Sweeping new wildlife plan must go back to the drawing board, say NGOs

Jun 23, 2024 | Commentary

By Don Pinnock – Daily Maverick

The government’s plan to create mega-landscape conservation areas equal to seven Kruger Parks seems a brilliant idea but – according to wildlife NGOs and a law centre – it has fundamental flaws and should be redrafted.

This is the draft National Biodiversity Economy Strategy: Proclaim 14 million hectares, the equivalent of seven Kruger National Parks, of wildlife and wilderness “mega-landscapes” to conserve biodiversity while using the natural resources of the areas to create jobs and promote economic growth.

The Department of Forestry, Fisheries and the Environment (DFFE) proposes to do this by generating wealth from wildlife and wild areas through a huge expansion of tourism, trophy hunting, meat hunting and wild meat sales as well as fishing and the harvesting of indigenous plants and food insects.

It also proposes setting up “health clinics to administer traditional remedies using rhino horn for health tourists from the Far East, or ivory carving being done locally for local sale and export for personal use”. This would be a clear violation of Cites trade restrictions which prohibit international trade in rhino horn and no clear indication is given on how it would be implemented.

The strategy proposal was put out for public debate on 8 March with a short period for response, but got some heavyweight replies — one is 53 pages long. While five of those seen by Our Burning Planet support the spirit of the strategy, they unanimously agree that, as drafted, it needs a complete overhaul or redrafting to meet constitutional, legal and policy requirements.

The five replies seen by Our Burning Planet are from the Endangered Wildlife Trust, Humane Society International-Africa, the Biodiversity Law Centre, the EMS Foundation and the SA Hunters and Game Conservation Association.

They all agree that the conservation of the natural world is essential, but the problem for all but the hunting association is that it would be paid for by commoditising wildlife, wild plants and wild lands. There are questions about whether it’s a workable plan of action or a wish list. The devil, according to all NGOs and the law centre, is in the detail.

The draft National Biodiversity Economy Strategy (NBES) is clearly influenced by South Africa’s model of permitting private landowners to own and derive economic benefits from wildlife. It intends to widen this model to include traditional community areas. Its aim, it says, is for the country’s biodiversity economy to achieve an average gross domestic product (GDP) growth rate of 10% a year.

All five submissions criticise the vagueness of language, unrealistic (or unrealisable) targets and the absence of definitions. Of particular concern to the Endangered Wildlife Trust (EWT) and the Biodiversity Law Centre is the absence of protecting wildlife by ensuring ecologically sustainable use, and the absence of animal “wellbeing” in many of the strategy’s proposed actions.

“We support conservation practices that … promote the ecologically sustainable use of wild animals in natural free-living conditions to the benefit of all,” says their report, but “we do not support industrial-scale production and management of South Africa’s wildlife when these activities are not in line with the principles of ecologically sustainable use, animal wellbeing and do not benefit the conservation of the species in the wild.”

In a combined report, the Biodiversity Law Centre (BLC) and EMS Foundation say the strategy is vague, with unarticulated assumptions which lack detailed references. The strategy, says the report, uses critical terms and concepts that are inadequately defined, making public engagement difficult. They agree with the EWT that it fails to connect with existing environmental policies and current frameworks.

Humane Society International-Africa (HSI-Africa) points out that the strategy conflicts with the findings of, among other reports, the high-level panel on lions, rhinos, elephants and leopards (which recommended the end of captive lion breeding and no trade in rhino horn or ivory until certain conditions are met) and the White Paper on the Conservation and Sustainable Use of South Africa’s Biodiversity, which requires duty of care and ecological sustainability.

There are concerns that there’s an overemphasis on the economic benefits from the consumptive use of wildlife, such as trophy hunting and game meat production, without considering the value of biodiversity and animal wellbeing. While farm animals have been bred for thousands of years to accept containment, captive breeding stresses wild animals.

“The Department,” HSI-Africa writes, “has adopted an extremely anthropocentric position which does not recognise that the country’s biodiversity has intrinsic value that is worthy of protecting for its own sake and not just for the immediate benefit of humans.”

The strategy is hugely supportive of hunting, but the Hunters and Game Conservation Association says it was drafted without consultation, especially with wildlife entrepreneurs, and is flawed.

The term “wellbeing”, says the association, requires hunters to consider the mental health of a wild animal being lined up in a hunter’s sights. The association is concerned that those opposed to sustainable use could use these terms to block any use of “faunal biodiversity” by demanding to know if the mental health of the animals had been considered.

Complex goals

The draft strategy is partitioned into a complex (almost bewildering) set of four “goals”, “cross-cutting imperatives” and ‘“enablers”. Goal 1 is to boost ecotourism, Goal 2 is the “consumptive” use of land-based wildlife, Goal 3 is the use of marine and freshwater resources and Goal 4 is bioprospecting.

“We are not convinced that South Africa can realistically sustainably hunt wild-ranging or free-living lions,” says the EWT report, “and the NBES is silent on scientific justifications for these targets … [and] on whether there is in fact a market for this degree of hunting”.

The strategy’s projected hunting revenues raise red flags. According to conservation writer Adam Cruise, around 6,000 international trophy hunters shot more than 36,500 wild animals in SA in 2022 (the latest year for which DFFE professional hunting statistics are available).

By calculating the current annual increase in real terms, after removing inflation, this means a GDP increase from R5-billion (including a contribution of R1.8-billion from trophy hunting) in 2022 to more than R13-billion by 2036, which is an increase in real terms of 7.6% per annum.

“Naturally, this will have to be underpinned by an increase in hunters and their prey, so by 2036, more than 16,500 international hunters will be required to shoot almost 100,000 animals annually. Therefore, a total of close to one million animals will have to be trophy-hunted during this period, which includes more than 10,000 lions, 1,300 elephants, 3,000 white rhino and 30,000 buffalo. It does not appear plausible that these increased numbers of animals will suddenly materialise in ‘extensive wildlife systems’, nor that the international demand for these exists,” said Cruise.

(Graphic: Adam Cruise)

(Graphic: Adam Cruise)

The EMS Foundation and the BLC say it is unclear how hunting can square with the biodiversity white paper’s requirement to promote the ecologically sustainable use of biodiversity and animal wellbeing.

They have requested that the entire NBES document be withdrawn and redrafted after meaningful consultation. HSI-Africa has also called for a complete overhaul of the document and warned that the department was acting inconsistently with previous policy processes and could be producing incompatible and contradictory policy frameworks.

EWT said it supported the intention to explore and develop economic opportunities in the wildlife sector, but that the draft needed extensive amendment after more stakeholder input.

The Hunters Association expressed alarm at the suggestion of providing wildlife to new entrants and rural communities, given the complexities involved, especially, in keeping Big Five animals.

It warned that owning the Big Five was not always a benefit and a proper assessment should be done on the most viable options for each community or new entrants. “A one-size-fits-all approach does not work in the wildlife sector and the best options depend on a range of variables that should be considered.”


In summary, the submissions say it is essential to:

  • Comprehensively review the strategy to identify where it falls short of constitutional and legal requirements and align with existing policy, including the White Paper on Biodiversity and Sustainable Use; the White Paper on the National Environmental Management of the Ocean and the Policy Position on the Conservation and Sustainable Use of Elephant, Lion, Leopard and Rhinoceros.
  • Integrate animal wellbeing considerations across all aspects of the NBES.
  • Provide clear definitions and justifications for actions and provide clear, measurable targets.
  • Establish clear guidelines and standards on the ecologically sustainable use of natural resources based on the best available science.
  • Integrate animal statutory requirements around wellbeing across all goals and actions.
  • Transparently address environmental impacts and ethical concerns.
  • Focus on the non-consumptive use of wildlife and wild lands.
  • Ensure a full 60-day period for public comments and involve key stakeholders, including communities, early on in policy development.
  • Clarify details on the proposed use of living landscapes/seascapes and bioprospecting.
  • Organise workshops and public consultations to gather input on the revised strategy.
  • Monitor and evaluate implementation regularly.

The conclusion by all four NGOs and the Biodiversity Law Centre is that the draft strategy may be a step in the right direction, but it needs to go back to the drawing board to iron out a blizzard of potential problems. It is, at root, asking wild areas and wildlife to pay for their own conservation and survival. It should not be done to their detriment.


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