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23073 GEZINA 0031

Reg No: 2006/010722/08 VAT/BTW No.: 4200 228 098

President: Dr PT Oberem, Adjunkpresident/Deputy President: Mnr W vd Linde,Direkteure/Directors: Mes/Mss: ER Davey, M Odendaal, Mnre/Messrs: PJG Koen, NJ Adami,

B Erasmus, DJ Cunningham, B Groenewald, K Landman, A Douglas, B York, Dr R Louw, PF Ernst, T Mogashoa

Notice 965 of 2015 Biodiversity Economy Strategy

Pg 9, last paragraph:The forecasted GDP growth of 10% per annum will not be realized unless the current property tax regime for game ranchers is substantially reviewed. Allow us to give a short synopsis of negotiations and challenges with respect to the draft act on property tax.

During the discussions of the draft Act on property tax that took 4 years where Agri SA with the support of WRSA regularly gave input, many definitions and articles of the draft Act were negotiated and “secured” for game ranching as an agriculture commodity/practice.

Following the recognition of a number of rebates for agriculture, these proposal were submitted to the portfolio committee, which however insisted that game ranching should be excluded from the definition of agriculture. This can only be understood as political and ideological resistance by politicians particularly given the political views and utterances that wildlife ranching is the playground for white, affluent individuals.

The Property Tax Act no. 6 of 2004 therefore excludes game ranching from the definition of agriculture. This resulted that game ranching is not entitled to any rebates on property tax and further implies that game ranching is classified as a business. A function of this decision by the state is, that a game rancher pays 8 times more in property tax than his fellow stock farmer.

During 2009-2011 the changes on the Property Tax Act were again on the table. Agri SA and WRSA again addressed the issue of including wildlife ranching in the definition of agriculture. The draft Act designers then changed the definition as proposed by the industry. However, at the portfolio committee meeting the ideological motivations won the day and in the final Act, game ranching was again excluded from the definition of agriculture.

WRSA firmly believes that it is unconstitutional for a stock farmer and a game rancher who farms on agricultural land and are using the same sub-standard roads, sub-standard electricity, no water supply or sewerage removal from local municipalities, while at the same time contributing equally to the local economy, to the development of the region and to social upliftment of workers and their families, not to be treated equitably in terms of property tax rebates. This is clear discrimination in terms of the Constitution.

Pg 11:WRSA supports the ideology and executive intent of the BES Strategy. We do however believe that this strategy cannot be implemented if effect is not given to the minutes of the meeting with the Honourable Minister Molewa on 4 November 2013 regarding the establishment of an agency for the wildlife industry reporting to the Ministry as a head office function only.

For ease of reference, we quote the minutes of the meeting:

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Only if the proposed agency in DEA is implemented, can a successful outcome be achieved, otherwise, the preservationist belief systems within the 1+9 institutional architecture namely, “that all game, whether TOP’s listed or other plains game translocated from a so-called natural distribution range should be issued a “passport” (permit) by DEA”, will limit and retard any growth and development of the industry.

Pg 15, Glossary of terms – Biological resources:Please refer to comments on pg. 44, Letter to D-G

Pg 19, footnote 11:WRSA cannot agree with this definition, since it reinforces the principle of ‘extra-limital’ for animals outside their district-based so called natural distribution ranges.

Pg 20, paragraph 2:Please refer to comments regarding CITES / IUCN made with respect to Pg.44.

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Pg 27, paragraph 1.2.2:Please note that the industry decided not to use the word “venison”, currently being internationally registered and “owned” by New Zealand as their brand name for game meat. The industry decided that for South Africa we will brand our game meat products that were raised on semi-extensive ranches as “game meat”, not venison. Please correct page 29, paragraph 3 and 4 as well.

Pg 33, paragraph 2.1:WRSA would like to quote from a peer-reviewed scientific article: The economics and institutional economics of wildlife on private land in Africa, Child et al. Pastoralism: Research, Policy and Practice 2012, 2:18. http://www.pastoralismjournal.com/content/2/1/18 to re-enforce the need for comprehensive strategic change:

We can view the wildlife economy in four phases (Table 1). In the pre-modern economy, wildlife was plentiful, and the primary constraint to use was the technology and costs of harvesting it. This was followed by a ‘frontier economy’ associated with the Industrial Revolution and the exploration and settlement of Africa by Europeans. New technology and markets, including guns, wagons, and even railways, radically altered the economy of wildlife and enabled hunters to harvest vast numbers of wildlife at a low cost to sell in new urban and global markets. In the absence of institutions for controlling offtake, wildlife, including North America's vast herds of bison, was decimated in a classic case of market failure whereby individuals internalize benefits but externalize costs to society.

In response to this, wildlife was nationalized. In 1900 and 1933, the European powers met in London to respond to the perceived extirpation of wildlife in their African colonies, making three policy decisions with long-lasting implications (Heijnsbergen 1997). First, they encouraged the formation of state protected areas, which led to the formation of Africa's spectacular national parks and now support vibrant economies when managed effectively. Second, they greatly restricted the commercial use of wildlife rendering wildlife valueless except for low-value subsistence uses. Third, they centralized ownership of wildlife in the state, disenfranchising landholders and taking upon themselves the burden of protecting wildlife from people (anti-poaching) and protecting people from wildlife (problem animal control). In some countries, local communities were severely disenfranchised, especially where traditional methods of hunting were made illegal and ownership of firearms was restricted (Carruthers 1989; Brockington and Igoe 2006). But in others, like Zambia and Botswana, local people were given considerable freedom to hunt under permit systems that often became difficult to administer (Astle 1999).

However, by the late 1950s, population growth and the rapid spread of agriculture and livestock were causing an inexorable decline of Africa's unique and spectacular wildlife. At the twilight of colonial Africa, many leading conservationists met at the Arusha Conference on the ‘Conservation of Nature and Natural Resources in Modern African States’, emphasizing that a radical new approach was needed to conserve wildlife (IUCN 1963). This, the delegates said, needed to be led by Africans, and wildlife needed to become an economic asset according to the emerging ‘use it or lose it’ philosophy. Thus, the opening comments of the conference proceedings emphasize:

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“Only by the planned utilization of wildlife as a renewable natural resources, either for protein or as a recreational attraction, can its conservation and development be economically justified in competition with agriculture, stock ranching and other forms of land use (p19, IUCN 1963).”

The emergence of wildlife utilizationConservationists began to argue that wildlife was better suited to using Africa's harsh environments than the domestic monocultures imported from Europe because, to quote again from the Arusha Conference, the variety of ungulate fauna, their mobility, high standing biomass, and greater nutritional efficiency is seen to give them advantages over domestic livestock that concentrate their attention on a single constituent of the plant standing-crop biomass - the graminacious carpet (p19, IUCN 1963). Nonetheless, by 1980 fully, some 95% of the large herbivore biomass in southern Africa was livestock (Cumming and Bond 1991).

The 1950s and 1960s saw unprecedented research into the ecology of wildlife, its meat production potential, and even domestication (Talbot et al. 1961; Talbot et al. 1965; Mossman 1975).

However, with the transition from colonial to African rule in East Africa, the control of wildlife was increasingly centralized (Kabiri 2010), and policy momentum shifted to southern Africa where there was considerable discussion about the potential value of wildlife (Riney 1960; Dasmann 1964), and experimental game cropping was initiated (Dasmann and Mossman 1961). By the late 1960s, the heads of wildlife agencies in southern Africa began meeting annually through the ‘Standing Committee for Nature Conservation and the Management and Use of Wildlife’ of the ‘Southern African Regional Commission for the Conservation and Utilization of the Soil’. Soon thereafter, we see legislation emerging in Namibia, Zimbabwe, Mozambique, Botswana, and South Africa's provinces allowing landholders to use their wildlife commercially and with far fewer state-imposed restrictions (Child 1971; Suich and Child 2009). When it became apparent that permits and surveys were impractical and that landholders husbanded valuable wildlife just as they husbanded their domestic stock, regulatory requirements were reduced. In Zimbabwe, they were virtually removed by the bold Parks and Wild Life Act of 1975.

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This policy response in southern Africa has been labelled community-based natural resource management (CBNRM).

On the one hand, it is naïve to suggest that wildlife can resolve poverty for millions of people in drylands, but on the other, CBNRM has clearly benefited both people and wildlife where it has been implemented with some level of competence (Child et al. 2003; NACSO 2006).

Although strongly associated with wildlife, CBNRM in southern Africa can be interpreted as a new institutional model that links payments for ecological services to poverty reduction (Child 2004a, Frost and Bond 2008), which is applicable to many ecosystem services, but just happens to take advantage of the value of wildlife and opportunities that arose because wildlife provided an institutional greenfield. We certainly need such models.

Pg 34, paragraph 2.4., 2nd last bullet:WRSA would like to state that should we look at live game trade only, a total of 29 281 animals were traded during 2014 at formal game auctions, generating a turnover of R1.8 billion. Compared to previous years, this is quite a major increase. The official turnover on game auctions has since 2005 increased by 26.5% on a year by year basis, i.e. a total increase of 238%. In addition to this, there was also a major growth in the increase of marketing activities through social media, internet-based agents, game capturers, etc., indicating that only a small percentage of game is sold via the auction system. According to literature, it is estimated that between 10 -20% of game sales are via the live auction systems. This implies that the R1.8 billion, representing 20% of the trade in live game, the total quantum of live game trade of 2014 would be conservatively quantified at R10 billion. Adding the value of the contribution of related services and costs tied to the capturing and translocation of game, one can add an additional R7.6 billion. According to Dr Flippie Cloete of the Unit for Environmental Science and Management of North-West University, the economic contribution of the game ranching industry in totality would be an estimated R20 billion in 2014. If this is expressed in terms of the scope of agriculture’s total production value, it implies that the game industry will be at about 11% of their total agricultural production value in South Africa.

Pg 37, paragraph 3.4, third paragraph, bullet 2 – Sustainable use of Indigenous Species:WRSA strongly recommends the following governance ideology for sustainable wildlife use:

Pg 37, paragraph 3.4, third paragraph, bullet 7 – Improving quality and standards of products:WRSA would like to confirm that the industry has succeeded in obtaining an international ISO game meat accreditation that would enhance the quality and standards of our game meat products. We require DEA endorsement to strengthen our ability to police the policy

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Sustainable use cannot be understood only from a biological or ecological perspective, such as the harvest of a specific species over time, in isolation. The broader social, economic, cultural and political dynamics should be factored into the equation.

Pg 38, paragraph 3.4.2:WRSA strongly recommends the following governance model by the State for South Africa in order to give effect to sustainable use of indigenous resources:

Pg 42, Table 1:Note that the Presidency: Department of Planning, Monitoring and Evaluation gave a Briefing on the 2014/2015 Annual Performance of the Department of Agriculture, Forestry and Fisheries on 13 October 2015.

During their presentation on the topic of Policies / Acts restricting agrarian transformation, the following 5 bullets were highlighted:

Referring to bullet 5, it is obvious that DEA’s policy designers, with respect to the TOPS Regulations, the Translocation Regulations and the ideology of Natural Distribution Ranges are recklessly ignoring the Land Capability Classes 1-8 as reflected on pages 21-24 in the draft PDALFA Bill. Looking at this classification and the fact that South Africa as an arid country, land classifications 5-8 cannot be used sustainably for any other commodity than game. Classification 5-8 comprises 70% of the agricultural footprint of South Africa. For ease of reference, we quote from the Bill:

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Sustainable use dictates a specific State Governance system. Eco- and humanity systems that depend on good governance change constantly. The governance system must be capable of detecting, assessing, and applying adaptive management prudently to changes in public, private, community-based, formal and informal environments.

Applied evidence-based peer-reviewed research by academic research agencies and Adaptive and consultative Management.

Adaptive management

The policy and legal environment related to land ownership and use has in the past not been conducive to agrarian transformation and development of the agricultural sector.

The National Environmental Act 107 of 1998 (NEMA) establishes principles for decision-making on matters affecting the environment.

However, NEMA does not adequately ensure the protection of high value agricultural land as its focus is on biodiversity and environmental conservation.

Spatial Planning and Land Use Management Act, 2013 (SPLUMA) provides the framework for spatial planning and land use, asserting that the use of agricultural land for agricultural purposes, is a matter that vests in the national sphere of government, however, there are issues related to capacity to implement.

SPLUMA also has the potential to create dualism in the management of land by Municipalities and Traditional Leadership.

“land capability classes” means capability classes I, II, III, IV, V, VI, VII and VIII;

“land capability class I land” means land –(a) that has a very high potential for intensive crop production;(b) with few permanent limitations that restrict its use;(c) which may be used safely and profitably for cultivated crops;(d) of which the soils –

(i) are nearly level and deep;(ii) hold water well(iii) are generally well drained(iv) are easily worked(v) are either fairly well supplied with plant nutrients or are highly responsive to

inputs of fertilizer, and(vi) when used for crop production, needs ordinary management practices to

maintain productivity; and(e) which has a local climate favourable for growing many of the common field

crops;

“land capability class II land” means land –(a) with some permanent limitations that reduce the degree or intensity of crop

production but is nevertheless of high potential;(b) which requires moderate conservation practices;(c) which may be used for cultivated crops, but with less latitude in the choice of

crops or management practices than land capability class I land;(d) with few limitations; and(e) the production and conservation practices of which are easy to apply;

“land capability class III land” means land –(a) with severe permanent limitations that restricts the choice of alternative uses and

the intensity of crop production;(b) which is of moderate potential;(c) which requires special conservation practices;(d) which may be used for cultivated crops, but has more restrictions than land

capability class II land;(e) when used for cultivated crops, the conservation practices of which are

usually more difficult to apply and to maintain; and(f) of which the number of practical alternatives for average farmers is less than that

for soils in land capability class II;

“land capability class IV land” means land –

(a) with very severe permanent limitations that restrict the choice of alternative uses and the potential for crop production;

(b) which requires very careful management;(c) which may be used for cultivated crops, but more careful management is

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required than for land capability class III land and conservation practices are more difficult to apply and maintain;

(d) with restrictions to land use which are greater than those in land capability class III land; and

(e) on which the choice of plants is more limited;

“land capability class V land” means land –(a) that is unsuitable for the cultivation of annual crops;(b) with a slight erosion hazard under natural veld, established pastures, forestry or

special crops that provides adequate cover;(c) which may be tilled for the establishment of pastures, forestry and special

crops; and(d) which has one or more of the following limitations which are impractical to

remove:(i) wetness or frequently flooded;(ii) stoniness or rockiness; or(iii) c limatic limitations;(iv) which could effectively be used for sustainable semi-extensive game

ranching.

“semi-extensive wildlife system” means an environment that is of sufficient size for the management of self-sustaining populations of listed threatened or protected species, irrespective of whether it is fenced or not, and irrespective of whether it meets the ecological requirements of such populations or not, but where human intervention is required in the form of—

(a) the provision of water;(b) the supplementation of food, except in times of drought (animals need food in times

of drought);(c) the control of parasites or predation; or(d) the provision of health care;

“land capability class VI land” means land –(a) which has permanent limitations that make it generally unsuited to cultivation and

limit its use largely to natural grazing, browsing, afforestation or game farming; and

(b) which has continuing limitations that cannot be corrected, including –(i) steep slope;(ii) severe erosion hazard;(iii) effects of past erosion;(iv) stoniness;(v) shallow rooting zone;(vi) excessive wetness or flooding;

(c) which could effectively be used for sustainable semi-extensive game ranching (see definition above)

(i)[(vii)] low water-holding capacity;(ii)[(viii)] salinity;

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(iii)[(ix)] sodicity; or(iv)[(x)] unfavourable climate;

“land capability class VII land” means land with –(a)very severe permanent limitations that make it unsuited to cultivation and that

restrict its use largely to natural grazing, browsing, afforestation or game farming; and

(b)restrictions that are more severe than those for land capability class VI land because of one or more continuing limitations that cannot be corrected, such as

(i) very steep slopes;(ii) erosion;(iii) shallow soil;(iv) stones;(v) wet soil;(vi) salinity;(vii) sodicity; or(viii) u nfavourable climate;

(c)which could effectively be used for sustainable semi-extensive game ranching.

“land capability class VIII land” means land with limitations that –(a) preclude its use for commercial agricultural production;[(b)] restrict its use to recreation, ecotourism, wildlif e, semi- extensive game

farming, water supply or aesthetic purposes; and(b)[(c)] cannot be corrected as a result of, amongst others, the effects of one or

more of the following:(i) erosion or erosion hazard;(ii) severe climate;(iii) wet soil;(iv) stones;(v) low water-holding capacity;(vi) salinity; or(vii) sodicity;

Pg 44, paragraph 1:Please note that WRSA cannot agree with the CITES / IUCN / CoP resolutions and we would like to draw your attention to letter to the Director-General of DEA, dated 10 September 2015 and for ease of reference, we herewith repeat the letter:

INVITATION TO REGISTER TO PARTICIPATE IN THE PREPARATIONS FOR THE 17 th

CONFERENCE OF PARTIES (CoP17) TO THE CONVENTION ON INTERNATIONAL TRADE IN ENDANGERED SPECIES OF WILD FAUNA AND FLORA (CITES), AND TO SUBMIT DRAFT PROPOSALS FOR CONSIDERATION BY THE NATIONAL SCIENTIFIC AUTHORITY

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Thank you kindly for the invitation to comment and participate. WRSA respectfully declines the invitation to participate or submit a formal position paper for consideration by CITES at CoP17, for the following reasons:

1. Rhino and Elephant matters: Committee of InquiryWRSA through its chamber, PROA, is fully represented, participates and supports the Minister in this regard.

2. Other Species related to CITES CoP172.1. In terms of your Annexures: Conf.9.24 (Ref. CoP16), game ranching on semi-

extensive agricultural land does not reside under the international intent, governance or conventions of CITES.

Note specifically: Resolution Conf. 9.24 (Rev.CoP16)-2

“(g) hybrids… populations in the wild”“(h) species of which all specimens in trade have been used in captivity or artificially propagated should not be included in the Appendices… of wild origin.”

Annexure 1: Biological criteria for Appendix 1“A. The wild population… following:”“B. The wild population has a restricted… following:”“C. A marked decline in the population size in the wild…”

Annexure 2a: Criteria for the inclusion of species in Appendix II… Convention.

Para.2 “… trends of the wild population(s)…”“B. … from the wild is not reducing the wild populations…”

Annexure 5: Definitions explanations and guidelines affected by trade“ii) … that may be detrimental to its survival in the wild.”

Wild populations“Wild populations refer to the total number of free-living individuals of the species within its area of distribution, as defined in this Annexure.”

Population size“… effective size (i.e. individuals capable of reproduction, excluding individuals that are environmentally, behaviourally or otherwise reproductively suppressed in the wild)…”

Annexure 6: Format for proposals to amend the AppendicesControl Measures“8.3.2. DomesticProvide information… ensuring a sustainable harvest from the wild of species in question.”

2.2. Red Data Listing

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Refer to DEA’s Criteria for substantial revision of the list of threatened or protected species, dated 07 August 2015.

“All South African species1. Evaluated as Extinct in the Wild or Critically Endangered according to the

IUCN 2001 Red List System…”

Refer to SANBI’s Revised Red List of Mammals of South Africa, Swaziland and Lesotho, 2014.

“What do we measure in the IUCN Red List? (Just like the criteria, there are also very specific definitions and protocols for what data we measure.)

- Only mature individuals (capable of reproduction)- Only wild and free roaming subpopulations inside the natural range.- No hybrids or exotic subspecies”

“Wild and free roaming IUCN definition 2014Subpopulations dependent on direct intervention are not considered wild, ifthey would go extinct within 10 years without “intensive” management, such as• Providing most of the food needs of most individuals in the subpopulation;• Captive-bred subpopulations or those inside camps; • Breeding manipulations, such as selective breeding to enhance certain traits; • Providing ongoing, intensive veterinary care to most individuals.”

2.3. National Environmental Management: Biodiversity Act, 2004. WRSA responded on April 2015 to Notices 255 & 256 of 2015 TOPS

Regulations and the Norms and Standards for Translocation of Indigenous Species. These issues and proposed norms & standards have to date not been resolved.

WRSA advised as follows:

“1.3. The DEA policy designers further ignored the Judgement of the Supreme Court of Appeal: Case No. 72/10 regarding captive bred lions (TOPS-listed). In the above court case the Minister’s evidence confirmed that breeding of lions in captivity plays no role in the conservation and survival of lion as a species in the wild. How is this different from breeding any other species on a semi-extensive game farm; it has no bearing or risk for the conservation for species in the wild. DEA does not recognize or count any mammal species on game farms for purposes of the national balance sheet for TOPS species numbers or the IUCN Red List Status, reinforcing the notion that mammals bred on private game farms have no conservation or biodiversity value.”

“2.2. This reality is totally ignored by the DEA policy designers, given their failure to recognise that Section 56 of the Act (Act No. 10 of 2004) only empowers the Minister to gazette lists of critically endangered species, endangered species and vulnerable species, the common characteristic of which is a high risk of extinction in the wild. A ‘restricted activity’ is extensively defined in S 1(1) of the Act, in relation to specimen of a listed threatened or protected species/specimen.”

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3. ConclusionGiven the content as reflected in paragraph 2 (above) and the factual situation that Wildlife Ranching has converted 20 million ha of marginal agricultural land into a sustainable land option of game farming, game animals farmed with on semi-extensive ex-agricultural farms do not fall under the ideological framework, international intent, governance or conventions of CITES.

In summary, CITES requires that all member states carry out this ‘Call for submissions’ by any member of society or NGO on any species they feel require attention. The member state in turn must consider if the request is justified and accordingly table such at the next CoP meeting if they support. Thus this covers all plants, birds, reptiles etc.

We therefore believe that we cannot make a meaningful contribution at the workshops in preparation for the COP17 meeting, other than with regard to rhino. At this stage it is still a local South African political and institutional matter to be resolved. Our Minister would not raise this issue at the upcoming COP17 gathering of nations; given the current CITES Resolutions to exclude all game animals on semi-extensive privately owned game ranches.

Pg 53, paragraph 5.2.2.1. Problem statement:This problem statement can be argued an understatement and in the view of WRSA is mission critical. This statement highlights the dynamics of agriculture, eco-tourism and “conservation” sectors. Wildlife ranching is currently only being governed by DEA and Provinces as preservation-extension of State conservation areas. In short it is a ‘compliance to conservation regulatory’ system ideology only.

Pg 54:Regarding the table and reference to permitting system, WRSA would like to strongly argue that permitting systems should only be for wild animals in the wild, i.e. protected areas, and that is not within the Minister of Environment’s mandate in terms of NEMBA for game animals on agricultural land.

Pg 56, paragraph 5.2.4.2:This table should provide for science- and evidence-based management and adaptive management practices for game ranchers in terms of herbivores. Refer to Science and the evidence-based management of mega- herbivores: linking elephant and bison by G.Kerley & M. Knight.

Dr Peter Oberem Dr Gert Dry13

WRSA President WRSA Past-President

5 November 2015

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