N&S and TOPS. The participation in informing the revision of the N&S raises concern as the suggested management interventions would necessitate a significant change in the definitions, guiding principles and restricted activities of the prevailing legislation and policy. It is not appropriate for a reserve level management plan inform national policy and legislation to such a degree. 136 A number of statements are made that are based on a lack Dr Michelle Henley Written inputs, 9 March We thank you for your opinion. What is not disputed is that of current scientific evidence or previously disputed 2018 heterogeneity associates with diversity and disturbances contribute scientific findings, especially within savannah systems to that. We have made some clarifying changes. such as the KNP. These include intermediate levels of disturbance leading to maximised biodiversity and successional recovery following disturbance. The preamble to the Table on the Herbivory Programme should be grounded in current scientific thinking 137 Reference to low mammalian herbivore numbers in Dr Michelle Henley Written inputs, 9 March The use of the term “Landscape of Fear” provides a potential mis- historic times cannot be used as justification for setting up 2018 interpretation. Animals in the wild will typically be vigilant about the a current system of low mammalian herbivore numbers in environment and evolve mechanisms to respond to undesirable certain areas. The scale at which high or low densities of elements and stress as and when these occur. SANParks recognize mammals were operating at the time were unknown and this as a key mechanism in how individual animals cope in ever reference to the historic events that influenced herbivore changing environments with different threats and challenges. It is

numbers should equally apply to justify that the system this aspect that SANParks seek to use and thus want to create “local could carry many more herbivores than are currently zones of increased vigilance” which allows individual animals to present and prior to the said abundance regulating events. make choices to respond to perceptions they have about the environment. As part of SANParks due diligence, any intervention are conducted within the ambits of the law and SANParks make use of an ethics committee to evaluate and approve animal interventions. 138 The sub-objective “to establish a landscape of fear” in Dr Michelle Henley Written inputs, 9 March The use of the term “Landscape of Fear” provides a potential mis- order to promote heterogeneous herbivory may 1) not be 2018 interpretation. Animals in the wild will typically be vigilant about the required due to the already proven heterogeneous environment and evolve mechanisms to respond to undesirable distribution of elephants, as a megahervivore within the elements and stress as and when these occur. SANParks recognize KNP. this as a key mechanism in how individual animals cope in ever 2) not be required when expanding on the scale of changing environments with different threats and challenges. It is utilisation beyond the KNP borders. As such we have high this aspect that SANParks seek to use and thus want to create “local elephant densities to the west of KNP in the Associated zones of increased vigilance” which allows individual animals to Private Nature Reserves with very low densities to the east make choices to respond to perceptions they have about the and in the neighbouring Limpopo National Park. environment. As part of SANParks due diligence, any intervention Consequently, there are already fear- and diverse water are conducted within the ambits of the law and SANParks make use resource distribution factors in place which are maintaining of an ethics committee to evaluate and approve animal heterogeneity over larger scales than are being proposed interventions. We have adapted the text. here. 3) be driven or subject to other socio-political With regards to your view on elephant management, we agendas/pressures such as distribution of resources from acknowledge your opinion, which is part of a range of opinions ‘removed’ herbivores due to disturbance shooting. Hence expressed by stakeholders. Viewpoints range from aggressive the scale and methods (with particular reference to the reduction in elephant numbers through culling, to calls for no Elephant Management Plan) at which the proposal is intervention at all. SANParks embrace several lessons and scientific being made. Extreme caution should be taken to not justify findings that help to inform management. The role that elephants ecological outcomes due to socio-political factors although play in socio-economic-ecological systems does not primarily we all know that socio-political factors are as important as associate with how many elephants there are, but rather with how ecological ones. There are a number of current and very elephants use landscapes. Impacts that elephants have on promising mitigation strategies in which, for example large conservation values associate with how intense they use the trees can be protected within the system by more peaceful landscape – for instance feeding year in and year out in the same and less politically charged methods as put forward in the area result in little time for some tree species to recover from such current Elephant Management Plan. Once we make a herbivory. The best science available highlights that what concerted effort to disentangle what is best for the ecology determines where elephants spend time are firstly, essential of the Park, using the most scientifically sound and resources like water, then high quality food. A third factor that ethically acceptable methods available within an adaptive becomes important, particularly in the dry season, is shade and management framework, we can decide on the best way water to control body temperatures. A fourth factor is how elephants to concurrently address social-political needs. Creating perceive undesirable features of the landscape such as people that expectations of a right to claim ‘’íce cream simply because are present. In such cases, elephants will have higher vigilance, you live next to an ice cream factory’’ and justify these avoid such areas at the appropriate time, or avoid these areas rights on potentially flimsy ecological outcomes would be entirely if it is hard for elephants to predict when undesirable contrary to the ethos of a National Park. All aspects are features of the landscape will be present. SANParks thus seek to important to address but entangling them may lead to not restore the ecological process that generates gradients in these seeking innovative and ethically sound solutions for both resources. To achieve this, the approved elephant management 81

people and the herbivores involved. To provide an plan of Kruger National Park seeks to restore natural gradients of example: trophy hunting is highly selective and cannot be water availability, hence the closing of places where authorities used as a method of population control in large open provided additional water. SANParks are also reconnecting areas systems but can be important to generate an income in through partnerships with neighbours and the lifting of fences that non-national conservation areas so they remain protected allow elephants to respond spatially to gradients of food and comfort areas. The need for economic benefits is what drives (e.g. shade) resources. A key challenge is to create the variable trophy hunting in neighbouring conservation areas, not the levels of perceptions that elephants may have about undesirable need for herbivore population control. Separating the features, often associated with humans, in the landscape. It is for ecological requirement from the economic one allows for this reason why SANParks seek to make use of various passive and frameworks and Protocols that lead to innovative ways to active techniques to disturb elephants and “create local zones of address both needs because they require different high vigilance”. The term “landscapes of fear” use previously mechanisms on which they operate. provides potential for misinterpretation. SANParks have not explicitly considered trophy hunting as a tool, but any such consideration need to be within the above context. This approach allows SANParks to responsibly manage the benefits and risks associated with elephants. 139 The current Management Plan of the KNP cannot be Dr Michelle Henley Written inputs, 9 March DEA is at present is reviewing the Elephant Norms and Standards subject to or in contradiction to a change in legislation with 2018 following experiences of various challenges with the implementation reference to the Elephant Norms and Standards. This of the specific Norms and Standards. SANParks are participating in notion would be equal to putting the proverbial cart before that process and will continue to advocate changes that emanate the horse. from lessons learned while managing elephants. 140 List of threats to Vital Attribute 6 (Multiple diverse rivers): Dr Campbell Murn Written inputs, 8 March We will incorporate your suggestion into the text. - We agree strongly that sedimentation is a threat 2018 to rivers - We urge strongly to include erosion and incision (i.e. bank erosion and bed lowering) to be listed as a threat. River processes are dynamic and riparian zones are subject to change and/or degradation due to these processes. Whilst loss of riparian vegetation is listed as a threat in the table, the reasons for it are not. Accelerated bank erosion from changing flow regimes is responsible for the loss of large trees and structural diversity of riparian vegetation. An ongoing research project (MURC1328) is investigating the spatio-temporal consequences of this for riparian-nesting birds of prey. 141 The following statement is made: The purpose of this Prof Rob Slotow Written inputs, 7 March We have adapted the text. programme is to provide guidance on managing factors 2018 and drivers that can derail the benefits of herbivory. This statement is very unclear as a purpose. In a system such as KNP, herbivory is a major process, and it should have both positive and negative inputs onto the system – e.g. enhance through facilitation and deplete through competition. The purpose as stated is a value statement as it speaks to benefits and “derail”. The values that

underpin such a statement are inconsistent with the value system as described for the overall plan. The purpose should be stated as a neutral one, that does not only speak to benefits of herbivory. 142 There is an assumption made when the point is made that Prof Rob Slotow Written inputs, 7 March Thank you for the suggestion and opinion. What is not disputed is herbivores act as disturbance agents. The statement is 2018 that heterogeneity associates with diversity and disturbances made “this implies maximised biodiversity at intermediate contribute to that. We have made some clarifying changes. levels of disturbance.” The intermediate disturbance hypothesis has been discredited in the literature, and should not be put forward in the plan as a principle in this way. We cannot assume that biodiversity is maximised at intermediate levels of disturbance. 143 There is an assumption made that “ecosystems recover Prof Rob Slotow Written inputs, 7 March We have made some clarifying changes. from disturbances such as herbivory, through 2018 successional processes which help create diversity” The concept of succession from primary (disturbed) to climax has been discredited, especially in savannah systems. This is not a sound basis of ecological theory for the conclusions that are drawn about having areas of high and low disturbance. From this point and above, the scientific argument that is put forward in this section as a basis to justify management for extreme high and low herbivory is flawed. There is no scientific basis for the conceptualisation as developed for extremely high and low herbivore disturbance. 144 There is a statement made “the Park had relatively low Prof Rob Slotow Written inputs, 7 March We have made some clarifying changes. mammalian herbivore numbers in historic times ….” This 2018 statement is then used as a premise for the rest of the logic that there are naturally low herbivore numbers in KNP. This is not true, as “historic times” in this statement is recent history, and not long before that the herbivore numbers would have been much higher, and we do not know at what level those numbers would have been. This statement sets up a premise of a desired state being one where there are low herbivore numbers. Our recent understanding of savanna systems is that they can deal with very high levels of herbivory, and that herbivore numbers could be concluded by that logic to have been very high historically. 145 The statement is made that “we operate from the premise Prof Rob Slotow Written inputs, 7 March We have made some clarifying changes. that if disturbance intensity is spatially heterogenious, 2018 biodiversity will be maximised.” There are many factors that influence biodiversity, for example, landscape and habitat being a major influence, which will be stronger than herbivory within those types. The scale at which one views 83

disturbance and biodiversity is ignored in making this statement, both in terms of spatial and temporal scales. It is not clear what is being envisaged as the extreme levels of disturbance in terms of intensity. It is not clear that in the absence of herbivory by one herbivore (elephant as proposed here) (one extreme) in a specific landscape or habitat would add biodiversity value when other herbivores are still present in the landscape. Similarly, it is not clear what is envisaged as the other extreme that would enhance biodiversity). There is no basis provided for this premise, and there is no evidence that I am aware of that demonstrates that this premise is correct. There is another challenge with this premise as stated. The premise has an explicit value judgement in the statement “biodiversity will be maximised”. It is not clear where that value judgement comes from. The management goal of the biodiversity should be framed around the biodiversity that naturally is present, and not to maximise that beyond what may be present. It is not clear why a management premise would be to increase diversity beyond what is naturally present in the system. 146 There is a statement made “to create gradients of resource Prof Rob Slotow Written I]inputs, 7 We have made some clarifying changes. The reality is that in the use by keystone species, we will aim over the longer term March 2018 face of uncertainty and some informed knowledge adaptive to actively deter species from certain areas where animals management allows management to have a perception on how have been kept historically at low levels by anthropogenic systems may function, design and implement management activities.” There is no evidence to demonstrate that were responses, and then use the evaluated consequences to check gradients of resource use by keystone species in the whether this proposed understanding was supported. It is the key Kruger system over an ecological time scale. Yes in recent principle of learning by doing. This is also the case for all the history most megaherbivores herbivores were eliminated previous comments. from the system, but it is not clear that this extended over the longer term. There is an implicit conclusion that there were spatially explicit gradients of elephant herbivory that were static. There are no data to substantiate this assumption, and everything we know about natural systems in Africa indicate both temporal and spatial gradients of usage that are very dynamic. The proposal to actively deter species from certain areas is not based grounded in our knowledge and understanding, but appears to be a thought experiment to do adaptive management and see what happens. 147 The higher level objective as stated in the table “in such a Prof Rob Slotow Written inputs, 7 March We value your opinion and perception of wilderness. This is part of manner as to conserve and restore its varied natural 2018 a spectrum of views on wilderness. See cross link to the wilderness structure, function and composition over time and space, programme and its wilderness qualities”

The sub-objective is then stated “to establish a landscape of fear”. The notion of managers setting out to establish a landscape of fear at the scale being proposed is directly counter the value of conserving “its wilderness qualities”. 148 The sub-objective is state “to establish a landscape of Prof Rob Slotow Written inputs, 7 March The use of the term “Landscape of Fear” provides a potential miss- fear” with the notion of creating heterogeneity in herbivory 2018 interpretation. Animals in the wild will typically be vigilant about the by elephants to promote biodiversity, with an extraordinary environment and evolve mechanisms to respond to undesirable intervention to create an artificial landscape of fear with elements and stress as and when these occur. SANParks recognize major intervention in the system to create extreme this as a key mechanism in how individual animals cope in ever situations of very low (and presumably) high. There is changing environments with different threats and challenges. It is already a very heterogeneous distribution of elephant this aspect that SANParks seek to use to create “local zones of across KNP, and there is no reason to believe that increased vigilance” which allow individual animals to respond to the elephants in KNP are homogenising the system. The environment. As part of SANParks due diligence, any intervention natural heterogeneity of elephant herbivory is likely to are conducted within the ambits of the law and SANParks make use become stronger as the population grows, so of an ethics committee to evaluate and approve animal heterogeneity in their influence on the system (facilitation interventions. We have adapted the text. See also the previous and competition), and it is not clear that there is any need response on the difference between seeking to understand first and for a more extreme situation to be imposed on the system. making use of adaptive management in the face of uncertainty. No basis has been put forward to substantiate the proposed intervention, which is inconsistent with the rest of the plan. 149 The sub-objective is stated “to establish a landscape of Prof Rob Slotow Written inputs, 7 March You are correct in that elephant responses are mismatched. fear” and then makes reference to the areas of local 2018 SANParks concern, however, is not the mismatch of elephant concern identified in the KNP Elephant management plan. responses, but the mismatch of consequences of elephants at a There is a major challenge with the spatial scale of thinking local scale. Impact is at a local scale and it is the time they are contained within the current KNP Elephant Management spending and what they are doing at that area of concern that is the Plan. We have demonstrated the mismatch in scale in that key requirement. Please see responses to previous comment to the elephants operate at a much larger spatial scale than clarify the change of the “landscape of fear” to “Local areas of high the planning scale for local areas of concern in terms of vigilance” to avoid miss-interpretation. The actions in the Lower elephants (Delsink, A., Vanak, A.T., Ferreira, S. & Slotow, Level Plans focus on defining the likely mechanism on how R. (2013) Biologically relevant scales in large mammal elephants are impacting values at these areas of concern as defined management policies. Biological Conservation 167: 116– in the approved Elephant Management Plan of Kruger. 126). Any proposed local effect intervention will cascade Interventions are a site of passive, active, static and mobile across the Park, including into adjacent reserves, with interventions that generate disturbances to chance the vigilance and extreme and long-lasting (decadal) negative effects. responses of elephants at that local scale. A specific response depends on the identified likely mechanism. Implementation is associated with evaluating whether the predictions of that mechanism realized – this is adaptive management in practice. 150 The sub-objective is stated “to establish a landscape of Prof Rob Slotow Written inputs, 7 March We acknowledge the opinion and prediction. This forms part of fear” and then makes reference to the areas of local 2018 assessing options. SANParks make explicitly use of risk-benefit concern identified in the KNP Elephant management plan. assessments to evaluate any time of mammal interventions. It forms There is a major challenge with unintended consequences part of the adaptive management approach that SANParks that will arise from creating a landscape of fear for embraced (see response to comment above). elephants, and the consequences of that for ecotourism within KNP, as well as increased risk of human-wildlife 85

conflict from such a programme. The risks and consequences of lethal control measures and disturbance per se has been reviewed in the Elephant Assessment (Slotow, R., Whyte, I., Hofmeyr, M., Kerley, G.H.I., Conway, T. & Scholes, R.J. 2008. Lethal management of elephant. In: RJ Scholes and KG Mennell (eds) Assessment of South African Elephant Management. Witwatersrand University Press, Johannesburg. Pp 370- 405.) That chapter in the assessment concluded that this “could create long-term problems requiring ongoing management” and “behavioural consequences are uncertain, but this assessment indicates they are potentially substantial” 151 Under the Landscape of fear sub-objective, the plan Prof Rob Slotow Written inputs, 7 March SANParks adhere to national policies, Norms, and Standards. The makes reference to the KNP Elephant Management Plan, 2018 interpretation of disturbances not being allowed is debatable as and the actions contained within that plan. The commented on here. Closing water is also a disturbance! SANParks Management Plan of Kruger Park should be governed by engage with several authorities when making mammal and aligned with the current legislation, regulations and management decisions to ensure that SANParks comply with the policy of the country and should not, as a premise, set out relevant legislation and policies. to change the legislation and policy. The plan should be framed within the existing laws and regulations, and should be governed by the current norms and standards. The current norms and standard specifically exclude disturbance as a mechanism to change the ranging of elephants. What is proposed in the KNP Elephant Management Plan is not permitted by the Elephant Norms and Standards. As such, this Park Management plan should be in accord with the prevailing laws and regulations, and should not be putting forward a sub- objective and actions that are in contravention with these. If the legal situation changes then the plan can be reconsidered at that stage. 152 Under the Landscape of fear sub-objective, one of the Prof Rob Slotow Written inputs, 7 March SANParks adhere to national policies, Norms, and Standards. The actions is” Advocate through participation in the review of 2018 interpretation of disturbances not being allowed is debatable as the Elephant Norms and Standards appropriate commented on here. Closing water is also a disturbance! SANParks management responses”. The Management Plan of engage with several authorities when making mammal Kruger Park should be governed by and aligned with the management decisions to ensure that SANParks comply with the current legislation, regulations and policy of the country relevant legislation and policies. and should not, as a premise, set out to change the legislation and policy. The plan should be framed within As one of the major implementers of legislation, SANParks is by the existing laws and regulations, and should be governed default involved with the DEA to adjust and review existing by the current norms and standards. The current norms legislation so that on the ground experience can be embedded in and standard specifically exclude disturbance as a the revised legislation. mechanism to change the ranging of elephants. The plan proposes an action to intervene in national legislation and

regulates as part of a reserve management plan. This is not appropriate in a section on herbivory in a reserve level management plan. 153 P48: Herbivory objective: 2.1 and 2.2 could almost be Prof Van Helden Written inputs, 6 March The managing of complex systems is best achieved through a seen in opposition, since 2.1 is to “establish”, whilst 2.2 is 2018 systems-based approach where SANParks seek to provide to “restore”. Should KNP be “establishing” in this context? opportunities for socio-ecological-economical process to play out. Note that KNP is an ecosystem that is now enclosed and Ecological processes are particularly challenging as, often, limiting. We need to be careful with this point I think. SANParks face degraded ecosystems. In such cases, SANParks Unfortunately, I have not come up with something better seek to restore the ecological processes such as re-naturalizing to suggest. ecological gradients like water availability, or re-introducing species when these were absent for several reasons. Often, however, landscape constraints prevent SANParks from restoring ecosystem processes. Then SANParks take the responsibility and embed management in a framework of mimicking the outcome of processes as best as if that process was fully functional. For instance, the absence of large predators in small Parks results in limited regulation of their prey species. SANParks then remove individuals of some prey species – this is the typical “offtake” generally perceived. These removals provide opportunities for SANParks to contribute to other socio-economic development (e.g. game available for communities of the wildlife economy) or financial opportunities. A societal context and reality is the benefits that people may derive from Parks irrespective of an ecological justification. In such instance, SANParks responsibly may use resources in a way that would not negatively impact on the persistence of those resources. With regards to animals, SANParks make explicitly use of population models, regularly updated by surveys and additional data, to advise and recommend removals. SANParks do share your concern about welfare consequences and as responsible management agency make use of best practice approaches to minimize welfare challenges for individual animals. 154 Unnecessary creation of competition for water resources GMFER Written inputs, 9 March The “9,000” is incorrect and must be a typo. 19,000 is what were between golf course and elephants: 2018 counted at the last count If one adult elephant drinks up to 80 gallons/day, 19K elephants would consume over 1,500,000 gallons. If there were only 9,000 elephants, the purported “historical” population of Kruger according to this document, they would consume 720K gallons of water (and presumably “free up” water usage for other purposes)

It would appear that elephants and a golf course are in direct conflict for resources. 155 “Landscape of fear” GMFER Written inputs, 9 March The use of the term “Landscape of Fear” provides a potential miss- Elephants, rhinos and other large herbivores already 2018 interpretation. Animals in the wild will typically be vigilant about the navigate a “landscape of fear” in certain areas in and environment and evolve mechanisms to respond to undesirable 87

around Kruger National Park. Following the elements and stress as and when these occur. SANParks recognize announcement of the intention to legalize domestic trade this as a key mechanism in how individual animals cope in ever of horn within South Africa there were spikes in poaching changing environments with different threats and challenges. It is occurrences in the Park, and even a foreign zoo saw rhino this aspect that SANParks seek to use and thus want to create “local killed and horn taken. zones of increased vigilance” which allows individual animals to (https://www.savetherhino.org/rhino_info/poaching_statist make choices to respond to the environment. As part of SANParks ics and http://www.trueactivist.com/16-rhinos-killed-in- due diligence, any intervention are conducted within the ambits of kruger-national-Park-since-beginning-of-march/ and the law and SANParks make use of an ethics committee to evaluate https://www.theguardian.com/world/2017/mar/07/rhino- and approve animal interventions. We have adapted the text shot-dead-by-poachers-at-french-zoo) Elephants safe not safe from human predation in Kruger. Until 2014, when two elephants were killed, South Africa had lost no elephants for "well over a decade." (https://www.telegraph.co.uk/news/worldnews/africaandin dianocean/zimbabwe/11948560/Huge-tusked-African- elephant-killed-by-german-hunter-in-Zimbabwe.html) The safety of Kruger for elephants has already disappeared. 156 “landscape of fear” (continued) GMFER Written inputs, 9 March Please refer to the comment above. As intelligent and social creatures, elephants have already 2018 been shown to act in a way to mitigate their risk, in a greater “landscape of fear” caused by human predations, by migrating to safer areas. (http://www.independent.co.uk/elephant-seek-safety-in- gabon-10431154.html and http://world.einnews.com/article_detail/342548418?lcode =BJBKD1rK-lkkQrdSxY7T-hynsXmLzm- LWRs32yNBbAk%3D) They are refugees. 157 Given that KNP already recognizes the concept of the GMFER Written inputs, 9 March With regards to your view on elephant management, we “landscape of fear” as a way that could (and, in view of 2018 acknowledge your opinion, which is part of a range of opinions poaching and human-animal conflicts within and without expressed by stakeholders. Viewpoints range from aggressive South Africa, already does) affect elephant behavior and reduction in elephant numbers through culling, to calls for no choice of range, there should therefore be a priority on intervention at all. SANParks embrace several lessons and scientific establishing migratory corridors. A “landscape of fear” as findings that help to inform management. The role that elephants a management mechanism is an incomplete, and even a play in socio-economic-ecological systems does not primarily negative approach prone to production of unnecessary associate with how many elephants there are, but rather with how anxiety in highly sentient creatures, unless and until safe elephants use landscapes. Impacts that elephants have on migratory corridors are established and protected. conservation values associate with how intense they use the landscape – for instance feeding year in and year out in the same area result in little time for some tree species to recover from such herbivory. The best science available highlights that what determines where elephants spend time are firstly, essential resources like water, then high quality food. A third factor that becomes important, particularly in the dry season, is shade and water to control body temperatures. A fourth factor is how elephants perceive undesirable features of the landscape such as people that

are present. In such cases, elephants will have higher vigilance, avoid such areas at the appropriate time, or avoid these areas entirely if it is hard for elephants to predict when undesirable features of the landscape will be present. SANParks thus seek to restore the ecological process that generates gradients in these resources. To achieve this, the approved elephant management plan of Kruger National Park seeks to restore natural gradients of water availability, hence the closing of places where authorities provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients of food and comfort (e.g. shade) resources. A key challenge is to create the variable levels of perceptions that elephants may have about undesirable features, often associated with humans, in the landscape. It is for this reason why SANParks seek to make use of various passive and active techniques to disturb elephants and “create local zones of high vigilance”. The term “landscapes of fear” use previously provides potential for misinterpretation 158 Questions about methodology and research GMFER Written Input, 9 March SANParks count elephants at two-yearly intervals making use of a The following questions need to be answered within this 2018 helicopter-based survey covering the total Park. This provides a document with full and proper citations, including page minimum number of elephants known to be alive. There are several numbers for ease of reference: thesis and papers about elephants in Kruger and specifically about How was the count of 19,000 elephants achieved? elephant trends. The last survey was in 2017. SANParks, in Does this number take into account the research about collaboration with several researchers, have some understanding of elephants gathering in areas of greater safety to avoid how elephants move across the landscape. The detail herbivore predation by human actors in search of their ivory and LLP captures integrated surveys across the Greater Kruger. hides, or to capture their calves and send abroad for zoos With regards to the comment of lack of science input – SANParks and entertainment? have an approved elephant management plan for Kruger, which is When was the inventory taken which led to the assertion embedded in the science findings and implications (see response to that the “historical number” of elephants in KNP was 9,000 comment 10). The herbivory plan explicitly cross-links to the individuals? approved plan and thus does not need an exhaustive literature What were the conditions immediately preceding each review for this purpose. inventory count? Were elephants more evenly distributed in South Africa’s wild areas at these points in time? The asserted numbers of elephants in Kruger can create a very misleading impression about actual standing populations. More details are necessary. These questions and more need to be answered: this is not a completely transparent document. Of enormous concern is a complete lack of input, or use of recent publications, by established and respected elephant researchers concerning best conservation practices. There is no reference to the Great Elephant Census. Nor does there seem to be substantial input about 89

elephant behavior and the affects on elephants due to human activity, from habitat encroachment to human- elephant conflict to wild capture to culling to poaching. Such publications are well known in the field, a few were cited in this response, and the experts are available and would surely be willing to lend their expertise to the Kruger management plan for 2018-2028 in order to see best practices in elephant conservation implemented and enhance Kruger for wildlife and responsible research and tourism. 159 The cost to Kruger’s reputation for science as well as a GMFER Written Input, 9 March We acknowledge the opinion and prediction. This forms part of touristic destination would be enormous if culling, or even 2018 assessing options. SANParks explicitly makes use of risk-benefit a public perception that it might be KNP Management assessments to evaluate mammal interventions at any time. It forms Plan’s intention, becomes part of its Elephant part of the adaptive management approach that SANParks Management Plan. embraced. Please see earlier responses. 160 Suggested Solution: GMFER Written Input, 9 March Thank you for your suggestion. Please see earlier responses. ELEPHANT MIGRATION CORRIDORS: 2018 Safe corridors for the movement of elephants and other wildlife are key to their well-being and survival, in Kruger and elsewhere. Even with the increased communications and co-operations created in recent years, there appears to be little incentive or political will, and therefore the resources to ensure the safety for elephants within the Great Limpopo Transfrontier Conservation Area (GLTFCA). As noted, the animals are already experiencing a "landscape of fear" at the borders; whether that prompts an increased population within KNP is speculative, but not one that is beyond reason. It needs to be studied in greater depth. What cannot be done is to add to the landscape of fear in and around Kruger itself. 161 Suggested Solution: GMFER Written Input, 9 March Contraception control the number of elephants, not the impact they ELEPHANT CONTRACEPTION IF THERE IS OVER- 2018 have. Please refer to earlier responses. POPULATION: Will Travers of Born Free has observed that: “Leading scientists have reported that it costs around £50 to contracept each female elephant. If you look at the number of reproductively viable female elephants in Kruger (roughly 3,700-4,500) that means that for between £180,000 and £225,000, a contraception programme could be implemented throughout Kruger National Park. For a country with a GDP that outstrips most other African economies more than ten-fold, (SA GDP, as of November 2014, US$350.63 billion) this is peanuts. I have no doubt the authorities could afford it if they really wanted to.”

(http://www.bornfree.org.uk/campaigns/elephants/campai gn-action/elephant-cull/) 162 Page 116: Herbivory programme: Mr Nick Zambatis Written Input, 7 March We acknowledge the interpretation and have altered the text for “The confinement, protection and historic high water 2018 clarification. Note that elephant populations were increasing at 4.2% provision within Park has been beneficial to elephant. The by the end of 2015 compared to 6.5% when culling were stopped population grew to about 7,000 towards the end of the and water holes were at a peak. 1960s and was kept at this figure through culling (about 16,000 elephants were removed between 1966 and 1994). A moratorium on culling was instituted in 1994 and elephant numbers have increased to around 19,000 by 2017.” This is a biased and contradictory statement: If artificial water provision was responsible for the increase of the elephant population, why has it continued to increase in spite of a very significant reduction of artificial water- points? Similarly, the claim, particularly that a reduction in artificial water-points will result in the elephant population stabilising and even declining, has proven not to be the case, and in spite of a general drought being experienced recently throughout the KNP. 163 Page 117: Mr Nick Zambatis Written Input, 7 March We have adapted the text to clarify. The viewpoint of too high “Ecosystems recover from disturbances such as 2018 number of elephants is part of a spectrum of viewpoints ranging from herbivory, through successional processes which help too few to high numbers. SANParks embrace several lessons and create diversity”. scientific findings that help to inform management. The role that This is a very broad, sweeping and generalised statement, elephants play in socio-economic-ecological systems does not with no evidence, examples or references being given. primarily associate with how many elephants there are, but rather Furthermore, no mention is made of a different ‘stable with how elephants use landscapes. Impacts that elephants have state’, as a result of this supposed “recovery”. The aim of on conservation values associate with how intense they use the this statement is an apparent attempt at downplaying or landscape – for instance feeding year in and year out in the same ‘softening’ the impact which uncapped herbivore area result in little time for some tree species to recover from such populations (and in the case of the KNP, elephants) have herbivory. The best science available highlights that what on confined areas. determines where elephants spend time are firstly, essential resources like water, then high quality food. A third factor that becomes important, particularly in the dry season, is shade and water to control body temperatures. A fourth factor is how elephants perceive undesirable features of the landscape such as people that are present. In such cases, elephants will have higher vigilance, avoid such areas at the appropriate time, or avoid these areas entirely if it is hard for elephants to predict when undesirable features of the landscape will be present. SANParks thus seek to restore the ecological process that generates gradients in these resources. To achieve this, the approved elephant management plan of Kruger National Park seeks to restore natural gradients of water availability, hence the closing of places where authorities 91

provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients of food and comfort (e.g. shade) resources. A key challenge is to create the variable levels of perceptions that elephants may have about undesirable features, often associated with humans, in the landscape. It is for this reason why SANParks seek to make use of various passive and active techniques to disturb elephants and “create local zones of high vigilance”, or as previously referred to as “landscapes of fear”. 164 “The intensity of herbivory will thus be a consequence of Mr Nick Zambatis Written Input, 7 March We have altered the text to clarify. The opinion of homogenization the spatial distribution and variability of resources. The 2018 is part of a range of views from various stakeholders. In some spatial gradient of herbivory disturbances reduce or instances, stakeholders have an opinion that no homogenization is homogenize if factors in the landscape make the taking place. See earlier responses. distribution of resources more even through the landscape (e.g. widespread water provisioning, broad-scale fires, fences excluding access to some resources etc.).” Also a biased statement which conveniently ignores the fact that the build-up of herbivores, e.g. elephants and hippos, also has a strong homogenising effect on the ecosystem, thereby reducing habitat diversity and consequently, reducing biota diversity. Elephants are known as ‘ecosystem engineers’, yet this is also conveniently ignored, with habitat changes being ascribed to non-herbivore management practices such as water provision and fire. 165 “In addition, using herbivores for socio-economic Mr Nick Zambatis Written Input, 7 March The opinion of population control of herbivores through reducing development purposes may result in reduced herbivore 2018 numbers is part of a range of views from various stakeholders. In effects if management implements excessive removals some instances, stakeholders seek no interventions at all. Please (mopane worms Gonimbrasia belina, buffalo, refer to earlier responses. hippopotamus etc.).” Once again, another biased statement which also grabs at straws in an attempt at evading the necessity for herbivore (and more specifically, elephant) population control. It also conveniently fails to recognise that providing benefits to adjoining communities accruing from the utilisation of herbivores results in the development of a very substantial positive and supportive attitude developing and being maintained in these communities towards the KNP and conservation in general. The statement is furthermore Eurocentric in its rationale and of no relevance in an African situation, and especially so where thousands of people, many of them very poor, live next to conservation areas.

166 “Excessive removals”: The harvesting of mopane worms Mr Nick Zambatis Written Input, 7 March We agree. The text does not imply that mopane worm harvesting is is not “excessive” and is restricted to a narrow strip along 2018 excessive. The text highlights a scenario for when this may be the parts of the north-western boundary of the KNP. case. Furthermore, what is removed is directly dependent on what is produced as a result of a particular year’s rainfall, and the ability of the section rangers concerned to provide guards for the safety of harvesters. Because this ability is very restricted, there is no chance of any “excessive removal” occurring. 167 Removal of hippo: The removal of hippo from artificially Mr Nick Zambatis Written Input, 7 March We acknowledge the opinion. SANParks embrace all facets of created hippo habitats, i.e. catchment dams, is not only 2018 resources use and all values associated with conservation and justified ecologically, but essential. Unlike the hippo society. This places enormous responsibility on SANParks. The population found in the rivers of the KNP (which, it can be managing of such complex expectations and systems are best argued, can be allowed to fluctuate according to natural achieved through a systems-based approach where SANParks events because they occur in a natural habitat), that of seek to provide opportunities for socio-ecological-economical catchment dams has been created artificially as a result of process to play out. Ecological processes are particularly the creation of the dam. Human intervention in a ‘human- challenging as, often, SANParks face degraded ecosystems. In made’ problem is consequently justified in controlling the such cases, SANParks seek to restore the ecological processes habitat impact of a large herbivore where it would such as re-naturalizing ecological gradients like water availability, otherwise not exist, or perhaps in very low numbers. or re-introducing species when these were absent for several Besides ecological considerations, not to utilise these reasons. Often, however, landscape constraints prevent SANParks animals for the benefit of adjoining communities, and from restoring ecosystem processes. Then SANParks take the especially in drought situations, cannot be justified, responsibility and embed management in a framework of mimicking particularly if it is remembered that during such the outcome of processes as best as if that process was fully circumstances, many domestic animals and crops functional. For instance, the absence of large predators in small belonging to these people will perish, placing communities Parks results in limited regulation of their prey species. SANParks under severe hardship. then remove individuals of some prey species – this is the typical “offtake” generally perceived. These removals provide opportunities for SANParks to contribute to other socio-economic development (e.g. game available for communities of the wildlife economy) or financial opportunities. A societal context and reality is the benefits that people may derive from Parks irrespective of an ecological justification. In such instance, SANParks responsibly may use resources in a way that would not negatively impact on the persistence of those resources. With regards to animals, SANParks make explicitly use of population models, regularly updated by surveys and additional data, to advise and recommend removals. SANParks do share your concern about welfare consequences and as responsible management agency make use of best practice approaches to minimize welfare challenges for individual animals. 168 Yet on page 138, the following is stated: “Through the Mr Nick Zambatis Written Input, 7 March We acknowledge the opinion. Please see earlier responses. promotion of the sustainable use of natural and cultural 2018 resources, the Park aims to share biodiversity benefits more equitably and fairly, and in so doing promote long- term relationships with stakeholders and neighbours. The 93

strong emphasis of resource use by and for local communities further aims to promote access and benefit- sharing locally, which in the spirit of historical redress and environmental justice goes far beyond simply the resource its self. As such, monitoring for the outcomes of resource use should go beyond simple numbers and quantities of resources (Swemmer & Taljaard 2011) and also look at the impact of these projects in fostering lasting positive relationships with neighbours.” So it is acceptable to provide natural resources of a variety of other kinds to communities, but not any elephant meat or other forms of benefits derived from elephant culling (or the culling of other herbivore species)? This is nothing other than double standards, which seem to suit the opinions of certain individuals who apparently are opposed to the offtake of elephants or other herbivores. 169 Furthermore, as large as the KNP is, the belief that the Mr Nick Zambatis Written Input, 7 March We acknowledge the opinion. Please see earlier responses. KNP is a natural system and must be managed as such is 2018 false. It is a closed system and will forever remain so. Basic veld and animal management principles consequently apply, as much as they do to a game farm of 1000 or 500 hectares, and the sooner this is realised and applied, the better. The only difference is a matter of scale and intensity – the smaller the area, the greater the management intensity required. 170 “The confinement, protection and historic high water Mr Nick Zambatis Written Input, 7 March We acknowledge the opinion. Please see earlier responses. provision within Park has been beneficial to elephant.” 2018 Yes, this is correct, confinement (i.e. fencing) has necessitated that drinking water be provided artificially, not only to elephant but to a diversity of other biota. There is no scope for elephants to freely move out of the KNP in significant numbers and settle elsewhere (where?), hence the need to regulate numbers, as stated above. There is no alternative to this, and not to do so is both unrealistic and in fact will result in irresponsible mismanagement of the KNP, which will in turn lead to ecological disaster. 171 Page 118: Ms Kim Da Ribeira, Written Input 10 March Thank you for clarification and your viewpoint. We have clarified the “Monitoring of the effects of herbivory on vegetation OSCAP 2018 text. dynamics has not taken place during the duration of the previous plan due to a lack of capacity. The aim is to direct future vegetation monitoring in such a way as to inform wildlife off-takes, to support the safe-guarding of species such as rhinoceros, and to support and inform elephant management strategies.”

This statement is not accurate and true. Fixed-point and low-level aerial photography was initiated in the early 80’s, and veld condition assessment surveys in 1989. The latter was aimed at long-term monitoring of the herbaceous layer and was later modified to specifically include the assessment of elephant and fire impact on the woody vegetation, which was not assessed by any other means at the time. It was however decided to terminate these monitoring programmes not because of a “…lack of capacity” but because certain persons who apparently neither any conservation training or practical experience and knowledge of either veld or game management, decided that the emphasis should be on pure research and that monitoring is not important. 172 Furthermore, when elephant culling was suspended, the Mr Nick Zambatis Written inputs, 7 March We acknowledge your opinion, which is part of a range of opinions reason given was that “…there is not enough evidence…” 2018 expressed by stakeholders. Viewpoints range from aggressive that the KNP cannot support more elephants. Yet 24 years reduction in elephant numbers through culling, to calls for no later, and after an enormous amount of research, no clear intervention at all. SANParks embrace several lessons and scientific and solid evidence has been presented by Scientific findings that help to inform management. The role that elephants Services either, that the KNP can support 19 000 play in socio-economic-ecological systems does not primarily elephants on a sustainable basis, without serious negative associate with how many elephants there are, but rather with how and permanent effects on the ecosystem. elephants use landscapes. Impacts that elephants have on The question then is, for how long must research be conservation values associate with how intense they use the undertaken to obtain “enough” evidence? How much is landscape – for instance feeding year in and year out in the same “enough”? And if there is still a need for more research, area result in little time for some tree species to recover from such what has happened in the interim with the application of herbivory. The best science available highlights that what the ‘Precautionary Principle’ until such time that “enough” determines where elephants spend time are firstly, essential evidence has been obtained? resources like water, then high quality food. A third factor that Or is the KNP perhaps regarded as an experimental area, becomes important, particularly in the dry season, is shade and for the benefit of certain individuals to satisfy their water to control body temperatures. A fourth factor is how elephants curiosity, and an endless source of publications? (‘Publish perceive undesirable features of the landscape such as people that or perish’ mindset). Nobody can be given an open licence are present. In such cases, elephants will have higher vigilance, to do as they please and to experiment on a large scale avoid such areas at the appropriate time, or avoid these areas with the country’s heritage, nor can they be immune to entirely if it is hard for elephants to predict when undesirable being held accountable for any blunders which they may features of the landscape will be present. SANParks thus seek to make – immunity only encourages recklessness and restore the ecological process that generates gradients in these irresponsibility. Nor do any of the country’s laws allow for resources. To achieve this, the approved elephant management this. On the contrary, the primary responsibility of plan of Kruger National Park seeks to restore natural gradients of conservationists in general is the custodianship of this water availability, hence the closing of places where authorities natural heritage – the “core function” of SANParks. provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients of food and comfort (e.g. shade) resources. A key challenge is to create the variable levels of perceptions that elephants may have about undesirable 95

features, often associated with humans, in the landscape. It is for this reason why SANParks seek to make use of various passive and active techniques to disturb elephants and “create local zones of high vigilance”. The term “landscapes of fear” use previously provides potential for misinterpretation. This approach allows SANParks to responsibly manage the benefits and risks associated with elephants. 173 “To create gradients of resource use by keystone species, Mr Nick Zambatis Written inputs, 7 March Please see the earlier comment in this regard for further details. we will aim over the longer term to actively deter species 2018 from certain areas where animals have been kept historically at low levels by anthropogenic activities.” Firstly, this seems to finally be an admission that elephants are causing severe and negative impact in certain areas, and their numbers in these areas need to be confined to within an upper ceiling. Never the less, to “deter species from certain areas” will only serve to shift the problem to elsewhere, once again failing to accept the reality of the situation and to control elephant numbers. In any case, what are these “anthropogenic activities”? The control of herbivore numbers, be it by capture and removal or culling, is also an “anthropogenic activity”! 174 Regarding section 10.6.8. In 2nd paragraph, there are Dr. Brandon Anthony Written inputs, 11 Thank you for the opinion. Please see the earlier comment in this examples of problem animals in Park (baboons, February 2018 regard for further details. monkeys, starlings, and hornbills). I believe there is increasing concern about negative human-elephant interaction in the Park which should also be addressed, integrated into the Elephant Management Plan, and monitored within the strategic adaptive management process. See countless cases on social media and Ferreira, S.M., Greaver, C. & Simms, C., 2017, ‘Elephant population growth in Kruger National Park, South Africa, under a landscape management approach’, Koedoe 59(1), a1427.

175 Elephant Management Plans must also take into account Ms Natasha Higgit, Written inputs, 9 March Noted. the destructive behaviour of elephants at sensitive SAHRA 2018 heritage sites 176 Culling GMFER Written inputs, 9 March SANParks seek to restore the ecological process that generates These kinds of amenities (just clay pigeon shooting and 2018 gradients in resources. To achieve this, the approved elephant golf courses alone) will inevitably lead to elephants being management plan of Kruger National Park seeks to restore natural seen as “over-populating” Kruger in a landscape that does gradients of water availability, hence the closing of places where not have enough water and vegetation to support them. authorities provided additional water. SANParks are also reconnecting areas through partnerships with neighbours and the lifting of fences that allow elephants to respond spatially to gradients

Such plans will create conditions guaranteeing that many of food and comfort (e.g. shade) resources. A key challenge is to (perhaps thousands) of elephants would be considered as create the variable levels of perceptions that elephants may have “excess” population and de-stabilizing the environment about undesirable features, often associated with humans, in the which, the report asserts, historically only had 9 thousand landscape. It is for this reason why SANParks seek to make use of elephants (vs. 19K claimed now). various passive and active techniques to disturb elephants and “create local zones of high vigilance”. The term “landscapes of fear” Once culling starts, there will be a “need” to codify it into used previously provides potential for misinterpretation. Culling in the Elephant Management Plan. Once culling starts, it will the traditional sense and meaning are therefore only considered in create more problems (Sheldrick; the above context. https://www.sheldrickwildlifetrust.org/html/debate.html and Travers; This approach allows SANParks to responsibly manage the benefits http://www.bornfree.org.uk/campaigns/elephants/campai and risks associated with elephants. gn-action/elephant-cull/) and do social and behavioral harm for decades to follow, damaging their abilities to survive as they have for millenia (G. Shannon, R. Slotow, S. Durant, K. Sayialel, J. Poole, C. Moss and K. McComb, “Effects of social disruption in elephants persist decades after culling,” https://frontiersinzoology.biomedcentral.com/articles/10.1 186/1742-9994-10-62).

These long-term social and survival mechanism damages are just one of multiple reasons culling has been rejected as a response to “over-population” of elephants. This is why virtually all contemporary elephant specialists are in agreement that culling is a wrong-headed solution to what may not even be a problem. “A scientific perspective on the management of elephants in the Kruger National Park and elsewhere” of 2006 (O. Smith, G. Kirley, B. Page, R. Slowtow, R.J. van Aarde) (http://www.bornfree.org.uk/fileadmin/user_upload/files/fa ctsheets/OwenSmith_et_al_2006._Ele_round_table_sajs ci_102_9_.pdf) even disputes the claims concerning the historic populations of elephants in KNP, and several other issues regarding its “carrying capacity” and damages done. Nearly all elephant researchers are in agreement. Science shows, and conservationists understand, that culling is counter-productive and counter-evolutionary. Hunters on the other hand, have called for the bulk of Kruger’s elephants to be culled, which would be a flagrant disregard of the National Park’s mission.

Section 10.3.9: NATURAL RESOURCE USE PROGRAMME

No. Comment / Input Commentator/s Reference Official response 177 Rare trees e.g. Warburgia only distributed to traditional Community member 13 February 2018, Warburgia plants are distributed at three different levels (increasing healers? Can these plants also be distributed to other Mutale in intensity): community members who are planning to develop 1) Internally to staff in KNP; nurseries? How can the Park assist these groups? 2) To schools and different community groups that are interested; We monitor the survival rates of these trees and also engage with communities at various workshops; 3) Traditional healers. We monitor the impact intensively and engage with them through various workshops; As the main users of the Warburgia plants, the traditional healers have been the first to receive these plants. So far, over 1,500 plants have been distributed this way. However, if other community members are interested, they are welcome to approach their community forum representatives with a motivation as to why they need the trees and where the trees will be planted and their application will be considered. Important to note that the project is not aimed to start many nurseries, because these are difficult to maintain and often not sustainable, but the main aim is that people plant the trees in their own gardens. Relevant KNP staff is able to advise and discuss lessons learned around the Warburgia project. 178 Appreciation and thanks to KNP for allowing access to Community member 14 February 2018, People must be informed before they enter the Park therefore Park communities to harvest Mopani worms. However, when Maphophe Management will ensure proper communication. In all cases, communities enter the Park to harvest Mopani worms, harvesters that have received harvesting permits are accompanied they request that the rules of harvesting be explained by rangers who both protect the harvesters from danger and ensure because some people harvest more then they’re that the harvesting takes place according to the criterion set out in supposed to. the KNP Mopane worm harvesting Protocol. 179 Before KNP burns the veld, can communities be allowed Community member 14 February 2018, The resource use Protocol governs resource use. Our role as KNP to collect elephant bones to make furniture? Maphophe is conservation (in its totality). When animals die, they become part of the ecosystem. In order to prevent disease spreading from one area to another we therefore do not allow people to collect bones or animal skins. This is also important for occupational health purposes. 180 Where can communities have access to more natural Community member 15 February 2018, Resource use is governed by international agreements and resource uses? Acornhoek conventions, national legislation as well as various SANParks policies and Protocols. The SANParks resource use policy outlines the criterion for resource use in SANParks. This policy also includes the steps that need to take place if a member of/group of the public would like to harvest a particular resource from the Park. You can get a copy of this document from your community forum representative.

Certain resource use may not take place in KNP, but the availability and feasibility of resources outside KNP need to be established. The nature reserves and private reserves have their own policies. Hunting for instance may take place in adjacent reserves that are open to the KNP, but hunting may not take place directly in a national Park.

Background: Harvesting of rare or endangered species inside KNP IS NOT allowed. Kruger Park allows harvesting of both mopane worms and thatch grass. Mostly communities living in proximity to where these species occur harvest these resources. There is a programme where we engage with Traditional Healers for medicinal plants outside KNP right along the boundary from north to south e.g. Warburgia (pepper-bark tree). Buffalo and elephant meat that may become available due to management actions is sometimes provided to communities as part of the Natural Resource Use Programme, with the aim of engaging around issues of conservation and creating awareness while building relationships.

There are many ways to work with people on this matter and we are open to suggestions on this. 181 Can KNP supply protein needs for everyone? When is it Community member 16 February 2018, It is still a learning experience. It is not our aim to supply meat to going to stop? White River everyone living in proximity of the Park. Just as we cannot employ everyone in need of a job, we cannot engage with every person through environmental education. Our aim is to use meat when it becomes available as part of relationship building through awareness days in local schools. The aim is to use the protein as just one of the many tools in the relationship-building basket to engage positively with people, restore rights for access and benefits and in so doing build positive relationships towards a more sustainable future. KNP is not harvesting according to maximum sustainable yield. Any resources that are harvested are done so in very small amounts with the aim that the amount removed will not negatively impact on the longevity neither of the resource nor on other associated ecosystem services. Monitoring trade-offs at various scales and scopes forms a large part of the management of the resource-harvesting programme in Kruger. 182 What is meant by access to alternative tissue? Ms Lorinda 16 February 2018, The meeting agreed to look into the concerns raised by certain Steenkamp White River stakeholders regarding the word “tissue” and suggest an alternative way of phrasing these objectives. This has been done for both actions under objectives 1 and 2. The resource use LLP refers to both biotic (fauna and flora) and abiotic resources. The associated resource use objectives are based on a set of guiding principles 99

that apply to all types of resources. In the case of propagating high value species this is primarily aimed at plant material through bioprospecting. 183 Wildlife sales are challenged by the public. The Mr. Louis Lemmer 14 February 2018, Using certain animals to increase revenue is a way to ensure perception in the public is that it is not legal. Is it in fact Pretoria financial survival and economic sustainability. This matter will have legal? to be tested in court to determine if we can or cannot. The question is; do you sell or do you cull animals? The public is not informed of what is happening and SANParks have to communicate these issues to public. 184 The mission of The EMS Foundation is to the Ms M Pickover, EMS Written Input We thank you for the opinion which forms part of a range of views advancement and protection of the rights and general Foundation across stakeholders specifically with regards to resource use. welfare of wild animals, children, elderly persons and other vulnerable groups in South Africa and Africa, for the Please refer to earlier responses. purpose of alleviating and ending suffering, raising public awareness, empowering and providing dignity. The EMS Foundation is extremely alarmed that none of our comments given orally at the Stakeholder meeting held in Johannesburg in 2017 have been taken into consideration in the development of this Draft Plan. This makes a mockery of the consultation process, which gives the impression of a sham. Wild animals are an integral part of South Africa and need to be treated with respect. As such, SANParks needs to take into account the various interests on which it has an impact. The manner in which wildlife is managed affects the wildlife itself, other industries, other non-human animals, the environment at large, biodiversity, surrounding communities and the South African population. In addition, it has a direct effect on South Africa and the way it is viewed by the international community. As part of its mandate, it is crucial that SANParks adheres to the ‘precautionary principle’ and use peer-reviewed and undisputed science, and ethical conservation practices and policies to inform its decisions. However, alarmingly, this Draft Plan seems to err on the side of unjustified commercialisation and exploitation, which is purely commercial thus opening SANParks up to legal challenges, particularly because there are many and more sustainable ways, which are more aligned with the Protected Areas Act, to build economies and create sustainable livelihoods without including or supporting consumptive and exploitative practices. The law no longer permits SANParks to view wildlife as a commodity. Wild animals are in the care of the KNP and

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as such it cannot take a position which does not protect any interest of the animals themselves, whether as individuals or as part as a greater group. The KNP Management Plan needs to take cognisance of animal protection and it needs to be very mindful of the Constitutional Court unanimous and landmark judgement handed down on 8th December 2016 by Justice Sisi Khampepe (with Nkabinde ADCJ, Cameron J, Froneman J, Jafta J, Madlanga J, Mhlantla J, Musi AJ and Zondo J concurring)1 which has elevated the welfare and protection of wild animals to a constitutional concern. Significantly, the Constitutional Court related the welfare and protection of wild animals to biodiversity and the constitutional right to have the “environment protected … through legislative and other means” in section 24 of the Constitution. The Constitutional Court emphasised that constitutional values dictate a more caring attitude towards fellow humans, animals and the environment in general and that this obligation was especially pertinent because of South Africa’s history. The exploitative and oppressive language used in the Draft Plan is offensive and not in keeping with a culture of caring and the scientific recognition of animal sentience. Words like “off-take”, “resource utilization”, ‘culling” etc. when referring to living beings are inappropriate and need to be changed. In relation to elephants specifically, the Draft Plan is seriously flawed and requires considered input. As such, its finalisation must be delayed until the stakeholders envisioned in Sections 39, 40 and 41 in the PAA are given the opportunity to read, research, and properly respond to this plan. Particularly because organisations such as ourselves speak on behalf of the wild animals in Kruger, who are the principal stakeholders. Elephants are not “inventory” or inanimate “resources” to be distributed and disposed of according to the interests of a controversial minority. 185 P137: sustainable use: is there really sustainable use by Prof Van Helden Written inputs, 6 March Please see the earlier comments in this regard for further details humans? Is this proven in any way in any environment? I doubt it. I am opposed to resource harvesting of anything The SANParks approach is to manage in a way that allows in Parks by the public. Therefore, I suggest that any ecosystem processes an opportunity to play out. We acknowledge regular use of resources is severely limited. I understand the disturbance of modern day man. Man as an ecological driver the concern the Park has if they were to ban any resource in historic times, however, would have different spatial extents harvesting. However, in the very long run, this should be associated with key resources that humans needed. SANParks the intention. Otherwise, pressure to increase access will can only mimic this driver. 101

increase, persons will be attracted to neighbouring communities and create ever-increasing problems, as I outlined earlier. Human use of any area will disturb animals and the ecosystem. 186 P137: “humans lived in the Park from 200 000 to 1 million Prof Van Helden Written inputs, 6 March We acknowledge your opinion, and highlight that the management years ago”. This statement, irrespective of any reference of SANParks is done through a multi-stakeholder lense, building is wrong in my opinion. Recent research as far as I am value among broader society in a way that does not lose relevance aware, estimates that modern hominids (Homo sapiens, or function. The extractive use of natural resources remains a humans) arose about 100 000 or slightly more, years ago. controversial issue due to both contrasting value systems as well This is based on many lines of evidence, from as concerns about what might be “sustainable”. The extractive resource use programme operates under a set of guiding principles archaeological to genetics. Therefore, if there were time that are set out in the SANParks Resource Use policy and is estimates for modern man from Kruger, they were either implemented under controlled conditions, is closely monitored and wrong or were wrongly quoted, or what was meant was is being done with the objective of creating value and in so doing that early hominids may have lived in Kruger in those building support for conservation without impacting negatively on earlier times. These were not humans, as we define it the environment. today. And their numbers would have been extremely small, or stated otherwise, arguably vanishingly irrelevant as ecosystem drivers. This must be changed please.

Provide for use of sustainable resources: I do not support this. I think that at the most, KNP should “allow” use. Exception can be the SKZ nursery, which is a wonderful resource.

187 Page 140: ‘Natural Resource Use Programme’ table Mr Nick Zambatis Written inputs, 07 Responsibly managing the harvesting of natural resources from “Write management plans for all types of resource use March 2018 within a conservation area requires an interdisciplinary (social and using a SAM framework.” Not the function of Scientific biological sciences) as well as interdepartmental (science and Services but that of Conservation Management to write several management departments) approach. The writing of the management plans. plans will be done as such involving various experts from appropriate fields as well as various departments in SANParks based on the specific context of the resource in question. 188 Section 10.3.9, page 140. At the meeting held in White Ms Lorinda Written inputs, 10 The meeting agreed to look into the concerns raised by certain River, it was agreed by Kruger Management to change Steenkamp March 2018 stakeholders regarding the word “tissue” and suggest an alternative the wording of the following action and objective to way of phrasing these objectives. This has been done for both specifically refer to Flora: actions under objectives 1 and 2. The resource use Lower Level “Facilitate the propagation of high value species as Plan refers to both biotic (fauna and flora) and abiotic resources. alternative sources of tissue supply, and industry The associated resource use objectives are based on a set of development.” guiding principles that apply to all types of resources. In the case of “To reduce the illegal utilisation of resources from within propagating high value species this is primarily aimed at plant the Park by promoting access to alternative sources of material through bioprospecting. biological tissue, security and raising awareness.” 189 On the topic of sustainable utilisation – is it possible to Ms Lindie Botha Written inputs, 9 March Resource use will remain a controversial issue due to contrasting scale up the current “small scale” projects so that more 2018 stakeholder value systems and a changing conservation mandate. people can benefit, and that more communities will derive Our intention is for many people to benefit from the Park in diverse

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value from living close to Kruger? and sustainable ways and as our knowledge grows on resource use, we can explore more options. 190 Re: The purpose of this programme is to allow for the Ms Kim Da Ribeira, Written inputs, 10 We acknowledge the challenges associated with illegal resource sustainable utilisation of natural and cultural resources OSCAP March 2018 use of various forms. Each formal legal resource use project is from within the Kruger NP that aids biodiversity managed adaptively including monitoring and evaluation of social management, shares socio-economic benefits, fosters economic and ecological impacts. All harvesting complies with positive relationships with neighbours and ensures the existing SANParks Resource Use Policy and harvesters are long-term persistence of the Park as defined in the NEM: accompanied by armed guards not only for their safeguarding but PAA. also to ensure compliance to the required harvesting criteria. Resource Use is seen as one of the many benefit sharing tools Monitoring of small scale resource use projects in the aimed at building support for conservation and is used in Park suggests that these projects have huge potential to conjunction with initiatives such as Environmental Education and enhance local stakeholders perceptions of the Park, Social and Economic Development coming at a low cost, operating for a short timeframe while meeting multiple objectives such as (i) enhancing access to the Park, (ii) contributing positively to basic livelihoods in a tangible way, (iii) enhancing human well- being (iv) promoting conservation constituency and (v) engendering positive long-term relations with neighbours.

A detailed lower level plan outlining the rationale and operational approach supports this programme. This programme links with high-level objective 2 and objective 2.9 on page 49. To achieve the purpose of this programme, the actions listed in the table below will be implemented.

OSCAP comment: • We fully support sustainable utilisation of resources; however, we are not of the opinion that SANParks has the capacity to monitor this effectively to ensure that illegal harvesting does not occur. • There are communities bordering the Park who do not have a tap on their property, the very basic of services is not provided. Has pressure been bought on the Government Departments and Municipalities responsible for this lack of service delivery?

Section 10.3.5: SPECIES OF SPECIAL CONCERN

No. Comment / Input Commentator/s Reference Official response 191 Suggest increased focus on indicator species eg. Birds Dr Jeremy Anderson 16 February 2018, We agree. We are partners with e.g. EWT. However, management White River at species level is problematic. Lessons learnt over time through e.g. 103

drought and water provisioning guides this, with a focus more on ecosystem management. The KNP system changed from a fire driven to an animal driven system. Lessons includes those of the fire policy, grazing lawns, impact of fire policy, hippo culling policy etc. 192 Why is there so little focus on small species such as Dr Jeremy Anderson 16 February 2018, SANParks have an ecosystem approach to conservation and do not oribi, suni, red duiker White River have capacity to monitor all species. These small antelope historically occurred in the Park but habitat changes impacted on them. The railway line impacted on the red duiker and oribi habitat. Suni is a marginal species. The same habitat is covered in the broader GLTFCA. The bush densification and high intensity of fires result in a further habitat modification. In addition, the species of special concern programme highlights clearly that small species management is best achieved by protecting habitats and various gradients of habitats. 193 With our long history in birds of prey related projects Mr. Gareth Clade 13 February 2018, Thank you, noted. both inside KNP and outside, we’ve got the skills and Durbanville support to provide specialist input. 194 Add to sentence: “populations. This together with the David Marneweck, 9 Written inputs This has been incorporated. Sentence rephrased as follows: This scant bird population data currently available for the March 2018 means that efficient and relevant long-term monitoring of bird Park means that efficient and relevant long-term populations both inside and outside the Park is essential for the monitoring of bird populations both inside and outside conservation of the Park’s avifaunal population. the Park is essential to the conservation of the Park’s avifaunal population 195 Should the LLPs be added as addenda to the plan? The David Marneweck Written Input, 9 March The Lower Level Plans will be available. SANParks developed an LLP for the “Species of Special Concern Programme” 2018 explicit definition of species of special concern within its biodiversity should be made available to assess the rationale for monitoring system and this is used this to inform the development certain species being listed as SSCs. of the plan. Criteria include: (1) red list taxa from local to regional scales; (2) taxa without a formal conservation status assessment or with insufficient data; (3) listed in the NEMBA TOPS Regulations or on CITES appendices; (4) species which is subject of a Biodiversity Management Plan as per NEMBA and NEMPAA; (5) endemic taxa that has >80% of range confined to a Park; (6) reintroduced taxa that were extinct or threatened or indigenous species recently introduced and (7) locally threatened populations. 196 Further and more thorough investigation into the David Marneweck Written Input, 9 March This is a very specific concern that is captured in several potential impacts of elephants on large tree nesting raptors 2018 drivers of dynamics of species including threatened species. This (Elephant Management Plan), understanding the requirement is covered under species of special concern dynamics of tree nesting raptor populations in elephant programme with a specific action “Identify, prioritize and manage vs elephant absent areas. This is to assess if vultures threats to the listed SSC”. (critically endangered) are losing key breeding habitat. 197 Paragraph 2: Species of special concern: Long term David Marneweck Written Input, 9 March We acknowledge the specific focal request but retain that this is monitoring of all vulture species as well as the Martial 2018 captured in the existing actions, which we specifically make broad Eagle in one of the species last strongholds is enough to deal with all special cases.

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imperative. With current trends, these species should, unquestionably, be treated as SSC. 198 Regional Conservation Strategy for the Cheetah and David Marneweck Written Input, 9 March We acknowledge the specific focal request but retain that this is African Wild Dog in Southern Africa can be referred to 2018 captured in the existing actions, which we specifically make broad here too. We suggest to include this as a reference as enough to deal with all special cases. There are numerous other KNP is part of the GLTFCA where regional approaches specific plans etc. The intention is that each species considered are are needed to conserve these species of concern (i.e. done so on a case by case basis that includes all other types of continuous monitoring of population, distribution, directives, plans etc. threats, land use planning and co-existence). 199 Action “Monitor large predator populations at David Marneweck Written Input, 9 March We will correct the time frame. appropriate intervals” seems unequal to the annual 2018 With regards to the monitoring suggestion, we acknowledge the timeframe. Should this timeframe not also say at specific focal request but retain that this is captured in the existing appropriate intervals? Alternately, action can be actions, which we specifically make broad enough to deal with all reworded to “Monitor large predator populations” then special cases and requirements. time frame can say at appropriate levels. Additionally, long-term continuous monitoring for large and threatened predators (especially Wild Dogs) be added as a specific action. This is the largest and only viable population of Wild Dogs (and very likely Cheetahs and Lions too) in South Africa and with a generation length of just five years, if continuous long- term monitoring is not achieved then the monitoring at different scales could miss a key threat that results in a declining population. Therefore, we suggest a long-term continuous monitoring programme for endangered Wild Dogs in KNP, with which the EWT can support and assist SANParks in implementing. 200 We would request that, in the paragraph related to avian Dr. Campbell Murn Written inputs, 8 March There are numerous other species, which have also had numerous monitoring, mention is made of the significant effort that 2018 investments and much more publications. We have kept this text as has been invested in large bird of prey monitoring and relatively general to set the context and scene that does not favour research in KNP from 2008 to present. This is or exclude species evidenced by a range of associated publications, some of which relate specifically to KNP (Murn et al. 2013; Murn & Holloway 2014; Murn & Botha 2016; Murn & Holloway 2016) and others where KNP monitoring data have made significant contributions to larger-scale research (Monadjem, Botha & Murn 2012; Murn & Holloway 2016; Murn et al. 2016; Ogada et al. 2016; Thompson et al. 2017; Monadjem et al. in press) 201 Species of Special Concern Programme (table of sub- Dr. Campbell Murn Written inputs, 8 March This is a very specific concern that is captured in several potential objectives) 2018 drivers of dynamics of species including threatened species. This We recognise and agree that: requirement is covered under species of special concern - Safeguarding against poisoning and pollution programme with a specific action “Identify, prioritize and manage is a fundamental part of the Rehabilitation Programme threats to the listed SSC”. (see point 3 above). 105

- The Safety and Security Programme at section 10.6.7 (and objectives table) is focused on implementation of existing safety/security plans and higher-level area integrity. - The Human Wildlife Conflict Programme at section 10.6.10 (and objectives table) is focused principally on mitigation of damage-causing animals and less on risks associated with retaliatory poisoning Given that: - The objective for this programme is managing threats as far as possible to species of special concern - Deliberate wildlife poisoning, increasingly associated with poaching, is a direct threat to a many species of special concern (e.g. Murn & Botha 2017) we urge strongly that an additional sub-objective be added to Species of Special Concern programme: Sub-objective: - To develop and maintain a robust poisoning response capacity that will enable rapid and effective response to wildlife poisoning events Actions: - Conduct training courses to provide conservation staff with methods to deal with poisoning events o POE: Register, Reports - Develop a system for reporting wildlife poisoning events o POE: Reports, Database Responsibility: - CM, RS, VWS, SSV Timeframe: - 2-3 years 202 Species conservation is a sub-set of landscape Ms Lindie Botha Written inputs, 9 March Thank you for your opinion. We have left the text as is. conservation. We cannot conserve species such as 2018 elephant and rhino if we divorce them from the wider issue of landscape conservation and the needs of people living adjacent to KNP. This concept can perhaps be emphasized more strongly in the management plan. 203 OSCAP comment: Ms Kim Da Ribeira, Written inputs, 10 Comment 1: The Park currently finds it difficult to curb rhino • The Park is currently not able to police rhino poaching OSCAP March 2018 poaching and recognize the challenge to ensure that plants such as how will we be in a position to ensure that plants such Warburgia salutaris (also known as pepper-bark tree that is listed as as Warburgia salutaris (also known as pepper-bark critically endangered because of over utilisation in the wild due to its tree, that is listed as critically endangered as a result of high medicinal value), is protected. over utilisation in the wild due to its high medicinal

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value), is protected. Response 1: Protecting rhino in 2 million hectares has many, complicated challenges. In the case of Warburgia, the fact that they • Is there any evidence that these plants are currently are trees and therefore stationary makes it easier to deploy rangers being illegally removed inside the Park? (albeit costly) to protect them. We have several rangers who are solely responsible for the protection of the Warburgia trees and we have been very successful in this regard since they were first deployed almost 10 years ago.

Comment 2: Is there any evidence that these plants are currently being illegally removed inside the Park? Response 2: Whether inside or outside protected areas, whole Warburgia plants are never removed. It is mostly the bark from Warburgia that is harvested. Bark from the Warburgia in the Park was periodically harvested illegally prior to their protection by rangers. Since our rangers were deployed to protect the plants, there has been much less illegal harvesting. As the supply of Warburgia seedlings increases outside of protected areas through our distribution programme, the pressure on the protected populations will become less. Our distribution project is ongoing and thousands of Warburgia are distributed to various stakeholders each year. Most of these stakeholders live adjacent to the KNP, the primary group including traditional healers. 204 List of threats to Vital Attribute 7 (Largely intact biota Dr Campbell Murn Written inpust, 8 March Thank you for the useful addition. We have adapted the text and and ecological processes): 2018 wildlife poisoning (non-intentional and deliberate) is a listed threat - We urge strongly that intentional wildlife in the Vital Attributes Table and the degradation and Habitat poisoning be listed as a threat to this vital attribute rehabilitation LLP. Wildlife poisoning is indiscriminate and multiple species and numerous species of special concern are affected. This threat has increased in recent years, especially in relation to poaching. Poisoning events occur within KNP (van Jaarsveld 1987; SANParks 2016) and adjacent areas and will have population-level impacts on numerous critically endangered species (Murn & Botha 2017). 205 The Rehabilitation Programme (table of sub-objectives) Dr. Campbell Murn Written inputs, 8 March We agree that deliberate poisoning of wildlife is becoming an We recognise and agree that: 2018 increasing threat in the region. This is included specifically at LLP - Safeguarding against poisoning and pollution level, but we have made changes to the text to make this particular is a fundamental part of this programme type of poisoning threat more explicit. - Poisoning and pollution in this programme is focused on unintentional, inadvertent or non-deliberate Added in the text, P 121, just above “Alien clearing…” para, “The events recent and rampant increase in deliberate poisoning of wildlife for Given that: the illicit trade in wildlife parts is increasing in the region. The recent - Deliberate wildlife poisoning, increasingly use to poach elephants and rhino has elevated public concern, associated with poaching, is a direct threat to a many since the magnitude of a single poacher using pesticides can be species of special concern (e.g. Murn & Botha 2017) large, killing not only the primary victim, but if used in sufficient 107

We urge that deliberate wildlife poisoning be concentration, several secondary consumers such as vultures and recognised as a separate threat and response methods lions. The actual pesticide can vary and several different be incorporated into the Species of Special Concern compounds and formulations have been used throughout Africa to Programme poison wildlife (Ogada et al., 2014). KNP is not immune to this threat and several mass poisoning incidents have killed large groups of vultures. The approach to preventing deliberate poisoning of wildlife is multi-pronged and involves greater understanding of the problem, greater protection of the natural assets, improved response times, arrests rates and prosecution as well as improved legislative control over pesticide use, storage and distribution. Specific detail will be provided in the LLP

Section 10.3.6: PREDATION PROGRAMME

No. Comment / Input Commentator/s Reference Official response 206 10.3.6 The section seems rather incoherent. Dr Louis Van Written inputs, 3 March Thank you for your opnion and suggestions. We have left the text Suggest that matters related to Schalkwyk 2018 as is,given limited further comments. - density, such as water availability, prey, DCA and certain diseases (rabies/distemper); - cumulative effects in apex predators, such as disease in prey species, chronic disease (e.g. tuberculosis), environmental health (e.g. pansteatitis); - anthropogenic influence, such as problem animals due to livestock densities/proximity, spillover of disease from domestic to wild animals (e.g. distemper/rabies), provision of water; - endemic disease with risk of high mortality in endangered species (e.g. rabies/distemper) be discussed separately to give better structure to the section 207 - 10.3.6 This paragraph does not make sense. Dr Louis Van Written inputs, 3 March We have adapted the text. The reference to Maputla et al., 2015, should be Maputla Schalkwyk 2018 et al, 2013

Section 10.3.2: HABITAT REHABILITATON

No. Comment / Input Commentator/s Reference Official response 208 Groups of people doing rehabilitation. Wants clarity on Community member 14 February 2018, Thorny branches are placed in disturbed areas to prevent soil the purpose of brush-packing? Maphophe erosion. If an area is not covered, the first heavy rains will washthe soil away. 209 Objective to restore the integrity, and support the David Marneweck Written inputs, 9 March We acknowledge and appreciate the work EWT is conducting within conservation, of important upstream river/riparian 2018 the catchment concerning the protection of the riparian habitat. The habitat, in particular on the Olifants and Blyde river integrity of the riparian habitat is a particular concern for SANParks, catchments, to reduce impacts downstream in KNP. this is captured In high level objective: EWT is working extensively within these river River health: sub objective: geomorphic habitat change and

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catchments (using Pel’s fishing owls as flagship species Riparian/vegetation dynamics. for the conservation of these important habitats). 210 Water provision programme Mr, Nick Zambatis Written inputs, 7 March Artificial provision of drinking water for wildlife is part of the Why is the artificial provision of drinking water for wildlife 2018 rehabilitation program as this is currently our objective: to remove not identified and listed as a programme in itself, and and rehabilitate the area. However, within this program a especially when it is the programme which has probably comprehensive database of all water points (irrespective whether existed longer than any other? man-made or natural) and their uses is being recorded and will be maintained. A separate program is not required. 211 The destruction of large catchment dams such as Mr, Nick Zambatis Written inputs, 7 March Noted. Langtoon. It cannot be disputed that some artificial 2018 water-points, including some catchment dams, have created more problems than they solved. The overall objective to remove as many catchment dams as possible however, and supposedly for ecological reasons, is short-sighted, and especially so with the threat of climate change and its currently unknown effects on the KNP ecosystem in particular. On top of this is an ever-increasing human population and correspondingly increasing demand for water. Consequently, what the Lowveld will look like in an ecological sense in even 20 years from now, let alone in 50 years’ time, does not seem to have been taken into account when deciding to remove catchment dams. Currently-perennial rivers can become seasonal in future and only flow through the dry season in exceptional circumstances. Ecologically, it is obvious that this would be disastrous for most aquatic biota. The effect of this in turn would be that these biota, and especially hippo and crocodile, decline drastically in number, with the only refuge left for them being Corumana and Massingir dams in Mozambique – both not only outside the RSA and the KNP, but in areas which have a high (and increasing) human population. Furthermore, being animals which are in conflict with human activities, it is not unreasonable to conclude that over time, their numbers in these dams would be reduced severely or even eliminated entirely because of human conflict. Yet if at least some large catchment dams in the KNP were retained as refuges for these animals, then their long-term survival would be enhanced very significantly and within a safe, protected area. But in all likelihood, the counter-argument by purists to this rationale would be that this is an artificial approach to the conservation of hippo and crocodile (and other 109

aquatic biota). Yes, this is correct, but it must also not be forgotten that climate change is man-made and not a natural phenomenon either, so human intervention becomes necessary to solve or mitigate a human- caused problem. This also again illustrates the point that as large as it is, the KNP is no longer a totally natural and open ecosystem and must be managed accordingly. 212 The Rehabilitation programme may cause impacts to Ms Natasha Higgit, Written inputs, March It is the Parks policy to remove all redundant artificial water points heritage resources such as the demolition and SAHRA 2018 as part of the rehabilitation program, in order to restore the rehabilitation for all undesirable artificial water Wilderness status of the area. We will take into account the possible infrastructure may impact on historical water structures. “heritage status” of structures if need be. Additionally, clearing Protocols for bush thickened sites may impact on archaeological sites and disturb the Known archaeological sites in areas that are bush thickened and stratigraphy of these sites. planned for rehabilitation will be noted. It is also SANParks’ policy to immediately terminate activities when new archaeological sites are exposed by its staff or contractors.

SECTION 10.3.3: INVASIVE ALIEN SPECIES

No. Comment / Input Commentator/s Reference Official response 213 Section 10.3.3 Ms Natasha Higgit, Written inputs, 9 March Where there are zones containing heritage sites that need to be As noted above, clearing of alien vegetation may impact SAHRA 2018 managed in a specific manner, NHRA restrictions will receive due heritage sites. Once all heritage sites are mapped and cognisance. zoned, a maintenance plan that is cognisant of the restrictions in terms of the NHRA must be developed and implemented.

SECTION 10.3.7: FIRE

No. Comment / Input Commentator/s Reference Official response 214 Can KNP assist communities with veld-fire prevention Community member 14 February 2018, KNP can provide fire awareness for communities. Municipality and and fire fighting. Veld-fires after drought. Is there any Maphophe local Fire Protection Associations are supposed to train the local technology or presentation available to educate communities because there are various purposes for using fire. communities about fires Some municipalities are very helpful whilst others are not. Municipalities are also supposed to assist and form local Fire Protection Associations, which should be able to assist and train communities. In areas far from municipalities, the National Fire Act is currently being amended so that Traditional Authorities can assist and develop a local Fire Protection Association. In KNP, some staff is trained on how to use fire. SANParks is not an accredited service provider that could provide official training for community members. 215 Request schedule of fires inside KNP! Also to inform Community member 14 February 2018, A summary of the fire map for KNP outlining the causes of fire is whether it is planed/controlled or not. Maphophe available on request. The total area to be burnt as prescribed fires during the fire season is available as this is based on rainfall.

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216 Page 134: Mr, Nick Zambatis Written inputs, 7 March The question is not if the fires that entire the Park from outside our “The previous Park Management Plan (2008) did not 2018 borders is natural or not. In KNP, we have accepted that man-made account for fires burning into the Park from neighbouring fires are considered natural and are part of this system. The areas, even though this was a common occurrence. concern is the intensity of these fires, which are mostly very high Sometimes, these wildfires would burn through intensity. If the fires from outside the Park were of the correct extensive areas of veld under extreme conditions making intensity, then we would allow them to burn freely. However, them difficult to control.” operationally this is not possible. This statement is largely incorrect in that fires entering the KNP from neighbouring areas, and especially from We agree with your assessment of the results of having high Mozambique, were regarded (by scientists, and not intensity fires on our basalts due to jumped fires from Mozambique. conservation managers) as being ‘natural’ (“mimicking primitive man”) and were allowed to burn. But with no The previous method of firebreaks along on borders was not concrete, science-based evidence. For this reason, no effective and therefore we are now experimenting with alternative special effort to make firebreaks (other than the firebreak methods of firebreaks. along the boundary, as is required by law) was made in order to limit the spread and frequency of these ‘jump‘ Our current Fire Protocol and TPCs acknowledges that fires have fires. historically been too frequent and too hot on the basalts; hence, we This resulted not only in enormous areas being burnt are trying to limit fire frequency and intensities in this part of the every year, but also in a very high fire frequency, which Park. As mentioned above, we are investigating other methods of in turn has led to a very extensive increase in the spread boundary firebreaks to improve the effectiveness of these of Themeda triandra (rooigras), a fire climax species with firebreaks to decrease the number of jump fires entering from very limited grazing value (in the Lowveld). In addition, it Mozambique. produces a relatively high biomass, which in turn favours high-intensity fires. The situation has thus been created where it is self-sustaining and the only way to reduce its dominance is with high-intensity grazing. But this is only practical with domestic livestock, the impact of which can be easily controlled (‘short-duration, high-intensity’ grazing). Never the less, large parts of these areas have been converted to open grassland, largely or totally devoid of any woody plants. Is this then a ‘desired state? In the Lowveld? Yet for a number of years, there were repeated warnings from section rangers and others with much practical field experience, that the fire frequency is too high and the fires too hot (intense), causing severe damage to vegetation. But this was ignored, no doubt because they are not scientists. 217 Page 135: ‘Fire Management Programme’ table: Mr, Nick Zambatis Written inputs, 7 March Both departments will be working together. “Develop and implement an integrated fire / elephant 2018 TD: Tourism Department operational plan”. Agreed – this will require scientific input from Scientists to facilitate The development and implementation of operational the development of the operational plan by Conservation plans is not the function of Scientific Services but that of Management. But it should be noted that this will be a multi- Conservation Management. The function of Scientific 111

Services is simply to provide the scientifically-derived departmental endeavour that’ll require the practical field experience information required by management to compile and knowledge from the rangers in Ranger Services as well operational plans, and to implement them. Scientists are not managers; the management of the KNP must be left to managers. Bottom of table: Who is ‘TD’? 218 Page 136: “Promote safety and protect infrastructure by Mr, Nick Zambatis Written inputs, 7 March This has been added to the LLP constructing and maintaining firebreaks.” 2018 The reference for this is both the National Veld and Forest Fire Act, and the GKFPA. 219 Maintain appropriate networks, collaborations and Mr, Nick Zambatis Written inputs, 7 March Both departments will be working together. support structures to encourage co-learning and 2018 knowledge sharing.” This action is a multi-departmental function that involves several This has nothing to do with Scientific Services but refers people which will be working together to achieve this, i.e. Scientific to operational fire management and fire safety – Services, Conservation Management, Technical Services, Ranger operational matters are not the responsibility of Services. scientists. 220 The fire management programme must consider the Ms Natasha Higgit, Written inputs, 9 March We agree that, where possible, heritage resources need to be impacts to heritage resources. Any planned burns must SAHRA 2018 protected from veldfires. Known structures in the Park are usually avoid sensitive heritage resources such as structures, surrounded by low fuel loads and hence not at risk of burning. In graves and rock art. some cases, firebreaks are actively made where fuel loads are reduced by bush-cutting in the surrounding vicinity. Similarly, the rock art is often located on granitic or sandstone outcrops, caves or rocks high above the grass layer where these veld-fires burn. KNP has had a burning programme since the 1950s, which has not had any known damaging impacts on our known heritage resources.

SECTION 10.3.8: DISEASE MANAGEMENT

No. Comment / Input Commentator/s Reference Official response 221 10.3.8 “Ecephalomyocarditis” should be Dr Louis Van Written inputs, 3 March Noted and changed accordingly. “Encephalomyocarditis” Schalkwyk 2018

222 10.3.8 “FMD Buffer zone” and “Disease buffer zone” Dr Louis Van Written inputs, 3 March Noted and changed accordingly. should both be “FMD protection zone” – this correction Schalkwyk 2018 will also prevent confusion with KNP’s buffer zone 223 10.3.8 “mains a veterinary cordon fence” should be Dr Louis Van Written inputs, 3 March Noted and changed accordingly. “maintains a veterinary cordon fence” Schalkwyk 2018 224 10.3.8 “Other diseases can be spread” should be “Other Dr Louis Van Written inputs, 3 March Noted and changed accordingly. diseases which can be spread” Schalkwyk 2018

225 10.3.8 Strategic vaccination and dipping of livestock is Dr Louis Van Written inputs, 3 March Noted and changed accordingly. the responsibility of provincial state veterinary services. Schalkwyk 2018

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Fence maintenance and monitoring is partially the responsibility of provincial state veterinary services. 226 10.3.8 “Animal Healh Fourm” should be “Animal Health Dr Louis Van Written inputs, 3 March Noted and changed accordingly. Forum” Schalkwyk 2018 227 10.3.8 “National Institute for Communical Diseses” Dr Louis Van Written inputs, 3 March Noted and changed accordingly. should be “National Institute for Communicable Schalkwyk 2018 Diseases” 228 10.3.8 - It is also important to mention the zoonotic risk Dr Louis Van Written inputs, 3 March Noted. that diseases such as tuberculosis, brucellosis, anthrax Schalkwyk 2018 poses, both to staff and neighbouring communities, Noted, the emphasis of this sentence is on indirect versus direct which is an important reason to monitor these diseases losses- rather than overall net benefit/loss. and their potential impact on staff/communities. - Correct term for “…disease buffer zone Added, “It should also be noted that FMD status does bring some surrounding the Park …” is FMD Protection Zone advantages to communal farmers such as improved access to (with/without vaccination). veterinary services.”

Perhaps too much emphasis is put on the indirect losses Added to risk assessment sub-objective that already exists. through FMD trade restrictions. Although these exist, they are often perceived losses, and few studies have quantified this or even compared it to other more direct losses (e.g.

SECTION 10.3.4: FRESHWATER ECOSYSTEM MANAGEMENT PROGRAMME

No. Comment / Input Commentator/s Reference Official response 229 I see that you’ve been monitoring ground water since Mr. Sven Kramer 15 February 2018, You are more than welcome to contact Dr Eddie Riddell and Mr 2007 and I’m interested in the results. If the current Johannesburg Robin Peterson to get the information. drought, as currently being experienced in the Cape, becomes a widespread factor then groundwater monitoring becomes critical. 230 Instead of pampers being thrown In the rivers where else Ms Zanile Sibuyi Public meeting Waste management is the responsibility of local municipalities. can they be disposed of properly? However, the KNP engages on this issue strongly through our own outreach and environmental education activities, and clean-up campaigns (e.g. clear river month). Furthermore, the KNP strategically engages on this matter through catchment management forums, where the issue of corporate social responsibility of the manufacturers of this waste material is elevated. 231 Freshwater ecosystem programme: Sub-objective; Written inputs We acknowledge the request: this is captured in the high-level Understand changes in water dependant (i.e. waders, objective: River health- sub objective: geomorphic habitat change piscivorous) species of birds in response to changing and Riparian/vegetation dynamics. We welcome targeted research water quality and loss of key riparian habitat. on the specific concern. 232 Riparian zones should be delineated and protected from Written inputs Note: Cross-link to Zoning non- sustainable tourism developments and those 113

developments that have washed away during 1:50 and The riparian zones are indeed an important and sensitive habitat. 1:100 year floods should be closed and redesigned to Whilst they are not specifically zoned in the use zones map they adapt to climate change and future threats. The Riparian have been afforded protection through the sensitivity layer on which zones do provide crucial habitat during drought periods development locations within use zones are selected. The reasons and has not only a rich biodiversity of living organisms for not affording them special protection within the use zones is but also contribute to the high aesthetical value and twofold; sense of place of the Park. - Remote Zone? Many of the developments in KNP where put in place many years ago before the use zones were implemented. To retro actively removing these developments would not only be costly, both in terms of direct costs but also due to lost revenue, but it was felt that retaining these already disturbed sites would have less impact than relocating the infrastructure to currently undisturbed areas 233 Improve the management of the Aquatic impact buffer Written inputs Note: Cross-link to Zoning zones that forms part of the Riparian buffer zones by relooking at the current tourism facilities and access This is a valid point and is something that we are taking note of roads that are negatively impacting on the river systems, going forward. Where infrastructure is damaged due to extreme (siltation, trampling of root systems, pollution and events such as floods their viability and impact they have on the sewerage contamination of soil and underground water. environment is assessed before being rebuilt. For all new developments, green building principles are being implemented to reduce their impact. In addition, infrastructure such as roads that are found to negatively impact natural processes are moved or closed where feasible. 234 The investigation of the creation of artificial wetlands in Written Input The integrity of wetlands systems “Ecological Infrastructure” is a the river systems before it enters the Park in order to catchment wide process that requires wetland system to be buffer out heavy metals and plastics are needed protected or restored to perform the desired ecosystem services. For this reason, creating artificial wetlands on the KNP will not necessarily remedy the problem. 235 Creation of Artificial wetlands to restore the ecosystems Written inputs Please refer to the comment above.

SECTION 10.4: WILDERNESS AND AS ALIGNED WITH SECTION 6 - ZONATION

No. Comment / Input Commentator/s Reference Official response 236 What is the status of the road network in the Wilderness Mr L Lemmer 14 February, Pretoria Roads in Wilderness areas are management roads (maintained areas? mainly as 2-spoor tracks) and will not be utilized as tourist roads. There are no roads in the wilderness zones. All roads that traverse the wilderness zones have been rezoned to primitive to adhere to the legal requirement of wilderness areas. No further roads will be constructed through wilderness zones. 237 Re: The following management activities are conducted Ms Kim Da Ribeira, Written inputs, 10 Noted. within the Park and will continue in the OSCAP March 2018 foreseeable future and the monitoring of these actions in wilderness areas is crucial: Monitoring and research;

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Removal of redundant structures, e.g. windmills, dams, buildings; Rehabilitation of roads, management tracks, gravel pits and man-induced erosion; Wildlife off-takes; Anti-poaching activities; Fire management; and IAS removals.

OSCAP comment: Until such time as Poaching is addressed with the urgency it deserves and real progress is made in combatting this crisis the concept of ‘Wilderness’ areas within the Park will be risk. 238 My question relates to the proposed zonation. Are you Mr Toney Carnie 12 February 2018, In theory the Wilderness areas are increasing because we are proposing any changes to the dark green areas Durban rehabilitating certain areas by removing dams, water points etc. (Wilderness zone) i.e. net loss? The % area covered by the Wilderness zone has in fact decreased. This is mainly because of the legal definition as stated in the Protected Areas Act. There is no development or roads allowed within the Wilderness zones. Therefore, we had to exclude these in the 2018 version. It was included in the 2008 / 2011 versions.

Though the official Wilderness zones have decreased slightly, the overall area that could potentially become zoned as Wilderness in the future has increased. 239 Wilderness High Level Objective: I am not convinced Prof Van Helden Written inputs, 6 March Thank you, the necessary change has been made. Appropriate use that one can have wilderness by means of “Park 2018 and management of tourism products will be undertaken in our development’. Maybe by management, perhaps. designated Wilderness Zones. 240 ‘Wilderness Programme’ table: Nick Zambatis Written inputs, 7 March Thank you. Both departments will be working together. “Develop appropriate monitoring and auditing 2018 mechanisms to verify whether developments adhere to target wilderness attributes and industry standards.“ This is the function of Conservation Management and not Scientific Services. Same for “Develop and maintain a collaborative network between the Park and other conservation or wilderness- associated institutions (regionally, national & internationally) so as to promote wilderness qualities and associated values.” Not the responsibility of Scientific Services but Conservation Management.

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SECTION 10.5: RESPONSIBLE TOURISM

No. Comment / Input Commentator/s Reference Official response 241 Could you give us an update on the Selati railway projects? Mr Tony Carnie 12 February, Durban The failed Selati train restaurant gave us the opportunity to advertise a package (accommodation and restaurant). The concession was put out to tender in 2017. Overnight facilities (5 star) will be offered on the bridge (sleeping wagons, bar and gym) while the current train restaurant will be split into fine dining for the train customers and a restaurant for other tourists. One bid was received. An evaluation process was followed, and it was awarded to the bidder (a consortium). 242 Could you also tell us about means to alleviate traffic Mr Tony Carnie 12 February, Durban A project was launched to develop a visitor management plan. The congestion in the south of the Park? University of Queensland as well as local role-players assisted with this project. A survey was done with stakeholders (staff, management, tour operators, communities etc.) to determine what they think. The feedback that they gave us were very interesting, highlighting various things for consideration, many of which we already know. A few of the main issues that were raised are the gate management system, visitor management (conduct and flow of visitors), interpretation.

The entrance to the Park has been staggered for different entry times to ensure there is no congestion or there is redirection of traffic. There are three entry times mainly used during peak. Visitors choose the time that suit their needs. 243 There are already limitations regarding the number of Mr Tony Carnie 12 February, Durban We currently have the gate quota system for day visitors. The day vehicles that can enter the various gates. Are you looking visitor quota for the entire KNP is 7,500 per day. The gate quota is at limiting that further and what are the present limitations? but one tool to manage the traffic. 40 % of this quota is bookable in advance according to time slots. 244 Which developments happened in the south of KNP and Community member Within the existing footprint, we need to renovate and improve what new developments are planned for the north? 13 February, Mutale current structures. In the north, we have developments at the gates, e.g. Shangoni gate and Phalaborwa hub. We also plan future wild activities/hub developments at other entry gates, pending feasibility studies.

Some developments have started and are nearing completion. Skukuza Spa completed, Lower Sabie additional tents 95% complete, Skukuza Lodge 90% completed, Berg en Dal Day Visitors completed, Mananga 4x4 Trails reopened. There are also new developments coming up; Selati accommodation, Nkuhlu accommodation, a new product coming up soon Rock Art Trails near Berg en Dal 60% complete and various products, which will be advertised accordingly as per the rule. There are six (6) new development earmarked for the North of the Park; Shangoni gate and Camp, Pafuri Port of Entry Gate, Phalaborwa Activities hub,

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Mobile tented Safari Camp (like a fly camp), Letaba Concession, Phalaborwa Safari Lodge. 245 I am mobility challenged, wheel chair Parking right next to Mr Hendrik (surname 13 February, Hazyview SANParks must provide adequate facilities and Park in process of shop but disability Parking should be by a ramp. Wheel- not known) updating facilities. We also hiring people with disabilities (2%, aspire chair access must be better planned. to 7%) and must upgrade facilities to accommodate these disabled people. The wheel chair friendly activities vehicles have been ordered to accommodate mobility challenged visitors. These will be placed at specific camps. 246 Have concessions been effective? Are they contributing Mr. Sven Kramer 15 February, The concessions are very effective in terms of revenue generation financially? Johannesburg and setting a standard that we find hard to meet. They are audited every six months regarding a range of issue i.e. environmental management, water consumption etc. Should they be non- compliant then they have 14 days to correct or they go into breach of contract. 247 Regarding the moratorium on development south of the Mr. Mike Whiting 15 February, The Malelane and Skukuza projects are continuing. The Skukuza Sabie River. Does this include or exclude the 2 “Hotel” Johannesburg Lodge is about 80 % complete. I have not received one complaint projects (Skukuza and Malelane)? to date, regarding noise or any other environmental issue. The current operator of the Malelane Lodge could not source the necessary funding. The project might go out on tender again but that decision has not been taken. We don’t intend to develop more big camps but we could develop more picnic sites or roads to enhance visitor experience and to give the tourists more opportunities to get off the road and out of their vehicles 248 Does this (infrastructure development) also include Mr. Mike Whiting 15 February, Part of their land has been fenced in due to the railway line, and developments in the community areas outside the Park i.e. Johannesburg needs to be sorted from a legal perspective. The land previously Pretoriuskop? thought to be community land (Nkambeni) is in fact declared Park land, and the land audit programme (within the regional integration programme) will address this together with interventions through the SED programme 249 Are there any other models around the world where a Mr. Fred De Groot 15 February, It seems to me unique in terms of how SANParks are working with National Park can have a mixture of off-road versus very Johannesburg the private sector. In America and Canada, there are models where strict regulation like is currently the case in the Park the Government works together with the First Nations of the respective countries.

KNP and conservation areas adjacent and open to the KNP is now in the process of compiling “: best practice” guidelines on a range of matters, including conservation, responsible tourism, safety and security etc.

When the concessions were conceptualise a Protocol for off-road driving was developed and this is audited regularly. E.g. they must record on GPS where they do it are also not allowed to drive off- road if the veld is wet. 117

250 At the last traffic alleviate meeting in Groenkloof it was Mr. Fred De Groot 15 February, This is exactly why we have commissioned the research. The report mentioned that the current visitor rate is 1.8 million per Johannesburg states that certain times of the year it is saturated i.e. school - and annum, hopefully to be 2.2 million per annum in the future. public holidays, long weekends. It also recommended that it must You’ve mentioned that no more big developments will be managed differently. The threshold for the number of vehicles happen south of the Sabie River. Does this mean that this per kilometer is being exceeded. There are a number of ways area has reached saturation point? suggested to manage the traffic i.e. expanded road network, one way roads, getting cars of the road for longer through additional picnic spots / bird hides, as well as staggered entry times, gate closure times stay same 251 You also mentioned that the Selati railway bridge Mr. Fred De Groot 15 February, The process that we followed was to test the market through the concession has been awarded. It has recently went out for Johannesburg PPP process, people then submit bids, it is awarded to a preferred interested and affected parties and the results have not bidder, and they then have to do an EIA as part of the process. If been circulated yet. Are you not putting the chart before the EIA states that it is a no-go, it is at their cost / risk. the horses, so to speak? 252 Can I get a copy of the Traffic alleviate document? Mr. Fred De Groot 15 February, You are more than welcome to contact Kevin Moore for a copy. Johannesburg

253 I’m worried that the individual developments is not seen in Mr. Fred De Groot 15 February, Thank you, we take note of your concern. Developments are context with regards to the cumulative impact that it will Johannesburg guided by the concept development framework and guiding have on the environment. principles of the environmental legislation. 254 OSVs are a big problem in the south of the Park as well as Mr R Potgieter 14 February, Pretoria Concessions are audited every 6 months on several areas of in the concession areas like Timbavati for the way in which compliance varying from diesel storage, water consumption, they behave and drive off-road. Is there a management behaviour on drives, including off-road driving. They are only plan for OSVs in concession areas? allowed to drive off-road under certain conditions and must report / map any off-road driving. They are evaluated on performance and monitored very closely by KNP section rangers. The relationship with them will be reviewed if found to be in breach of the contract. 255 What is the Policy on game spotting and the congestion as Mr Jansen-Davies 16 February, White It is a challenge. One can make rules, but policing in an area the result of the OSV’s? River size of KNP is challenging

There are Visitor Management control vehicles that have been recently introduced (Dec 2017). These vehicles travel on any of the Park roads for help, information sharing and to address non- compliance by perpetrators. 256 Camp developments should keep aesthetics, such as the Stakeholder 16 February, White Thank you for your comment. Any developments are guided by our Pretoriuskop pool, golf course, Tshokwane. Current River Infrastructure development Protocols, camp masterplans and buildings are very visible. zonation plans. A key focus is to minimise visual and environmental impact as reasonably possible, as guided by the required environmental audits. 257 P143: tourism: Is it not time that KNP had a plan for local Prof Van Helden Written inputs, 6 March KNP caters for all market segments, including camping, bungalows tourism. In this sense what is meant by “local” is South with communal ablution and kitchen facilities, bungalows with their African citizen. KNP is clearly targeting upmarket tourism own facilities, family cottages, guest houses, tented with the building of new hotel facilities in SKZ. Chalet accommodation and concessions to cater for the five-star market. accommodation in KNP is becoming extremely expensive The Skukuza Safari Lodge is not targeted at only international for locals. There is a gap between expensive chalet and

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cheap camping options, which could be filled or maintained visitors but rather to accommodate conference delegates which by existing or new, but simple bungalow or fixed tent makes use of the conference facility at Skukuza Rest Camp accommodation. 258 In order to curb speeding and congestion, I’d like to Ms Trude McDonald Written inputs, 09 Feb. We take note and value your suggested interventions to curb contribute the following for your consideration: 2018 speeding and congestion on the Park tourist roads. A mobile Tourist  Ban radio contact among the drivers of open Management Patrol Unit has been implemented and will be further viewing vehicles. developed and expanded upon to control traffic congestion and  Ban the sighting app. speed control in high impact tourist roads in the Park.

Radio contact is a necessity on the SANParks open game viewers to have communication for emergency purposes. These radios are not used to notify colleagues of sightings. Your request to ban the sightings app is noted and discussions to manage these sites appropriately are currently taking place internally.

With respect to the Commercial operators: The radio issue was attended to by SATSA saying they will monitor if the guides abuse this. It must also be noted that the KNP did raise the issue with the OSV operators where the operators claimed that that is the only tool they have to can communicate with guides for business of the following day not necessarily for sightings. Hence their commitment to manage the issue. The KNP suggested an MoU in this regard, and this will be addressed accordingly 259 In all instances, heavy fines and a limited restriction on Ms Trude McDonald Written inputs, 09 Feb. We take note of this valuable input and will certainly factor these visiting any of the SANParks reserves should be imposed. 2018 constructive suggestions into our strategic planning and These considerations are both to the safety and well-being implementation. of the animals, and visitors who truly enjoy all the Park offers. 260 Negative publicity in the press and on social media is going Dr. Michael Brett Written inputs, 17 Feb. The South of the Park is more accessible to visitors travelling from to damage the strength of the Kruger Park brand. It is 2018 Gauteng, rather than to North of the Park. Be this due to location suggested that the Kruger Park should not be marketed as of Park entry gates, condition of road infrastructure from Gauteng a “one size fits all” destination but, rather, that to the Southern parts of the Park but surveys have indicated that consideration should be given to marketing the 4 regions the economic situation of the country plays a role as well as the of the Park as offering different things to different niche extreme heat conditions experienced in the North of the Park during markets. There is resistance to the Northern and Far Summer months. The Shangoni gate could attract more visitors Northern regions as the public perception is that they are from Gauteng to the North of the Park as it will allow for direct further away from Gauteng, and that they do not contain access to camps like Bateleur and Shingwedzi. as much game. (See page 38 in the report). 261 Thus, the southern region could be marketed as a “Big Dr. Michael Brett Written inputs, 17 Feb. The tourism concept is that the developments near Shangoni Gate Five” region but the Far Northern region could be marketed 2018 should include the theme you are suggesting. These ideas are still as “the unspoilt northern wilderness.” A camp the size of at discussion stages and your input is appreciated. Mopani is therefore out of step with the profile of the northern half of the Park. Marketing the northern half of the Park as offering a different experience could include establishing historic camps illuminated only by paraffin 119

lamps, accessible only by ox waggon or 4x4 vehicle, and which would cater to a nostalgic gaze. Consideration should also be given to establishing additional 4x4 routes in this region and on establishing a number of small, unfenced camps. 262 In the southern region, there should be a moratorium Dr. Michael Brett Written inputs, 17 Feb. Any product will be based on zonation, which supports development placed on additional accommodation unless this is placed 2018 of products at the periphery of the Park, considering the current on the periphery of the Park and it can directly benefit congestion. The camp master plans guide any developments in adjacent communities. It should also be noted that there camps. A visitor management plan will address these concerns, are at least 200 lodges adjacent to the Park, and these whilst processes are underway to address the arrangements with lodges make continuous use of the Kruger Park. peripheral areas.

263 As the southern region is losing its ambience, serious Dr. Michael Brett Written inputs, 17 Feb. This route is used mainly due to access areas of interest in the consideration should also be given to closing the H4-1 2018 south; Crocodile Bridge gate visitors from the western side of the during peak periods. By way of comparison, the 200-ha Park (H4-2) also use it. Closing this rote during peak may cause Animal Kingdom at Disney World in the USA receives 10.5 total chaos when it comes to visitor management. Most visitors from million visitors per annum, or 52,100 visitors per ha, Mozambique also use this route to access the Park. The southern compared to 0.92 visitors per ha for Kruger. Such a part is a day 1 night over for visitors who wish to proceed with their considerable number of visitors is accommodated by using journey to other parts of the Park. 27-seater trucks, and visitors are generally pleased with the experience they receive. However, a visitor management study completed recently, is providing options to address congestion on this road during peak seasons, and recommendations will be implemented and monitored. 264 The Park and Ride system, which has been established at Dr. Michael Brett Submitted via email on The Marketing department will be informed about this suggestion. Phabeni, Numbi and Kruger gates, needs to be better 17 Feb. 2018 The Activities Co-ordinator is aware of the potential and has the marketed so that it attracts day visitors during peak holiday plan for improving the activities from that point. periods. This initiative needs to include “value adds” such as exceptional game sightings, refreshments on board or access to no-entry, patrol roads so that it becomes more marketable. 265 Page 147, Marketing the Park Stakeholder Written inputs, 27 The possibility of introducing the suggestion will be investigated and February 2018 implemented where possible. This is one of the key areas, and ultimately where we know many problems lie. This is mainly due to ignorance or plain disregard of rules by some visitors. Social media has been to ‘blame’ for many targeted attacks against the Park, as in ‘they aren’t doing anything to address this’, so whilst I don’t like ‘name and shame’, I feel there needs to be some feedback to the conforming visitors that something is being done. E.g. X amount of people were apprehended for speeding in one month etc.

Signage has been shown to be largely ineffective as a method to control driver behaviour, mainly because people

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become habituated to signs. However, mobile and seasonal signs may modify some behaviour and encourage people to behave more responsibly. I know many people will NOT like to see more signs in the Park ( as they will say it interferes with their viewing), but there could be more awareness signs dotted around (not just at gates or in the guidebook). Things like, there are X amount of snake species in the Park … how many can you see…. Look on the road as this is where they like to bask, etc.

Visitor radio – excellent idea – it may go someway in preventing the congestion and speeding to sightings often blamed on Latest Sightings Facebook sites. Social media control – this seems to be to blame for poor behaviour as people rush to sites. However, some surveys and research should be undertaken first before limiting this. I.e. surveys to assess how many people actually use it, what do they use it for, how can it be improved? Update guidebook – may be expensive, but this could be done on an annual / two year basis, and include not just generic Park information, but recent science snippets. Visitors like to know more about what is being done on a research level, so what about some interesting findings … what to look out for? If it can’t be incorporated into the guidebook, what about a one-pager that list some of the exciting projects in the Park that people can collect at the gate? I know there is the SANParks Times, but it isn’t always up to date. You often see people in research vehicles in the Park, and wonder who they are and what they do … more information about projects would be very interesting. Can we encourage some of these researchers to make themselves available at the rest camps to chat to people about the work?

Adequate training of staff – in addition to the items already mentioned in the draft, gate staff should be more informed of projects in the Park, so that they can then chat to visitors about research.

Many of the above probably falls within the section for research, but for me, I feel there is an overlap between visitor experience / behaviour and work being undertaken. The marketing of the Park should also include the research.

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266 Traffic monitoring surveys Stakeholder Written inputs, 27 Thank you. We take note of your suggestions, and this will be Don’t limit to the south of the Park. We know there is less February 2018 implemented where possible, and as supported by the traffic in the north, but it doesn’t mean behaviour is any recommendations from a recent visitor management study. different. Speeding? There should be a flood of traffic surveys across the Park – it will take time, but will identify hotspots.

External tour operators need to be better governered – induction at gate? 267 The responsible tourism programme should include Ms Natasha Higgit, Written inputs, 9 March Thank you, this aspect will be addressed through the Tourism educating staff and visitors of the importance of heritage SAHRA 2018 interpretation programme. resources, the relevant legislation and general do’s and don’ts around heritage resources. 268 Identify, review and mitigate the visitor impact on Ms Natasha Higgit, Written inputs, 9 March Thank you, noted. …heritage …resources. – These reports must be SAHRA 2018 submitted to SAHRA. 269 Develop and implement a Park interpretation plan – As per Ms Natasha Higgit, Written inputs, 9 March Thank you, noted. section 44(2) of the NHRA “Where a heritage resource SAHRA 2018 which is formally protected in terms of Part 1 of this Chapter is to be presented, the person wishing to undertake such presentation must, at least 60 days prior to the institution of interpretative measures of manufacture of associated material, consult with the heritage resources authority which is responsible for the protection of such heritage resources regarding the contents of interpretive material or programmes.” Section 44(3) of the NHRA states “A person may only erect a plaque or other permanent display, or structure associated with such presentation in the vicinity of a place protected in terms of this Act in consultation with the heritage resources authority responsible for the protection of the place”. The above means that SAN Parks must consult with SAHRA prior to the establishment of any interpretive material or structures (museum or centre). 270 Re: The development and improvement of tourism Ms Kim Da Ribeira, Written inputs, 10 A 10-year maintenance plan informs the high-level maintenance infrastructure is critical for sustainable growth. OSCAP March 2018 programme and annual budget requirements. A detailed annual OSCAP comment: maintenance plans are compiled from the 10-year maintenance plan and is informed by the condition assessments and budget • There is evidence that maintenance of existing availability. There are budget constraints to execute the required infrastructure is lacking, what provisions have annual maintenance plans, but it was approved to increase the been put in place to ensure that adequate maintenance is available maintenance budget annually to ensure that we close the carried out on existing infrastructure? gap between the required maintenance budget and available Re: The Park recognises that apart from the limitations of maintenance budget. the biophysical environment and the Park’s desired state;

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that tourist density and experiences must be managed through a strong but flexible visitor management Protocol that is informed by a sound research programme as well as the experiential expectation and perceptions of the broader market place.

OSCAP comment: • Is the research mentioned in this paragraph available? 271 Re: Potential risks to tourism in the Park are diverse and Ms Kim Da Ribeira, Written inputs, 10 Your comments and concern expressed are noted and appreciated. largely unpredictable. A study conducted during 2016 by OSCAP March 2018 All efforts are being made to identify, understand and mitigate the the University of Pretoria concluded that rhino poaching risks posed to both tourists and staff. and anti-poaching measures do impact tourism and could affect future visitations to the Park. Conservation fees will increasde by 11.3 % in 2018 /19 for all national Parks with rhino’s. This increase has been brought about to support the increasing costs associated with Anti-Poaching operations.

OSCAP comment: • The word ‘increased’ is misspelt. • Until such time as poaching is addressed with the urgency it deserves and real progress is made in combatting this crisis revenue from tourism is at risk. • I would suggest that this aspect be included in your follow up Customer Satisfaction Surveys. • Have SANParks addressed the internal problem of staff’s involvement with poaching? There is no point in collecting extra funds if staff and auxillary staff are not being correctly monitored by means of for example life style audits? Corruption is probably our biggest driving force in the poaching crisis and yet the word corruption is only cited in two instance in this Draft. • What measures have been implemented to ensure that funds from this additional levy are channelled to support anti- poaching efforts?

SECTION 10.7: SOCIO-ECONOMIC DEVELOPMENT PROGRAMME

No. Comment / Input Commentator/s Reference Official response 272 Are there any other plans to increase the future Mr Tony Carnie 12 February, Durban This is an important programme, which in future will be expanded environmental education programmes outside the Park? through strengthening partnerships with a range of strategic

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Equally important, increasing the budget for these stakeholders, addressing various age groups, the youth and programmes. internship programmes.

About 80,000 children that participate each year in the various programmes, ranging between quality and quantity. We have 5 formal education centres in the Park, based at the major camps. The Department of Basic Education do support the programmes, but this is limited to resources. Transporting the children to the Park is a major limitation. Our focus is on changing behaviour rather than just pushing more children through the programmes.

We take the education of the youth very serious. We cannot reach all the children but for those that we do reach this might be a life changing experience. We have started a project in conjunction with the Peace Park Foundation and the Laureus Foundation on the Mozambican side of the Park. These communities are 10 times worse-off than the South African communities along the Park. These children were taken to the science laboratory in Skukuza and the rhino boma. These children have a different view of the Park, without a doubt. 273 With the establishment of the lodge, ward councillors Mr Zodwa Mthetwa 13 February, Hazyview SANParks did its best to include everyone in the Skukuza Safari rather than community members were consulted, must not Lodge development. We do not condone Traditional Leaders being use political platform but use community, must talk to left out in any KNP developmental processes. A Project Steering community leadership, chiefs have been left out re talks Committee was formed consisting of all community relevant about lodge. Not employing local people, buses with structures and thus we thought all are represented in the workers to build lodge coming past here. Committee. Based on this we assumed that communication was Lodge employed people from 45 kms away and not from going to reach all stakeholders and we sincerely apologise to all closer by. Traditional Councils and forums if not included.

The Project Steering Committee takes charge of community beneficiation in the projects. The number of employment opportunities for the members of the community depends on the nature of the project. They do try to take people from forums. See January 2018 community employment report below:

In January 2018 the Skukuza Safari Lodge community employees record stated: Total number of local employees for January 2018: 113 land claimant - total number 67.8%, 75 in total and community in general under the leadership of the councillors are having 45.2%, 38 in total. SANParks have the statistics available in terms of all local employment and spent on local communities. 274 Promote opportunities through infrastructure development, Mr Zwelithini 13 February, Hazyview There are programmes through the ME’s office and SED that will increased communication for youth, must use skilled youth Mkhapela be developed to accommodate youth. This is a high priority for the and elders to mentor. CEO and we are rolling out various programmes.

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SANParks has an Environmental Monitors Programme that involves Youth in Environmental Education and community awareness and it is aimed at local youth participation. KNP will be hosting a Youth Summit in 2018/19 to create a Youth platform to raise their conservation issues and suggestions on how jointly we can fight wildlife crimes. SANParks support Youth Sport development through KNP Wild About Soccer Project whereby soccer is used to attract youth to Conservation programmes, KNP uses local Retired Rangers in various programmes such as Paperbark trees monitoring and propagating back into the communities. They are also engaged in Oral History documentation for proper Cultural Heritage Management in Kruger Park. The Promoting Access programme will also seek to support various events, such as sport events as platform to build an understanding and appreciation of conservation.

The Human Capital Management programme is guided by the SANParks policy framework in terms of advertising vacancies, internships, volunteer programmes, with these opportunities being communicated via community fora, traditional authority structures and a range of other media. 275 Can land claims and cultural heritage opportunities be Mr Lemmer 14 February, Pretoria Yes, indeed. Recruiting and training of local guides through the used to create tourism opportunities for example, training Guides Association is in planning. Until now, it has not been used local people as guides? to the advantage of the Park. 276 Who decided that SANParks should be responsible for Stakeholder 16 February, White This role should be played by society as a whole. Working beyond Social Development? And how does this tie in with the River our boundaries in an integrated manner is vitally important. Similar land claimants? to our river management programme, which is working outside of KNP, why cannot we play this role with people on issues e.g. sanitation, health issues etc. SANParks can use their clout, and deal in a meaningful way to enhance opportunities and livelihoods which will also help reduce civil unrest etc. 277 Communities ask what are KNP doing for them. But need Ms Wiggins 16 February, White There is a significant cost to communities to have the KNP on their to look at what they are doing without an immediate return. River doorsteps. Communities lost their land to form the Park, we have to Perception of poverty vs Park not being addressing that? find sustainable ways in which they can benefit. From a government and private sector perspective, we all have a CSI role to play. SANParks implemented a CSI contribution of 1% of tourism revenue. We are looking at additional programmes. 278 What is the SED wildlife Economy? Stakeholder 16 February, White This programme is more for previously disadvantaged farmers, River where feasible. This includes a range of programmes, such as donations, land inclusion, wildlife management projects, etc. However, there was a workshop where it was decided to review the principles and criteria for such a programme. 279 What is the second window for land claimants? Stakeholder 16 February, White The Government led land claimant programme is open until 30 June River 2019.

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280 How are you (SANParks) going to resolve unemployment Community member 13 February, Mutale The KNP has a new SED programme, which seeks to further issues in the communities? enhance opportunities for employment and other programmes for the next 10 years.

This programme has several sub-programmes, which will focus on supporting sustainable wildlife economy initiatives, bioprospecting, SMME development, EPWP, land claimant programme, Tourism products and access, strategic business and sector integration approaches, environmental education.

However, KNP cannot be the only provider of economic opportunities, and a major focus of KNP, communities and sectors would need to see how best opportunities could be aligned. This will require enabling governance arrangements within communities, including the transparent communication of any opportunities.

If an opportunity through EPWP, for SMMEs etc. exist, or through other partner programmes, further support can be given, pending funding, feasibility, community readiness, long-term sustainability etc.

The SANParks Policy framework guides the communication and distribution of vacancies through the community forums, local traditional councils and other structures, pending the requirements for a specific position or programme. This implies that adverts will be advertised locally, whilst certain positions requiring expert skills, will be advertised Nationally. However, if community fora and structures are well-constituted and formalised, transparent, efficient and broad communication of opportunities are better enabled. 281 What is KNP doing to help the people living right next to Community member 13 February, Mutale The KNP provides a range of opportunities and participation in the Park (less than 3km)? Do we give education to the various programmes to communities adjacent and further away communities close to the Park (3km)? from the Park.

This includes education and outreach programmes as per KNP Protocol and guidelines. A future expansion of the programme is envisaged in collaboration with external partners.

The SANParks policy framework and KNP Protocols also guides a range of further collaboration opportunities, e.g. pertaining to learnerships/internships, bursary opportunities to staff (often from communities). Future processes will inform the development of guidelines to ensure realistic support to communities, whilst leveraging joint opportunities with other sectors and partners.

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However, it is imperative that the current community and other fora be constituted to ensure transparent and efficient communication, and enabling governance arrangements for joint partner opportunities pending the necessary feasibility studies. 282 If communities can collect litter and make recycled arts and Community member 13 February, Mutale There is an opportunity to collaborate with communities, ito bulk crafts, can KNP help them to sell these crafts to the services. However, this will require the necessary feasibility studies tourists? In these projects, litter, can be seen as job to guide process and economic opportunities. KNP has a project creation project (recycling). manager that could engage with communities on this matter. 283 Forceful removals, e.g. Masorini – who does the Community member 13 February, Ba- The Masorini example is illustrative of the land claimant process. 6 descendants benefit, and how many years back? Phalaborwa settlement agreements have been concluded, and 10 need to be verified. This process deals with this. 284 Similar wrt the forceful removals, how are people Community member 13 February, Ba- Currently 10% of the shareholding has been allocated to the benefitting from the Skukuza airport? Phalaborwa Buffelshoek Trust. 285 About land claims, when Jacob Zuma came, they were Phumzile Mthetwa - 13 February, Hazyview KNP is not responsible for payouts, the Department of Rural also invited. However, other claimants have received Belfast Development and Land Reform is responsible for Land Claims money but they have been referred to Nelspruit. Why? compensation payment. Currently out of the 16, only 6 land claims have been legitimised and KNP is working with those claimants. A communication forum called Land Claimant Forum was formed to address KNP and land claimant matters. Yes, its true former President Jacob Zuma came to Skukuza to official launch Land Claims Compensation and he showed cheques, which were dummy cheques. There are two types of compensation: Household compensation, which is shared by family clans, not individuals, so money must be shared amongst family. The second phase will be Community Development Scheme wherein money will be used for development, therefore all Compensation issues must be addressed to your contact representatives. 286 From Belfast, the managers sitting in office and deciding Mr Bethwel - Belfast 13 February, Hazyview Nobody is promoting shooting of people by rangers, we must build that poachers will be shot but these people must rather better relationship. help to solve poaching by solving poverty. It is hard to see people driving smart cars and you get sucked in, Park must make plan to solve poverty. 287 KNP visited the area to celebrate Mandela day and Ms Susan Mkhatshwa 13 February, Hazyview It is true that KNP has celebrated Mandela Day and our offer still promises were made to build a kitchen facility (Siphephela - Nyongane stand, it is just a matter of finalising the logistics. We are an Khona), people came to do site visit but nothing has organization that sticks to its value systems and our promise will be happened. fulfilled. 288 KNP asked communities for a list of unemployed youth Community member 14 February, Maphophe This is not a KNP initiative but an initiative from the local forum. with Grade 12 so that it can be used to identify potential employees. Since then, there has been no response from This information was required for the EPWP programme (BSP), but KNP. Why? in future we will seek alignment with and communication through the SED platforms. 289 Does KNP recognise community based projects and Community member 14 February, Maphophe Refer to the previous comments on SMMEs and guidelines / support them? Protocol to be reviewed (community economic empowerment Protocol).

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290 How can communities influence wildlife economy plans Community member 15 February, Acornhoek SANParks have developed a strategy and guidelines to evaluate and become part of these? how communities could benefit from wildlife economy programmes, based on governance, feasibility, risks, etc. Communities, if they qualify, can participate through a range of opportunities, e.g. wildlife donations, making their land available for Wildlife programmes etc. Communities can engage with the KNP SED unit. 291 Possible solution to the Pampers problem. Could we go Prince Gulukhulu 15 February, Department of Health and relevant organizations need to come back to using the cloth nappies? Malumulele together and address this environmental crisis and health threaten challenge

Waste Management SMMEs focus can assist in addressing the challenge 292 Not enough workshops and teach youth artisan skills. Build Community member 15 February, Ka- There is already an existing workshop. Meet up with the woman craft workshops at TSB. Mhlushwa working there. Engage with TSB to put develop a craft workshop and mechanical workshop. They enrol about 600 “students”. If you are from Bushbuckridge, you will get a bursary and accommodation subsidy and food allowance. Currently there are no funds, you need to apply at other institutions. Councils must approach government to enquire about learnerships. People should not be jealous that people from other Provinces are working here, as KNP is part of SA. 293 Request for hampers to disabled children and build centers Kholiwe – Shongwe 15 February, Ka- The Park cannot provide facilities for disabled persons. The Forums for disable children and their parents. Mhlushwa should approach the relevant Government departments and NGOs. NGOs can liaise with the Department of Social Development. KNP operates under constrained budget. Information received must be shared with others in the forum. 294 3 to 4 years without a forum and no members from Mr Vusi Nkosi - 14 February, Ka- Thank you, we take note of your concern. We are currently Matsulu. Seems that the current forum activities only deals Matsulu Bokweni reviewing the constitution of forums to be more sector integrated, with fences and DCA but not with development or and to be aligned with the People and Parks programme. We are recycling? also in the process of setting up offices in community areas, so that we are more accessible. 295 How can KNP assist the local disability forum with selling Community member 16 February, Giyani The contact person can be contacted at 013 735 4340, and then their arts and crafts? meetings can be called to discuss opportunities for communities to sell crafts. 296 A community member with welding skills enquiring how he Mr Mabunda 16 February, Giyani SANParks / KNP strives to ensure community access to benefits. It can be of assistance to the KNP? will be difficult to only focus on individual needs hence KNP promote community group projects i.e. the Science Labs within community schools. We encourage individuals to form Close Co-operatives / Pty Ltd companies. 297 Does KNP donate to or support community based Mr M Chauke 16 February, Giyani KNP do support community-based projects through its CSI Legacy projects? programme whereby a number of Science Labs have been built at schools. 298 How far is the land claim compensation process for Mr S Mathebula 16 February, Giyani We are not aware of Shangoni Gate Land Claimants but we have Shangoni land claims? opportunities identified around the soon to be build Shangoni gate. Land claimant communities who have signed the phase one

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settlement agreement will also be required to sign the beneficiation scheme agreement with SANParks. Once the business legal entities have been registered with either the Master of High Court for Community Turst or a PTY LTD with the CIPC then the opportunities will be accessed. 299 Referring to a project at Ndindani, where they have planted KR Mshengu 16 February, Giyani It is noted that the Ndindani Lalapalm Project suffers from the lala palms, but it is not working properly because they take shortage of water. KNP is prepared to work with relevant too long to give them water and the plants die government departments and private agencies as well as the local municipalities to assist minimizing the failing of projects because of water shortages. 300 Community members should be employed to provide Dr. Michael Brett Submitted via email on Noted. The KNP Business Development Unit and Strategy provides meals at Nkuhlu picnic spot, which could be included in the 17 Feb. 2018 the framework for such business opportunities. tariff, and the number of visitors should guarantee a reasonable source of income. The Kruger Park would therefore be contributing to regional social-economic upliftment. 301 Section 10.7.1, page 155. During the public meeting held Ms Lorinda Written input, 10 March Noted, the comments will be considered when the SMME in White River I asked Mr Phillips to clarify what species Steenkamp development support is implemented. will be offered to emerging black farmers. The answer I got (which will be on the video taken during the proceedings) was a reference to the failed scheme in the North West province where high value species taken from provincial Parks ended up in the wrong hands. Yet still this type of project is still included in the Kruger Management Plan with rather vague descriptions.

There is also mention made that Kruger will facilitate land access. No indication is given on what land will be made available.

How are the members of the public expected to support such vague objectives?

May I add, I do think it will be a good idea to support surrounding communities to start farming with general game species which meat is in high demand. Species like kudu, impala etc can be farmed specifically to supply meat in the communities. In Mozambique, for example, you also find Guinea Fowl farms. Fish farms may also aid in combating the unsustainable fishing happening in the rivers surrounding Kruger. 302 10.7.1 Socio-economic development programme Ms Kim Da Ribeira, Written inputs, 10 SANParks is not facilitating any social security programme. What SANParks’ socio-economic development programme is OSCAP March 2018 we are able to do is to facilitate the linkages with different aligned to Governments’ National Development government departments to ensure the development of community sustainable livelihoods programmes. 129

Plan and the National Biodiversity Economy Strategy (the DEA objectives to enhance fair and equitable sharing of benefits from biological resources and to improve the socio-economic benefit flow from biodiversity conservation).

OSCAP comment:

• We welcome that fact that the Park is engaging with the local communities and that some of the communities will be in a position to benefit from income generated by the Park and the income generated by tourism in and around the Park. We are concerned however that SANParks is accepting a mandate and or responsibility that is not theirs and that the Park will in future be looked too, to provide social security to surrounding communities where this responsibility should lie with other Government Departments? • Will support for the emerging black farmers projects be dropped after the 9 year period mentioned in the plan?

SECTION 10.6: CULTURAL HERITAGE PROGRAMME

No. Comment / Input Commentator/s Reference Official response 303 You have shown that there are heritage sites and rock art. Community member 13 February, Mutale The KNP will implement a Cultural Heritage programme with various But in our communities we have people that have sub-programmes that will focus on improved visitor interpretation, knowledge on heritage etc. who can be used to explain including cultural heritage and indigenous knowledge; cultural these things to the tourists. Why are there no opportunities tourism; cultural products; cultural site management plans etc. for the community to showcase their culture/heritage by providing arts and crafts? Protocols will also be developed to inform opportunities pertaining to products such as arts and crafts and the afore-mentioned opportunities. 304 What is the current staffing structure / capacity to deal with Ms Natasha Higgit, 13 February, Cape There is one person in the Park that focusses on Cultural Heritage. cultural heritage in the Park? SAHRA Town Apart from Mr Madzhuta, we also now have a General Manager: Cultural Heritage, based at Head Office. We are hoping that more capacity will be made available otherwise; we will not be able to achieve some of the objectives / actions. 305 Perhaps you could launch an internship programme to Ms Natasha Higgit, 13 February, Cape We take note of the suggestion. increase the capacity and assist with the programme. SAHRA Town This is already underway through the corporate HR department and CSD 306 How far have you progressed with the development of the Ms Natasha Higgit, 13 February, Cape The cultural heritage lower level plan is still in draft format. We would cultural heritage lower level plan? SAHRA Town like to ensure that we get external input into the plan, including South African Heritage Resources Agency (SAHRA).

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There should be an agreement or Memorandum of Understanding (MoU) between the Park or SANParks and SAHRA. If there is capacity / expertise at National or Provincial level, we will welcome support to the Park. There is a bigger focus on the cultural heritage. There are many site and stories in the Park and most other Parks as well, and the public is not being informed / educated about it. The draft LLP is based on available capacity and seeks to achieve compliance with the National Heritage Resources Act. 307 Has any progress been made regarding the theft of the Ms Natasha Higgit, 13 February, Cape The Park does not have the capacity / skills to properly curate Thulamela gold artefacts? SAHRA Town according to the SAHRA regulations. We have museums that can display various artefacts and in fact, most of our artefacts are being curated at other institutions. We have opened a criminal case with the South African Police Service; however, they are still investigating.

The matter is also being presented to the SANParks Board 308 With regards to the request for an MoU, there are Ms Natasha Higgit, 13 February, Cape A MoU between the two organisations would be ideal because most Provincial Heritage Resource Authorities, however their SAHRA Town Parks have cultural heritage assets. powers and functions are very limited. Not all of them are competent to perform all the functions. The Limpopo and SAHRA’s Executive for Heritage and the SANParks ME Mpumalanga Authorities can only provide input regarding Conservation has a scheduled meeting that will also look at the issue the build environment. We are currently in discussion with of co-operation between the two organizations. SANParks already Mapungubwe National Park to draft a MoU regarding the invites SAHRA to give expert advice on specific issues. KNP is one management of their resources. We could then move such Park where SAHRA is engaged. forward and either develop individual Park MoU’s or a MoU between the two organisations. 309 There is the GRAAP103 requirement that the Park needs Ms Natasha Higgit, 13 February, Cape We take note of this. to comply with, for auditing purposes. GRAAP103 can also SAHRA Town assist with complying with section 9 of the National The Heritage Unit and the CFO’s office in SANParks have worked on Heritage Resources Act that state that all state funded compliance with GRAP 103. It is work in progress, but sufficient work agencies must provide an inventory of all the heritage has been done to comply assets under their control. We’ve just send out regulations for section 9 and 39. 310 Old buildings make great places for poachers to hide and Ms Natasha Higgit, 13 February, Cape We take note of the requirements. We acknowledge that some of the is something that can be taken into account. SAHRA Town infrastructure are old and require upgrade. When we talk about You refer to camp upgrades in section 9. Whenever those upgrade, it could mean that we change how it looks or we just give it buildings are older than 60 years then you would require a coat of paint / new layer of thatch. We are aware of the heritage permits. value and sensitivity of our old buildings.

SANParks has a policy called “Guidelines for the Development and Maintenance of Heritage Sites in SANParks” which are based on the National Heritage Resources Act and provide guidance on issues of upgrades and maintenance of heritage as well as Section 34 infrastructure. 131

311 I’ll be providing more detail comments at a later stage. For Ms Natasha Higgit, 13 February, Cape We would welcome any input. example the removal of alien vegetation at a heritage site SAHRA Town would require permits because it will be seen as an This is done in compliance with guidelines and policy alteration to a heritage site. 312 In section 9 there is a table that lists a few heritage sites Ms Natasha Higgit, 13 February, Cape We take note of the requirements. with tourism potential. If the Park wants to develop these SAHRA Town sites they would have to develop site management plans This is done in compliance with guidelines and policy for the identified sites. These plans will have to be submitted to SAHRA for approval. 313 Linking with GRAAP103 and section 9 of the National Ms Natasha Higgit, 13 February, Cape We take note of the development and will inform our colleagues. Heritage Resources Act. SAHRA is busy with the SAHRA Town development South African Heritage Resources SANParks is aware of the SAHRIS and we have been using it Information System (SAHRIS). This will be an online database where you will be able to record all sites. It can also be used as a management tool, to upload site management plans and reports. 314 Perhaps as part of the training that rangers receive at the Ms Natasha Higgit, 13 February, Cape We work very closely with the South African Wildlife College and the Hoedspruit Wildlife College, a component on cultural SAHRA Town comment regarding a heritage component as part of their training is heritage could be added. We tried to organise a training something we should pursue. event last year in the Kalahari Gemsbok National Park but unfortunately it didn’t happen. We will try to do it in the The course content should be relevant and not just academic of future. We can provide training on the Heritage Act nature. It could be expanded to include even the P&C staff. implications for ranger. This aspect will enjoy a future focus. 315 We’ve ran a course at the Rhodes University, so there is Ms Natasha Higgit, 13 February, Cape Thank you very much. course material available that can be used. We must just SAHRA Town ensure that it’s applicable for the rangers. I can make Noted. contact with the staff at SAHRA who ran the course and see how we can be of assistance. 316 The plan needs to take into account any new regulations Ms Natasha Higgit, 13 February, Cape We take note of this. or legal requirements that will be promulgated. SAHRA Town Although the management plan has a 10-year horizon the lower level plans could be updated on a much more frequent basis. Our Cultural Heritage strategy and policy will be updated to ensure that it is in line with legal the requirements. 317 The Lower Level Heritage Management Plan must be submittedMs to Natasha SAHRA and Higgit, the LimpopoWritten Provincial inputs, 9 HeritageMarch ResourcesThe documents were made available through public consultations Authority (LIHRA) for comment, as well as the SAHRA 2018 including to SAHRA. KNP will keep on engaging with SAHRA with Mpumalanga Heritage Resources Authority (MPHRA). respect to the implementation of the LLPs.

318 Section 4, page 36. With regards to heritage resources, Ms Natasha Higgit, Written inputs, 9 March Noted, and supported. SAN Parks must consult with SAHRA and LIHRA before SAHRA 2018 any decisions are made. 319 -The Cultural Heritage Programme is an ambitious plan, Ms Natasha Higgit, Written inputs, 9 March Noted. SANParks has already addressed most issues and is working one SAHRA looks forward to being realised. Given the SAHRA 2018 in co-operation with SAHRA. strained capacity within the Park to implement this programme, SANParks must look into Internships or Contract positions that would not only create jobs for the

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heritage sector, but train individuals at the Park, allow for skills transfer and capacitate the sector to be employed as the Park in future. -SAHRA must be involved in all discussions with regards to the Cultural Heritage Programme. -Collections Security Plan: The repositories located within SAN Parks that house archaeological and palaeontological material must adhere to the 2004 SAHRA Guidelines to Ethical and Curatorial Considerations for Accredited Repositories for Archaeological and Palaeontological Material. All Conservation Management Plans must be submitted to SAHRA for comment. -As noted above, any rock art sites that are to be opened to the public, must have HSMPs developed. -SAHRA can assist with SAN Parks staff capacity building workshops 320 OSCAP comment: We agree that the Cultural Heritage of Ms Kim Da Ribeira, Written inputs, 10 Noted. the Park needs to be respected and we OSCAP March 2018 welcome that this is part of the Strategic Plan 321 All old reports must be submitted to SAHRA as per Ms Natasha Higgit, Written inputs, 9 March All requirements of SAHRA will be met. Section 9 of the NHRA. SAHRA 2018 -Excavation research in the Park must be subject to NHRA permit requirements

SECTION 10.8: STAKEHOLDER RELATIONSHIPS AND CROSS-LINK WITH SECTION 10.9.9 COMMUNICATION PROGRAMME

No. Comment / Input Commentator/s Reference Official response 322 How do SANParks and communities communicate? Community member 13 February, Mutale Within this area, we do have community forums and we hold meetings every month with the communities. We also have Park Forum meetings that we hold quarterly.

However, a range of other feedback mechanisms will be addressed with the different stakeholder groups, including the aligning the Communication strategy to it. In future, a major emphasis will be on reviewing institutional structures, constituting community and other fora/structures, and ensuring improved sector integration.

We have monthly meetings with community forums, but we are experiencing challenges with feedback, and going forward, this will be addressed. 323 There is a communication breakdown that really needs to Community member 13 February, Mutale Communication with fora in the past was not up to standard. Whilst be addressed. How do we address the communication certain community fora are more functional than others, KNP will pay breakdown between KNP – community forum – community special attention to a range of matters in the near future, in liaison members? with community and other structures , i.e. review and constitute the 133

community fora and other fora; support/open offices in time in respective community fora regions; strengthen the stakeholder engagement and communication strategy and approaches; ensure access to information at the offices and through disseminations through re-constituted community fora and traditional authority structures; review current sector integration; provide feedback during annual roadshows etc. 324 Time management – provide breakfast as people came Community member 13 February, Ba- SANParks apologised. We do have financial constraints and are from far and there are old people who take medication. Phalaborwa open and transparent on this matter. However, a light lunch is served.

325 Provide access to the presentation to make inputs into the Community member 13 February, Ba- The presentation is available, or can be emailed, accessed at the Management Plan. Phalaborwa Traditional authority or Community forum offices/representatives. It can also be accessed via the SANParks website. 326 Concerns about the functioning of community forums, and Community member 13 February, Ba- Communities including the Unemployment forum need to join the mention of 7 forums. Queries about who is represented by Phalaborwa community forum and participate through this. The community forum these forums, and how the Unemployed community forum represents the Traditional authorities, as well as other is represented. Adverts arrive late. stakeholders/sectors. Tribal councils are requested to take the lead, which will assist to improve the feedback. 327 Forum meetings are not being held due to conflicts in Community member 13 February, Ba- Forum representative (Richard) answered: Forums meet on a forums not being resolved. Phalaborwa quarterly basis. Forums to ensure transparency. Unemployed Forum, Youth Forums need to be part of the community forum.

The current forums will be reviewed and constituted to ensure inclusive representation of all relevant structures. 328 I’m happy about the draft plan but want a copy of the draft Mr Titus Mboweni 13 February, Hazyview The Promoting access programme provides the principles and criteria plan. People from the Metros do visit the Park. for access to the KNP. Communities are left behind in terms of economic opportunities. Transport is also a challenge to get to the KNP promote local black visitation through community fora, and Park. Communcation must be improved between KNP and through providing half-price entry permits which are aimed at giving forums and also the forums communicating back to all local neighbouring communities an easy cheaper access into the community (two-way) Park. SANParks do not condone cases where local leaders and chiefs do not give permits to all people. We will engage the Chiefs to make sure everyone access the permits. The permits can be obtained from traditional leaders (the traditional authority has these permits). Groups can book through Socio-economic Development officers (People and Conservation: Environmental Education), Large groups up to 120 people but must be planned. SANParks’ week offers another opportunity to enter the Park free. Pensioner’s day, provide free access to pensioners from different forums. However, we have daily quotas that determine the access numbers that we can accommodate, based on our infrastructure. 329 Want jobs to come to the children in the communities. Mr Abednigo 13 February, Hazyview The Park values relationships, and youth and others must register Importance of traditional leadership. When it comes to Mokoena – Traditional with appropriate forums. benefits, then traditional leaders are left out. Park will come

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to the traditional leaders when they have problems but councel (Mathibela There is a structure for traditional leaders. –it is the Park can when it comes to employment, then the are traditional Traditional authority) unfortunately not provide jobs to everyone, as we have many villages leaders left out. Please respect the traditional leaders, who on borders of the Park. SANParks KNP can employ approximately wants equitable representation. 2200 people, excluding Concessionaires and service providers. We are happy to work with each local Traditional Council to enhance our existing working relationship and any structure that our traditional leaders can forward through the stakeholder engagement plan. S. 330 I’m being told that there are community fora but I don’t not Mr Ted from Oakley 13 February, Hazyview There are outreach programmes to enable communities to better have access to these. The Park must look at people that (Mathibela Traditional understand conservation. However, the community and private live in poverty because people will poach because they are authority) sector should join hands to address poverty concerns. KNP provides poor. The Park must be giving courses etc to bring opportunities through permanent positions, and through the importance of conserving biodiversity and make people Biodiversity Social projects and other development programmes, understand how important it is and not only come with Oakley forms part of the Ntirhisano community forum. The office can hand-cuffs. Want is the poaching statistics? Can you shoot be reached at 013 735 6355. There are many programmes that the animals and distribute meat? Park offers to engage with and benefit local communities, as well as education and outreach programmes focussing on conservation- based themes. These are all summarised in a report that can be accessed on the SANParks website (Biodiversity for society) or through any of the community forum representatives. We have school environmental awareness programme, whilst now starting to pursue options to support sustainable resource use programmes, such as providing meat, pending guiding principles and criteria. 331 Appreciation from the Hlanganani forum for the effort made Chief Mhinga 14 February, Maphophe Acknowledged. by SANParks to communicate with the communities via this meeting. Based on the relationship between Hlanganani Forum and KNP, a pamphlet of presentation would have been appreciated. 332 Where do I access more information about KNP in general Community member 15 February, Acornhoek All information is available, except intelligence information. The after today? information goes to the leadership of communities.

SED – P&C will provide the information. This is provided e.g. to leadership groups, to youth centres, to municipal offices e.g. Acornhoek, Agincourt, to traditional authorities (e.g. Amashangaana, Mnisi, Jungilana). P&C also engages with schools.

KNP engages with 7 community forums, and have workshops with Traditional leaders e.g. harvesting of resources and traditional medicines. 333 We are concerned that the community forums are Community member 15 February, Acornhoek KNP management is looking at ways to review and resource the voluntary, and that we don’t have resources. Jeremiah community forums. Machavi was thanked for his good work 334 We hear SANParks indicates that all information goes out. Community member 15 February, Acornhoek This is noted. We will continue to have monthly meetings with all KNP However, it should go out to all Traditional authorities. neighbouring Traditional Councils and disseminate information directly in their offices.

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335 Message for young people by Phillips Machavi Mr Phillios Machavi 15 February, Acornhoek Youth must get involved through the youth centres or participate in a community forum. 336 Concern about lack of forum members and Community member 15 February, Concern is acknowledged. farmers/communities in the task team. Malumulele Please refer to the Shangoni comments, of which this is part. 337 The strategic engagement between the Private sector, Mr. Mike Whiting 15 February, One of the biggest challenges that the Park faces is how to SANParks and the Government community related Johannesburg meaningfully engage with communities and their structures, opportunities that exist and the difficulties that the Private especially in the context of socio-economic development. As sector and community projects can experience without departure point, the internal governance of parties needs to be sorted relevant guidelines and how communities can perform. out before engaging with the Park. This principle is being applied Where Private sector involvement can start and stop with from the north to the south. It critical that developers fulfil their regards to communities. commitments to communities as well. SANParks will facilitate fair and sustainable development so that both developers and communities fairly benefit. 338 I want to congratulate everyone in SANParks that work on Mr. David Marnavick 15 February, Thanks, it was a team effort. this document, I think you have done a really good job. Johannesburg 339 We will submit written comments to ensure full Mr. David Marnavick 15 February, We look forward to your input. participation in this process. Johannesburg 340 You mentioned that you will have annual meetings in the Mr. David Marnavick 15 February, Yes we have budgeted for this communities to give feedback. Have that expense been Johannesburg included in the costing? 341 On page 2 you mention that stakeholders can submit input Mr. Sven Kramer 15 February, We take note of this. Just to clarify, the final version will have all the until 09 March 2018. This is the only place that mentions Johannesburg necessary signatures on page 3. Without the signatures, it is only a that it’s a draft document. Someone could download the draft. document and present it as the final version. 342 a) Thanked the KNP for the presentation. Thami Dlamini - 14 February, Ka- Forums members should report to the community after meetings. The b) Not happy with the current forums, does know Dwaleni Chicken bokweni community members decided that the TA should administer the about the meetings where they can give their farmer permits. However, if this is a problem, it can be reviewed in the future. views and no communication. Currently it is too far to get to TA to access the KNP half price entry permit. Need for representation and placement of the permits with the Induna. 343 Comment: Would like to see more forums to represent Mr Honest Banda – 14 February, Ka- The Parks involvements is not limited to the development of Science more local communities. Question: What has Kruger done Dwaleni Development bokweni labs, there are also arts and craft shops next to the gates for the for the people now? Forum communities. Job opportunities especially for youth development, employment (contractors) and half entry permits are also examples. 344 Need for contact and office details of those dealing with Mr Steven Ngomane, 14 February, Ka- Fencing office is in Skukuza at the State Vet (Dept of Agriculture). fence issues Spelanyane bokweni Contact person is Papi Hlalele. Work is in progress on fixing the fence. 345 Comment: Too much English in the presentation. Forums Mr Welcome 14 February, Ka- First issue is noted. This is the official language though. do not report back to the communities. Matukane – Gutshwa bokweni 346 Currently the forums don’t suit young people. Would like to Mr Kulani Ngwenya - 14 February, Ka- A youth summit to communicate with youth will be held soon. have youth forums so that youth concerns can be raised Empakeni bokweni Business opportunities are available for all, youth and elders, who with Kruger. qualify. KNP appoint youth who have passed grade 12 first and give

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b) Access and opportunities in Kruger to empower the them internships. We need assistance from government regarding youth so that they can access benefits and not get involved bursaries for those who passed grade 12. As the guest experience in with drugs etc. KNP is important, the Park cannot employ youths in hospitality positions who cannot speak English, as they will not be able to engage with guests effectively. KNP is not exempted from procurement legislation. Service providers must be registered on a Central Supplier Database. Qualifying conservation students will be interviewed to study through bursaries at Mpumalanga University commencing this year. Young women between the ages of 18 and 35 are given bursaries to study Tourism in Cape Town so that they can work in KNP and surrounds when they return. The meeting was advised to submit their applications for positions according to the advertisement. You cannot apply if you have a criminal record. 347 Thanked the KNP for this meeting and plan but requested Muzi Ngomani 14 February, Ka- The KNP will focus especially on the Youth, and Community forums that the youth be involved much more in the Forums, bokweni are currently being reviewed to ensure inclusive engagement with especially when there are meetings. Youth. 348 Impact of social media - Will there be a spokesperson Ms J Lane 14 February, Pretoria A big challenge is private groups on social media who expect appointed to get SANParks’ view on specific issues? immediate reaction. SANParks will only respond on the official SANParks / KNP sites and manage it carefully. The Park is in the process of developing a social media strategy. Appreciation is expressed for SHRs assisting with management of Facebook. It is sad that members of the public with strong views on social media are not present in today’s meeting where they have the opportunity to effect change. 349 Continuous feedback (as it’s a long plan) can communities Community member 16 February, Giyani There will be annual feedback to report on progress made. have more regular feedback? 350 Requesting that the community is invited earlier so that Community member 16 February, Giyani We have noted your comment and will ensure that the information is there is enough time for more people to attend. provided timeously, via forums and other communication channels. 351 Could you at least have the document printed so that we KR Mshengu 16 February, Giyani KNP Management Plan document has been distributed in the can read them out to our communities. community strategic positions / areas such as Post offices, Traditional Councils and community shopping centres. 352 Is the purpose of the (public) meeting for SANParks to get Stakeholder 16 February, White KNP welcomes participatory stakeholder engagement opportunities “capacitated” through public consultation? (e.g. with River to ensure focused and integrated land and water management regard to external land and water use issues) approaches. This can only be done in collaboration with sectors and stakeholders, and through having a collective understanding of the status quo and emerging drivers.

KNP has been leading several programmes in the broader landscape. There are examples of river management, the municipal land use planning, broader land use planning etc. That SANParks is implementing through co-operative partnerships and such public consultation is therefore essential to inform these integrated sector approaches and management focus within KNP.

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353 SAHRA to be included in the stakeholder relationship and Ms Natasha Higgit, Written inputs, 9 March SAHRA has been listed as a Strategic stakeholder within the engagement programme SAHRA 2018 stakeholder database and will be engaged on all aspects pertaining to the Cultural Heritage programme. 354 OSCAP comment: We understand that the initial round of Ms Kim Da Ribeira, Written inputs, 10 The KNP completed 54 stakeholder and focus group meetings. KNP community engagement with communities bordering the OSCAP March 2018 will establish offices in each community forum to ensure accessible Park has been well reflected in the draft. And then the information, and annual feedback will be provided to all stakeholder follow up meetings this year saw frank discussions with groups with respect to progress made in terms of the implementation those communities about a range of issues covered in the plan. Information will also be disseminated through a range of plan. From employment nepotism to not advertising in stakeholder fora. home languages (if there is a platform such as a local paper to even advertise in) through to the roll of traditional leaders in reducing poaching and other crime on the functioning of the Park. Local communities have engaged with the Plan and this is excellent news. 355 10.7.2 Environmental education and interpretation Ms Kim Da Ribeira, Written inputs, 10 Thank you. Acknowledged and addressed in Sections 10.7 and 10.8. programme OSCAP March 2018

OSCAP comment: The provision of these educational programmes is of paramount importance to the conservation of our natural resources. 356 10.7.3 Stakeholder relationship and engagement Ms Kim Da Ribeira, Written inputs, 10 The public participation processed was broadly advertised through a programme OSCAP March 2018 range of media mechanisms (2 weeks prior to the meeting), whilst a further opportunity for written inputs were given. 40 days were given OSCAP comment: in total for inputs into the KNP Management plan (draft made • The initial round of meetings was announced too close to available on 30 January). the time to allow many of the stakeholders the opportunity to engage. • This draft is a large document to effectively comment on and an extension of the ‘prescribed’ 30 days would have been appreciated

SECTION 10.8: STAKEHOLDER RELATIONSHIPS - ENVIRONMENTAL EDUCATION AND AWARENESS

No. Comment / Input Commentator/s Reference Official response 357 Does KNP provide children from the communities with Member from Dept of 13 February, Mutale The KNP has an environmental education programme which provides Environmental Education? Education a range of activities, and which will be strengthened in future through collaboration with external partners and programmes.

There is an MoU with the Department of Education through Kids and Parks programme, and the Education Awareness will receive significant focus in the future implementation of the Management Plan.

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358 What is the relationship between KNP and Department of Commmunity member 13 February, Mutale There is an MoU with the Department of Education through Kids and Education re allowing kids to enter? Parks programme, and the Education Awareness will receive significant focus in the future implementation of the Management Plan. 359 There is a group that is interested in environmental Ted from Oakley 13 February, Hazyview KNP has 4 Environmental Education Centres and each centre has a education, how can they get benefits? Who to contact? (Mathibela traditional responsible officer for awareness and interpretation programme. Want to learn more about Park. authority) They are working in the People and Conservation and SED units and are responsible for forums, there is a place where they offer awareness sessions in Tshabalala forum area. There is no money from Park to assist community members to participate in fora. If people want to communicate, they can go to forums and can get a chance to address issues. People in those areas can ask for Lucia and Jeremiah to come and do EE. 360 Reach out through a broader range of environmental Community member 14 February, KNP work closely with various Environmental Education partners education instruments. This should include competitions Acornhoek such as WESSA and their Echo School programmes that present between schools as well. different schools and communities with various educational development and competitions. There are a number of Environmental Education programmes offered by KNP such as Kids In Kruger, Walk And Learn On the Wild side programme, Take Kruger To Kasie and Outreach Awareness Programme e.g. Greening and School Beautification Competition in the communities. 361 Not all are equally gifted with education. How can different Community member 15 February, See reply above. groups be accommodated, including different events e.g. Acornhoek soccer, other means besides being skilled? 362 Trees being cut for firewood. Require awareness and Community member 15 February, KNP in partnership with LEDET promotes greening along the borders environmental education on the importance of the large Malumulele of the Park hence, jointly they monitor deforestation. trees 363 Kruger management must meet chiefs to go to all schools Steven Ngomane, 14 February, Ka- KNP supplies bursaries for staff but other opportunities include and assist all schools with bursaries Spelanyane bokweni Internships, learnerships, and supporting 18-35 year old girls to study tourism in Cape Town. 364 Does KNP assist Department of Education with Community member 16 February, Giyani The different departments within KNP are explained as well as the programmes / subjects on conservation that help students type of subjects / course required to be employed. Higher education to get jobs in KNP? needs to be obtained in order to be employed in SANParks/KNP. Encouraging the community to take kids to school, however KNP also has environmental education programmes to facilitate conservation awareness. Communities are also encouraged to seek jobs within other organisations i.e. Department of Education etc. 365 Concern about waste management in the rivers. Concern Community member 16 February, Giyani SANParks provide environmental education awareness, teaching about Pollution of rivers e.g. pampers communities to take care of the environment. Community members are encouraged to stop buying diapers (pampers), but to rather make use of the cloth diapers as was used in the past. Community members can contact the Environmental Education centre contact number (Punda Maria Gate) at 013 735 0001 or (Letaba) at 013 735 6664.

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The municipality is responsible for collecting the refuse/litter in the communities, and KNP will engage with local government to seek solutions to this matter. 366 Environmental education is mentioned a lot in the Ms Lindie Botha Written inputs, 9 March Thanks for the comment and the issue is noted. document. This also needs to target the traditional visitors 2018 to KNP, which includes a lot of white South Africans. It is a concern that many of these visitors to the Park still perceive the Park as an “island” divorced from its neighboring environment (i.e. we heard from Louise Swemmer at the Network meeting that some visitors still feel that seeing community members in the Park - who are, for example, harvesting Mopani worms - would detract from their “wilderness experience.”) This means that these visitors also need to be educated about the history of the Park (which features human inhabitants) as well as KNPs sustainable utilisation philosophy. In other words, it is not just “environmental’ topics that need attention, but also the socio-political and historical context of Kruger – something that most visitors are completely ignorant about. We recognize that many KNP managers already have a much more progressive understanding of what “environmental education” mean, but this nuance could perhaps be better reflected in the management plan. 367 Mr Johan Eksteen, Written inputs, 9 March The alignment, integration and institutional together with partners It is noted that an integrated approach to environmental MTPA 2018 such as the People and Parks fora, MTPA, LEDET and private education and interpretation has been adopted by reserves are underway, and will be critical to ensure co-ordinated and SANParks. Since KNP, MTPA, Private Nature Reserves efficient outcomes. The afore-mentioned partners, as well as NGOs, and other roleplayers could engage with the same will be closely engaged in this integrated approach with respect to stakeholders, it is important that the regional activities are conservation, socio-economic, environmental education and coordinated/integrated. compatible land use development outcomes. This process will also be further through the enabling GLTFCA institutional arrangements (see sections 10.8 and 10.2).

SECTION 10.8: STAKEHOLDER RELATIONSHIPS - PROMOTING ACCESS

No. Comment / Input Commentator/s Reference Official response 368 Does KNP only allow free entry during September Community member 13 February, Mutale It is guided by the formal Environmental Education guidelines that (Heritage week) and also for special occasions? allow for 120 entries.

Free entry also takes place on other special days, e.g. Youth Day. An entire programme dealing with “Promoting access” will guide access to the Park, based on clear principles and criteria.

Refer to the Promoting access LLP, Section 10.8.3, KNP Management Plan.

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369 Can KNP organise special entry for people with Community member 14 February, People can arrange for their visits. The KNP has a Protocol that disabilities? Maphophe provides the principles and criteria of access, within the Promoting access programme. See Section 10.8.3, KNP Management Plan. Register for SMME’s contact number is 013 735 0001.

370 What is the minimum amount of people for KNP to come to Community member 15 February, KNP has events Protocol that promote events management and a community event? E.g. Soccer events Acornhoek channel all KNP official events within the organization. KNP Sports Day whereby 300 people can be accommodated per event and Kruger Staff Achievement Awards, which aim at 300 internal staff (Receipts and witnesses). However, it should be noted that we have Environmental Education Programmes that allows 120 learners per day per group and 6 adults for organized and booked Biodiversity learning Programmes and only minimum of three groups per day can be booked. We host various special groups such as Pensioners Day and Traditional Councils Special Imbizos in the Park whereby 300- 500 delegates are hosted per event. 371 KNP needs to have representatives at traditional events Community member 15 February, Representation at such events could be handled by the SED/P&C hosted by traditional leaders. How do communities access Malamulele units. There is a resource use Protocol for guiding this. Ranger resources such as wood for events and animal skins for services could also attend. However. It’s important to have a calendar weddings etc.? upfront. 372 Requested an access gate between KNP and Mpakeni and Community member 14 February, Any access and additional gates will be guided by the Promoting Luphisa to allow for vendors to sell things. KaBokweni Access and Regional Integratiopn programmes and are based on a range of conservation, socio-economic, safety-and-security, management, and zonation guidelines, legal and other considerations. A formal submission will be required, which will undergo KNP and SANParks governance processes. 373 Any access to graves or intangible heritage sites will Ms Natasha Higgit, Written inputs, 9 March Although SANParks is not opposed to this, it is not a legislative require a HSMP to be developed as stated above. SAHRA 2018 requirement as the graves are not open to tourists but only for family visits. 374 10.7.4 Promoting access programme Ms Kim Da Ribeira, Written inputs, 10 Thank you. This programme will be guided by principles and criterial The purpose of this programme is to promote visitation to OSCAP March 2018 for a range of Access categories, of which community access is one the Park specifically by neighbouring communities in the of the key focus areas. spirit of historical redress.

OSCAP comment: • This is as a good initiative that should further strengthen positive community involvement, even if there was no need to address ‘historical redress’ it is important that the communitiesexperience what the Park has to offer

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SECTION 10.9.2: RISK MANAGEMENT

No. Comment / Input Commentator/s Reference Official response 376 10.6.2 – Risk management Mr David Marnewick, Written inputs, 9 March Noted, The proposal will be discussed during the next annual risk The EWT would like to ensure that the risk regarding EWT 2018 review electrical infrastructure mortalities is considered in the risk profile. We must also bear in mind that the electrical infrastructure incidents also have an impact on the KNP’s business as it causes interruptions in electricity supply that will affect customers and business operations. The EWT did extensive research on supply interruptions caused by large mammals, birds and other wildlife, which can be made available on request.

SECTION 10.9.5: INFORMATION AND RECORD MANAGEMENT

No. Comment / Input Commentator/s Reference Official response 375 All heritage site data must be recorded on SAHRIS Ms Natasha Niggit, Written inputs, 9 March This will be covered through the Cultural Heritage Implementation SAHRA 2018 Programme.

SECTION 10.9.9: EFFECTIVE PARK MANAGEMENT – COMMUNICATION PROGRAMME

No. Comment / Input Commentator/s Reference Official response 377 Page 183. Social media Stakeholder Written inputs, 27 Thank you, noted. The Social media is one of the key platforms within February 2018. the Communications programmes, Section 10.9.9 Very valuable tool – but definitely needs some monitoring and a review of its value / detriment to sightings.

…otherwise a great plan

SECTION 10.9.6: INFRASTRUCTURE DEVELOPMENT

No. Comment / Input Commentator/s Reference Official response 378 What is the delay with Shangoni Gate opening? I see that Community member 15 February, The development of the Shangoni gate is in process. As per the EIA has been completed, but still no progress. Why? Malamulele SANParks commitment, we continue to engage with the communities. There are activities happening in support of the suggested proposed gate i.e. the road has been tarred up to the gate. There are other processes that needs to be completed. It is include as part of the future developments (section 9). 379 Why is the location of Shangoni Gate different to what was Community member 15 February, The EIA has been completed. There are 3 appeals for the Shangoni agreed upon by previous Ministers? Malamulele Gate and the project will not continue unless those appeals are addressed. The DEA Director has been requested to address these appeals.

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380 According to the presentation, jobs and DCA’s were top Community member 15 February, Refer to the aforementioned response priorities for community, but in reality Shangoni Gate is the Malamulele main concern at the moment. Where are the funds being allocated to it?

381 When will communities know the final and confirmed Muhlanga P. (072 274 15 February, A letter was received from Muyexe community, KNP acknowledges position of Shangoni Gate considering that the KNP 4660) email: Malamulele receipt of the letter, and all its suggestions will be discussed and Management Plan will be finalised end of March 2018? [email protected] addressed where relevant. m 382 The plan states that 0.69% of the surface area has been Ms Leonie Meyer 15 February, We cannot give you a figure at this stage because there are a few developed (under infrastructure), what will the percentage Johannesburg unknowns. We still need to determine the footprint etc. and that will be if all the developments as envisaged in section 9, have ultimately determine the percentage under development. been completed? 383 In relation to the solar project at Tshokwane. How is the Mr L Lemmer 14 February, Pretoria Solar panels do have a visual impact, especially at Tshokwane. visual impact of future solar energy generation projects Screening will be put up where it is a problem (e.g. Tshokwane); at being managed? Nkuhlu it is part of the covered parking area. It is being incorporated as part of the building structure in new developments, for example at Skukuza Lodge. The Park is looking at purchasing electricity through third parties i.e. neighbouring communities who will install solar farms on their land as part of the socio-economic development projects in the future.

Some infrastructure to hide visibility is being considered. 384 Page 175 Assess roads in need of upgrade Stakeholder Written inputs, 27 Thank you for your comment. The proposal will be discussed with February 2018 Conservation management to establish the feasibility of such a What can be done during upgrade or design phase? Can proposal. we install any frog tunnels (for example) or chameleon crossings in areas that we identify as being high risk for roadkill of certain species? Upgrading or building a new road, will be a great opportunity to retrofit some crossings for smaller wildlife. 385 Shangoni Gate Development and hub activity (at MASWANGANYI K.N. Written inputs, 8 March The process that is being followed regarding the Shangoni gate is the current “2018” claimed environmentally authorized (ALTEIN CIVIC 2018. transparent, a stakeholder forum where all discussions pertaining to position). The environmental CHAIRPERSON) the development of Shangoni Gate was established right from the authorization did not follow proper steps required which beginning in 2012. Consultants conducted the EIA process and it may result in the delay of the approval of this programme. included public participations. Unfair movement /removal of Shangoni Gate from its current historic position affects the smooth development The Environmental process was concluded in accordance with the of this programme (KNP management plan) and that area NEMA Act. The appeals regarding the record of decision to continue (Shangoni Gate). with the Shangoni Gate development was evaluated in detail and the Minister dismissed the appeals after careful consideration. The Reasonable objections that are delayed any project implementation plan is being finalized and will be implemented response by SANParks are more helpful than a hindrance accordingly. to the economic development of our country. The gate should be developed in line with the governmental 143

policies which include: heritage acknowledgement of the area/society, consultations, flora and fauna studies, etc.

The Management plan should align itself with the Department of Tourism on its programmes aimed at developing the Shangoni Gate that is adjacent or attached to Altein Village.

Kruger National Park Management Plan team must engage communities concerned in the manner that will fasten the implementation of this programme. Mtititi residents and Collins Chabane Local Municipality are eager to assist the opening of the gate at the current historic position.

The R40 085 000 amount transferred to SANPARKS by the Department of Tourism to develop the Park through Shangoni Gate development can complete the project in that area should proper channels be followed. (Download and see the Annual Report for 2016/17 of the DoT on page: 58) 386 10.6.6 Regarding this statement “This is primarily to ensure Mr David Marnewick, Written inputs, 9 March Thank you for your comment. Your inputs will be discussed with that the Park’s infrastructure (buildings, roads, fences, etc.) EWT 2018 Conservation Management. A major focus will be on green and services infrastructure (provision of water, electricity environmental practices, and we will be happy to engage with EWT. and waste management) are well maintained and its capacity is continually improved in order to provide safe, reliable, increasingly environmentally friendly and affordable products to its clients and visitors.” Please take note that the electricity infrastructure within the Park is not currently wildlife friendly. KNP should insist that all existing and new electric infrastructure is made wildlife friendly. EWT can provide guidance in this matter. 387 See earlier comment with regards to historical structures Ms Natasha Higgit, Written inputs, 9 March This is provided for in the Guideline for Development and and NHRA permit requirements SAHRA 2018 Maintenance of heritage sites.

SECTION 10.9.7: SAFETY AND SECURITY

No. Comment / Input Commentator/s Reference Official response 388 What are the solutions to deal with crime and wildlife Community member 13 February, Mutale A holistic approach with other sectors and with communities with poaching? respect to economic opportunities, poverty alleviation and dealing with organised crime is necessary. KNP cannot address it on its own, since this is a broader societal matter. The Park has identified several socio-economic development opportunities, but this needs to be complemented with other sector and partner programmes focusing on sustainable economic opportunities, education and awareness,

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good governance within communities and sectors, youth development programmes and special safety and security programmes. This requires substantial resourcing, willingness to work together, good information systems and technologies, programmes dealing with economic development, health, education, etc. to address safety and security within communities and with respect to wildlife poaching. 389 The safety and security budget – does this include internal Stakeholder 13 February, Collaboration includes the broader safety and security clusters, and and external collaboration, or only internal operations? Hoedspruit hence with parties such as SAPS and SANDF.

The SANParks budget allocation for Ranger Services covers all internal Ranger operations including safety and security and conservation management related operations. Funding is also received from several fund-raising projects managed by the SANParks Fund Raising department and Honorary Rangers. SAPS and SANDF operations in the KNP are funded from their respective budget allocations, and are not reflected in the Costing section. 390 I think there are a few aspects that require additional Mr. Gareth Clade 13 February, Cape KNP has a long history of working with the Endangered Wildlife Trust attention, especially from the poisoning of vultures’ Town (EWT). The way the media communicate is a big concern for us. I perspective. This is being said within the context of the heard once where the media stated that rangers use the vultures to poisoning of vulture events both inside and outside of track carcasses. This is untrue and will lead to all the vultures being Kruger National Park (KNP). There is definitely a need for poisoned. Dr Danny Govender would be able to provide more the training of rangers with specific emphasis on poisoning information regarding this matter. The Peace Parks Foundation has response training. made money available for an investigation into the poisoning events in Mozambique.

After the 2 poisoning incidents, we took a decision that the curriculum of the basic field ranger training course should include a component “how to handle poisoning incidents”. We have approach Tim Snow and André Botha regarding this matter and André will be training the field rangers regarding this matter.

The constructive remark suggesting the need for Rangers to receive training in poisoning incidents and the specific responses required for such incidents is appreciated and noted. This specific training requirement will be included in the basic and advanced Ranger training curricula. 391 Old buildings make great places for poachers to hide and Ms Natasha Higgit, 13 February, Cape We take note of this. is something that can be taken into account. SAHRA Town 392 In response to what Danie Pienaar said earlier, we want to Mr. Gareth Clade 13 February, Cape As clarification, the rangers do not. It is important that we convey this avoid a situation where information is shared that rangers Town message. use vultures to track carcasses. 393 We’ve now got a Field Officer based on the western Mr. Gareth Clade 13 February, Cape We take note of this development and will inform our colleagues. boundary of the Park, between Phalaborwa and Town Hoedspruit. The objective of our outreach will be to 145

empower the communities to support conservation. Within this context there could be a lot of support for the management plan. A lot of the lessons currently being learnt in Kwazulu Natal could also be applied in the Lowveld. 394 Crime and corruption is a concern, and the SAPS is Community member 14 February, Yes, it is true. Government is trying its best, and the current political corrupt. Traditional authorities deal with these issues Acornhoek environment is fighting against it, also internal in KNP. Nobody is harshly, and it is required that SANParks take a more harsh above the law. approach to address crime When staff is caught they are arrested, charged and fired.

KNP is taking this seriously, through the Safety and Security and other programmes, focus is placed on this element and ito community engagement. Support is also provided to recover stolen goods.

Ranger services will work closely with Traditional authorities and youth to address crime through a range of programmes. KNP welcomes views on how best to deal with it.

To address safety and security challenges, which includes crime and internal corruption, SANParks has developed and is implementing a safety and security strategy and procedures as well as an integrity management policy and procedures for all Parks, including the KNP. These measures require effective communication with and support from communities surrounding the KNP. 395 What is in place to manage cross border traffic, especially Mr. Louis Lemmer 14 February, Pretoria Speeding and breakdowns are indeed a problem. There are key issues such as speeding? periods when people are move between South Africa and the neighbouring countries. The plan is to rather have a bus available to transport people and thus provide a service. Some local chiefs are lobbying for a formal trade border post but SANParks do not support this suggestion. 396 How can KNP assist to curb the crime in the area? Community member 16 February, Giyani We are working together with SAPS to alleviate crime including poaching in the Park. Various law enforcement agencies are also incorporated.

The Provincial Security structures, PROVJOINTS comprising all provincial security (law enforcement) structures including, but not limited to, SAPS, SANDF and SANParks, meet regularly to discuss, identify and mitigate safety and security risks and threats impacting the Provinces and KNP 397 Do we have a security company to assist with anti- Community member 16 February, Giyani Historically the poaching was not as rife as it is currently. In the past poaching operations in the Park? 5 years we realised the security companies are not skilled/equipped for anti-poaching operations. We have recruited, trained and How do we prevent security guys from leaking information equipped our own security personnel to fight poaching. or get involved with poachers?

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The responsibility of countering poaching activities in the KNP lies with department Ranger Services, comprising Ranger Corps, Protection Services, Air Services and the Joint Operations Centre.

Leaking information: Security officials also work at the gates. All the rangers and security staff have gone through integrity tests. We have even arrested one of our own colleagues to show that we do not tolerate crime. Communities are urged to go to SAPS to report any conservation related crime. When we employ people from the community, they need to provide a Police clearance certificate. SANParks has instituted an integrity management policy and procedures to assist in countering internal staff collusion and collaboration in poaching activity in Parks, including the KNP. 398 1 person should not be working in the same “security” Community member 16 February, Giyani We cannot shift employees around continuously. It also depends on position for too long because the person becomes the education. However, we have shifted staff from certain despondent and could also become involved with departments i.e. rangers or tourism departments where there was a crime/poaching? requirement. 399 Staff training (traffic officers) Stakeholder Written inputs, 27 Your constructive comments are noted with appreciation and the February 2018 interventions suggested will certainly be investigated as we further I think we need to think a bit more ‘out of the box’ for develop workable mechanisms to control driver behaviour in the Park. solutions for changing driver behaviour on the roads, and This is relevant to SANParks staff employees, and a range of not just assume that we need more law enforcement. What interventions will be addressed. about sticking traffic loops on the road to mimic speed traps (even though they are redundant). We found ‘fake’ traffic strips in Pilanesberg to be effective as drivers through they were speed traps. 400 Archaeological sites, ruins and non-used historical Mr Natasha Higgit, Written inputs, 9 March Thank you, noted. structures pose a security risk as they may be used by SAHRA 2018 poachers to hide in during their time in the Park. Rangers and security personnel should be educated about their locations to include them in their patrols. 401 You state that there are 9 airstrips located in the Park, Mr Tony Carnie 12 February, Durban Two airstrips are being used by concessionaires namely Satara and primarily being used by SANParks. Are these airstrips also Pufuri. The Skukuza airport is well known and accommodates being used by the concessionaires? scheduled flights. The other airstrips are being used by our fixed wing aircraft for a variety of reasons i.e. poaching, census

402 Do you plan to increase the number of airstrips? Mr Tony Carnie 12 February, Durban Any increase will be determined by the poaching situation, and/or guided by clear principles as per NEM: PAA and SANParks policy framework.

403 Action 2, “Implement key species (as identified)…”. Not Mr David Marnewick Written inputs, 9 March In the Biodiversity Programme, Section 10.3. clear where these have been identified? In the text section 2018 of 10.6.7 or in the SSC programme? Needs to be clarified. 147

404 Action 13, “Ensure boundary and facility fenceline Mr David Marnewick Written inputs, 9 March Whilst it is the function of DAFF to attend to disease management integrity”, under the responsibility of RS, TS. Is this not 2018 issues, is the function of Ranger Services to address area integrity under the responsibility of DAFF and should be listed here (safety and security) and Technical Services (in terms of the for SSV? Infrastructure Development Programme support, road maintenance on boundaries) in compliance to NEMPAA. 405 10.6.7 Safety and security programme Ms Kim Da Ribeira, Written inputs, 10 The comments are noted with appreciation. The overall poaching risk is high. The security of the Park’s OSCAP March 2018 key species, particularly rhino and elephant are at significant risk due to the rampant nationwide wildlife crime. Key species protection plans have been developed to address the specific security needs in order to safeguard the Park’s rhino and elephant populations.

Poaching activity involving the use of snares and poisons, which target indiscriminately, also pose a challenge and risk to wildlife. Certain plant species sought after for their medicinal qualities could also be at risk.

To meet the ever-increasing threats and risks associated to safety and security within the KNP there has been a steady increase in both funding, personnel capacity, equipment, such as aircraft and supporting hi-tech technologies which are required to support the interventions necessary to deal with this.

OSCAP comment: • OSCAP will support all positive efforts to address the poaching risk in the Park and would welcome a positive outcome to these efforts. • This numbering is incorrect it should read 10.8.7

SECTION 10.9.4: HUMAN CAPITAL MANAGEMENT

No. Comment / Input Commentator/s Reference Official response 406 Why don’t KNP employ local community members as Community member 13 February, Mutale The SANParks Policy framework guides the employment and rangers? placement of community members.

KNP have a specific focus on providing local job opportunities.

The SANParks Policy framework guides the communication and distribution of vacancies through the community forums, local traditional councils and other structures, pending the requirements for

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a specific position or programme. This implies that adverts will be advertised locally, whilst certain positions requiring expert skills, will be advertised Nationally. However, if community fora and structures are well constituted and formalised, transparent, efficient and broad communication of opportunities are better enabled

Hence, no employment opportunities given to specific communities – this is an open process as per policy framework. However, people often do not meet the requirement for vacancies and/or fail training.

SANParks therefore has an internship programme to address in- service training, with funds received from SASITE etc. 407 Acknowledge the work done by EPWP. Are there Community member 13 February, Mutale KNP has internship programmes, and the Management Plan will learnership programmes to train rangers? Very few people specifically seek to strengthen programmes that expose people to the know the KNP. Interested in learnership programme. Park through e.g. providing training, internships/learnerships, volunteer programmes, and various implementation projects.

The SANParks policy framework will guide this, and communication will be facilitated through constituted fora and other structures. 408 Concerns about recruitment process: when there are Community member 13 February, Ba- Communities need to participate in the Park Forums that will assist vacant posts, inform Traditional authorities and all relevant Phalaborwa access to information such as advertisement of jobs. Information is communities in advance, and not only 2 days prior to the also left at the gates, at Tribal councils, municipalities, Tourism closing dates. Adverts at gates not broad enough agencies. SANParks will start with the process of opening offices in exposure. very community Park fora so that information could be more accessible. 409 Concern about nepotism, especially in terms of the Community member 13 February, Ba- SANParks would welcome the specifics of such cases regarding recruitment process and filling of vacant posts. Phalaborwa nepotism, and the stakeholder was requested to engage with HCD (Simon) afterwards. SANParks has a strategy that informs the recruitment process, and will not tolerate nepotism, and this needs to be addressed immediately 410 Comment – vacancy adverts should be given to the Community member 13 February, Ba- Advertisement of positions: internal adverts, and external adverts. traditional authorities. People in communities should be Phalaborwa This is guided by the recruitment strategy. Recruitment by KNP employed. Queries on how community gets informed to should not only focus on local interests and filling of positions, but ensure monthly attendance. also consider that KNP is off National interest, and hence the filling of positions will reflect this as well. 411 Asking Park to make database of youth that needs help Ms Sharon Mhlanga - 13 February, Hazyview We do not have bursaries for communities. Bursaries are for the with bursaries and scholarships (for instance), because Madras children of employees. What we have are internships and the information stays with councillors and does not reach the challenge we have with applications is that they do not submit all the youth. right documents. Therefore, HR has requested SED to invite HCM department to apply correctly for positions. In addition, we consider internships for people that have qualifications from university, technical colleges and take your time to make sure you understand what you apply for. Encourage youth to go to school and further their studies. Grade 12 is crucial because you communicate with tourists and international customers. 149

412 Can KNP provide unemployed youth with training, Community member 14 February, KNP used to get funding for learnerships but no longer. That is why bursaries, etc. to improve their chances of employment? Maphophe they are only involved in internship programmes. KNP wants to uplift / improve the community capacity. Moving forward, KNP will seek strategic partnerships to enhance opportunities for learnerships/volunteer opportunities, as guided by the SANParks policy framework. 413 Job advertisements. Other areas have job advertisements Community member 14 February, Advertisement of positions is guided by the recruitment strategy. posted but nothing in our communities. Is there someone Maphophe Recruitment by KNP should not only focus on local interests and filling dedicated to ensure that job adverts are distributed in our of positions, but also consider that KNP is off National interest, and areas also? hence the filling of positions will reflect this as well.

People with email access are encouraged to forward their contact details to KNP so that the Park can circulate vacancy information. These advertisements will then be placed in relevant villages. Each position has its own requirements and examples were used of a few staff members currently employed. KNP cannot employ everyone, but people also encouraged to seek employment elsewhere.

People are encouraged to attend meetings to get appropriate information. 414 Information about jobs does not go into communities, and Mr Reginald Mabunda 14 February, Information goes to the SED and P&C units, and then to the we are concerned about nepotism Acornhoek community forums. It should be established if there is internal miscommunication in community forum. The adverts should go out as broadly as possible and need to go to all Traditional authorities. KNP recently advertised internships, and 6,000 applications were received, showing the reach and how broadly it went out. Certain positions require very specific skills. In some cases, HCD (Simon) travels to reach community members, since they are not in the position to travel. KNP is a National Park – anybody in SA can apply. Certain positions are open to everyone, and other positions are reserved for local communities. 415 Jobs need to be advertised in communicated on other Community member 15 February, Cultural diversity is important. However, English is the official languages for Tsonga/Shangaan speaking communities Acornhoek language. SANParks Policy also stipulates that the medium for

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communication should be in English. This applies for learnerships, adverts, etc. 416 Always see posts for rangers, and chefs. Where can we Community member 15 February, KNP does have internships and learnerships. This is external funded. apply for learnerships? Acornhoek These are advertised. However, KNP also engages with TUT, University of Mpumalanga and other Tertiary institution (2nd and 3rd year students) for providing possible learnerships. More internships/learnerships will be advertised within the new Financial year, from April. 417 Why in our community, are vacancy adverts received at Community member 15 February, Communities should identify additional platforms through which late notice? Malamulele adverts can be displayed or posted. Adverts are accessible to all people bordering the KNP. 418 They want a local office to submit CVs beside internet. Khulula Mangweni - 15 February, The Human capital office does not take CVs because of the Law, i.e. Want to know other places to submit application for jobs, Shongwe KaMhlushwa POPI ACT. Not easy for the Park to bring adverts to all thee areas, besides Kruger but we will investigate finding options to create awareness of the jobs available in KNP. They have already shortlisted and hired people. They will advert at human dev centres and must apply there. Scientific services, conservation, tourism. All departments advise that they cannot help someone who does not have tertiary education. They need people who can speak English in Tourism sections to engage with guests. Encouraged to further studies if you have grade 12. Must see if you have applicable qualifications for advertised post. Avoid unrecognised qualifications – verify with SAQA. College diplomas verified with SAQA. To do internship you must have qualifications already. Will not be hired without suitable qualification from recognised university or college. There are colleges in local regions. KNP can help with information after registration. KNP take women from the age of 18 to 35 to Tourism College in Cape Town. KNP does not pay for this but sources eligible young women for learnerships. English preferred language for tourism college. Finalisation of Grade 12 is important. They rarely take people for internships without Grade 12 but only for construction and minor technical services. Offer to all youth in the hall to provide their names and contact details so that this can be sent to the youth centres 419 They have their CV’s but limited access to job ads and they Ms Lucia Nkosi 14 February, Adverts will be shared with the SED colleagues (People and are often received past the closing date. Concerned that KaBokweni Conservation) to ensure that adverts reach the forums well before the only people from Limpopo and Bushbuckridge are closure date for applications. For internal employees appointed. They need transport for forum members. Communications and Marketing will assist with the cell phone facility Suggested forum leaders obtain sponsorship for transport so that all employees can get the adverts in time. to advertise jobs. Offices will alsobe opened in communities to ensure easy access to information. 420 Complimented KNP of the wheelchair programme, where Mr Makhosazani 14 February, Shops and restaurants are not part of the KNP as they are KNP has made it possible for 6 people to have wheelchairs. Theledi KaBokweni outsourced. When positions are advertised in the Park there are However, she would like to see that people that do not have always requirements, therefore, if a person meet those requirements

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a matric but have the necessary skills to be also be given the normal recruitment process will be followed and appointments will an opportunity to work (cooks to become chefs). be made.

421 Where does KNP advertise their jobs and learnerships? Mr Trueman Simane 14 February, The learnership programme is advertised through SED (People and Would also like to have a gate from Matsulu to KNP. KaBokweni conservation) and the community forums. We will also advertise via the radio stations. Gate access is guided by the SANParks policy framework and KNP Protocol on this matter, and a formal process to access additional guides, will need to be approved according to the policy framework (including that this is supported by the zonation plan). 422 Would like males to be also taken for training and not only Mr Evans Mkhabela 14 February, This is unfortunately a decision by the SA Tourism College, and not girls as per the current program. KaBokweni the KNP’s decision. 423 There are no rangers selected from our village. Mr Eric Ngomane 14 February, Adverts are issued through SED (People and Conservation) to the all KaBokweni the community forums and in future will even ask some Community Radio Stations to assist in announcing. However, this will be guided by the requirements for such positions. 424 No employees from our village in KNP. Mr Elijah Mnisi – 14 February, People are encouraged to apply when positions become available. Phabeni KaBokweni These days’ adverts are even placed on Social Media to make it easy for more people. We are in the process though of setting up offices in community fora, through which opportunities will also be advertised. 425 How many members of local communities are employed in Ms Potgieter 14 February, Pretoria 1,387 of 2,220 staff members are from local communities, which the Park? represent a high percentage. Information is available regarding the villages from which these individuals come from. A detailed report with statistics on employment is available. Ms. Louise Swemmer can supply a link to the report. 426 How many people have been employed from Giyani since Community member 16 February, Giyani The statictics are available though and could be provided by our HR last year? department. 427 People being employed in the Park. Why are some people Community member 16 February, Giyani We have many departments, but this question may be referring to working in the Park getting paid late? EPWP/WFW. These projects are not permanent. They are not on the payroll but on claims submitted. They are task based and that is why it depends on the length of the project/contract as to when they are paid. 428 Does SANParks give students who passed grade 12 Community member 16 February, Giyani SANParks currently assist its employees’ children with a minimal bursaries? (RW Chauke) bursary aid but do facilitate learnership programme for students who have passed Grade12 for career path development based on the availability of government learnership grant. 429 What is the recruitment and appointment procedure? J Maswanganyi 16 February, Giyani Information goes to SED (People and Conservation), and then to the community forums. It should be established if there is internal miscommunication in community forum. The adverts should go out as broadly as possible, and need to go to all Traditional authorities. KNP recently advertised internships, and 6000 applications were received, showing the reach and how broadly it went out. Certain positions require very specific skills. In some cases, HCD (Simon) travels to reach community members, since they are not in the position to travel.

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SECTION 10.9.10: HUMAN WILDLIFE CONFLICT PROGRAMME

No. Comment / Input Commentator/s Reference Official response 430 I’ve noticed with interest that a lot of emphasis has been Mr John Scutcher 12 February, Durban A key focus of the HWC programme will be to better understand and placed on damage causing animals outside the Park. What address the drivers of human-wildlife conflict, and not only deal with I’m interested in is problem animals inside the Park. I’ve the actual mitigation. A major focus will be on areas with food noticed in the plan that you’ve got a process to manage resources, a waste management, and building awareness. these animals. There are concentrated food sources throughout the Park i.e. camp sites, staff villages, picnic We do not have the figures to say yes or no but gut feeling tells us sites. Can you tell me the density of baboons / monkeys in that the numbers are higher around sites where the can scavenge. the vicinity of camps versus baboons / monkeys that don’t Apart from waste site etc., these animals are also attracted to the have access to these concentrated food sources? camps / staff villages because there is water available and gardens as a year-round food source. Although the camps and staff houses are fenced, it is extremely difficult to keep out baboons / monkeys. Vervet monkeys have now taken-up permanent residence in big camps like Skukuza. Baboons are clever and strong, we have seen how they break into houses and sometimes we need to remove individuals/troops. We try to manage the accessibility to prime sites such as waste site and refuse bins. From an environmental management and problem animal perspective, we are looking at moving all our waste off-site. Many other species can become problem animals. There are several factors that influence this issue i.e. an increase in the number of an individual species, drought conditions. 431 Following on this topic. I stayed at Shingwedzi during Mr Tony Carnie 12 February, Durban You start-off with minimum force to chase them away. They learn very December 2017 and noticed how a camp attendant walked quickly how to adopt and evade the minimum force approach. At one around with a “kettie” to chase the baboons away. At what point we have even had baboon chasers appointed but the baboons point do you tactic? adopted a hit and run approach. We also get feedback from the local Doctor regarding injuries caused by vervet monkeys as well as the tourism department regarding refunds due to damage caused by baboons. Based on this a decision is made regarding euthanizing problem animals. 432 Section 10.6.10, page 185. “upgrading most of the western Dr Ben du Plessis Written input, 3 March Noted and corrected boundary disease control fence” should be “upgrading 2018 most of the western and southern boundary disease control fence” 433 Add in term Vehicle-Wildlife-Conflict Stakeholder Written inputs, 27 This is a registered research programme, covered under Biodiversity. February 2018 434 Record roadkill incidents more rigorously – still don’t know Stakeholder Written inputs Noted. There are several projects underway to identify hot spots and extent of animals being hit on the roads, and many goes potential mitigation measures for these areas, such as signage, speed unreported. We will only know over time (a few years), and bump and visitor awareness campaigns. then be in a better position to identify trends and areas (as well as species and habitat).

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435 What is the required distance between communities and Community member 13 February, Mutale A Compensation Protocol with guidelines has been developed, but KNP in order to be considered for DCA compensation? the Protocol will need to be reviewed. This will include the review of the communication and report-back platforms. Incidents are being reviewed on merit, and future workshops with communities are planned. KNP also have a Protocol with the provincial conservation authorities, LEDET and MTPA, with respect to investigating and mitigating HWC incidents. It is important to note that the fence maintenance is the key mandate/responsibility of DAFF and State Veterinary Services, whilst the Provincial Conservation authorities respond to HWC-DCA incidents outside the KNP. However, the Provincial authorities will engage with the KNP and Section rangers in providing assistance to respond to HWC-DCA incidents if required. It is critical though that KNP, State Vets, the Provincial authorities and affected parties review how reporting and communication could be improved to address HWC-DCA mitigation and compensation issues, as well as ensure that their roles and responsibilities of respective authorities are understood. 436 Where do communities report DCA incidents? Community member 13 February, Mutale The current Protocol between KNP and the Provincial authorities guide the reporting. Whilst it is the primary responsibility of the Provincial Conservation authorities to respond to incidents, it can be reported to rangers in the Park and outside the Park to LEDET (Limpopo Province), and the MTPA (Mpumalanga Province). The State Vets also respond to buffalo incidents in liaison with the KNP and Conservation Authorities. However, when such incidents are reported to the local traditional council, it is important that the afore- mentioned reporting and communication lines be followed. KNP do plan future workshops in this regard, also with in the context holistic rangeland and crop management approaches. 437 The issue of animals breaking the fence (DCAs). Exit KNP Community member 13 February, Mutale The current Protocol between KNP and the Provincial authorities to eat watermelons/crops outside the Park. Why don’t KNP guide the reporting. Whilst it is the primary responsibility of the provide crops to the animals? Provincial Conservation authorities to respond to incidents, it can be reported to rangers in the Park and outside the Park to LEDET (Limpopo Province), and the MTPA (Mpumalanga Province). The State Vets also respond to buffalo incidents in liaison with the KNP and Conservation Authorities. However, when such incidents are reported to the local traditional council, it is important that the afore- mentioned reporting and communication lines be followed. KNP do plan future workshops in this regard, also with in the context holistic rangeland and crop management approaches. 438 Concerns about the DCA process – what are the document Community member 13 February, Ba- Reports are submitted to LEDET, the Traditional authority, Stock required to receive compensation? Phalaborwa inspectors. Proof such as pictures should be submitted. No remains at kills should be taken.

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439 Human wildlife conflict: How long does it take for the Community member 13 February, Ba- DCA compensation for incidents from 1994-2013. Consulted files compensation once all the documents have been Phalaborwa from government, and compensation up to December 2013. A submitted? submission from 2014 up to current to access more funding is in process. 440 Please at Numbi side, have challenge with wild animals Community member 13 February, Hazyview The current Protocol between KNP and the Provincial authorities (lions) coming to villages. They are losing their livestock. guide the reporting and dealing with DCA animals. Whilst it is the Please come and get your animals and take them back! primary responsibility of the Provincial Conservation authorities to MTPA is not playing a role, not coming to their rescue. respond to incidents, it can be reported to rangers in the Park and Nobody evers report it. outside the Park to LEDET (Limpopo Province), and the MTPA (Mpumalanga Province). The State Vets also respond to buffalo incidents in liaison with the KNP and Conservation Authorities. However, when such incidents are reported to the local traditional council, it is important that the afore-mentioned reporting and communication lines be followed. KNP do plan future workshops in this regard, also with in the context holistic rangeland and crop management approaches.

We would also like to emphasise that the fence maintenance is not responsibility of KNP, but that of the Department of Agriculture, being maintained by the Directorate Animal Health (and monitored by the State Vets). 441 Reporting of DCA issues – focus only on rhino, but not on Mr Ondanye, EWT 13 February, DCA responses are the responsibility of the MTPA and LEDET as lion and leopard? Hoedspruit provincial authorities. KNP respond (section ranger) if requested by the MTPA/LEDET to attend to the matter, pending an investigation. National Norms and Standards exist that governs responses. Existing Protocols exists between KNP and the MTPA and LEDET ito the response and reporting, and with communities. However, communities and other external stakeholder are not always aware of this Protocol and reporting, and the MTPA and LEDET does not always have the resources or capacity to respond timeously.

Note: subsequent discussion indicated that community forums are not aware of reporting processes, and further meetings with external stakeholders and conservation entities are planned through the Lowveld Protected Area Group.

We do not prioritise rhino. However, lions and predators are difficult to detect and are more mobile, and gets out easy. As result, there is a longer response period and associated positive outcome, opposed to large herbivores such as elephants that are easily detected. Predators are logistically also more difficult to detect. 442 The fence is poorly maintained and results in DCA Community member 14 February, Maphophe Provincial conservation agencies (MTPA in Mpumalanga and LEDET problems. in Limpopo). There is a significant improvement in the fence maintenance. Department of Agriculture is responsible for fence maintenance. Communities with queries about this can send their 155

representatives to the community forums, which are mostly held monthly. At the forums, they can consult the chairperson of the community forum. In cases where livestock are killed by lion, spotted hyena, wild dog or cheetah escaping from the Kruger National Park, there is a process of compensation for verified claims. This involves several steps including completing certain forms, and providing appropriate evidence of these incidents. More information on this can be obtained from the community forum representatives for each area. DCA also covered in the new Park Management Plan. 443 Community members that have lost livestock have been Community member 14 February, See reply to 442 promised compensation but not yet paid. Maphohphe 444 Communities closest to the Park have not yet been Community member 15 February, Procedure to be undertaken was explained. KNP/SANParks is not the compensated whilst communities further away from the Malamulele owner of the fence. It has to be maintained by the Department of Park have been compensated. Why? Agriculture. Valid reason for compensation is required e.g. DCA report from 1955 not really supported as there is no clear evidence. Legally once the animal escapes the Park, it becomes the responsibility of the provincial departments. Hlanganani Forum. We cannot attest the compensation already received (distance). Consult with relevant Forum. 445 DCA (question 2 above) was not clearly answered. DCA Community member 15 February, The speaker is confirming that in communities where there was reports have been personally submitted but still awaiting Malamulele compensation a task team was established. This was part of the compensation? discussions that happened in KNP. 446 Mentioned the problem with the fence and KNP’s animals Welcome Matukane – 14 February, Fence maintenance is done by the Department of Agriculture – eating their cattle. DCA reimbursement also takes too long. Gutshwa KaBokweni Directorate Animal Health, and monitored by State Veterinaries. All cases of injury and lion attacks must be reported – the MTPA is the relevant conservation authority, and will liaise with the KNP Section Ranger. There is a compensation program and all procedures must be followed. However, there are unfortunately instances of incorrect or false reporting, and thus, there must be proof before compensation can take place. 0137355641 – Number to report fence issues. 447 Working at the municipal office in the speaker’s office. Mr Vusi Linkhele - 14 February, Ka- Thank you, your comment is noted. Commented that 15 cows were killed by lions but they were Mvangatini bokweni never compensated. Suggest fence patrols, especially The SED department (People and Conservation) will engage with you after floods and that forums should include ward about the matter. The DCA compensation Protocol guides the councillors. compensation process, and this will be addressed in the discussions. The MTPA is the relevant Conservation authority to address escaped lions, and they should be informed about such incidents to do the necessary investigations, whilst State Veterinary Services is responsible for the fence maintenance. This matter will be taken up with them. 448 Theme: Safety and security Community member 16 February, Giyani In terms of the rules, when the animals get out of the Park, it is the How does SANParks/KNP compensate for DCAs? responsibility of Department of Agriculture. All incidents are reported to the community forums where claimants are required to complete incident forms to be compensated.

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SANParks does however assist in terms of knowledge sharing and to bring the animal back into the Park where possible. 449 How does KNP maintain the fence and prevent DCA from Community member 16 February, Giyani Department of Agriculture is responsible for fence maintenance. exiting? There is a significant improvement in the fence maintenance. Concerns could be reported to the Conservation authority (LEDET), State Veterinary Services or the Section ranger.

Communities must also work with their forums 450 How do communities chase warthogs from Ngove village Community member 16 February, Giyani Communities must also work with their forums. Procedure needs to and Thomo 14 village back to the Park to avoid crop be followed i.e. completion of forms detailing the damage causing damage? incidents.

Incidents of damage-causing animals should be reported immediately to the appropriate authority, LEDET and acted upon timeously. 451 Are we allowed to kill the animals that have escaped from Mr Mulambo 16 February, Giyani No one is allowed to kill an animal whether it is an escaping animal, the KNP because when we report it to you, you take too or whether it is outside or inside the Park. Anyone involved in animal long to respond. killings will be prosecuted by law.

The DCA Protocol guides the reporting and mitigation of such animals through LEDET, and such issues need to be reported to LEDET or the Section ranger. 452 Regarding section 10.6.8. Within sub-objective To Dr. Brandon Anthony Written inputs, 20 Feb. We take note of the comment, and the necessary amendments have monitor and evaluate the impact of human wildlife 2018 been made to the plan, also to allow a broader stakeholder conflict interventions on environmental, social, consultation driven review. economic and institutional/ legislative outcomes, please note that indicators have already been identified for monitoring/evaluating the damage compensation scheme, and should be expounded on. See Anthony, B.P. and Swemmer, L. 2015. Co-defining program success: Identifying objectives and indicators for a livestock damage compensation scheme at Kruger National Park, South Africa. Journal for Nature Conservation 26:65-77.

453 10.6.10, 185 par 5. “…has been attributed to the DAFF Dr Louis Van Written inputs, 3 March Noted and corrected. (State Veterinarians) upgrading most of…” should read Schalkwyk 2018. “…has been attributed to the DAFF (Directorate Animal Health) upgrading most of…”

“…the fencing standard has shifted to the “I” Beam fence since 2010,…” should read “…the fencing standard has shifted to the “I-beam” fence since 2008,…” 454 10.6.10 First paragraph, the DCA legislation classifies the Mr David Marnewick, Written inputs, 9 March Noted. The KNP and Provincial Agency Protocols also seek all other listing of an animal as a DCA if significant loss is incurred. EWT 2018 methods of pro-active interventions, and the necessary investigations

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before a DCA animal is destroyed as last resort (this being the function of the provincial conservation authorities). 455 10.6.10 Fourth paragraph, “…DCAs which are listed TOPS Mr David Marnewick, Written inputs, 9 March There is a Protocol, which has been signed between SANParks and species are managed jointly by the province and EWT 2018 the Provincial agencies. The KNP and Provincial Agency Protocols management authority of the protected area from which the also seek all other methods of pro-active interventions, and the DCAs have escaped.” It is unclear if there is a guiding necessary investigations before a DCA animal is destroyed as last document, whether that is available or if DCAs are resort (this being the function of the provincial conservation managed on a case-by-case basis. Having such clarity will authorities). providing justification for control measures (such as lethal) for cases over the next 10 years. 456 The fence is poorly maintained and results in DCA Community Member 14 February 2018, See comment to 442. problems. Maphophe 457 Page 186: ‘Human wildlife conflict programme’ table Written Input As in the natural resource use programme, the adaptive management “Develop and continuously review incentive framework that of human-wildlife conflict requires an interdisciplinary approach, not will promote responsible rangeland, cropping and only within SANParks between social and biological sciences, science conservation management practices.” and management but also between SANParks and our partners such Again, who in Scientific Services has the appropriate as Conservation South Africa. CSA through the Herding for Health training and knowledge to do this? Veld (rangeland) and programme are working with SANParks on rangeland improvement in animal management are specialised fields which over the the KNP buffer. years, have made huge progress and have become very ‘fine-tuned’. What veld or animal management is carried out in the KNP and related to the carrying capacity of the KNP? 458 This situation arises when animals termed DCAs or Ms Kim Da Ribeira, Written inputs, 10 Noted. The DCA Norms and Standards is a National process, and Problem Animals pose a direct threat to the material and / OSCAP March 2018 the KNP approach follows a holistic socio-ecological systems or psychological well-being of people, simultaneously approach, in close consultation with affected communities. Please resulting in financial, social and ecological costs to refer to Section 10.9.10, which expands on the proposed actions and conservation. future consultation processes, considering economic, social, ecological, legislative and governance aspects. OSCAP comment: • OSCAP has in the past commented on the Norms and Standards for Damage Causing Animals, where we expressed our concern regarding the document. • This numbering is incorrect it should read 10.8.10

SECTION 10.9.11: DISATER RISK MANAGEMENT PROGRAMME

No. Comment / Input Commentator/s Reference Official response 45 Heritage resources to be included in the Disaster Ms Natasha higgit, Written inputs, 9 March Thank you, noted. 9 Management Plan, primarily with regards to monitoring SAHRA 2018 heritage resources after a disaster has occurred. Additionally, the Disaster Management Plan must also incorporate the results of the Collection Security Plan in the Heritage Programme and vice versa.

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46 OSCAP comment: Ms Kim Da Ribeira, Written inputs, 10 March Thanks for the input. The Disaster Management Plan conforms to the 0 • Does the Park subscribe to the ICS system? OSCAP 2018 National Disaster Management Act and Framework. The subscribing • This numbering is incorrect it should read 10.8.11 to the ICS system will be discussed during the next review.

The numbering has been corrected.

SECTION 10.9.13: CLIMATE CHANGE PROGRAMME

No. Comment / Input Commentator/s Reference Official response 46 Regarding climate change. I see that it has been Mr. Sven Kramer 15 February 2018, The climate change programme in section 10 of the document is 1 addressed to some degree however, I’m still concerned, it Johannesburg supported by a detailed lower level plan. It focusses on monitoring seems that no scenario planning has been incorporated in and mitigation. Our 2017/18 Annual Performance Plan also states the the plan. reduction of electricity and water usage as a key objective. We are already monitoring consumption monthly and telemetry systems provide us with the necessary data. This matter has also been included in the Key Performance Areas of Managers to ensure compliance. You are more than welcome to contact Eddie Riddle and Robin Peterson to get the information. Danie Pienaar mentioned the following: The Climate Change document does not specifically mention scenario planning, but it has been included in regional land use planning (LLP). The Savanna areas will not be as negatively impacted as compared to the Succulent Karoo areas. We have the Science Learning Centre in Skukuza where we are experimenting with a couple of technologies. If it proves to be successful, it will be rolled out to the rest of the infrastructure.

SECTION 10.9.14: RESEARCH, MONITORING AND CO-LEARMING PROGRAMME

No. Comment / Input Commentator/s Reference Official response 462 I am very impressed with the new management plan and Dr Rina Grant Written inputs, 6 March Thank you for your positive comment. We will strive to improve our think it is a huge improvement on the previous one I think 2018 monitoring and evaluation of programme implementation accordingly. adding a section on RESEARCH, MONITORING AND CO-LEARNING PROGRAMME is a very good development. I would like to see the objective o To ensure monitoring and evaluation of programme implementation and effectiveness - in every plan. I think the plan will need extra resources and budget and I hope that this will be available. Congratulations. 463 Page 192: Mr Nick Zambatis Written inputs, 7 March It is agreed that most of the threats for conservation in future will be “Based on a recent analysis of peer reviewed publications, 2018 coming from outside the Protected Areas and not internal ecological the Park is the most researched savanna protected area issues, especially in large and ecologically resilient savanna systems in Africa. The research emanating from the Park is used like KNP. Furthermore, it is agreed that effective Park management to inform decision-making, challenge, adapt and reflect on is critical for the future existence of Protected Areas. As such, current management actions, influence policy (at multiple Scientific Services, with inputs from management across departments and across the organization, is in the final stages of 159

layers from Park to organisational to national level), drafting a “Research Strategy” to be tabled at SANParks EXCO. This highlight potential risks and identify opportunities…” strategy will highlight the non-ecological aspects, including The “…most researched savanna protected area in Africa” management effectiveness and organizational functioning, which are is irrelevant and only a self-boosting statement by important research themes to be further developed in future. Various Scientific Services. How much of this research has been research projects on these themes are already conducted and will be of direct relevance to the management of the KNP? further developed in future. It is an undisputable fact that the primary need by all the Parks of Africa is effective management, with ecological Regarding the Savanna Science Network Meeting, an initiative was research playing a supportive role, when and where started in 2018 to invite all (and fund) section rangers and colleagues needed. from Conservation Management to attend a morning session of the Stated differently, how much ecological research has been meeting. This session was based on talks specifically selected by undertaken in the other African Parks? Yet they continue managers based on their specific interest and/or relevance for their to survive; by far the greatest threat being faced by them work. It is hoped that this initiative will become a regular fixture at is due to human interference, in some form or other, direct future meetings, and it is hoped that this session can also be tailored or indirect. The control and management of this human in future to become an additional platform for managers to directly intrusion and human pressure is consequently and without express their pressing research and monitoring needs to the scientific any doubt, the most urgent priority, a priority which community. increases with the passing of each day, not internal ecological issues. The programme for the 16th Science Network Meeting held in Skukuza recently lists a total of 137 talks and poster presentations. Assessing each one (based on the title only), only 28 (20,4%) were considered to possibly be directly relevant to the management of the KNP! Furthermore, only 12 presentations (8,8%) dealt with monitoring and survey matters and of these, only 3 were thought to possibly be of value to the management of the KNP! 464 “There are numerous examples where management Mr Nick Zambatis Written inputs, 7 March We thank you for your comment and opinion. Due to the slow and Protocols in the Park have been amended and adapted as 2018 considered nature of science, not every research project will have a result of continued research, including the cessation of immediate management relevance (nor should they). It is through the culling predators in the central district in the 1970’s, the collective knowledge gathered over several years through a series of numerous amendments of the Fire Protocol, the Artificial research projects that the most useful information is discerned. Water Provision Protocol and Alien Vegetation Clearing Sometimes new thinking and novel experimentation lead to the real Protocol.” breakthrough in management solutions. We hope that SANParks “There are numerous examples…”. Again, a self-boosting science support makes room for applied as well as basic and blue- statement. In spite of all the research and the millions sky research that solves problems and advances our thinking. It spent on it, only the examples given above have benefited would be over-simplistic to believe that we have all the answers and directly from research, not “numerous”. equally over-simplistic to believe we have thought of all the questions. 465 “The Park is also well known for its management–science– Mr Nick Zambatis Written inputs, 7 March Please refer to the above responses. academic partnerships and these strongly support the 2018 SAM framework where the best available knowledge is used to take decisions or actions, which are continuously evaluated and refined and modified if required, facilitating a learning-by-doing approach and co-learning attitude”

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Yet another publicity statement by Scientific Services. Far too much attention or emphasis is placed on academic aspects and far too little on work of an applied nature and of direct and immediate relevance to the ecological management of the KNP. 466 After 24 years of a moratorium on elephant culling, how Mr Nick Zambatis Written inputs, 7 March Please see responses to comments on the herbivory programme. much use of “…the best available knowledge…” and 2018 progress has been made with the management of elephant, other than a continual denial that an increasingly serious threat to the KNP ecosystem has arisen as a result of this not recognising that a problem does indeed exist, and the paralysis in dealing with it appropriately, instead of wasting time and resources ‘experimenting’ with chili sauce, bees and “landscapes of fear”? 467 “Over 700 projects have been registered in the Park since Mr Nick Zambatis Written inputs, 7 March Management inputs and ecological thinking as influenced by science 2005, with 545 peer reviewed papers published between 2018 have jointly played a role in shaping management actions in the KNP 2003 and 2013 as a result of these registered projects.” in the past and it will continue to do so. In many cases, it needs to be A basic ecological management objective for the KNP is to considered whether management interventions are required and to interfere (i.e. manage) as little as possible in its ecology. what extend (e.g. management fires, artificial water provision, Why then is all this research necessary? What percentage herbivore management, impacts of sustainable resource use, river of these projects have been of direct relevance to the management, etc.). In other cases, humans exert a pressure and ecological management of the KNP? Similarly, how many research is needed to quantify and inform management in terms of of the 545 peer reviewed papers are of direct relevance to measuring the pressure/impact and proposing possible mitigation the ecological management of the KNP? Or is the primary strategies. For example, research on Lowveld rivers are used to reason for the existence of the KNP and Scientific Services determine expected flow rates in rivers under different conditions, and to undertake research projects and produce publications, this information, together with daily flow monitoring, are used to regardless as to whether they are relevant to the request releases from upstream dams or suggesting irrigation management of the KNP or not? restrictions (decision-making through the relevant catchment Some will argue that it is necessary “…to get a better management agencies). Furthermore, some aspects like global understanding…”. And what then is done with this “better change and the fact that Kruger is an enclosed reserve with understanding”, considering that a basic management objectives that can sometimes be “competing” with each other, mean objective is to interfere in the ecology of the KNP as little that management interventions are sometimes needed. Furthermore, as possible in the first place? and in relation to a previous comment that threats for KNP will be mostly from human pressure outside the Park rather than ecological pressure within the Park, adequate socio-ecological research is needed to better understand and hence be better prepared through possible intervention to reduce risks in Parks. 468 A disturbing phenomenon in the KNP ecosystem, and an Mr Nick Zambatis Written inputs, 7 March Scientific Services undertake ongoing monitoring to keep track of indication that the ecological management of the KNP is 2018 elephant impact (e.g., large tree monitoring on perennial rivers, large deficient, is the lack or great scarcity of mature individuals tree terrestrial monitoring, phenology monitoring) and is aware of the of certain tree species, except in places such as rest- impacts of elephants on vegetation. camps and exclosures/enclosures where elephants have The management of elephants is a highly contentious issue governed been excluded and/or where a different fire management by norms and standards and complicated by the wishes, sensitivities policy has been applied. Examples are species such as and expectations of our many stakeholder groups (as can be seen by Hyphaene petersiana and Dalbergia melanoxylon. the many comments on the herbivory plan – either demanding 161

In the case of the latter species, individuals with a basal elephants to be culled or demanding that no disturbance of elephants trunk diameter of 40 cm or greater have disappeared, yet should take place, not even disturbance culling). 30 years ago, some were still present (even though rare). In addition, the dead trunks of individuals of this species were also reasonably common, indicating that they were more abundant. But now, they too have disappeared. Yet who in Scientific Services, in spite of all their research, is aware of this? What monitoring has been undertaken which has detected this trend? Similarly, the viability and long-term survival of the kiaat (Pterocarpus angolensis) population of the KNP is also a cause of great concern. It is severely targeted by elephant (debarked), to the degree that large trees with a trunk diameter of 50 cm and greater in diameter eventually succumb as a result. To aggravate the situation even further, like marula, the recruitment of new individuals (seedlings) seems to have ceased, as is evidenced by the absence of seedlings in the veld. Yet outside the KNP, even casual, ‘drive-by’ observation shows that the distribution of individuals of various ages is more ‘normal’ (bell-shaped), with a lot more young trees being evident. Why? And why has Scientific Services not detected this?

Yet another species which seems to have been very severely affected by elephant is Albizia tanganyicensis, confined to the ridge slopes of the Punda Maria area. According to the late Piet van Wyk (botanist of the KNP), this species is “severely damaged elephants”.

Twenty years ago, individuals of this species were clearly visible on the slopes when driving on Mahonie loop. Now however, none are visible. Has Scientific Services detected this drastic decline?

These are only a very small number of woody plant species which I have personally observed to have been impacted negatively or having declined severely in the 31 years in which I have been in the KNP. How many other plant species, woody or herbaceous, have suffered the same (or worse) fate? 469 The primary and most important first step in the effective Mr Nick Zambatis Written inputs, 7 March The role of science in SANParks is complex and integrated into all ecological management of the KNP (and, for that matter, 2018 spheres of decision making across 22 PAs in the estate as well as practically all other Parks, be they in the RSA or elsewhere several departments from Tourism to Conservation management, in the world), is close monitoring. This then without any and therefore might lead to misinterpretation in terms of traditional doubt, should be the primary function of Scientific Services role of scientists and managers in other sectors. In an integrated

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and not research, and particularly research of academic agency scientist role, SANParks science support provides value. Only where monitoring identifies a problem or institutional knowledge to attract and facilitate credible and productive otherwise highlights the need for specific research, should science collaborations to improve the knowledge base for decision this be undertaken. However, monitoring has little or no making; it also integrates knowledge across several fields, translates appeal and little or no scope for the rapid production of this information into policy and management recommendations and publications! engages at the science management and policy interface. The role as “scientists on tap”, or “monitoring technicians” is not considered In order to address these organisational shortcomings, as the most efficient use of a skilled group of people that can contribute was the case many years ago, Scientific Services in the more broadly to rigorous and considered decision making See earlier KNP should be under the direct control of, and directly comments in this regard. responsible to, the GM: Conservation Management, and not a ‘stand-alone’ department; nothing more than a sub- section of Conservation Management.

Furthermore, the function of Scientific Services must be ‘tightened up’ and become far more focussed than at present. And what exactly it should be is very simple and straightforward to define: As the name implies, ‘Scientific Services’ must provide a SERVICE, and not dictate to Conservation Management – the tail cannot wag the dog!

The primary objective of a scientific section in any conservation organisation should be the monitoring of the ecological processes of the area concerned, particularly those processes or trends which have raised warning signs or alarms and which are or need to be managed. This must be undertaken according to sound scientific principles and procedures, in which conservation biologists are specifically trained as specialists; which is why they are employed in the first place.

The motivation to undertake research must stem from a problem or need identified through monitoring, and be solicited by and approved by Conservation Management (and not by outside institutions having a different (academic) agenda). Furthermore, the emphasis should be on applied research, and the final report on the particular project concerned must have management recommendations.

For greater credibility, any assessment of management effectiveness must not be undertaken as an ‘in house’ exercise by serving SANParks personnel, but undertaken by an independent panel comprising non-serving persons 163

– retired conservation managers (not only SANParks but from other conservation institutions as well) and an appropriately-qualified and experienced scientist (e.g. in wildlife and veld management). 470 Research, monitoring and co-learning programme Ms Lindie Botha Written inputs, 9 March “Thank you for engaging with the draft KNP management plan and (10.6.14): The term “co-learning” is often used, but I’m not 2018 for commenting on the “Science, Monitoring and Co-learning” plan. sure if it is really practiced by traditional conservation The comment about citizen science and community led research are stakeholders. There is no doubt that Western-Scientific indeed relevant and of interest in the context of co-learning. There are knowledge is privileged above local, indigenous and currently some examples of projects where citizens are involved in citizen-generated knowledge. For example, at the recent data collection (e.g. EWT’s cheetah and wild dog photographic Savanna science network meeting, not a single census) or where members of the public (i.e. no formal training in presentation featured any research project led by science) register research projects with KNP (mostly with a natural community member(s) or “ordinary citizens.” If this history focus, including tree, butterfly and bird enthusiasts). However, situation persists, the lived experiences of community we acknowledge that this only reflects a narrow focus of citizen members (for example, as it pertains to DCAs or wildlife science and it will indeed be valuable to involve local communities in security) will never influence scientific discourse. There is jointly constructing and conducting research projects. Currently there much opportunity for KNP to work with NGOs and other are various studies conducted within the Park and with people living partners in the Greater Kruger to make sure that “co- in close proximity to the Park to understand and share each other’s learning” is not just a one-way street wherein academics perceptions and responses to various issues (e.g. DCA’s and the and scientists enjoy a privileged position. Changing this is compensation scheme where livestock farmers are engaged in the the collective responsibility of all organisations in the development of the objectives for compensation as well as the landscape who “do” research on topics that are relevant to identification of appropriate indicators to use in monitoring outcomes; those outside the fences of protected areas. However, the conservation and sharing of benefits from medicinal plants). KNP can play a leading role here to set specific actionable Sosio-ecological research are conducted in the areas outside of the objectives in this regard. There is a wealth of knowledge in Park, However, such projects take time and resources to implement SA about how to facilitate Citizen Science and one does effectively, which does remain a challenge. As such, we value your not have to reinvent the wheel. comment, specifically in terms of partner support and we would be keen to engage with external scientists and NGOs in this regard.”

SECTION 10.10: MONITORING AND EVALUATION

No. Comment / Input Commentator/s Reference Official response 471 At what level will you be measuring achievement, will it be Mr. David 15 February, In each of the programmes there is a table that sets out the objectives, at the objective level or the action level? Marnavick Johannesburg sub-objectives and actions that must be achieved. We have already started a process to ensure that the 2018/19 KPAs of staff reflect the programme / actions as listed in the management plan. Identifying the correct indicator is not so easy and this is a challenge, especially for some of the social objectives. Report of numbers is easy however, measuring social engagements / relationships is a bit more difficult. 472 Monitoring and evaluation: Most conservation-related Ms Lindie Botha Written inputs, 9 March M&E rely on quantitative indicators (i.e. METT scores, nr 2018 of hectares, etc.). Does SANParks/KNP have a commitment to also look at qualitative indicators – such as community sentiments towards the Park, which can be

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tracked over time, and some of the non-financial benefits of engaging with communities, including the sustainable utilization projects? This requires a substantial time- resource investment to regularly collect, analyse and share data. It has the potential to be a really important feedback loop into the adaptive management process.

SECTION 11: COSTING

No. Comment / Input Commentator/s Reference Official response 473 Section 11: staff are no longer appointed based entirely on Prof Van Helden Written inputs Your comments are valued and noted. merit, but following equity and transformation criteria for example. I would argue that this has poor support in our SANParks is engaging at the highest political level to obtain support. constitution, has lead to and will continue to generate poor morale and the appointment of many persons who are not the “best”. KNP will thus run a risk of not being world class in the long run.

Another major problem is the lack of political buy-in, resulting in a very poor government subsidy. Consequences are that SANParks has to generate own revenue, which means that conservation drops ever lower on the priority list. Just one small point of evidence for this is the current inadequate ranger and research staff. A great deal of attention at SANParks level needs to be given to this point.

APPENDICES - CROSS-LINK TO CERTAIN SECTIONS/LOWER LEVEL PLANS No. Comment / Input Commentator/s Reference Official response 474 Regarding Appendix 1. This section also does not include Dr. Michael Brett Submitted via email on Please note that the Exclusion notice of 2013 indicates these. the excision of land near to Phalaborwa (Klaseriemond 90 17 Feb. 2018 and Diepkloof 91 and a rectangle of land south of Phalaborwa Gate and adjacent to the copper mine) and the inclusion of the farm, Peru 28, in the Houtboschrand section. 475 Regarding Appendix 1. The excision of the Makuleke area Dr. Michael Brett Submitted via email on Please refer to the notice of 2013. is repeated twice and the land excised does not tally. 17 Feb. 2018 476 Ms Michele Pickover, Written inputs, 9 March Please refer to Appendix 3, which has been amended to assist with ELEPHANTS IN THE KNP AND BUFFER ZONES EMS 2018 the correct interpretation. These activities are not offered in the Park. pp. 217 - 222 Section: Table 22 Products, etc. Adjacent land use is governed through the municipal LUMS and SLUMA Act, and is not the jurisdiction of KNP. KNP will only support “Appropriate” Products in and around Kruger in relationship compatible land use practices as guided by clear principles and to elephants. associated co-operative arrangements. “Elephant backed rides/safaris” p. 217 165

Elephant back rides, even if only in the Park buffer zones, KNP cannot dictate to private landowners which activities they can are never “appropriate.” and cannot operate / sell. What we have learned about elephants through extensive, over-whelming and indisputable science-based research means that we are confronting very real ethical issues in relation to elephant management policies and practices. An understanding of a common neuro-ethology means that human biomedical models are now scientifically appropriate for investigating and evaluating elephant psychophysiological states and stress effects. Stress is a key concept in the analysis of elephants in captivity because it describes in scientific terms what the experience of capture and confinement translates to in terms of elephant mental and physical well-being. The predisposition of elephants to Post Traumatic Stress Disorder (PTSD)2 have demonstrated that among all species, elephants are extremely vulnerable to suffering in a captive setting. 2 Bradshaw, G., 2005, New York Times, Oct. 8, 2006. Many individuals, scientists and interest groups are particularly concerned about the abuses of elephants which are attributable to the captive elephant industry, including:

in which they are kept safety of people handling them

done to individual elephants, their communities, and their habitats

The KNP cannot be seen to be supporting (bad) zoos and personal businesses built on the

Exploitation of elephants. Moreover, the KNP will be sending a contradictory message to the public between KNP’s wildlife conservation mission versus one of animals for “entertainment” in close proximity to the Park in the buffer zones. 477 Table 22 Page 216 - 222 Ms Karen Trendler, Written inputs, 9 March See comment 476 The NSPCA has serious concerns about the promotion, by NSPCA 2018 SANParks of the following activities being promoted by and taking place in buffer zones: Elephant back rides and Wildlife interactions

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Responsible tourism includes the promotion of activities that do not harm or impact negatively on wild and exotic animal species. There is a growing global movement against these activities and a number of the large tourist representative organizations both locally and internationally no longer promote of book facilities that support these activities. The training and management of elephant for elephant back safaris and interactions is increasingly acknowledged as cruel and results in long-term health problems for the elephant. 2

There are safety risks. Furthermore the Norms and Standards for the Captive Elephant regulating the training and management of captive elephant have not yet been finalized\ gazette and thus there are no controls and standards. Clay pigeon shooting The noise from the guns used for clay pigeon shooting could be potentially disturbing and distressing to both birds and animals in the area and should rather be practiced in areas not populated by or directly adjacent to areas populated by wildlife. Green hunting and green darting It should be noted that green darting\ hunting is still against the policy of the South African Veterinary Council and whilst still ‘illegal ‘should not be included in the Management Plan. Golf courses Given the current (and future) water shortages and challenges in South Africa, golf courses that are water demanding and have the potential to encourage wildlife \ human conflict, should not be included as acceptable buffer zone activities. Game-capture training If this is to be carried out, it should be genuine \ accredited training carried out in accordance with the relevant legal requirements in terms of drugs and weapons handling and should not be in contravention of the Animals Protection Act 72 OF 1962 478 APPENDIX 3: Ms Kim Da Ribeira, Written inputs, 10 See comment 476 TOURISM PRODUCT DEVELOPMENT OSCAP March 2018 FRAMEWORK

OSCAP comment: • The following are activities OSCAP does not deem suitable for inclusion as an offering in the 167

Park o Conference lodge / hotel - 50 beds plus o Overnight train rides o Archery o Clay-pigeon / clay target shooting o Motorcycle trails (varying facilities) o Motorcycling o Motorcycling - off-road o Motorised boating o Quad biking o Railway o Firearm skills o Festivals o Musical concerts o Sports bar o Hunting (lethal) o Sustainable utilisation of resources (What is meant by this do what degree do you intend to take this?) 479 “Elephant backed rides/safaris” GMFER Written inputs, 9 March See comment 476 2018 Elephant backed rides, even if only in the Park buffer zones, are never “appropriate.”

The practice causes elephants injury due to their anatomy being unsuited for riding and the inherent damages of captivity. Concerns about how the elephants acquisition via wild capture; the psychic, physical, social, and conservational damage done to individual elephants, their communities, and their habitats by “taking” elephants. Enables continuation of bad practices in zoos and personal businesses built on the exploitation of elephants. Elephant rides send a contradictory message to the public between the wildlife conservation mission of KNP versus one of animals for “entertainment” in close proximity to the Park, in the buffer zones. 480 “Clay pigeon shooting” GMFER Written inputs, 9 March Clay pigeon shooting will not be allowed in the Park. 2018 There should be refuge for elephant populations under fire by poachers in nearby Mozambique. Clay pigeon shooting, envisioned in Table 22 on page 217, will bring gunfire into and around the Park.

Elephants and others of the “herbivory” will doubtless avoid areas where they can hear gunshots. These areas will

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become over-crowded as a result and it will be tempting or deemed “necessary” to begin culling them to prevent irreversible damage to the environment’s “carrying capacity” where they gather as a result of a misguided addition to KNP’s tourist products. 481 “Golf courses” GMFER Written inputs, 9 March KNP is not building new golf courses. 2018 A single 18-hole golf course can use between 250K and 1 million gallons of water per day, depending on weather conditions and the acreage and physical features of the course. Yearly, this translates between 91.25 million and almost one third of a billion gallons. Estimates based on USGA report, Water Use and Conservation Practices on U.S. Golf Courses, and presuming a variety of sustainable use practices from 2012. For purpose of estimation, at least 104 million gallons/year or 285 thousand gallons per day would be required for a single golf course in KNP’s area.) (https://www.usga.org/content/dam/usga/pdf/Water%20Res ource%20Center/how-much-water-does-golf-use.pdf 482 We are concerned that, given the apparent intention to GMFER Written inputs, 9 March Please see earlier comments under the Herbivory Section. develop of 5-star resort amenities in and around Kruger 2018 National Park, based on the activities and “products” listed in Table 22, that this “landscape of fear” will be brought inside this UNESCO Wildlife Heritage site and National Park which should be devoted to its conservation mission. 483 Wrt the southern and south-western boundaries of KNP it is Mr Johan Eksteen, Written inputs, 9 March The fence is a Veterinary fence, and does not represent the KNP noted that the KNP boundary is: MTPA 2018 boundary, which is gazetted and described (see Appendix 1). a) on the right (northern) bank of the Crocodile River, but the fencing is erected on the left (southern) The fencing was also erected (in the case of the Nsikazi river) to bank. follow the railway servitude, hence including slithers of land. Refer to b) on the right (eastern) bank of the Nsikazi River, Section 8 for a more detailed description in this regard but the fencing is erected along the railway servitude, some distance from the left (western) The land audit programme (Section 10.2.1) will specifically address bank boundary and land audit matters, formalising servitude agreements and relevant Protocols, in liaison with relevant parties, including The MTPA would appreciate clarification wrt the DRDLR, Department of Public works, Veterinary Services and title agreements/Protocols that are in place wrt this arrangement. deed holders where affected by boundary issues. This is mostly along river systems (Crocodile, Nsikazi, Sabie river), and for land portions between the Numbi gate and Matsulu.

A detailed KNP land audit has been concluded in the past year, and actions will be prioritised based on legal, management, social and conservation criteria, including for these areas as per query.

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ANNEXURE 1: STAKEHOLDER MATRIX

Stakeholders from the following stakeholder matrix were invited to participate in the 15 stakeholder meetings:

This table reflects the various organisations that were identified to participate in the Park management plan process. The government departments are at national, provincial and local level. The intention is to show that, in terms of the spirit of co-operative governance SANParks has approached these parties.

International Great Limpopo Transfrontier Conservation Area JMB; GLTP ANAC National Government/Institutions Department of Environmental Affairs, Department of Agriculture, Forestry and Fisheries, Department of Water and Sanitation, SANDF, SAPS, SANBI, SAHRA Provincial government Mpumalanga and Limpopo Departments of: Health, Social Development, Finance, Home Affairs, Sports and Culture, Education, DARDLEA, DAFF, DWS, COGTA Provincial conservation MTPA, LEDET authorities District Government Ehlanzeni DM, Maruleng DM, Vhembe DM Local government Mbombela Municipality, Nkomazi Municipality, Greater Giyani Municipality, Bushbuckridge Municipality, Ba-Phalaborwa Municipality, Mutale Municipality, Collins Chabane Municipality, Musina Municipality Community fora Hlanganani, Lubambiswano, Mahlamba Ndlofu, Makuya, Nkomazi, Ntirhiswano, Phalaborwa Traditional authorities All traditional authorities bordering KNP, as per detailed list. Land claimants Land claimants as per NLCC settlement process Local Resident Rural communities, conservation areas, agricultural sector, river fora, biospheres, concessions, tourism sector, Local /Neighbours/Businesses business, Chamber of Commerce, Business associations, Environmental consultants, Taxi associations Broader Sector Partners Forestry: SAPPI, York, Komatiland, Catchment management agency: IUCMA, Mining: Foskor, Ba-Phalaborwa complex (including Phalaborwa Mining Company); Rand Water; Irrigation Boards, Community based organisations Woman’s groups, Mother’s union, Youth Groups Media MEDIA 24 NGOs general EWT, Earthlife Africa, WESSA, SANParks support group, WWF, K2C, CSA, Vhembe biosphere, AWARD, GKEPF, SAIAB, Birdlife, Conservation Outcomes etc. Conservation areas bordering Mjejane, Marloth Park, Mala Mala, SSW, Manyeleti (MTPA), Timbavati, Kapama, Thornybush, Balule, Umbabat, Klaserie, KNP Selati, Letaba ranch complex (LEDET), Makuya (LEDET), Makuleke Contractual Park, Limpopo National Park, GLC, Lifestyle estates bordering KNP Sabie Park (western boundary), Elephant Point, Lisbon, Leopard Creek, Selonque etc. Research and Tertiary institutions Savanna Network Research database- local and international research partners; All major Universities and other Tertiary institutions in SA, and entities such as SAWC, WRF, SAEON, ARC, UP Hans Hoheisen Wildlife Research Station Tourist Associations SATSA, Lowveld Tourism, MISA Tour operator Untamed, Siyabona Travels, Thomson Indaba, Safaris Direct, Elephant Herd, Sefapane Lodge etc., OSV operators etc. (as per detailed list) Staff Information sessions across all KNP regions with all departments Honorary Rangers Yes

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Visitors to Park Wild card holders, broader public invited to Public meetings Key Focus / Interest groups  Conservation Areas open and adjacent to KNP  GLTFCA  Technical Focus Groups  Water River Fora / Committees  Savanna Science Network Meeting and Research Institutions  Animal Health  Tourism fora (MISA, SATSA, Lowveld Tourism)  Safety and security clusters: Natjoints, Limpopo and Mpumalanga Provincial Commissioners, Mozambique Security cluster  Mpumalanga House of Traditional leaders  Limpopo House of Traditional leaders

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ANNEXURE 2: DESIRED STATE STAFF MEETINGS

A total of 10 KNP staff meetings were held during 2017 to obtain inputs into the “Desired state process”. Detailed reports were prepared following each staff meeting, submitted to the KNP Management Committee and considered during the drafting of the KNP management plan.

The main categories and keys issues related to these, as summarised at a high level.

Overarching Theme Issues related to the theme Sections in the Plan where key issues raised have been considered Biodiversity Big 5 Section 10.3 Small 5 Section 10.3 Birds Section 10.3 Special trees Section 10.3 Vegetation Section 10.3 Reptiles Section 10.3 Wildlife Section 10.3 Diseases Section 10.3 Invasive alien species Section 10.3 Environmental management, protection and environmental Pollution Sections 10.2, 10.9.1 drivers (linked to biodiversity) Littering Sections 10.2, 10.9.1 Fire and fire breaks Section 10.3.7 Natural disasters e.g. floods, droughts Section 10.9.11 Soil erosion Section 10.3 River management Sections 10.2.3, 10.3.4 Windmill management Section 10.3 Sustainable resource use Mopani worm Section 10.3.9 (linked to biodiversity) Marula Section 10.3.9 Pepper bark Section 10.3.9 Medicinal plants Section 10.3.9 Animal products Section 10.3.9 Fire wood Section 10.3.9 Thatch Section 10.3.9 KNP size, sense of place, landscapes, wilderness, unique KNP size Sections 2, 10.4 features tranquil Sections 2, 10.4 Diversity of landscapes Sections 2, 10.4 Sense of place Sections 2, 10.4 Wilderness areas Sections 2, 10.4

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Noise pollution/issues Sections 10.4, 10.9.1 Provides safety (away from crime) Section 10.9.7 mountains Sections 2, 10.4 gorges Sections 2, 10.4 Fountains, springs Sections 2, 10.3, 10.4 Human capital issues Nepotism Section 10.9.4 Corruption Section 10.9.4 Low salaries Section 10.9.4 Employment of family Section 10.9.4 Recruitment processes Section 10.9.4 Staff accommodation Section 10.9.4 Maintenance of staff accommodation Section 10.9.4 Skills development Section 10.9.4 Training Section 10.9.4 Bursaries and learnerships Section 10.9.4 Career-pathing Section 10.9.4 Pension Section 10.9.4 dishonesty Section 10.9.4 values Section 10.9.4 Recreation Section 10.9.4 Safety and security Poaching Section 10.9.7 Crime Section 10.9.7 Staff safety Section 10.9.7 Guest safety Section 10.9.7 Crime in communities Section 10.9.7 Illegal traversing Section 10.9.7 Tourism and hospitality Tourism products Section 10.5 Tourism services Section 10.5 Hospitality Section 10.5 Activities Section 10.5 Impact of law enforcement presence Section 10.5 Experienced staff Section 10.5 Skilled in hospitality Section 10.5 Professionalism Section 10.5 Tourism infrastructure Section 10.5 Camp gardens Section 10.5 Cultural, heritage and history Cultural sites Section10.6 Heritage sites Section10.6 History/historical sites Section10.6 173

Traditional dancing Section10.6 Traditional beer Section10.6 Crafts Sections 10.6, 10.7 Markets Section 10.7 Knowledge transfer Section10.6 Cultural diversity Section10.6 Traditional dressing Sections 10.6, 10.7 Cultural tourism and cultural products Sections 10.6, 10.7 Socio-economic/financial Local procurement Sections 10.7, 10.5 Sub-contracting Sections 10.7, 10.5 Privatisation Sections 10.7, 10.5 Local economic opportunities Sections 10.7, 10.5 Business opportunities Sections 10.7, 10.5 Revenue Sections 10.7, 10.5, 10.9.3 Tenders and processes Section 10.9.3 Transboundary issues Immigrants Section 10.9.7 International boundaries Section 10.9.7 Cross-border Section 10.9.7 Border access Section 10.9.7 Education, awareness and interpretation Environmental awareness Sections 10.8.1, 10.7 Environmental education Sections 10.8.1, 10.7 interpretation Sections 10.8.1, 10.7, 10.6 Human wildlife conflict DCAs Section 10.9.10 Wildlife escaping Section 10.9.10 Fence breakages Section 10.9.10 Inadequate compensation Section 10.9.10 Agriculture: livestock and cropping livestock Sections 10.2, 10.8 Livestock farmers Sections 10.2, 10.8 Pride of livestock farmers Sections 10.2, 10.8 Burning of sugar cane (and air pollution) Sections 10.2, 10.8 Basic services (outside) Water Section 10.8.2 Dumping sites Section 10.8.2 Bridges (outside – linked to infrastructure) Section 10.8.2 Municipal services Infrastructure Roads Section 10.9.6 Fences Section 10.9.6 Accommodation Section 10.9.6 Staff accommodation Section 10.9.6 Bridges Section 10.9.6

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Relationships and communication Improve communication Sections 10.8, 10.9.9, 10.9.4 Transparency Sections 10.8, 10.9.9, 10.9.4 Two different levels of communication Sections 10.8, 10.9.9, 10.9.4 Lack of feedback Sections 10.8, 10.9.9, 10.9.4 Does not consider knowledge and skills from A Sections 10.8, 10.9.9, 10.9.4 and B bands Lesedi inadequate distribution Sections 10.8, 10.9.9, 10.9.4 Lack of communication between lower and Sections 10.8, 10.9.9, 10.9.4 snr/top management Poor relationships with communities Sections 10.8, 10.9.9, 10.9.4 Internal rules and regulations, law enforcement Speeding Section 10.9.7 Policies Section 10.9.7 Rules Section 10.9.7 Alcohol/drinking by staff in uniforms Section 10.9.7 Uniformed staff involved in poaching Section 10.9.7 Off-road driving Section 10.9.7 Noise Section 10.9.7 KNP branding Kudukop Section 10.5 world famous brand Section 10.5 Interpretation material Section 10.5 Technology Internet Sections 10.9.5, 10.9.6 Cell phone networks Sections 10.9.5, 10.9.6 Free wi-fi Sections 10.9.5, 10.9.6 Political instability strikes Sections 10.8, 10.7, 10.2, 10.9.7 Note: linked to basic services and poverty/employment protests Sections 10.8, 10.7, 10.2, 10.9.7 riots Sections 10.8, 10.7, 10.2, 10.9.7 Human well-being Health Section 10.9.4 Malaria, HIV Section 10.9.4 ambulance Section 10.9.4 paramedics Section 10.9.4 Life-guards at swimming pools Section 10.9.4

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Figure 9. Word cloud of main themes and related issues, as discussed during the Staff information sessions, Desired State phase (2017).

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Figure 10. Word cloud of the Vital attributes, as discussed during the Staff information sessions, Desired State phase (2017).

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ANNEXURE 3: DESIRED STATE WRITTEN INPUTS – June 2017

Stakeholders were given the opportunity to submit written inputs within a specified format, based on seven key questions. Stakeholders received written confirmation on receipt of the written inputs. The inputs were categorised according to the seven questions and were then considered during the development of the draft management plan and lower level plans.

24 written inputs were received, with 19 in the appropriate format. Another two statements were submitted during the Public meetings but did not comply with the requested format. These stakeholders were invited to submit inputs according to the requested format.

The following seven questions were asked:

1. Please indicate your specific interest in the KNP Management Plan review. 2. What were the key issues addressed through the current Management Plan (programmes) in which you have an interest. 3. What is changing in the KNP and surrounding area context, which you as a stakeholder believe we should consider in the management plan review. 4. What are the key vital attributes/key features (uniqueness) to be considered as part of the KNP Management Plan review (KNP and broader environment)? 5. What are the current perceived key drivers/challenges/gaps/threats that need to be considered in the KNP Management Plan? 6. What are the opportunities to be considered as part of the KNP Management Plan review? 7. What would you suggest that the KNP need to consider/ amend e.g. in terms of the focus, approach, actions, prioritisation etc. for the development of the KNP Management Plan/lower level plans?

A broad summary of the inputs is summarised according to the seven key questions:

Question 1: Please indicate your specific interest in the KNP Management Plan review.

Summary

Interest group/Stakeholder Issues Sections in the Plan where key issues raised have been considered Legislative requirements IUCN compliant Coordinated Policy framework, Section 3 SAHRA SAHRA compliance Section 10.6, Cultural Heritage programme Environmental journalist Biodiversity and ecosystem services Section 10.3, Biodiversity Management Programme Concerned stakeholder Individual Responsible tourism Hot Air Balloon industry Responsible Tourism addressed in Section 10.5, and in Appendix 3 Concerned group Expose illegal trapping Safety and security programme, Section 10.8 SA citizen National heritage Cultural Heritage programme, Section 10.6 Environmental lawyer Legal Regular customer Tourism Responsible Tourism addressed in Section 10.5, and in Appendix 3 Research Light pollution Addressed in Section 10.9.14 Regular visitor Concerned about commercialisation Responsible Tourism addressed in Section 10.5, and in Appendix 3.

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Wilderness addressed in Section 10.4 Research Cultural and history Sections 10.9.14, 10.6

The following issues were summarised (as stated in the table above), and were considered in the review of the Management Plan, and development of the low-level plans:

 Challenges to the integrity of conservation areas change with time. It is imperative upon SANParks, as mandated by the NEMA Act and IUCN norms and standards, to maintain the established values and ethos of the RSA’s flagship national Park, the Kruger National Park.  SAHRA- Cultural; Development of cultural lower level plan  Environmental journalist – interest in biodiversity and ecosystem management, broad consultation with society.  Sustainable Tourism – The introduction of Hot Air Balloon Safaris into the KNP. Following research on the different eco zones throughout the KNP, the best opportunity for flying hot-air balloons exists in the ‘Primitives Areas’ located to the East and North East of the Satara Camp.  EXPOSE ILLEGAL TRAPPING - SOUTH AFRICA.  I am a South African citizen who has a direct interest in the management of our national heritage  Environmental lawyer: I am a regular customer, I used to visit the Kruger National Park (hereinafter: KNP) about five times a year (on average). These days I visit it less frequent but visit other SANParks more often. I introduce many Dutch tourists to the KNP, as my network extends to many foreign visitors, particular the Dutch and Canadians. I arrange mainly non-profit tours to the KNP as part of my hobby (that is getting out of hand now and then). I try to arrange trip where one can experience the walks in the KNP such as the backpack trails, wilderness trails, combined with low cost accommodation such as the safari tents and camping.  Research - How the impacts of light pollution may alter the biodiversity conservation values, and aesthetic enjoyment, of the Kruger National Park. a. My specific interest the KNP Management Plan is the development/management envisaged for the Park and ensuring that the Bio-diversity, sense of place and ethos is not negatively affected and that the KNP not be transformed into just another holiday resort, exploited and abused through over utilization. b. Does the KNP still in all aspects meet the IUCN definition of a National Park?  I am a frequent visitor to the Park and hate to see the way the growing commercialization is bound to remove “The Wild Feeling” of the Park and the way that too many visitors to the south is ruining the experience.

1. What were the key issues addressed through the current Management Plan (programmes) in which you have an interest.

Key category More specific issues Sections in the Plan where key issues raised have been considered Wildlife management programmes Concern about fire management Section 10.3 Concern about larger herbivores Commercialisation Concern. Hotels, etc. Sections 6, 7, 9. Not complying with IUNC standards Light pollution Sections 10.9.1, 10.9.14 Cultural Heritage Management Section 10.6 Programme Stakeholder Relationship Sections 10.8, 10.9.9 Management Programme Civil and Building Management Section 10.9.6 Programme Commercialisation with Sections 10.4, 10.5 accompanying changes that affect biodiversity and the sense of place. Integrated biodiversity and cultural Section 10.6 heritage management Bio-diversity issues Water quality; managing water Sections 10.2, 10.3 availability for wildlife and people 179

(staff/visitors); climate change; invasive and alien vegetation; threat of animal diseases spreading; from surrounding areas.

Socio-economic issues and tourism Adequate resource/funding Sections 10.5, 10.7, 10.8 experience allocation from the State; traffic congestion; trade in wildlife; Trade in wildlife; Transfrontier Parks management; neighbouring community perceptions of the role of the KNP.

Broadening the scope of Eco – Tourism Products within the KNP. There is a more diverse range of guests visiting the KNP, who require unique ways in which to experience the KNP.

Do the Lower level plans form part of -Have the co-management Sections 8, Section 10.2 this KNP management Plan? agreements concerning the Provincial Nature Reserves, Rhino and Elephant issues – referred to on page 66 of the current Section 10.3, Section 3 KNP Management plan been (Coordinated Policy finalised? framework) -The recent turnabout by the Minister of EA regarding the trade of Rhino products and Elephants despite the CITES ban on these matters is very concerning.

Advise to Minister Who keeps the minister informed? Addressed in Section 5. SANParks as Management authority keeps in the minister informed via various intergovernmental and other platforms, and annually based on the Management Plan work plan.

The below issues were summarised as above, and were considered in the review of the Management Plan, and development of the low-level plans:

 I am not particularly au fait with the current MP and cannot address the question with specific reference to the current MP. I am, however, hugely concerned about: the current wildlife management programmes, in particular fire management and the monitoring and management of the larger herbivore populations (together with their impact on the environment, i.e. biodiversity). The commercialisation policy is also of intense concern, i.e. all but the accommodation of the rest camps is, or is intended to be, outsourced (re current situation and recently published proposals). The fear is that outsourcing of rest camp accommodation will follow suit, probably piece-meal, and eventually place the KNP out of reach for a vast segment of current South African visitors.  Hotels and other kinds of commercialisation that should not be allowed in a Park where the only reasons for visiting should be the atmosphere, peace, fauna and flora.  The 2008 KNP Management Plan expressly mentions the potential impact of light pollution on the Park, but only once; p.58 “impacts related to incompatible land use and developments that may impact on the ecosystem functioning and sense of place such as visible infrastructure, light pollution, diminishing of habitats and ecosystem services, fragmentation of migration routes…”.  However, it is unclear to what extent this concern has been addressed, or what management actions have been taken to alleviate light pollution, over the past decade.  Cultural Heritage Management Programme

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 Stakeholder Relationship Management Programme  Civil and Building Management Programme  Commercialisation with accompanying changes that affect biodiversity and the sense of place.  Integrated biodiversity and cultural heritage management  Cultural: welcome the development of site management plans  Commercialisation with accompanying changes that affect biodiversity and the sense of place.  Commercialization, Wildlife Management, Water Management, Staff Management as well as Stakeholder Engagement  Bio-diversity issues -Water quality; managing water availability for wildlife and people (staff/visitors); climate change; invasive and alien vegetation; threat of animal diseases spreading; from surrounding areas.  Socio-economic issues -Adequate resource/funding allocation from the State; traffic congestion; trade in wildlife; trade in wildlife; Transfrontier Parks management; neighbouring community perceptions of the role of the KNP.

 Broadening the scope of Eco – Tourism Products within the KNP. There is a more diverse range of guests visiting the KNP, who require unique ways in which to experience the KNP.

The demand for balloon flights over the KNP is becoming an increasingly sought-after activity, which is evident from the numerous enquiries we already receive for such flights. As the KNP is the largest National Park in SA, it contains the largest areas of wilderness, and carries with it the ultimate dream/romance of having a hot-air balloon drifting peacefully over it. As balloon safaris have become synonymous with the large wilderness area of Africa, where the balloon safari experience is a “must do” with tourists, it will in turn become a sought-after tourist activity in the KNP.

According to the Tourism Objective of the KNP, “The KNP’s unique selling point (wilderness according to the Roz Plan) is grossly under-exploited.” Kruger is currently looking at various ways to create awareness and “to promote a wider use of wilderness areas in the KNP, e.g. people must see walking in one of the wilderness areas almost like viewing the Big 5” (Wilderness Qualities Objective) to the public. As guided walking trails are the predominant way for the public to experience these wilderness areas, the Kruger is limiting itself to a small segment of the market place, the ‘outdoor adventurers’. There is a significant percentage of the market that is not being catered for and is not getting the chance to experience those “spiritual and experiential qualities associated with the concept of wilderness.” (Wilderness Qualities Objective). This portion of the market place, to name a few; the elderly, unfit, with medical conditions, those with a fear of exposure to the bush on foot, and those who would prefer a more exclusive, less strenuous experience of these areas, is being lost on that which is the Kruger’s unique selling point.

A hot-air balloon flight over a wilderness area can accommodate a much larger portion of the market. The spiritual and experiential qualities of the wilderness are easily captured from a balloon flight, as guests are given a vantage point to the vast miles of untouched bush in an activity that is using nothing other than natural elements. The pristine silence of floating over the bush in a balloon (other than the occasional heating of the balloon), offers guests an alternate way to experience these ‘spiritual and experiential qualities’ associated with wilderness. This is especially important for local tourists, as many will not get the opportunity to travel through Africa for this experience, but in the KNP, we have everything needed to offer this dream right on our doorsteps.

 Do the lower-level plans form part of this KNP Management Plan?  Many items were mentioned in the current Management Plan, but it is not clear whether they have been finalised: a. Have the co-management agreements concerning the Provincial Nature Reserves, referred to on page 66 of the current KNP Management plan been finalised? b. The recent turnabout by the Minister of EA regarding the trade of Rhino products and Elephants despite the CITES ban on these matters is very concerning.  The RSA Minister of EA has no conservation background or qualifications, yet she has the final say in the approval or rejection of conservation matters. a. Who advises the Minister of EA on Conservation matters? Is SANParks sufficiently involved in this process? b. Are the SANParks on-the-ground scientists and conservation staff taken sufficient notice of?

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2. What is changing in the KNP and surrounding area context, which you as a stakeholder believe we should consider in the management plan review.

Categories More specific issues Sections in the Plan where key issues raised have been considered Increasing land demands and Clearly defined policies and strategies Sections 3, 10.2, 10.8 population densities in terms of SANParks’ responsibility to be in place

Keep public informed/communication Sections 3, 10.2, 10.8 strategy to inform public continuously Guidelines included in the Sections 3, 10.2, 10.8 Management Plan to deal with the aforementioned issues (drivers external to KNP and/or Policy environment) Adjacent private reserves Co-operation and support? Sections 8, 10.2 Support in terms of rhino losses? Section 10.9.7 Concerns around Letaba ranch and Sections 8, 10.2, 10.9.7 loss of rhino Concern around hunting in adjacent Section 10.2.2 private reserves Meaningful liaison committee with Section 10.2.2 private reserves? Agreements with these private Section 10.2.2 reserves? KNP used as short-cut to Access control Sections 8, 10.2, 10.8.3 Mozambique Implication in terms of road use and Section 10.8.3, as above impact Shangoni Access control from Shangoni gate? Sections 10.7, 10.8.3, Sections 7& 9 Envisaged developments at Shangoni As above gate? Camps sites etc.? Consultants not being As above open/transparent Communal land incorporation Concern about hunting Sections 10.2.2 and 10.3.9 How can SANParks be in favour of Sections 10.2.2 and 10.3.9, trophy hunting and resource use Section 3. including Mopani worm? Please note that KNP does not allow hunting in National Parks. It is allowed in co-operative areas and contractual Parks, as per Agreements and Protocols. The MTPA and LEDET govern hunting in the co-operative conservation areas in accordance to the Agreements, Protocols and legal framework. Land claims Community levy of 1% - how much has Section 10.7. been used to support community projects? Sustainable resource use Protection of biodiversity should be the Section 10.3.9. Conservation primary mandate of biodiversity is the key outcome, and the sustainable resource use supports this as primary outcome. This

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includes education, awareness, monitoring and evaluation of the resource use through the adaptive management process. Resource use should be a secondary See above. focus Pollution Commented on expertise of Dr Riddell Thank you. Fine for Phalaborwa pollution paid? Yes, and secured in fund to support water outcomes programmes. Cause of pansteatitis? It is believed to be a combination up factors, and full scientific reports can be requested from Scientific Services. Light pollution Skukuza Hotel development Sections 10.6, 10.9.1, 10.9.14 Mitigation in general Sections 10.6, 10.9.1, 10.9.14 Include this in MP Sections 10.6, 10.9.1, 10.9.14 Camping Low cost camping to be provided Section 10.6 Keep it as is Section 10.6 Public information More accessible Section 10.8, 10.9.9 Decision-making processes Make available Addressed in Sections 10.8.2, Sections 3 and 5. KNP will provide annual feedback on the Management Plan implementation through a range of platforms. Policies, guidelines and procedures? Addressed in Section 3 and reviewed continuously in line with legal framework. Policies, procedures, SOPs and guidelines as being reviewed and/or developed for all programmes. Commercial and management To inform management? Section 10.6 sub-committee Criteria development for commercial Section 10.6 and management issues Support to existing “supporters” not felt Addressed in Section 10.8. KNP will provide annual feedback on the Management Plan implementation through a range of platforms. Outsourcing Sounds fine on paper, but concern in Section 10.6 practice New roads No for access to Taxis, transboundary, Section 10.6 – Visitor new areas Management; 10.8.3- Promoting Access. Transboundary issues addressed in Sections 2, 8, 10.2, as informed by the Vital attributes, determinants and threats. Visitor numbers/Congestion Congestion Section 10.6 Too many people Road kills Traffic concerns Buses and OSVs contribute to problem Delivery vehicles a concern

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Congestion at Big 4- education problem Tourism behaviour Education process, to be reinforced at Section 10.6, Interpretation, gates and in Section 10.8.1. Start Big 5 campaigns As above. Addressed in Section 10.9.9 as well. Litter Education problem As above Music Music a no Addressed as per KNP internal rules. Cultural (SAHRA’s inputs) Plans for increased visitor numbers of Sections 10.6, 10.9.7 north: requires mitigation plan for poaching of cultural heritage sites Meat distribution / food parcels Negative incentive Section 10.3.9 to adjacent communities Will increase entitlement As above Decision-making not well enough As above informed Wrong message to communities, As above entitlement, generations to come will expect this Socio-economic issues Burden too much on KNP to deal with Sections 2, 10.8, 10.2.1, 7 external population issues Government place too much pressure As above on KNP KNP to focus only on mandate As above Biodiversity Water quality concerns Sections 10.2.3, 10.3.4 Climate change concerns Sections 10.2.1, 10.9.13 Ground water quality concerns Sections 10.2.3, 10.3.4 Trade in wildlife inside and Reconsider – major concern Sections 10.2.2 and 10.3.9, adjacent to KNP, and Hunting Section 3. neighbouring areas Please note that KNP does not allow hunting in National Parks. It is allowed in co-operative areas and contractual Parks, as per Agreements and Protocols. The MTPA and LEDET governs hunting in the co-operative conservation areas in accordance to the Agreements, Protocols and legal framework. Selling of rhino Sends wrong message Guided by Policy framework, and addressed through the Rhino strategy, Communications programme and legislative framework. Refer to Sections 3, Section 10.3 Transfrontier areas Regulations in Place? Section 10.2 MoUs in place? Section 10.2 Guidelines and Protocols in place? Section 10.2 Hospitality and tourism related Poor management of e.g. picnic sites, Section 10.6 rest rooms as result of increasing tourist numbers, e.g. nappies, litter Too high tourism numbers and Section 10.6 concerns around visitor management Broader scope of eco-tourism, e.g. Section 10.6 hot-air balloons Increase in crime/poaching/ Section 10.9.7 danger to staff and public

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The following issues were summarised (as in the table above), and were considered in the review of the Management Plan, and development of the low-level plans:

 It is readily accepted that new challenges, with respect to ever-increasing land demands and increasing densities of neighbouring communities, will intensify. Clearly defined policies and strategies regarding aspects mentioned under 2 and to which SANParks can be held responsible are therefore of utmost importance. Other than policies of local or immediate concern, the KNP needs to up its public information/communication strategies and clear guidelines on these should be included in the MP.  It was very concerning that the media reported the discovery of 17 buried Rhino carcasses in the Letaba Ranch, Private Nature Reserve, how is this possible, are the PNR owners really playing open cards and are they acting in the spirit of good conservation? This needs to be addressed as a matter of urgency.  Do SANParks have satisfactory input in the Management of the adjoining KNP, Private Nature Reserves? i. E.g. hunting in private nature reserves, recently permits were made available for the hunting of a trophy Elephant bull, after public outcry, this was withdrawn. A permit was also issued for the hunt of a White Rhino; information is that this hunt had already taken place. ii. Is there a meaningful liaison committee between KNP and the owners of the PNRs, if so how often do they meet, are these meetings to the satisfaction of SANParks, if not should SANParks have a review of the agreements?  The KNP is on an increasingly way being used as a shortcut to and from Mozambique. iii. In spite of the SANParks website stipulating that travellers using the border entrance gates are required to overnight in the Park. This rule is not enforced. iv. The new Shangoni gate will be linked by a tar road of 50.6 km with the H1-6 main road between Letaba and Shingwedzi rest camps on enquiry I was told that it would be for the use of KNP visitors the Shangoni development is for 20 camping sites and 20 tents. v. Surely something more is envisaged for the future. No mention is made of traffic to and from Mozambique. The appointed consultants did not consider a tar road necessitating a traffic impact assessment. The reason given was that the vertebrate assessors indicated the impact as being of lesser significance; this is the assessor’s untested opinion, despite the fact that the specialist was not a qualified traffic assessor.  Appointed consultants seem to be under the impression that they are in charge and their decisions are final. The appointed consultants create the impression that I&APs are just a nuisance. vi. I had to contact the SANParks CEO and the KNP Management Executive to have a meeting in Gauteng as the appointed consultant refused such meeting. He told us that he applied the minimum requirement rule. vii. Hopefully this is not the SANParks policy, I suggest that this matter be addressed, and this attitude be change with immediate effect. viii. Of the appointed consultants do not act objectively; the above is a typical example of what I have stated. ix. Of the appointed consultants may have the theoretical qualifications but due diligence by the appointers will find that lack of good judgement is evident.  Communal Land Incorporation. -Page 68 It is envisaged that sustainable resource use within these areas will be conducted under controlled conditions that will be captured in the agreements with these areas. Significant income can be generated from trophy hunting while utilisation of renewable resources such as meat, mopane worms and thatch will be able to be sourced at sustainable levels, thus allowing the communities access to food sources as well as to earn an income (e.g. from trophy hunting, ecotourism ventures, etc.). - SANParks can surely not be in favour of trophy hunting of their game animals that have migrated to adjoining areas.  Land claims. -Page 73 SANParks propose to phase in a community levy to be charged to each visitor to the KNP. This initiative is intended to generate goodwill community levies, which will be transferred directly to a trust fund to be established for this purpose. The trust fund will be independently managed and will have the task of ensuring that funds are distributed to legacy projects, directly benefiting legitimate land claimants in KNP.

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-The 1% levy has now been in operation for many years, how much money is in trust, and how much of this has been made available to the communities and for what use, reasonable details?  Sustainable Use – Statement of Intent page 79. -SANParks recognise that it has been established to protect and conserve areas of biological diversity. -This is its primary mandate and all other activities must be regulated by and treated as secondary to this goal.  Pollution. -It is commendable that SANParks have a section under the leadership of Dr Eddie Riddell, monitoring the state of the rivers daily. -Slurry from an industrial institution in Phalaborwa polluted the water flowing into the KNP, the offenders were charged and fined, have these fines been paid, my information is that about 18 months ago they were not. -The death of Crocodiles due to Pansteatitis, has the source of the pollution been established and have the offenders been charged?  Light pollution is tied to human development, particularly that of electrical grid infrastructure expansion. Human development is increasing in both cities and rural areas outside of the borders of the Park, with a concomitant increase in lighting use. Skyglow (the diffusion of light pollution through the atmosphere) is particularly pronounced in the Southern Areas of the Park and can now be seen with the naked eye at night. Its biological impacts are unknown, but does compromise the atheistic enjoyment of the Park (lights and skyglow is visible on the borders, and skyglow pollution hinders the visibility of stars and celestial objects). Furthermore, little attention has been historically given to light pollution when developing Park infrastructure such as the rest camps, or to new developments such as the Skukuza hotel.  Low cost accommodation  Keep the camping option the way it is  Public information  Decision-making procedures  Commercial and management sub-committee  Criteria development for commercial and management issues  There are several growing ills within KNP which have not been successfully addressed or resolved, and it feels reckless to be expanding on, in particular, the commercialization drive, when those ills not only still exist, but are escalating. Surely start by addressing the existing problems, ensure that workable mechanisms are put in place to resolve them…before embarking on new initiatives? It would certainly go a long way towards assuaging the fears held – and voiced – by so many die-hard, passionate visitors/stakeholders. We, the ‘die-hard’s’ are often dismissed as the ‘old guard’ and considered of little importance to the brave new world…but I think that’s a massive mistake, because there’s an enormous amount of knowledge, skill and goodwill in that older band of Krugerites…and it should be harnessed.  On paper, one must assume that outsourcing as a practice is more lucrative, otherwise it would make no sense – in reality, the practice seems to be one large headache for the visitors and SANParks.  New roads – when these are being built to provide access for taxis, or as thoroughfares to other countries/areas, this is a huge NO. There is almost no foolproof way of policing this, and it will drive visitors away from that area.  Numbers of people. I don’t know what the ultimate ceiling is on cars/people, I just know I now only go to the middle and northern parts of the Park to escape what has become unpleasant crowding, not only of my space…but of the animals too. Where/how will that pressure end? I suspect not well, and judging by the road rage incidents which are reported daily on social media, it’s only a matter of time before something tragic occurs.  Tourist behaviour - this needs an education program AND a more committed desk/entrance gate staff who must reiterate key elements of the rules, in particular about alighting from or hanging out of vehicles, speed, litter, the danger of elephants, and how to behave at a sighting (nobody reads the booking form, and it won’t matter how many times they’re told to) - there must be effective punitive action taken by law breakers, such as banishment from the Park for a year etc., with little leave to appeal. SUGGESTION: Start a THE OTHER BIG FIVE campaign, a sticker for your car at the gate – and those would be the five things you cannot do in the Park, along the lines of…litter, speed, get out your car or have any part of your body protruding, drive close to elephants, be inconsiderate to other visitors.  Increase in traffic which seems largely uncontrolled, bad behaviour at sightings, speeding, seldom- seen policing of speed and behaviour of heavy vehicles. This is not only heart-breaking for those

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witnessing road kills, dangerous for others on the road, but it’s reminiscent of being in town/cities – a key reason we come to Kruger, is to get away from that. The idea of traffic jams, dangerous driving and speed in Kruger is a complete contradiction of why people come to KNP.  Litter – a combination of total disregard for, or lack of understanding of, the concept of why littering is unacceptable, to a shortage of restroom facilities through the Park. Education is critical here, but so too is punitive action. A few discreetly positioned rest-room facilities like those at Muzandzeni or Tshanga would be enormously welcome.  Noise – There must be a zero-tolerance policy of NO music/noise anywhere – and that includes the restaurants, loud ‘parties’ at picnic sites/campgrounds, pumping music from cars etc. If everybody knew that music/noise is a no-no, they would either choose KNP…or go elsewhere.  SANParks’ belief that handing over meat is a humane way to assist a community, is strange when it’s widely known that it is not sustainable as a practice, there’s no ‘growth’ in knowledge or skills for the people, and it will lead to a sense of entitlement AND sadly, in time, undoubtedly, some level of corruption.  Plans for increased visitor numbers of north: requires mitigation plan for poaching of cultural heritage sites  Tourist traffic congestion is an increasingly significant issue, particularly in the southern section of the KNP. Open safari vehicles and busses contribute to this issue and it might be considered worthwhile to open a limited number of game management roads in congested areas for their monitored use. This would ease some traffic pressure on main roads used by self-drive tourists, but due consideration would need to be given to ensure this in no way interferes in wilderness areas. Alternatively, some game management roads could be opened for the use of all visitors and this too could spread the traffic load.  Another traffic issue concerns delivery vehicles, construction vehicles and those driven by various contractors employed to do a variety of jobs in the Park. Although some education work has been undertaken, there is an urgent need to help all drivers become aware of the needs of those viewing game or simply enjoying the bush. Speeding also needs to be addressed further.  Traffic congestion at sightings of the “Big Five” is another issue of concern and visitors, including drivers of busses and open safari vehicles, need to be further encouraged/educated to display courtesy to others. There is also a need to try and dilute crowds at sightings by focused information programmes that help explain that “Big 5” sightings are only small component of what a visit to the KNP has to offer.  Socio-economic issues Similarly, it appears that the national government is creating an unrealistic expectation that the KNP can solve many of the socio-economic problems in areas that border the Park. The KNP can certainly contribute to solutions but cannot be expected to do this on its own and socio-economic upliftment should be the job of national, provincial and municipal governments.

Rapidly growing human populations across the globe are placing increasing pressure on all protected areas and the situation in the KNP is no different. The long-term effects of rapid population growth need to be understood, a task which must include all sectors of government and civil society. Again, the KNP cannot be expected to deal with these challenges alone. Managers at KNP have a duty towards protecting and promoting biodiversity and this should be their primary task.  Bio-diversity issues -Climate change poses many threats but the KNP does not exist in isolation from the rest of South Africa, Mozambique or Zimbabwe and cannot be expected to deal with this issue on its own. Government officials need to be continually reminded that it requires a joint effort to create programmes that mitigate against the effects of climate change and the KNP cannot achieve this without broad support. -Water quality is a key issue. All the major rivers that enter the KNP from the west are key to its survival and significant education programmes, law enforcement and water catchment protection are needed to try and improve water quality in the region. This is also an international issue because all major rivers flowing through the KNP are critical sources of water in Mozambique.

-The quality of groundwater is also critical to both wildlife and visitors to the Park.

-Countering the effects of climate change, removing alien vegetation, improving water quality, environmental education and many of the issues mentioned elsewhere all require funding and government must be lobbied to rethink its funding model for national and provincial Parks. More state funding is essential if South Africa’s protected areas are to survive.

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-Trade in wildlife, both legal and illegal, and hunting in areas which share unfenced boundaries with the KNP needs to be reconsidered. Protected areas should not be expected to sell wildlife to raise funds. This should be provided from the national budget.

- Selling rhinos sends the wrong message that the value of a wild animal rests in the animals’ monetary value rather than its intrinsic worth. The same argument applies to trophy hunting in the APNR and provincial reserves which share unfenced boundaries with the KNP. Hunting implies that the value of an animal is best assessed in economic terms. It also suggests that while it is acceptable for a rich person who can afford to pay for a permit to kill an animal for entertainment it is not acceptable for a poor person to kill an animal to feed a family.

 Transfrontier Park. The development of Transfrontier conservation areas and efforts to counter poaching often suffer because of a lack of ability to hold all international stakeholders accountable to the same set of standards. Greater political efforts are required at an international level (Mozambique, for example, until recently had no legislation designed to counter wildlife poaching. This issue should have been vigorously challenged earlier through international diplomacy). International environmental MOU’s are ineffectual if a list of basic criteria cannot be met.  Tourist behaviour generally- this needs an education program.  Increasing tourist numbers. How to deal with the resulting increase in congestion, rubbish, harassment of animals etc. all placing a heavier footprint on the Park. What is your ceiling in terms of numbers? Is it going to be controlled by the above, or will the determinant be financial?  Unpleasant litter problems such as nappies, toilet paper etc.; often due to lack of restroom facilities – this need an education program and maybe the building of a few discreetly positioned rest-room facilities like those at Muzandzeni or Tshanga.  Increase in traffic which is currently mainly uncontrolled; behaviour of heavy vehicles (because of their weight, stopping distance much longer, yet they are permitted to go 65kph?)  Increasing numbers living around the western and southern borders of the Park and accompanying hostility to the Park. Birth control programs and education programs to improve schooling and improve perceptions of the value of the Park. Job opportunities. (I know a lot is already put into this area). Programs to convey importance of not polluting water.  SANParks belief that giving food parcels is not going to lead to a culture of increasing entitlement in that respect. This will lead to increasing expectations and increasing demos if these expectations are not met. You may be educating an entire generation to believe that SANParks is the sole provider in this area –rather supply materials that enable people to make a living/grow food themselves. Training programs to help entrepreneurs, etc. There is a lot of potential in well-run picnic sites outside the peripheral camps of the Park. Entrance fees could be charged, craft outlets, cultural displays etc.  Increase in crime/poaching/ danger to staff and public  Broadening the scope of Eco – Tourism Products within the KNP. There is a more diverse range of guests visiting the KNP, who require unique ways in which to experience the KNP.  The demand for balloon flights over the KNP is becoming an increasingly sought-after activity, which is evident from the numerous enquiries we already receive for such flights. As the KNP is the largest National Park in SA, it contains the largest areas of wilderness, and carries with it the ultimate dream/romance of having a hot-air balloon drifting peacefully over it. As balloon safaris have become synonymous with the large wilderness area of Africa, where the balloon safari experience is a “must do” with tourists, it will in turn become a sought-after tourist activity in the KNP.

- According to the Tourism Objective of the KNP, “The KNP’s unique selling point (wilderness according to the Roz Plan) is grossly under-exploited.” Kruger is currently looking at several ways to create awareness and “to promote a wider use of wilderness areas in the KNP, e.g. people must see walking in one of the wilderness areas almost like viewing the Big 5” (Wilderness Qualities Objective) to the public. As guided walking trails are the predominant way for the public to experience these wilderness areas, the Kruger is limiting itself to a small segment of the market place, the ‘outdoor adventurers’. There is a significant percentage of the market that is not being catered for and is not getting the chance to experience those “spiritual and experiential qualities associated with the concept of wilderness.” (Wilderness Qualities Objective). This portion of the market place, to name a few; the elderly, unfit, with medical conditions, those with a fear of exposure to the bush on foot, and those who would prefer a more exclusive, less strenuous experience of these areas, is being lost on that which is the Kruger’s unique selling point.

-A Hot Air Balloon flight over a wilderness area is able to accommodate a much larger portion of the market. The spiritual and experiential qualities of the wilderness are easily captured from a balloon flight, as guests are given a vantage point to the vast miles of untouched bush in an activity that is using nothing

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other than natural elements. The pristine silence of floating over the bush in a balloon (other than the occasional heating of the balloon), offers guests an alternate way to experience these ‘spiritual and experiential qualities’ associated with wilderness. This is especially important for local tourists, as many will not get the opportunity to travel through Africa for this experience, but in the KNP, we have everything needed to offer this dream right on our doorsteps.

3. What are the key vital attributes/key features (uniqueness) to be considered as part of the KNP Management Plan review (KNP and broader environment)?

Categories More specific issues Sections in the Plan where key issues raised have been considered Meeting IUCN standards national Park status of the KNP by Addressed in Section 3. KNP is IUCN standard managed within the Protected area legislative framework and associated Norms and Standards. Unique visitor experience The facilities on offer should never Section 10.6 be the main draw card; foreigners come to the KNP for an African experience. KNP to maintain ethos, sense of Sense of place Section 10.6, Section 10.4, place, character, features Place to breath Section 9 Unique character Quietness Size of Park Spiritual Railways not going transboundary – keep it like this Simplicity of camping geology Cultural heritage programme Section 10.6 Stakeholder relationship Section 10.8 management programme Light pollution Sections 10.9.1, 10.9.14 Institutional framework Decision-making to keep to Sections 3, 5. programme mandate The staff component wonderful Thank you. See Section 10.9.4 Riverine system Unique and important Sections 10.2.3 and 10.3 Like-minded community Share love of nature Noted Non-threatening, non-pressured Noted. Part of adaptive opportunity for learning management process. Wilderness trails Unique Section 10.4 Traffic congestion Visitor management a concern Section 10.6, 10.9.7 Traffic a concern Transboundary thoroughfare Access and regulation a concern Sections 10.9.7, 10.2 Culling issues a concern Section 10.3.9 Socio-economic As mentioned in 3 Sections 10.7, 10.8 and 10.2 – Co-operative partnerships. Wildlife trade and hunting As mentioned in 3 As mentioned in 3 Biodiversity concerns As mentioned in 3 Section 10.3 Climate change As above Alien invasive species Water management

The following issues were summarised (as in the table above), and were considered in the review of the Management plan, and development of the low-level plans:

 Probably most of the aspects mentioned in 2 and 3, but also the continued maintenance of the national Park status of the KNP by IUCN standards. 189

 Exactly that, the uniqueness, which has started to change. Why has SANParks not asked for KNP to become an UNESCO International Heritage Site?  The Kruger National Park is a Conservation Area and should be treated and respected as such. The ethos of this National Park, which is a worldwide icon, needs to be retained. Persons visiting the KNP should visit it as such, the major draw card needs to remain as a refuge away from the rat race, where peace, tranquillity can be enjoyed, and healing can take place.  The facilities on offer should never be the main draw card; foreigners come to the KNP for an African experience.  Kruger reduces light pollution because it is large and relatively free of major infrastructure. It is key to understand how light pollution has changed over the past decades, what the potential impacts are on both biodiversity and tourism, and to explore and implement ways to stop it.  Cultural Heritage Management Programme  Stakeholder Relationship Management Programme  Civil and Building Management Programme  Institutional Framework Programme: The KNP Management plan should improve on the institutional aspects, as it seems to lack a clear institutional framework within SANParks. Only the powers of the Board are mentioned in the NEMA 57 of 2003. The management plan seems to miss a clear institutional framework when it comes to decision-making power. If allowed to continue there is a significant risk that interest groups might start litigation against SANParks as they will start disputing the legitimacy of decision-making. Therefore, the issue of institutional powers should be considered.  Kruger represents and offers everything which the world outside it doesn’t:  Space to breathe  Quiet other than natural sounds  Like-minded people/community - tolerant of each other because of a shared love of nature  A non-pressured, non-threatening opportunity to learn – whether it’s about birds, trees etc.  First and foremost, KNP is a nature reserve and fauna and flora MUST be given number one priority, NOT visitors and staff.  Visitors are paying good money to have the privilege of visiting and making use of the facilities. KNP Management must ensure that these facilities are looked after properly and that the staff employed to do the work must do the work. The staff must be given strong signals from management that there are rules to abide to in this unique working environment and any infringement will have consequences – it is a privilege to work in the KNP NOT a right.  KNP Management must also be more transparent (both with the public and local communities) with how the conservation fees are being spent/distributed.  Include paleontological plans in cultural plans  Tourism guides and rangers to be trained in such fossil and cultural heritage plans/history  The KNP boasts many special features which need to be nurtured and preserved. These include:  An increase in the number of backpacking trails and day trails. There are many areas where more trails can be undertaken. These trails provide tourists an experience seldom forgotten and can, or should, act as a powerful public relations tool explain the intrinsic value of wild places.  Self-driving, despite the congestion issues mentioned above, remains one the most important components of many people’s visits to the KNP. The “traditions“ of self-driving have developed over many years and should be retained.  The size of KNP and its dramatic range of biodiversity is an irreplaceable asset. The KNP should be further promoted as a unique “window” on the natural environment of the region, an example of the “seed bank” of the Lowveld.  Only two public roads and no rail lines cross the KNP into other countries. This situation should be preserved as a special feature.  The size of the Park, particularly the size of the undeveloped areas, makes it unique.  The geological strata running lengthways, contributing to different soils, thus different plant groupings, thus different animal groupings, plus the differences in the topography and the N to S climatic differences – the sheer variety that this combination gives is unique.  The sense of place engendered by all of the above and combined with the spiritual aspect of being in wild places.  The simplicity of the camps. The lack of luxury trimmings. The lack of organized activities. You go into a camp, you get your place and you do your thing. Fabulous.  The staff. A very important and wonderful resource.  The riverine system. The West to East pattern all the way down the Park.  The sheer size of KNP and its dramatic range of biodiversity is an irreplaceable asset. The KNP should be further promoted as a unique “window” on the natural environment of the region.

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Additionally, and in international terms, it represents a ‘seed bank’ of all biodiversity. South Africa, as a signatory to the United Nations and specifically to the three “Rio conventions”; UNFCCC, UNCCD and CBD, has an obligation to comply and adhere to their determinations. The world and civilization need to conserve nature and natural areas. We as humans are unlikely to survive long without them.  Wilderness trails: backpacking; trails camps and day trails. These are special offerings of KNP. Their ability to affect a change in peoples’ appreciation of wild areas and nature is immense. More offerings in this arena should be promoted as a powerful public relations tool in explaining the intrinsic value of wild places.  Self-driving: despite the congestion issues mentioned above, remains one the most important and valuable components of many people’s visits to the KNP. The “tradition“ of self-driving has developed over many years and should be retained.  Lack of public thoroughfare: Only two roads (and no rail lines) provide limited access across the KNP into other countries. There is a growing worldwide imperative to build pipelines or public roads/train lines through Conservation/protected areas. Please resist/prohibit this.  Traffic congestion: This is becoming a serious issue and is already often distracting from the tourist experience, particularly in the southern section of the KNP. Open safari vehicles and busses contribute to this issue and it might be considered worthwhile to open a limited number of game management roads/new roads in congested areas for their exclusive use and prohibit them from existing main roads. A challenge I know, when considering game viewing along the banks of the major rivers.  Another traffic issue concerns delivery vehicles, construction vehicles and those driven by various contractors employed to do a variety of jobs in the Park. I have witnessed delivery trucks screaming through a buffalo sighting at way more than the speed limit. Perhaps tachometers or speed limiters installed in the vehicles could help monitor and police these.  Congestion at sightings of the “Big Five” is another issue of concern and visitors, including drivers of busses and open safari vehicles, need to be further encouraged/educated to display courtesy to others. The advent of cellular data and ‘sightings apps’ is also of major concern. Perhaps cell phone reception/internet data could be restricted to camps?  Climate change: This possibly poses the single largest threat to the KNP. It is clear to the average observer (let alone the overwhelming science) that our climate is changing, or at least more variable. This is already resulting in the increased frequency of extreme events, from floods to droughts, increased or decreased ‘shoulder’ seasons, effect on vegetation and animal lives and reproduction, diseases and invasive aliens. Whilst the KNP alone cannot make any meaningful impact on CO2 mitigation (in global terms), it is going to have to develop strategies to adapt to the effects of climate change, for example both in water quantity and quality, both for human and animal consumption, and one can go on. The effects on biodiversity too could be massive.  Invasive alien Plants: This is becoming an ever-increasing problem. From the DEA’s web site… “Invasive alien plants (IAPs) pose a direct threat not only to South Africa’s biological diversity, but also to water security, the ecological functioning of natural systems and the productive use of land. They intensify the impact of fires and floods and increase soil erosion. IAPs can divert enormous amounts of water from more productive uses and invasive aquatic plants, such as the water hyacinth, effect agriculture, fisheries, transport, recreation and water supply.” Dealing with invasive aliens requires not only work inside the Park but working in conjunction with others outside to try and prevent the ongoing introduction into the Park.  • Socio-economic problems: it appears that the national government is creating an unrealistic expectation that the KNP can solve many of the socio-economic problems in areas that border the Park. The KNP can certainly contribute to solutions but cannot be expected to do this on its own and socio-economic upliftment should be the job of national, provincial and municipal governments.  Rapidly growing human populations across the globe are placing increasing pressure on all protected areas and the situation in the KNP is no different. The long-term effects of rapid population growth need to be understood, a task that must include all sectors of government and civil society. Again, the KNP cannot be expected to deal with these challenges alone. Managers at KNP have a duty towards protecting and promoting biodiversity and this should be their primary task.  Water quality and quantity: is a key issue. All the major rivers that enter the KNP from the west are key to its survival and significant education programmes, law enforcement and water catchment protection are needed to try to improve water quality in the region. This is also an international issue because all major rivers flowing through the KNP are critical sources of water in Mozambique.  The quality of groundwater is also critical to both wildlife and visitors to the Park. If ground water is polluted, it becomes an extremely expensive resource. Countering the effects of climate change, removing alien vegetation, improving water quality, environmental education and many of the issues mentioned elsewhere all require funding and government must be lobbied to rethink its funding model

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for national and provincial Parks. More state funding is essential if South Africa’s protected areas are to survive intact.  Wildlife trade: both legal and illegal, and hunting in areas which share unfenced boundaries with the KNP needs to be reconsidered. Protected areas should not be expected to sell wildlife to raise funds. This should be provided from the national budget. Selling rhinos sends the wrong message that the value of a wild animal rests in the animals’ monetary value rather than its intrinsic worth. The same argument applies to trophy hunting in the APNR and provincial reserves, which share unfenced boundaries with the KNP. Hunting implies that the value of an animal is best assessed in economic terms. It also suggests that while it is acceptable for a rich person who can afford to pay for a permit to kill an animal for entertainment it is not acceptable for a poor person to kill an animal to feed a family. The hunting of threatened species for profit, such as rhino, and yes elephant, lions, leopards and others, just sends the wrong message and often the legal ‘trade’ just opens the door for the illegal trade.  Culling is a different issue altogether.  Transfrontier Parks: The development of Transfrontier conservation areas and efforts to counter poaching often suffer because of a lack of ability to hold all international stakeholders accountable to the same set of standards. Greater political efforts are required at an international level (Mozambique, for example, until recently had no legislation designed to counter wildlife poaching. This issue should have been vigorously challenged earlier through international diplomacy). International environmental MOU’s are ineffectual if a list of basic criteria cannot be met.  The KNP is world famous National Park, but it is the ways in which a visitor can experience the Park, which is what keeps visitors coming back and entices new visitors to visit the Park. A key factor in this is Eco-Tourism Products.  It is a known fact that many foreign tourists visiting Africa use South Africa only as a transit airport, before travelling to various other African countries for their African safari. Currently tourists wanting to experience a balloon safari in a world-renowned wilderness area must travel to neighbouring countries or East Africa. The offering of a Balloon Safari in the KNP will not only fill a gap in the South African tourism market but should also be a deciding factor for foreign tourists to extend their itineraries and spend a few more days in South Africa to experience this unique tourism product in the KNP.

4. What are the current perceived key drivers/challenges/gaps/threats that need to be considered in the KNP Management Plan?

Categories More specific issues Sections in the Plan where key issues raised have been considered Complying with IUCN standards as See earlier comment National Park Core mandate Should remain conservation See earlier comment. Conservation is the core mandate, as captured in the SANParks Vision, KNP Mission and implementation programmes. However, KNP is embedded in broader socio-ecological continuum of different land uses, and management therefore follows a holistic and integrated approach Poaching Trials not concluded/taking too long Sections 10.9.7, 10.9./4 Polygraphs Various issues Development pressures/concerns Concerns around peripheral Section 10.2.1 developments of property developers and life-style areas Concerns about commercialisation Sections 9,10.6 internal in KNP CDF/zonation Good on paper, but Board overrules, Sections 3, Section 7. Any e.g. with development changes are subject approval by the Minister,

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guided by the legal framework and clear principles. Also refer to Section 9 EIAs Need to be compliant to support As above development Is KNP meeting this? DEA very As above lenient? Regain the trust of its supporters. Section 10.8. Should now rely much less on Comment noted. outsiders and do more in house. Should illustrate more to the public The entire consultation that they support Conservation tourism, deriving the Values, show less emphasis on tourism. Mission and Lower Level Plans demonstrated transparent consultation. Management focus will be in line with this, the mandate of SANParks, the reasons for which KNP was declared, and in line with the adaptive management framework to be responsive to emerging issues (see Vital attributes, determinants, threats) Tourism: tourism carrying Section 10.6 capacity/potential and unambiguously declare what it is after putting it to public debate. Relationships: should now realise Section 10.8 that their clients who register as stakeholders or I&APs are not part of the enemy, they are their greatest supporters and should be treated as such. Grow the PP process and consider Section 10.6 a liaison group. Distribute Cultural Lower level plans Thank you. Will liaise to SAHRA closely with SAHRA. See section 10.6 Include the above in the CDF Considered. Communication - Stakeholder Supported. See section 10.8 report given back to stakeholders of and earlier comment. challenges and achievements – Annual feedback will be more constant feedback given to stakeholders, and communication on a continuous basis through a range of platforms. Commercialisation and privatization Numerous concerns around camp Section 10.6 sites and trails groups – block bookings, outsourcing etc Biodiversity issues and welfare of As previous See previous comments animals Transboundary concerns See previous comments Socio-economic As previous See previous comments Commercialisation As previous See previous comments Too many people Visitor management Human capital-staff Behind the scene staff not properly Section 10.6. This will form informed in terms of tourism part of the key performance management/hospitality areas of all staff when

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signing the annual performance contracts. Decision-making processes Follow up on previous records, See previous comments implementation, transparency, policy guidelines Light pollution See previous comments Public information and feedback Not sufficient See previous comments

The below issues were summarised as above, and were considered in the review of the Management Plan, and development of the low-level plans:

 Probably most of the aspects mentioned in 2 and 3, but also the continued maintenance of the national Park status of the KNP by IUCN standards.  The conservation should be the key feature and the refurbishment of the existing accommodations should make the building of lodges superfluous.  Poaching, what is SANParks/DEA doing to bring arrested poachers to book much sooner? - There are cases dating back to 2010 which are still not heard. Many of SANParks personnel have been involved in poaching activities, most of these offenders are still ‘untrialled’ out on bail and most probably also still up to their old tricks. - Poaching is of course not limited to SANParks personnel, members of the Shishangane and Lukimbi Concessions were arrested for being involved in Rhino poaching activities. - Outside institutions/partners need to be limited as SANParks have no control over their personnel. - I am aware that polygraph testing is carried out mainly on more senior managers.  I suggest that polygraph testing becomes part of the routine and that all persons employed in our National Parks be tested at least on a three yearly rotational system. Trade Unions may not like this but so be it.  Developmental threats page 55 of current Management Plan states: A. It has become very fashionable to have a holiday or retirement residence in a natural area or as close as possible to such an area. Property developers have identified this need and are actively pursuing this along the boundaries of the KNP, especially where a river forms the boundary between the KNP and other areas. This has put considerable strain on the biodiversity conservation objectives of the KNP in the sense that river corridors are being impacted on, and future bioregional plans are seriously negatively influenced. Additional capacity to deal with this issue is urgently needed, especially to engage local municipalities in the development of their IDPs, and to integrate these into the KNP Conservation Development Framework (see also sections 2.1.1 and 2.1.3). a. SANParks have now embarked on similar developments inside the KNP, 1000 new beds are planned for being added: i. Malelane tent camp 240 beds. ii. Skukuza hotel 220 beds. iii. Phalaborwa activities hub: Lodge & mobile tented safari camp 40, after gate closing hours access. iv. Nkuhlu 30. v. Letaba Riverside lodge 50. vi. Phalaborwa peripheral lodge 100, after gate closing hours access. vii. Tshokwane tent camp 30. viii. Shangoni cultural camp, 30 beds, after gate closing hours access. ix. Mobile safari tents 100 + 100 = 200. x. Pafuri tents, 100 beds. xi. Treetop camps 15 + 15 = 30. xii. WHY? b. SANParks cannot state that the developments outside the KNP are a threat and then do the same within the borders of the KNP, surely the threat of developments outside the KNP are then also a threat inside the KNP. c. SANParks can also not allow access to of these planned developments after gate closing hours. Persons who want to make use of these facilities, should make their arrangements such that they arrive in time. Same as what I have now been doing since September 1967 for my 132 visits to the KNP.

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B. Most of these plans are for private ownership, I suggest that should SANParks implement these plans they should manage these developments themselves. a. If job creation is one of the aims, then recruit staff from local communities, train them up to the required standard and employ and control them. b. It would be much more profitable to SANParks if SANParks manage these ventures themselves, they will have additional responsibilities but will not need to share the profits. c. Should capital expenditure be a problem, do a proper business plan and obtain funds from whoever is prepared to provide funding. d. Accommodation on offer page 92 of KNP Management Plan. i. These figures (number of beds) cannot be correct. 1. E.g. Malelane 5 units, 15 campsites = 19 beds. 2. Orpen 15 units, 20 campsites = 42 beds. 3. Balule 6 units, 15 campsites = 18 beds. 4. Tsendze 34 campsite = . . . . . beds. 5. Shingwedzi 80 units, 65 beds = 264 beds. 6. Punda Maria 31 units, 60 campsites = 74 beds. C. The Zonation information on the currently being reviewed Management Plan looks good on paper. However, although one must realize that it may be subject to revision, it is very often revised to suit what has been decided at Board level, e.g. the rezoning of the preferred site for the Malelane Tent Camp and the implementation of the PDZ concept from a primitive wilderness area to what it is now. D. Proper EIAs need to be carried out for these developments, as well as Need and Desirability studies as per DEA NOTICE 891 OF 2014. The DEA seems to be very lenient on this when considering developments in the KNP which is a Conservation area. Rules should not be made, and non-adherence then be condoned.

 SANParks have the grand opportunity to regain the trust of its supporters.  SANParks should now rely much less on outsiders and do more in house.  SANParks should illustrate more to the public that they support Conservation and show less emphasis on tourism.  SANParks now have the grand opportunity the tourism carrying capacity/potential and unambiguously declare what it is after putting it to public debate.  SANParks should now realise that their clients who register as stakeholders or I&APs are not part of the enemy, they are their greatest supporters and should be treated as such.  SANParks now can grow the PP process and consider a liaison group.  DON’T bring into the Park the elements which are found outside – the absence of sophistication/retail/franchised food/traffic jams/aggression/litter/each man for himself….are the very reason why we go there. Bring them in, and you rob us of the joy of nature unplugged!  Distribute Cultural Lower level plans to SAHRA  Include the above in the CDF  Stakeholder report given back to stakeholders of challenges and achievements – more constant feedback  The greatest threats to the Park and its biodiversity are climate change and the burgeoning socio- economic demands of an ever increasing, bordering population. It is going to be a real challenge for KNP management to deal with these two issues, neither of which are of their own making.  The key issue in which I have an interest relates to the commercialisation of the limited public facilities in the KNP. This refers specifically to SANParks currently allowing private commercial activities to take place in the general camps of the KNP. A current example (which has been brought to the attention of SANParks) is the private commercialisation of camping sites in the general camps. A specific example of such activity is the Tented Adventures setup in Pretoriuskop camp, where a private company (Tented Adventures) rented camping sites for many months in advance. Tented Adventures is occupying these sites (prime sites along the fence) with semi-permanent structures and renting their tents out to (mainly foreign) tourists at a huge profit. Most importantly, these activities are allowed to take place to the detriment of ordinary South African citizens who can now no longer book these sites (even though these tents often stand empty) and cannot afford the exorbitant fees charged by Tented Adventures. The company, and others like them, also takes advantage of SANParks amenities e.g. communal bathrooms at the expense of other paying campers, by not contributing to the maintenance of such communal infrastructure.

According to Section 2(e) of the National Environmental Management: Protected Areas Act 57 of 2003, the objectives of the Act include: "(e) to promote sustainable utilisation of protected areas for the benefit of people, in a 195

manner that would preserve the ecological character of such areas ..."

Section 3 explicitly states that: "ln fulfilling the rights contained in section 24 of the Constitution, the State through the organs of state implementing legislation applicable to protected areas must- (a) act as the trustee of protected areas in the Republic; and (b) implement this Act in partnership with the people to achieve the progressive realisation of those rights." Section 20 deals with the declaration of national Parks and states that a declaration may only be issued to (b) prevent exploitation or occupation inconsistent with the protection of the ecological integrity of the area; (c) provide spiritual, scientific, educational, recreational and tourism opportunities which are environmentally compatible; and (d) contribute to economic development, where feasible. The Kruger National Park's current management plan provides for its pricing strategy in the following manner: 2.2.1.3 "Pricing strategy - To ensure that pricing is competitive, affords access to all South Africans and that it correlates with star grading, tourism in The KNP will need to focus on the flexibility of packages, in line with the rest of SANParks and the ecotourism industry." From the above it is clear that: 1. SANParks acts as the trustee of the Kruger National Park, and SANParks must implement the NEMA 57 of 2003 with the people. The people referred to are first and foremost the citizens of South Africa. 2. The KNP's pricing strategy must be competitive and must afford access to all South Africans.

Most campers go into camping because it's cheaper than other accommodation options. By allowing private commercial operators to operate on existing camping sites, SANParks is making it increasingly difficult for most South Africans to stay over in the Kruger National Park, as: 1. Camp sites are the only accommodation option most South Africans can afford; 2. There are already limited camp sites available, especially over school holidays and long weekends; and 3. Most South Africans cannot afford the fees charged by the private commercial operators which now occupy an increasing number of the already limited camping sites. 2 The current arrangements are to the detriment of South African citizens and to the benefit of international visitors. This is in contrast with: 1. The NEMA provision that SANParks must act as trustee for the citizens of the country; and 2. The current management plan provision that pricing must afford access to all South Africans. I (and many other interested parties (as is evident from the SANParks Online Forum and various social media groups on the KNP) am of the view that the current arrangements relating to private commercial activities are a threat to the Kruger National Park, and specifically to access to accommodation options in the Park for ordinary South Africans. The Tented Adventures setup in Pretoriuskop is just an example of several similar private commercial activities in the Park (e.9. a company called Outback Safaris is also active in the KNP). There are also strong rumours that Tented Adventures will be setting up an additional camp at Malelane. Furthermore, there is a real threat that such private commercial activities will spread to chalets as well, with chalets booked out semi permanently by private companies / tour operators, which will then sublet these chalets to South African citizens or foreigners at a huge profit, and to the detriment of ordinary South African citizens.

 A Key Threat/ Challenge for the KNP Management Plan is not to follow on from past decisions but to offer a review process on products/ activities that have been previously disregarded.  WATER o We (the normal man-in-the-street), have been left in the dark regarding the water situation in KNP. Last year the drought was particularly bad and we could see the damage done (dead and dying animals due to no vegetation). I understand that there is a cycle that nature goes through, but when the decision to break down all manmade waterholes was taken was a decision also made to limit the amount of water given to humans? I think not, because if the figures of visitors (never mind staff) is considered, they have risen dramatically – take a small example – 1 million visitors use the toilet - once a day which uses at least 5 litres – how much

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does this equate to per year? Has this calculation even been considered – water which should be used for animals is now being used by visitors and staff.  STAFF o Generally, the staff which the public come into contact with are very pleasant and well trained. The ‘behind the scenes’ staff however seem to lack training and/or leadership and/or funds to do their jobs. Maintenance is left too long which results in camp facilities looking shabby and unkempt and when suddenly maintenance is scheduled to be done no planning has been done and this results in chaos (e.g. The tents in Lower Sabie). The security staff at the gates are a law unto themselves – there appears to be no clear instruction to them as to how to perform their jobs correctly.  Staff which have recently been found guilty of wrong doing are not ‘punished’ according to the crime they committed, e.g. speeding, this needs to be addressed. Staff must know that they are working for KNP and KNP is a nature reserve and should they disobey the rules there are consequences.  CAMP SITES o This is going to become a major problem if not addressed. More and more people are only able to afford the camping options. However, because most of the camps’ campsites are ‘informal’ this is open to abuse. The campsites need to be marked off, people need to be checked in correctly, i.e. if they have paid for electricity on a site they should receive it. People in the campsites need to also be checked to see that they have indeed booked into that camp for the time or not. There is NO control over who stays in a campsite at all and there is little interest in correcting anything either. o The new trend of private companies/people erecting their tents in the campsites needs to be addressed urgently. I understand that the KNP needs to make money, but not at the expense of campers – many of whom cannot afford any other option.  RESTAURANTS  People who have tendered for the ‘right’ to own and operate a food operation in the Park MUST be vetted properly, the very minimum requirement must be that they have a proven track record in this industry – not just their connections or skin colour.  FEEDBACK  SANParks must consider moving into the era of social media – there is very little ‘official’ feedback on social media platforms. Very often incidents occur, and the response eventually received on social media is ‘we are investigating the matter and will revert back to you’. This never happens.  VISITORS  I feel that KNP are allowing too many visitors into the Park each year. With the impending hotel and other accommodations on the cards this is going to ruin the unique atmosphere for most visitors. There are already too many OSV’s in the southern part of the Park and when there is an exciting sighting there is a traffic jam of note.  WELFARE OF ANIMALS  While I appreciate that nature must run its course, it is a huge problem reporting an animal with a snare – which is a man-made problem. I personally came across an elephant with a snare around its trunk. I took down the co-ordinates and reported it as soon as I was back in camp (cell phone signal is not strong in many parts of the Park). I also reported it to police who I passed on the way back to camp. There was a general lack of compassion and I knew nothing would come of this report. I was also told that the vet is in Skukuza and would not come up to the northern part of the Park and anyway elephants more very fast! The next day we went to the co-ordinates and the elephant was a few meters away! It appears that only certain animals receive priority attention – but this is a nature reserve and they should all receive the same attention. If vets are only situated in Skukuza then more vet stations should be made available to cover the whole Park.  Tourist traffic congestion is an increasingly significant issue, particularly in the southern section of the KNP. Open safari vehicles and busses contribute to this issue and it might be considered worthwhile to open a limited number of game management roads in congested areas for their monitored use. This would ease some traffic pressure on main roads used by self-drive tourists, but due consideration would need to be given to ensure this in no way interferes in wilderness areas. Alternatively, some game management roads could be opened for the use of all visitors and this too could spread the traffic load.  Another traffic issue concerns delivery vehicles, construction vehicles and those driven by various contractors employed to do a variety of jobs in the Park. Although some education work has been undertaken, there is an urgent need to help all drivers become aware of the needs of those viewing game or simply enjoying the bush. Speeding also needs to be addressed further.

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 Traffic congestion at sightings of the “Big Five” is another issue of concern and visitors, including drivers of busses and open safari vehicles, need to be further encouraged/educated to display courtesy to others. There is also a need to try and dilute crowds at sightings by focused information programmes that help explain that “Big 5” sightings are only small component of what a visit to the KNP has to offer.

 Socio-economic issues

o Similarly, it appears that the national government is creating an unrealistic expectation that the KNP can solve many of the socio-economic problems in areas that border the Park. The KNP can certainly contribute to solutions but cannot be expected to do this on its own and socio-economic upliftment should be the job of national, provincial and municipal governments. o Rapidly growing human populations across the globe are placing increasing pressure on all protected areas and the situation in the KNP is no different. The long-term effects of rapid population growth need to be understood, a task which must include all sectors of government and civil society. Again, the KNP cannot be expected to deal with these challenges alone. Managers at KNP have a duty towards protecting and promoting biodiversity and this should be their primary task.

Bio-diversity issues

o Climate change poses many threats but the KNP does not exist in isolation from the rest of South Africa, Mozambique or Zimbabwe and cannot be expected to deal with this issue on its own. Government officials need to be continually reminded that it requires a joint effort to create programmes that mitigate against the effects of climate change and the KNP cannot achieve this without broad support. o Water quality is a key issue. All the major rivers that enter the KNP from the west are key to its survival and significant education programmes, law enforcement and water catchment protection are needed to try to improve water quality in the region. This is also an international issue because all major rivers flowing through the KNP are vital sources of water in Mozambique. o The quality of groundwater is also critical to both wildlife and visitors to the Park. o Countering the effects of climate change, removing alien vegetation, improving water quality, environmental education and many of the issues mentioned elsewhere all require funding and government must be lobbied to rethink its funding model for national and provincial Parks. More state funding is essential if South Africa’s protected areas are to survive. o Trade in wildlife, both legal and illegal, and hunting in areas which share unfenced boundaries with the KNP needs to be reconsidered. Protected areas should not be expected to sell wildlife to raise funds. This should be provided from the national budget. o Selling rhinos sends the wrong message that the value of a wild animal rests in the animals’ monetary value rather than its intrinsic worth. The same argument applies to trophy hunting in the APNR and provincial reserves which share unfenced boundaries with the KNP. Hunting implies that the value of an animal is best assessed in economic terms. It also suggests that while it is acceptable for a rich person who can afford to pay for a permit to kill an animal for entertainment it is not acceptable for a poor person to kill an animal to feed a family. o Transfrontier Park. The development of Transfrontier conservation areas and efforts to counter poaching often suffer because of a lack of ability to hold all international stakeholders accountable to the same set of standards. Greater political efforts are required at an international level (Mozambique, for example, until recently had no legislation designed to counter wildlife poaching. This issue should have been vigorously challenged earlier through international diplomacy). International environmental MOU’s are ineffectual if a list of basic criteria cannot be met.

 Too much development which will change the perception of vast space and thus the specific sense of place that all Kruger visitors experience.  Too much outsourcing so that Kruger will no longer be seen as an entity but as lots of unrelated areas.  Control of all these outsourced areas. How can you ensure that private operators will adhere to the ethos of biodiversity and conservation?  Large climatic changes – droughts, floods, rise in world temperatures. Beyond control but need to be assessed and planned for.

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 Related to the above – lack of water. Storage needs to be initiated in camps and staff villages etc. e.g. underground reservoirs.  Economic climate. Also, beyond control but a serious threat.  Population increase along western and southern borders, not only because of birth rate but also because of perceived job opportunities and support.  Poaching; increase in poaching of rhino and several other species because of political moves.  Political changes  Low cost accommodation o No enough low-cost accommodation is offered. SANParks should provide more options for low cost accommodation such as the safari-tents in Skukuza, Crocodile Bridge, Tambotie and Letaba. o There seems to be a huge market for low cost accommodation types. The bungalow accommodation is priced along the general pricing that is acceptable to foreigners, as it provides a good balance between self-catering units in SA compared to those for example in Europe. However, since the economic situation in South Africa has changed, SANParks should opt for more low cost permanent accommodation for the local populations. Any South- Africans in general cannot afford the bungalow type of accommodation. They opt for less expensive options, such as camping and safari-tents. The options for low cost accommodation is limited and should be expanded, samples of very successful units are the safari-tents. There should be a balance in the accommodation, there is enough ‘expensive’ being unused, while the safari-tents will ensure a higher occupancy rate as they are cheap and popular. Example: the fact that this type of accommodation is also popular to foreign tourists is evident from the fact that the private sector (the tour operator) has installed similar safari-tents. It adds more to the bush experience than brick-build units, as sounds are less filtered, and one feels closer to nature. There is a huge market for these tents, SANParks should exploit it themselves to keep it payable. The tents in Pretoriuskop are too expensive for South-Africans as they can organise the services themselves for less. If the private sector is allowed to erect it and exploit it the way it is done, it will become very expensive as the private sector imposes a big revenue margin and it will exclude a great part of potential visitors, as 60% of the clients in SANParks is local. This will in the long run outprice SA Parks accommodation and bring it close to the price-range of other African reserves, for example Kenya. I might lead to a less competitive market position. o Keep the camping option the way it is: SANParks should protect is current camping structures as it is a part of their most successful accommodations offered. A great deal of very loyal SANParks visitors are camping. With regards to campsites, SANParks should not limit the existing camping options available to customers by allowing tour operators to book more than 4 sites (max 24 people) per block. Example: With regards to the concept of semi-permanent safari-tents in Pretoriuskop, the following is important. The public as customers has a disadvantage, as their options become limited by occupying an ordinary camping site with semi-permanent structures that cannot and will not be moved. The possibility of a choice is taken from ordinary visitors opting to camp. The fact that there are still enough sites available next to the fence is not the core issue. Numbers per se are not decisive. The situation is not dramatic at this stage, but we'll get there in the future, as the risk of this concept being rolled out to other camps is quite high. The Public has no guarantees that another company won't do the same and build more tents in Pretoriuskop or any other Kruger camp. Nor is there any guarantee that Tented Adventures won't o expand in future, most likely they will as it is commercially motivated. The long-term risks of losing ordinary campsites to these companies are huge. Add the fact that initially tenders were the way to ensure and enforce a degree of fairness and control by SANParks, the guarantees to the public are reduced to a minimum, and the tender process is partly circumvented. Joe Public does however realize that it is highly unlikely that these tents will never disappear if this practise continue to be allowed. Your argument is superfluous when fitted to a similar scenario in another camp (which is where this will also happen). The situation in any other KNP camp is different and needs to be assessed ad hoc. Nice plea but not materially relevant to the decisive facts on the issue.  Public information  The communication for provision of public information is seriously lacking and fragmented. It undermines the public image of SANParks as professional organisation and is not up to standard. For practical illustration I will use the sample of the semi-permanent Safari-tents erected in Pretoriuskop, debated extensively on the SANParks forum. The SANParks forum is according to the (old) management plan under 2.3.2. Stakeholder Relationship Management Programme (p.108) it mentions in Table 19a: Details of objectives and initiatives to address the Stakeholder Relationship Management Programme of the KNP the following “To build an effective constituency at all levels in SA and abroad, which fosters and enhances sustainable public support for SANParks‟ objectives and

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actions, and for the conservation cause in general”. When the public posed questions as to the identity and validity of these semi-permanent safari-tents in Pretoriuskop (I use them as an example) there was and still is almost no communication about the issue from SANParks. This is very strange since SANParks has this online Forum for constituency and to enhance public support, as their own management plan suggest!. The handling of this matter is a core sample how SANParks is reaching the opposite: public rejection of the way SANParks handled this matter has been significant and the members whom posted information or a reaction has overwhelmingly judged the lack of response by SANParks. SANParks can improve this issue by providing the relevant information in all openness. Especially foreign tourists preparing themselves for an overseas holiday in Kruger read this information and will be discouraged to make use of our Parks if this is becoming standard practise.

 Decision-making procedures: There is confusion about the question which organ within SANParks is authorised to take certain decisions. For the potential businessman wishing to engage in commercials activities in Kruger via a PPP, there is no clarity about the competence of an organ or committee entitled and competent to provide information and take decisions on e.g. commercial and business deals as well as management issues. For instance: if a potential businessman wants to register as a tour operator with SANParks, it is not immediately clear to which organ or person he should direct his questions to if he wishes to receive additional information. Example: I will use the sample of the tour operator managing semi-permanent safari-tents in Pretoriuskop again: a businessman might like the concept and wishes to do the same in another camp. If a SANParks manager then indicates that it is not allowed in other camps but only in Pretoriuskop, there should be reasons as to why this would be the case. The businessman would have to receive answers as to why this is the case and the argument on which this is based.

These decisions as to whether or not to allow a certain commercial activity need to be taken by a properly authorised and competent commission or organ authorised to do so. The National Environmental Protected Areas act 57 of 2003 (hereinafter: NEMA) demand in section 71 states that the SANParks board should, for an employee or person to decide on a particular matter delegate a power (a) in writing and (b) list the limitations if there are any. If this is not done, and tents are for example erected in a camp, a SANParks employee without a written delegation will have no authority to disapprove or regulate this area. It will lead to lawlessness one businessmen will find out this is the case, as then only the Board has the necessary authority. Secondly, the procedures to be followed should be clear: so, what is the time-frame within which an answer or decision of the relevant committee may be expected, and what can be undertaken if no decision is taken or if no information is provided?

 Commercial and management sub-committee Furthermore, in order to secure some guarantees that should bind SANParks, there need to be a committee or organ that is properly delegated to decide on these types of issues. If a member of the public (i.e. potential businessman) would like to engage in business activities in the KNP, he will need information and possible guarantees. Example: there are questions about the tour operator in Pretoriuskop placing semi-permanent safari tents on the camping grounds. The question of other businessmen who want to start a similar project in e.g. Crocodile-Bridge have no idea who they can approach to discuss this possibility. The question is: is the SANParks board the competent organ of is it the section manager, camp manager or the general manager for strategic tourism services? There is no clarity and it prevents serious PPP partners from entering the market. It reduces the pool of potential interested businessmen interested in PPP’s and therefore may also reduce the quality of the potential PPP businesses.

 Criteria development for commercial and management issues If there are criteria applicable, the businessman would need the ability to discuss the issue with a commission or organ properly qualified or delegated with the necessary powers to decide on the matter. This will prevent arbitrary, decision take by various ‘managers’ who cannot be held accountable when the information provided is incorrect, absent or in the case certain guarantees are made but not delivered. SANParks should improve their institutional system by providing an organ or commission that can decide on certain commercial and management issues that are not important enough for the Board named in terms of article 57 National Environmental Protected Areas act 57 of 2003 (hereinafter: NEMA). Example: Let’s suppose a businessman would like to erect semi-permanent tents on the camping in Crocodile- Bridge. He would like to know whether it is: (1) Allowed (2): For what period it is allowed (3) which organ or committee can decide op practical questions, such as: the size of the safari tents, whether I may dig in

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the poles for support and whether I may claim a part of the camping (4) guarantees that his investment would be compromised within 5 months. For all these questions, there should be one centralised committee or organ competent to decide on these issues. Otherwise various practices and criteria may be developed by various SANParks staff that can be arbitrary with different conditions applying to various tour operators. This will create the assumption that SANParks is applying different standards which are seemingly arbitrary. This will hurt the image and reputation of SANParks. This should be prevented!

Light pollution is the excessive and obtrusive artificial light produced from anthropogenic sources. It is gaining international prominence as an anthropogenic global change driver, as measured by its expanding distribution and extent, its novelty as a threat to species and ecosystems, and the severity of its impacts on both environmental and human health. Alarmingly, however, in South Africa its effects are still underappreciated and studying its impacts is still in its infancy. These consequences of light pollution may be severe. It changes foraging patterns, species behaviour and the distribution patterns of species, which alters ecosystem functioning via changes to local assemblage structure. The impact of light pollution is drastic for humans also. Because it interferes with melatonin production, it contributes to obesity, diabetes and depression. It may also cause increases in the risk of breast and prostate cancers, especially in shift workers such as nurses and miners. Light pollution may affect Kruger in two ways – by impacting its biodiversity and by compromising the enjoyment of the night sky by tourists. Because the use of artificial lightening is increasing outside the Park, the Park must consider the impact thereof. Lighting is also increasing within the infrastructure used in the Park, and so the management plan must consider ways to reduce or eliminate it.

5. What are the opportunities to be considered as part of the KNP Management Plan review?

Categories More specific issues Sections in the Plan where key issues raised have been considered Retain world leaderships Section 10.9.4 Shops and retails under single brand Addressed through Business development unit and associated Strategies and Protocols Privatisation a concern As above Use of OSVs a concern Congestion Section 10.6 Complying with rules Calls on radios- traffic jams Commercialisation Who are the beneficiaries? Sections 10.7, 10.8.2 What informs the mandate? Section 3, Section 5. Legal framework, reasons for which KNP was declared, National Development Plan Local Socio-Economic Development Do it in-house Sections 10.7, 10.8. Programmes. Make It work However, consider also the section on the Costing, broader socio-ecological landscape which requires a much broader and integrated co-operative approach with range of partners and sectors. Stakeholder participation Pay more attention to this See earlier comments. Value stakeholder inputs Section 10.8 We care, we are not armchair conservationists Awareness/access Inclusive of other demographic See section 10.8 groups However, what about affordability for most? Civil and Building Management Looks good on paper, but not See section 10.9.6 Programme page functional Poor maintenance As above Safety and security Law enforcement lacking Section 10.9.7

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More enforcement required As above Vehicle and fleet management Concerns about deals that KNP Informed by the SANParks went into in terms of fleet Policy framework, and management etc. section 10.9.3. Research Build on expertise of people Section 10.9.14. retired Relationships are maintained with several networks, institutions and experts, including local knowledge. Human capital Staff should remember it is Addressed in Section 10.6, special to be employed in KNP – 10.9.4 must improve on hospitality, serve public Transboundary control Restrict border access to See earlier comments Mozambique Cultural programmes Learn from KZN in terms of Section 10.6 programmes Relationships Strengthen with stakeholders Section 10.8 Special features Enhance these Section 10.4 More open policy towards making Sections 3, 5. Annual informed decisions on products/ evaluation as per Protocols, activities they may be very beneficial to workplan and adaptive the Park. management framework. Day drives Expand on these during certain Section 10.6 time slots, and the regulation thereof

The below issues were summarised as above, and were considered in the review of the Management plan, and development of the low-level plans:

 To retain (regain?) world leadership by retaining a stringent conservation ethos amidst a plethora of challenges and threats  I would recommend that all shops and restaurant franchises are under a single brand each. A single franchise may also make negotiations far more efficient and with less litigations.  Privatization of KNP is a huge concern. o Trails are mentioned as being privatized. o I have information that the privatization of rest camps in the long-term future is under SANParks consideration. i. SANParks are allowing more and more outsiders whose main objective is profiteering to operate in the Park, these institutions have very little concern for conservation and bio-diversity. ii. SANParks state that they have control measures in place, poor service delivery, diminishing quality and standards in places like Afsaal, Nkuhlu, Tshokwane, the recent restaurant fiasco, Singita had to renegotiate their contract and Shishangani who went bankrupt, are just a few examples of where privatization did not work. The Selati train restaurant was once a place one would like visiting, it has now been closed for years. 1. It may be argued that the restaurants may have previously been running at a loss. If the current restaurant owners/operators can run it a profit, I can see no reason why SANParks cannot do so as well. iii. SANParks have no control over the staff activities of outside partners, therefore these partnerships should be reduced and eventually be weeded out. In the meantime, a strict set of rules need to be implemented and enforced. What these people do wrong is not on their plate, it is all seen as SANParks poor whatever. iv. Page 98 states Implementation of operational management and auditing – Currently KNP employs one Hospitality Standards Manager and has a very newly developed Standards Manual. This capacity needs to be expanded and independent auditing procedures and site inspections instituted to maintain a high-quality tourism product. v. This does not seem to have much effect for the reasons mentioned in 6.B.iii.above.

 Commercialisation strategy page 98

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A significant element of the ecotourism pillar is the Commercialisation Strategy (which through the implementation of Public Private Partnerships (PPP)) has as its objective the reduction of cost of delivery, improving service levels by focusing on core business and leveraging private capital and expertise as well as the objective of expansion of tourism products and the generation of additional revenue for the funding of conservation and constituency building. vi. What is the core business referred to? Surely, it cannot only be connecting to society, it must be in the first place Conservation and then others can follow. Constituency building will not be affected if SANParks embark on a “Less privatising” campaign, in other words, do it in-house. vii. The true beneficiaries under the current policy are those who already are affluent. 1. I have stated before that SANParks can recruit people from the local previous disadvantaged communities, train or have them trained end then employ and control them as required.  SANParks are increasingly encouraging the use of OSVs. OSVs are causing increased visitor frustration. viii. These OSVs are in radio contact and race from one big 5 sighting to the next chalking up and generating their tipping service. OSVs should be better controlled and limited. OSVs seem to expect preferential treatment at entrance gates, it needs to be made clear to all that queues are to be followed, no jumping of queues allowed. ix. Stating that control measures are being implemented is not enough visitors would like to see these measures becoming effective. x. Should SANParks consider visitors to make use of OSVs instead of their own transport, this will not work as regular visitors know where and when they want to travel, they do not need to be guided by a guide who may have the theoretical qualification but who does not seem to realize that do not only appreciate the big 5 and his whit. These guides create the impression to foreign visitors that they are rangers, this is a false impression. xi. SANParks should realize that if the use of own transport is limited, there will be less traffic on the roads, the reason being that less persons will visit our National Parks.  Awareness. o Encouraging other race groups to visit our National Parks is great, my estimation is that at least 26% of the visitors to the KNP are from other than white race groups. The “exclusion” of other race groups in the past was not good for anyone. Unfortunately, the National Parks Board had to follow the laws of the land, fortunately bit by bit they succeeded in making the par accessible to all. o I see nowhere in the planned developments that facilities for the less affluent are planned. All the developments are for the rich, no wonder it is said that the KNP and many other National Parks only cater for the rich and therefor it is or may not be wrong to poach or steal from the area. xii. SANParks are not doing enough to attract persons who cannot afford lavish facilities to our Parks. Here I include adults and children of all races. xiii. I suggest that SANParks create more affordable/subsidized basic accommodation say a three-day stay-over for those persons who cannot afford what is on offer in the rest-camps. Awareness programmes can be run by suitably qualified information officers also offering game and interpretive drives for these people.  Stakeholders’ participation. One often gets the impression that stakeholders are tolerated only because the rules indicate so. xiv. I suggest that SANParks pay much more attention to what their clients to say. We went on the Sweni trail during June 2010, the trail leader was Lawrence Baloyi, who acted very suspiciously as a person as well as what was on offer during the trail. xv. I reported this to the person in charge of the trails in the Central Area, firstly I seemed to be ignored, after a further prompt and eventually a telephone call from me I got a response and the assurance that Baloyi was above reproach. xvi. All should please realize that we participate because we care. We are not just armchair conservationists.  Local Socio-Economic Development Programmes. I have already mentioned that doing it in-house should take place, this will not be negative towards the Socio-economic development of the poor, recruit them, train them, employ them and control them. This may require some extra effort from those in charge but is this not what management is about. Make it work.  Civil and Building Management Programme page 117. o This all looks wonderful on paper, however when tourists find that taps are leaking, electric stoves in accommodation units and camp kitchens and ablution facilities are unserviceable, curtain rails are tied with string, walls need a coat of paint, in general buildings are not being kept well maintained and hygienically clean, it becomes clear that much needs to be done regarding this. o When complaints are lodged one is referred to the checklists in the facilities, these seem to be more of an attendance list than an inspection list. What is lacking is a follow up action list.

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 Safety and Security programme. o Despite what is said on page 122, Law enforcement seems lacking; rule breaking is part of the daily routine. Speeding and road kills and littering and poor behaviour take place daily; offenders do not seem to realize that they are in a Conservation Area. o Much more visible Law Enforcement is required.  Vehicle and fleet management PAGE 125. o Vehicle fleet and transport management within a national Park the size of the KNP is an important supporting function to enable effective Park management. This programme essentially enables effective transportation of goods and staff throughout the KNP, ensuring effectiveness and cost reduction within inflationary constraints. o The Mail and Guardian reported during May 2013: 1. Belly-up Nkandla company linked to bizarre SANParks deal. 2. In the years since, the company has shared in the proceeds of a R500-million contract with the South Africa National Parks (SANParks), the details of which are fiercely guarded. 3. But now, Bohlabela is in the final stages of liquidation in a process that will cost another state organ, the Industrial Development Corporation (IDC), R2.9-million in bad debt, even though the SANParks contract was hastily renewed for three years, giving Bohlabela a theoretical 40% share of another R300-million in revenue at the same time. 4. Other peculiarities around the company, its liquidation, and the SANParks contract include: 5. The contract with SANParks in which Bohlabela has a stake was suddenly extended from five to eight years, apparently recently. xvii. Surely, a proper due diligence exercise does not seem to have been carried out. Items like this do immense damage to the image of SANParks.  Research. Much is done by suitably qualified persons, this is commendable. May they follow in the footsteps of Dr Nell, Piet van Wyk, Dolf Brynard, Tol Pienaar, Salomon Joubert, Willem Gertenbach, Leo and Harald Braack, Peet van der Walt, Johan Sithole. Nick Zambatis and many others. xviii. May they be appreciated, and their work respected and considered when decisions are taken. Hopefully they will also get the support from their superiors when the object to matters that are not in the interest of bio-diversity and Conservation, may they also heed to the motto that has since disappeared from the logo being CUSTOS NATURAE.

 Human resource support programme. One often gets the impression that many of the staff regard their employment in the KNP is just a job. They do not seem to realize that being employed in the KNP is special. xix. Not all are like this, tourism staff and the rangers are friendly and polite, this is commendable. Hopefully management can extend this culture to those who are lacking in this aspect.  Access to bordering countries. I get the impression that the KNP is being earmarked as a short-cut route to Inhambane, Xai-Xai, Vilanculous and other Mozambican areas. xx. I suggest that a high restriction be placed on the use of the KNP roads and border posts with Mozambique. Persons using the KNP as a short-cut have no regard for the speed limits and road safety of the KNP roads. xxi. Potential users of these roads should be required to well in advance submit a well-motivated application for permission to make use of the route. This should then be considered and if refused the decision should be final. Going on holiday or unlimited trade should not be allowed. xxii. Users need to be escorted en route in a convoy, leaving early enough to reach the border post or the exit gate of choice before closing time. xxiii. The cost of this would then be for the applicant. Uncontrolled use of the KNP roads to and from border posts should not be allowed.

 Cultural- liaise with KZN Ezemvelo  Expand on those elements which make the KNP experience unique.  Take advantage of the local knowledge and know-how of all communities, not just certain groups. There is a wealth of experience out there and everyone wants the KNP to be a successful and thriving place to visit. For example, the restaurants, why go the chain group route, use local people with local flavours, foreign visitors love experiencing our cuisine.  An opportunity to strengthen your relations with stakeholders.  An opportunity to be world leaders scientifically and in management of areas of important biodiversity such as is under your control.  To relook at the use of certain areas within the KNP, and the opportunity for introducing additional Eco- Tourism activities into these areas to enhance the visitor experience.

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 A more open policy towards making informed decisions on products/ activities they may be very beneficial to the Park.  The plan must consider light pollution as a risk to its biodiversity, and that it compromises its aesthetics.  Ways must be explored to reduce light pollution within the Park (i.e. see Gaston et al. 2012 Journal of Applied Ecology,49, 1256–1266).  The aesthetic enjoyment of the night sky must be recognized as a key factor that why tourists visit.  The plan can explore initiatives to retain its dark sky attributes, and register the Park as a “Dark site of international importance” with the International Dark Sky Association (www.darksky.org).

 Day drives (8 a.m. till 11 a.m. and 3 p.m. till 6 p.m.) SANParks offers awesome morning, sunset, and night drives. These drives are very popular and attract a lot of tourist. The private market is filling the gaps by providing day-drives, mostly offered by day drives for mostly foreign tourists or the wealthier local consumers. The costs of day-drives organised by tour operators is considerable, however there is no alternative for the foreign tourist and therefore, they have no option but to choose the private sector day-drives. The gap between self-drive and day drives offered by tour operators is big, and some foreigners are not willing to drive in Kruger themselves. SANParks can offer an in-between solution by offering a day-drive from (for example) 8 a.m. until 11.00 a.m. and 15.00 p.m. until 18.00 p.m. This means people foreign tourists will not be dependent on self-drive or the tour operators but can stay in a camp for multiple days and enjoy day-drives organised by SANParks. It’s an opportunity which should be tried.

6. What would you suggest that the KNP need to consider/ amend e.g. in terms of the focus, approach, actions, prioritisation etc. for the development of the KNP Management Plan/lower level plans?

Categories More specific issues Sections in the Plan where key issues raised have been considered Go back to the basics See values, Section 7, Section 9, Section 10.4, Section 10.6 Commercialisation Don’t squeeze to much out of KNP As above Recognise limitations Including ecological limitations Considered in the adaptive management process and guiding principles. Thank you. See several LLPs Peripheral limitations As above. Tourism limitations As above Keep public more informed See earlier comments. Sections 10.8 and 10.9.9 Funding a concern Government support to deal with all Sections 10.9.3, Costing, socio-economic issues 10.8.2 (co-operative partnerships and sector integration). Several processes are underway in this regard, from the National to local level, including engagement with government, private sector, communities, NGOs, funders etc. Fund raising What goes back for the right intended Please feel welcome to purpose? engage with the Business Development Unit. Fund raising is governed by the SANParks strategy, and associated monitoring, evaluation and auditing aspects. Cultural heritage programme Include several aspects – zonation, As per earlier comments. (SAHRA) fire management, poaching, visitor Covered in several sections, management, appointment of HR including 10.6, 10.9.7 manager for Cultural aspects 205

Expand on programmes in terms of the history Ethics around sustainable resource Global awareness Section 10.39 use Concerns with current approach Marketing Improve on marketing Section 10.6 Brand Biodiversity Focus on water Sections 10.3, 10.2.2 and Focus on IAS 10.9.13. See earlier Focus on Climate change comments Strategic adaptive management With stakeholders to guide these This was the basis of the processes in terms of advisory entire review process. See capacity also sections 4, 5. Value proposition to visitors Sections 9, 10.6 Value of the brand Section 10.6 Funding sustainability Different models to be considered This will enjoy a key focus moving forward, and reviewed continuously based on guiding principles, mandate, core business and values of KNP. Radical socio-economic Is this the core and sole mandate of Sections 10.7, 10.8.2, 10.3. development KNP? This is a co-operative partnership programme, in line with the National Development Plan and Ministerial outcome delivery agreements Privatisation Managed by Business Development Unit in accordance to SANParks Corporate Framework and Strategies. See Sections 9, 10.6 Apply for Kruger to be declared an An initial assessment was International Heritage Site. done, considering different scenarios and the implications. Public consultation Hold on n Saturdays Guided by the SANParks Electronic notification a month in Stakeholder Engagement advance etc Strategy. However, the recent public participation meetings have shown that Saturdays and notification well in advance does not guarantee good attendance, or constructive participation. Stop rhino sales See earlier comments. Guided by legal framework and SANParks Corporate Strategies. Political Oversight and Self- o All major commercial Noted. Several independent promotion by Kruger at National developments in Kruger studies have been conducted Level should be submitted to the and are in process, which Parliamentary Sub- guides the strategic direction committee on Environmental of KNP in a well-informed Affairs for approval, not just manner. This is part of the the Department. adaptive management o Greater emphasis must be process, and KNP will provide placed on co-operation with feedback on a continuous and all conservation NGO's, not transparent basis on progress

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just preferred or selected made, constraints and ones. opportunities. o An independent study must be undertaken by a professional or academic institution to establish how much income and employment Kruger generates INDIRECTLY. o The astronomical benefits that will be revealed by the above study will dispel the myth that Kruger needs to commercialise to pay for itself and the other Parks Engagement Engage with stakeholders once a Supported. See Section year 10.8.2, and earlier comments.

The below issues were summarised as above, and were considered in the review of the Management plan, and development of the low-level plans:

 Go back to basics … refer to my comments in Question 5  Conservation – back to basics: in spite of its size the KNP is not an open ecological unit – retain the integrity of natural processes (fluxes) as far as possible, experiment where practical and necessary but retain control, i.e. the ability of redeeming mistakes from mis-interpretations.  Commercialisation – trying to squeeze too much out of the “golden egg” will inevitably reveal its vulnerability and destroy much of its intrinsic attractions.  Recognise limitations – the notion that the KNP is large enough to absorb uncontrolled ecological experimentation, even with the addition of peripheral areas, and unbridled increases in tourist traffic are a pipe-dream. Both approaches can ultimately lead to the destruction of its most valued intrinsic beauty!  This review process is good, I do realise that it has not always been like this, however I am also aware that much research was done, and many meetings held before major decisions were made in the past, the old timers did not have the text books and information available as today, much was done in a trial and error fashion, many mistakes were made. Please let us learn from those mistakes and not repeat them or make new ones.  The Hoek Commission of 1951 recommended that the Punda Maria to Pafuri road be closed daily at 13:00, this seems a good idea and should be considered to many of the other roads. o I have often seen vehicles travelling to exit gates at times of which it would be impossible to reach if the speed limits were respected. The H11, H4-2, H7, H3 H9 come to mind. o Early mornings speeding in the opposite direction takes place obviously to get staff to their workplace, being late for work should not be sufficient reason for speeding.  In addition to my comment I request that as part of the PP process SANParks should consider a public liaison group this will reduce much of the, current distrust and bad-mouthing that is going on.  SANParks should keep the public more informed of their conservation successes, currently most about SANParks is about poaching, SANParks failures as well as their commercialization and privatization plans. . My request is that CUSTOS NATURAE returned to the SANParks emblems and to everything they do.  I am saying this as the great jobs by the Nature Conservation staff seem to be overshadowed by the need for Commercialization.  CUSTOS NATURAE will illustrate that SANParks are not only connected to society as their current vision and mission statement indicates, it should be made clearer that SANParks regard their core business as being in the Conservation business.  Just having press releases about what SANParks conservation successes is not good enough, the Conservation successes need to be made available to the public by the people who caused the successes. Over the radio, in the press on TV, in magazines. Create partnerships with these and the bad-mouthing of SANParks will reduce exponentially, all that is currently in the media is the SANParks commercialization and privatization policy.

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. In the past stickers were issued to every vehicle entering the gates with abbreviated rules on, indicating speed limits, do not litter and stay in your vehicle in Afrikaans and English.  I recommend that similar stickers be made available, only this time optional stickers with of the other indigenous languages as well. Having stickers available in foreign languages could also be beneficial.  This may also increase abeyance of the National Parks rules as it will serve as a reminder that persons are in a National Park.  Reconsider your privatization and commercialization policies.  Funding may be a challenge, SANParks should make it very clear to the RSA Government and insist that they be heard that SANParks contribute much to the economy of this country as well as the earning of foreign revenue.  It should also be made very clear to the Government that SANParks are doing much regarding the upliftment and job creation for the desperately poor which is part of the National Government function, therefor sufficient funding needs to be made available from the fiscus. . Much fundraising is done in the name of so called conservation, it is common knowledge that not much of these funds end up where the donors intended them to be. Unfortunately, many see this as another method of self-enrichment as has become so prevalent in our country.  I suggest that SANParks together with the DEA decide on approved fund-raising institutions and then make them public knowledge.  The Lowveld region of the SANParks Honorary Rangers annually arranges a fishing competition in the Reënvoël Dam near Phalaborwa. It is publicised as fund raising and research. o Some funds may be generated, unfortunately this is just an outing in the KNP for a selected few, and much more funds can be raised if this is done in dams or waters elsewhere. As far as research is concerned, this has nothing to do with research as angling is species specific. Research is done with electric probes and fine gauged soft nets. . Stop permitting these types of activities in the KNP.  Please “Keep it Simple and Keep it Wild”.

 HR objectives – Appointment of cultural heritage manager  CDF- zonation of cultural heritage plans  Fire management – impact on rock heritage sites  Rehabilitation of dams, old structures – first consider age of structures before commencement of work- SAHRA  Cultural Management Plan – should inform Tourism and CDF objectives/Plans  Tourism visitor management plan – Monitor and Mitigate impacts on heritage sites  Training of rangers and guides – legal aspects and management of cultural sites  Ease traffic congestion  More walking trails  Understanding the socio-economic issues facing the KNP & the need for sufficient resourcing by government  Address and improve water quality problems  Planning for and countering the effects of climate change  Removing invasive and alien vegetation  More environmental education awareness training is needed  Cease trade in live wildlife from the KNP.  CONSIDER: The perception that you may be placing less emphasis on your core mandate and moving towards more emphasis on Socio Economic development; thus, apparently positioning SANParks as an agency for such development, especially in rural areas, to the overall detriment of the Park in the long run. (This is not a criticism of the way you approach your core mandate per se.)  CONSIDER: The effect overall of dividing the Park up into smaller units, all run by different service providers.  CONSIDER: Your financial approach. How do you balance the considerable increase in costs to the consumer that will arise as a result of outsourcing, with the resulting loss of your loyal customer base?  FOCUS: Future water provisions for camps and staff villages as already mentioned.  ACTION: Looking at more in-house financial opportunities e.g. you have a nursery, wonderful indigenous plants, a lot of indigenous knowledge to tap, a mobile spa - in-house natural beauty and wellness products.

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 ACTION: Improvement in tourist behaviour  CONSIDER: Looking at ways of increasing development of abilities and opportunities in the surrounding populations. Mentor schemes, training schemes, entrepreneurial schemes, bursary schemes ( Companies?) etc.  FOCUS: Other ways of attracting tourists to your hubs instead of the extremes of bars, breweries (? alcohol banned in Park) balloons and microlights (another current no-no in the Park).  FINANCIAL: We are very impressed with the volume of tasks and challenges the Kruger must face daily. The financial implications are huge. The absence of the Government is a shameful reality, and this puts the Kruger in a position where budgeting can impact on the ethics of certain solutions in the management of the Park.  KNP must hugely develop its marketing abilities and media communication.  People, tourists, companies, institutions are unaware of what the Kruger is doing in the whole, to protect its values from the external world. This could be an ICON itself, the symbol of what nature is experiencing on a global scale. Wildlife slowly being crushed to death from outside. Your incredible efforts and success should become the main message. It is not only about plants and animals. In order to protect them you must save com munities, you become the school, the doctor, the government, the lawyer, the teacher. This is a huge message that you can launch worldwide because the abuse on the environment and the loss of suitable land is an issue globally. This is what A NEW PARK MUST LOOK LIKE. You should tell stories, film videos, you should develop social media communication on what you already do, in order to raise funds. Big international companies, celebrities, NGOs, Associations financed by the European Union would contribute, financially or with projects, with volunteers, which would hugely help you with the communities.  UNICITY OF THE KRUGER: Kruger is a gem for its “Sense of Place”, its size and therapeutic vastness, its genuine biodiversity, its competent management at different levels, its Vets and rescue teams, its balance between wilderness and development, its wild and untouched style, its accessibility and geographic position. ITS SOCIAL INVOLVEMENT, which is already in place but not promoted properly and not included in your Park image. All these factors must continue and represent the best you can aim for.  LONG TERM RISKS: to become too much commercial and overdeveloped, to lose land to neighbours to over-exploit animals and land inside and outside, to let profit win on ethics, to lose biodiversity, to suffer poaching, to suffer a decline in management, to suffer corruption, to lose on pollution and deterioration of resources, to suffer climate changes. WHAT TO AVOID: ignoring the global trend towards a growing ethics in regards of the management of wild animals. Your trading in animals is a shameful side of the Kruger National Park. Selling animals ‘in excess’ even primates to laboratories, to hunting farms, to zoos, circuses, to private traders, is something that cannot survive in the social media world if you are looking for long term public consent. You need to wash that face of the KNP and find alternatives in your management. Also using the Skukuza abattoir won’t help your image. Another country which feeds the poor with elephant meat is Zimbabwe and you don’t want to associate yourself with such management, do you? Harvesting selected problem elephants is a metaphor. You are sending a message that there are “too many elephants”, and that’s not a good message, especially where poaching is present. The census methodology you apply to count and manage animals is also questionable and often decisions are taken on the base of inaccurate data. Elephant populations have shown the capability of self-regulating and problem animals can often be managed with strategies Animals can be pushed to move in different areas, can be managed with sterilization, deterrents, waterhole closures, fencing, use of natural antagonists, in the case of elephants, the use of beehives and enclosures to protect specific vegetation. We understand the moral issues linked to allowing animals to die as a consequence of the drought and rot in the face of the huge need in neighbouring areas, but when you feed communities with wild animals, these communities start demanding regular supply and see you as a permanent food program.  The moment you stop the legal supply, the poaching cases will increase

 Strategic Adaptive Management Objective To reach or stay within the desired conditions agreed upon, KNP will adopt a strategic adaptive management approach. The strategic component will keep the longer view in focus, while the adaptive components will strive to ensure continual feedback at various levels in a spirit of continuing learning, fine-tuning and adjustment.  Like Dwight D. Eisenhower said, “In preparing for battle I have always found that plans are useless, but planning is indispensable.” It simply means that the moment the ink dried on your plan, there are new factors that are/ have developed that will influence your plan and if you are not adapting it will be out of relevance soon. That correlates with the Adaptive Management Objective and should be incorporated as a principle of the plan.

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However, the amount of stakeholder inputs into the plan varies. At the lowest level one expects the responsible employee to adapt as it sees fit within a broad parameter (within budget and time) without major rehashing of the issues. At the highest level the responsible Board cannot change direction without taking due consideration of stakeholders’ interests and inputs. For Eisenhower to decide on his own he will first invade Japan and then Europe and halfway through change that, has profound implications if not properly validated with his stakeholders (War Councils of the Allied forces, presidents, etc.). For the corporal to attack left of the barn instead of right (as originally planned) is probably ok, as long as his peloton is informed during the battle. In between those two poles some structure needs to be agreed to for adapting the plan during the next 10 years. If the plan needs to change the planning process (ideas, alternatives, positives, negative, factors, decisions) is as important as the new adapted plan. In fact, if the planning process is neglected under the Adaptive Doctrine, then the idea of stakeholder participation falls flat. As a general approach the higher up in the plan changes occur the more those need to be ventilated amongst stakeholders. The lower changes to the plan occur the more can delegate that to the implementers of the plan to make those decisions.

 One of the most contentious matters that illustrate this was the recent culling and distribution of meat to surrounding communities. Using that as a case study one can see that it impacted KNP at the highest strategic level (mission, image, intervention into animal numbers , role and mandate) as well as at tactical level (meat processing plant, choice of who benefits, which scientific studies to be commissioned / used) to operational level (who shoots, how to distribute meat). Strategic Adaptive Management Objective must in no way mean that changes at Strategic level should not be ventilated with the correct stakeholders.  In short: Add to that objective something that underpin a way in which Strategic Adaptive Management, will be coordinated with the stakeholders  Direct Human Benefits Objective to provide benefits, particularly in the sense of „benefits beyond boundaries‟, to meet or exceed reasonable expectations and foster partnerships, in a spirit of equity redress.

My only comment is that any harvesting of any resources (whether it is trees, grass, animals, water) should not in itself be presented to / for Human Benefits. The mandate of KNP is what it is, but resources can never be directly utilised to the benefit of any human. KNP must primarily deal with a sustainable eco system. No more and no less. Once that is in place all the other Human Benefits (employment, dividends, education, free tours, concessions, etc.) will follow from that basis. SANParks never was meant to be a direct social tool for South Africa and once we play is that space it is difficult to manage the real or perception that decisions, are for the benefit of nature conservation.  Constituency Building Objective to build an effective constituency at all levels in SA and abroad, which fosters and enhances sustainable public support for SANParks‟ objectives and actions, and for the conservation.... My comment is that KNP must wake up to the powerful trend that comes from the digital era. Social media will drive a lot of public support. A more effective way should be devised to deal with various social or more formalised groupings via the electronic media  Administration Objective to support all clients within the KNP by providing them with the Administration and Protection Services. o To the extent that safety concerns are part of the obligation of KNP, the budget should come from central government. KNP can be regarded as a National Key Point and protection (for endangered species, staff and tourists) should get a security allocation from the fiscus. o SANParks could engage more often in public research through online polls and discussions on its forum.

 The KNP Management Plan and/or lower level plans: o No subletting should be allowed in the public areas of camps (i.e. on the current camping grounds and in the current chalets). ln other words, a blanket ban on all subletting on ordinary/existing camping sites and chalets in the camps open to general visitors of the KNP. o Should SANParks wish to accommodate such private commercial activities, provision should o be made in designated areas - either within newly designated areas in camps (but not impinging on ordinary campers and other overnight visitors) or, preferably, in other areas such as unused day visitor areas (e.g. near Berg-en-Dal). Either way, such areas should be separate from public camping areas and other overnight facilities and have their own ablution and other infrastructure facilities, which must be paid for and maintained by the commercial operators themselves and not through the monies generated through normal tourist activities or monies appropriated by Government (i.e. South African taxpayers money).

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All commercial operators must undergo public and transparent tender processes and all such activities must be subjected to environmental impact assessments. Limits must be set on the duration of bookings - e.g. 3 weeks per camp, to discourage such subletting activities. lf a tent, camping site, or chalet is not occupied for a night without a valid excuse (e.g. medical reasons), such booking must be handled as a no show, cancelled, and be made available to the public through the normal booking channels. When finalising a booking (either in person, telephonically or online) a specific camping site or chalet number should be allocated to the booking based on availability at the time and as requested by the client. o These measures should be introduced in all SANParks-operated Parks.

 Value Proposition to Visitors o Regarding future tourism development in KNP I suggest that KNP tourism management consider the KNP brand and the unique “value proposition” that they seek to offer visitors. o Amongst other things it is recommended that tourism management consider the following:

- Defining the KNP brand - Clarifying the brand “promise” - Understanding how the KNP brand is positioned relative to competitor products in SA, Africa and overseas - Specific plans to deliver the KNP brand promises in terms of visitor experience - Ultimately defining a unique value proposition to offer to visitors (what experience you want to offer, to whom and how you will fulfil the promise)  Radical Socio-Economic Development o It is noted in the presentation that SANParks and KNP are committed to radical socio- economic transformation in areas adjacent to the Park. o The question is whether SANParks/KNP has the primary responsibility and mandate to create radical socio-economic transformation in surrounding areas or whether other organs of state are more directly charged with this responsibility and have a formal mandate, budget and qualified resources to achieve this? o The corollary is whether other organs of state equally share SANParks’ primary responsibility and mandate of biodiversity management and conservation in the same way as SANParks shares radical socio-economic transformation? o It may be most useful for all state departments to work together towards a common vision and common goals in areas that have a direct and meaningful impact on the KNP mandate such as the quality of water in rivers that flow into KNP.

In this regard reference is made to this article which appeared in the Saturday Star on 27 May 2017.

http://www.iol.co.za/saturday-star/news/eco-warriors-at-the-coal-face-in-mpumalanga-9380336

 Consolidation/centralisation of conservation assets and management authorities o It is common cause that efficiencies can be gained from either centralised consolidation or completely decentralised management systems. o It is my contention that SANParks is well positioned to become the centralised conservation management authority responsible for all state conservation areas and assets in SA. o In particular KNP could and should take over management responsibility for all the state owned protected areas in its vicinity. o This will lead to cost and expert resource efficiencies and should be explored in the KNP Management Plan for the next 10 years.

 Apply for Kruger to be declared an International Heritage Site.  Have these stakeholder meetings every year, preferably more, at the major centres as is. (Private financial assistance if required, although SANParks money is public money anyway)  These meetings be expanded to include discussion on ALL SANParks.  Communication and Interaction with Public  Newspapers and other National Media be approached to provide regular articles on Kruger news pertaining to developments, management projects, details of contact persons within all National Parks, conservation projects and poaching, and results and minutes of Public Meetings and online consultation/stakeholder input mechanisms.

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 Notice of ALL public meetings be given a month in advance via national media, in addition to internet information, with detailed logistical information and agendas accompanying said notices from the outset, not later.  Minutes of Public and other important management meetings to be distributed electronically to stakeholders and NGO's within 10 days of said meetings, not just to those who managed to attend the meetings.  Public meetings and consultations to be held on Saturdays outside school and Public holidays.  A general change in attitude being made regarding taking the concerns of the public seriously, with special effort being made to address all concerns speedily. In other words, it must be accepted that Kruger management serves at the behest of the public.  Commercialization.: An immediate cancellation or indefinite suspension of all commercialisation projects and new developments, including the following: - Skukuza Safari Lodge - Malelane Safari Lodge - Shangoni Gate - Century City Gate - Phalaborwa Wildlife Activity Hub and Lodge - Orpen Hotel - Punda Maria Hotel - Nkuhlu Tented Camp - Mobile Tented Safari Experiences - Mobile Spas and Wellness Centres - Kruger Tree Canopy Camps - Tshokwane Tented Birding Camp - Selati Bridge Train Accommodation  Private access roads not be allowed from Letaba Riverside Lodge, and Mjejane Gate be permanently closed. The need for all of the above remains questionable, if not unethical, and has not been scientifically or properly been established. The financial implications of the projects are un-quantified and potentially disastrous. Kruger cannot afford any more visitors, it is already overfull. New developments also mean extra private contractors and vehicles, contributing to security concerns regarding rhino poaching. Future development will occur naturally as concession Camps and roads pass into SANParks hands eventually. Kruger accommodation costs have also been increasing annually at far more than the inflation rate.  Franchises It is recommended that all shop and restaurant franchises be consolidated under a single brand each. This will reduce supply chain traffic. It will also eliminate the need for a variety of agreements with different providers, which leads to potential inconsistencies and increased chances of corrupt dealings as oversight is made more difficult. A single franchise may also make labour negotiations far more efficient, leading to fewer disruptions.  Rhino and other poaching o Random lifestyle audits must be done on all employees, regardless of rank, right up to potentially CEO level. o All persons found to have contributed to poaching must be named and shamed relentlessly and nationally, with progress on arrests and prosecutions being made public extensively on a monthly basis. o Private security firms must be employed to do random DETAILED searches of vehicles at any place in the Park, from entry points to camps to staff villages to open roads. This fact must be stipulated under the terms and conditions of entry into Kruger/employment by visitors, conference attendees, staff and contractors. The contract with the security company must be heavily performance-based and short-term in nature, pending renewal. o All staff villages must be comprehensively searched on a regular basis. Unwarranted persons must be arrested, not evicted. o Staff visitors may only enter at Skukuza and Phalaborwa gates. All vehicles are to be FULLY searched at a point slightly within the Park from there. This should form part of the terms of employment for all Kruger employees. o All staff and staff guest vehicles are to be fitted with a temporary electronic tag, which will monitor movement and times. The tags must be issued and collected by private security at the gates. o All Kruger rhino sales must be indefinitely suspended, and the holding bomas be converted to a rhino orphanage in co-operation with experienced private orphanage workers.

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o The existence of incident-reporting and whistleblowing numbers and apps must be more actively promoted via all means possible to tourists, and via national media. Extra staff and incentives must be provided in this regard. o A far greater amount of pressure must be brought to bear on our foreign relations departments regarding cross-border co-operation with Mozambique. Kruger management and the Board has a very strong voice, regarding which it underestimates itself, as do its many foreign visitors. o Greater emphasis must be placed on video surveillance at gates, including number plate recognition technology linked to the criminal database. Defective equipment must be replaced instantly, with reserve equipment kept at each gate o With regard to funding of all the above, donor agencies may be approached regarding "adopting" very specific projects/gates, which they can monitor, rather than having them pour money into a general anti-poaching fund, which is putting many donors off as time goes by.

 Political Oversight and Self-promotion by Kruger at National Level o All major commercial developments in Kruger should be submitted to the Parliamentary Sub- committee on Environmental Affairs for approval, not just the Department. o Greater emphasis must be placed on co-operation with all conservation NGO's, not just preferred or selected ones. This should take the form of electronic media discussions on a monthly basis with a database of registered and invited stakeholders. o An independent study must be undertaken by a professional or academic institution to establish how much income and employment Kruger generates INDIRECTLY. This would include the money spent by the average visitor from booking to returning home. This would include factors such as like travel agent fees, fuel purchases, toll fees, airline costs, vehicle hire costs, local curio and grocery purchases, local accommodation purchases by day visitors and foreign exchange benefits. o And the employment created by all of the above. o The astronomical benefits that will be revealed by the above study will dispel the myth that Kruger needs to commercialise to pay for itself and the other Parks, as it is more than entitled to demand financial government assistance in the event of any shortfalls.  Major focus on cultural heritage programme and history

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ANNEXURE 4: KNP MANAGEMENT PLAN WRITTEN INPUTS 2018 – SUMMARY OF STAKEHOLDERS THAT SUBMITTED WRITTEN INPUTS.

Thirty-two stakeholders submitted written inputs. All emails were acknowledged. A template was provided for the inputs, aand such comments were considered for comments. Inputs that were not submitted in the required format, were considered, but not necessarily included.

Name of Stakeholder Date Ms Trude McDonald 9 February 2018 Dr. Victor W Meyer 11 February 2018 Dr. Michael Brett 17 February 2018 Dr B Anthony 20 February 2018 Prof Van Helden 6 March 2018 Dr Ben du Plessis 3 March 2018 Dr Louis Van Schalwyk 3 March 2018 Ms Penny Legg 3 March 2018 Ms Lisbeth Scalabrini 4 March 2018 Dr R Davies - PPF 4 March 2018 Dr R Grant 6 March 2018 Prof Rob Slotow -UKZN 7 March 2018 Mr Frans… 7 March 2018 Mr N Zambatis 7 March 2018 Ms Patricia Vineski 7 March 2018 Mrs Wendy King 7 March 2018 Mr KN Maswanganyi – Altein Civic Chairperson 8 March 2018 Dr Campbell Murn 8 March 2018 Ms Judy Malone - Tourists Against Trophy Hunting 9 March 2018 Dr Audrey Delsink 9 March 2018 Ms L Botha – WWF Khetha 9 March 2018 Mr David Marneweck EWT 9 March 2018 Ms Michele Pickover 9 March 2018 Ms Karen Trendler, SPCA 9 March 2018 Ms Natasha Higgitt, SAHRA 9 March 2018 Dr. Peta Thomas; Prof. Llewellyn Leonard, Prof. Robin Nunkoo 9 March 2018 Ms Kim Da Ribeira - OSCAP 9 March 2018 Mr Patrick Mhlanga 9 March 2018 Heike Henderson Altenstein 9 March 2018 Ms Lorinda Steenkamp 9 March 2018 Dr Michele Henley – Elephants Alive 9 March 2018 Global March for Elephants and Rhinos (GMFER) 9 March 2018 Mr J Eksteen - MTPA 9 March 2018

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