WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

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Ms Marlene Laros

Department of Environmental Affairs and Development Planning

4th Floor, Leeusig Building

1 Dorp Street

Cape Town 8001

Email: marlene.laros@westerncape.gov.za

Johannesburg, 6th of August 2019

Dear Ms Laros,

RE: DRAFT WESTERN CAPE BIODIVERSITY BILL, 2019, Provincial Gazette, 8094, 7May 2019

The undersigned organizations are part of the Wildlife Animal Protection Forum South Africa

(WAPFSA), an alliance of diverse organizations that share certain values, knowledge, and

objectives and that collectively comprise a body of expertise from scientific, conservation,

legal, welfare, rights, social justice, faith, and public advocacy sectors.

We welcome this opportunity to comment on this Draft and to review the existing legislation.

In particular, we welcome the initiative of replacing the current Provincial Ordinance, on the

terms that this is done in accordance with our TOPS and NEMBA regulation.

Please note that this submission has attached Annexure I, II III and IV:

Annexure I Lion Bone Judgement

Annexure II Submission of Whale Coast Conservation

Annexure III Submission of Humane Society International South Africa

Annexure IV Submission of Landmark Foundation

We want to highlight the importance of today’s Lion Bone Judgement1 which has major

implications for CapeNature and the issuing of permits to facilities keeping captive wildlife

and offering wildlife/human interaction2. We request a moratorium on issuing of permits

1 Annexure I – Lion Bone Judgement 2 https://conservationaction.co.za/media-articles/ruling-that-lion-skeleton-export-quotas-are-illegal-is-a-victory-for-ethical-conservation/.

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until processes and procedures will be in place to implement the judjment which we reqest

you to incorporate into the Biodiversity Bill.

1. GENERAL CONSIDERATIONS

The Global Assessment Report on Biodiversity and Ecosystem Services3, a summary of which

was published recently by the Intergovernmental Science-Policy Platform on Biodiversity and

Ecosystem Services has highlighted the unprecedented crisis facing the world’s biodiversity.

Furthermore, a recent study published in the journal, Nature Ecology and Evolution,

highlights that 37 of the 600 plant species which have gone extinct since 1900, were in the

Western Cape. This shows that the Western Cape is one of the hot spots for plant extinction

on the planet.4

In addition, the Western Cape hosts the smallest of the six world floral kingdoms, i.e. limited

areas with a high concentration of relatively similar, but distinctive species. In particular, the

Cape Flora has a very high density of species that occur nowhere else on earth, and any

impacts in the area have a very disproportionate impact on species. In a recent interview, Dr.

Tony Rebelo of SANBI (South African Natural Biodiversity Institute), said that the extinction of

these unique plants has a knock-on effect: without their habitats, animals are also

disappearing. He also mentioned that fish and amphibians are particularly badly affected. The

impact on insects still needs more in-depth assessment, but according to Dr. Rebelo, this

category of animals “appears to be in dire straits”.

Future challenges require not only continuity, but also radical changes, if we are serious

about protecting our biodiversity and, most of all, about meeting our international

commitments: the South African government is a signatory to the United Nations Agenda

2030 Sustainable Development which launched in New York on September 25-27, 2015. In

the Agenda, there are 17 “Sustainable Development Goals (SDGs) that are all interconnected,

with “Climate Action” being number 13, “Life below the Water” being number 14 and “life on

land” being number 15.5

3 https://www.ipbes.net/global-assessment-report-biodiversity-ecosystem-services 4 https://www.nature.com/articles/s41559-019-0906-2.epdf?shared_access_token=IWH2yPE3-seGeBbwxPiAztRgN0jAjWel9jnR3ZoTv0MjshkozOI4RClIULpuoSBETZ6eu7hTz0zAj-zrWJ2MhobrWExV0XhYpkPZWYtIRTaSjETR9NiA_ynX78h8l5tALwOT9TbEsvXOFrzfUS8DOA%3D%3D 5 https://www.un.org/sustainabledevelopment/development-agenda/

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Transformative changes are required to restore and protect nature, and the opposition from

vested interests must be minimised

2. "ECOLOGICALLY SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES"

DOES NOT MEAN “ECONOMICALLY SUSTAINABLE CONSUMPTION”

While the Global Assessment Report on Biodiversity and Ecosystem Services has identified

Economic Exploitation as one of the key drivers of biodiversity loss, section 24 of our

Constitution gives us “the right to an environment that is not harmful to our health or well-

being, to have our environment protected, for the benefit of present and future generations;

through reasonable legislative and other measures that prevent pollution and ecological

degradation, promote conservation and secure ecologically sustainable development and use

of natural resources, while promoting justifiable economic and social development.”

This provision, which meant to strike a balance between the protection of our vital resources

and responsible low impact development, has slowly and very controversially been

interpreted as 'consumptive'. The term “use” has gradually prevailed on the imperative to

preserve, whilst more and more often, private economic “returns and short term individual

benefits” has overtaken the need to respect public interests on the sustainability of the

environment for the benefit and wellbeing of present and future generations, and ultimately

for the survival of our own species.6

We believe this Bill should highlight the increasing scarcity of our resources and the

unsustainability of our consumptive habits. Furthermore, the Bill should clarify that the

majority of our daily practices are harming the environment, jeopardizing our health,

polluting and degrading our environment, depleting the biodiversity we rely on and putting

at risk our well-being and also the survival of future generation; these patterns are clearly

unconstitutional.

3. FURTHER ISSUES TO ADDRESS IN THIS BILL

We are particularly concerned by the fact that there is no clear mention of the following very

important points, which we view as essential:

a. There is no definition of the word “research”. This word can be used ambiguously to

justify commercial activities under the guise of scientific purposes.

6 https://researchspace.ukzn.ac.za/handle/10413/12290

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b. There is no definition of the expressions “resources”, “biological resources” or

“indigenous biological resources”. This is problematic and it allows for the consumptive

use of species for profit.

c. There are no clear definitions regarding: 1. Private Reserves, 2 Sanctuaries, 3. Game

Farms / Game Ranches. In this regard, we fully endorse the submission of Whale Coast

Conservation7.

d. It is problematic that the Bill does not take into consideration that all animals have

intrinsic value, no matter the population numbers. There should be no discrimination in

the intrinsic value of ‘rare’ and ‘common’ animal species. Organisms and species should

not have to be useful to have value.

e. The Bill does not restrict activities or regulate the management of captive wildlife in

terms of welfare and wellbeing. We are gravely concerned that within this draft, there is

no reference to any animal welfare legislation as defined in the Animal Protection Act

71 of 1962 and Act 7 of 1991. We oppose the use of poisons to kill animals , as stated in

the Bill. It is illegal to use an unregistered product on animals regardless and it is illegal

to use a registered product on an animal for which it has not been manufactured for,

e.g. the usage of a registered rodenticide to kill bats or the use of an illegal

deregistered substance such as two- step on any animal8. The Bill should highlight how

threatened and protected species classified as problem animals will be controlled, and

which organisations will be called upon to deal with the illegal usage of poisons and

the cruelty aspect resulting from the usage of the illegal poisons on animals.9

f. The bill should clearly define what ‘responsible’ tourism means in terms of

environmental impacts and animal cruelty. The exploitative use of wildlife has been

identified as a major cause of tourism decline in the last two years10. The international

community is becoming more responsible in choosing destinations that do not exploit

wildlife, i.e. elephant rides, lion cub petting, snake handling, etc.

g. The trade of flora and fauna is regulated by CITES (Convention of Trade in Endangered

Species Fauna and Flora) a treaty which fails to acknowledge and take into account the

crisis due to the following major threats:

7 Annexure II: Submission of WCC 8 National Environmental Management: Biodiversity Act, No. 10 of 2004 (NEMBA) and the Threatened and Protected Species Regulations (TOPS) 9 Medicines and Related Substances Control Act, 1965 (Act 101 of 1965), or the Hazardous Substances Act, 1973 (Act 15 of 1973) 10 https://www.thesouthafrican.com/travel/tourism-in-south-africa-on-the-decline-2019/

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o Biodiversity loss due to climate change, and

o the illegal traffic of species via social media.

o Having no systems in place to identify wild species from captive bred animals;

plants harvested from the wild or grown in a nursery. Illegal harvesting is

blurred by legal harvesting.

The Bill should err on the side of extreme caution when it comes to trading our

precious fauna and flora.

h. The province faced a huge crisis due to the 2015-17 drought. The consumptive use of

water and unregulated welling is not sufficiently controlled. Global warming is a reality,

and all decisions should be driven by this reality. The Bill has not identified what

measures will be adopted to avoid/manage major disasters, and what measures will be

taken to mitigate the effects of such disasters. Cape Nature should publish which

departments will be managing these issues, and what penalties, if any, will be incurred

for non-compliance.

i. Abandoned fences and barriers have a negative impact on biodiversity. The duty to

remove abandoned or unauthorized and potentially harmful fences, barriers,

infrastructures should be added in section “Duties of CapeNature”11.

j. Given the fragility of the ecosystems in the Cape Province, special importance must be

given to the management of alien species. Non-native plants and exotic animals are a

major issue, threatening ecosystems and habitats. Travel, transport and tourism have

allowed invasive species to become established and, in many cases, these species have

proliferated. Climate change and human mobility have fundamentally altered the

biological world in which we live.

k. The Bill is unclear on the management/prevention of ecological disturbances to land,

air or water which are threatening species and affecting an ecosystems ability to

survive. Clarification is needed on what efforts will be made to recover ecosystems that

have been degraded, damaged, or destroyed, i. e. the repairing and replanting of

wetlands, forests and other habitats. Land usage should be carefully evaluated in

favour of restoration of indigenous and protected areas.

11 Large-scale fences can cause ecological meltdown, https://www.sciencedaily.com/releases/2014/04/140403154506.htm

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The Bill does not include appropriate measures to implement in case of disasters –

droughts, fires, and oil spills in marine areas, and it does not list the different bodies

that procedures will be delegated to.

l. The Draft “Management of Damage Causing Animals (DCA)” at national level has never

been approved after a Public Process was initiated in 2016. The mitigation of conflicts

and humane management of so-called Problem Animals is a complex issue that has

not been adequately addressed. We urge legislators to frame the DCAs issue in a

detailed manner. The use of inhumane and indiscriminate traps and poisons, and of

invasive strategies like the removal of individuals versus relocation, are outdated,

ineffective and cruel. In this regard, we fully endorse the 2016 submissions of HSI12 and

Landmark Foundation13 in favour of modern/effective/ less invasive methods.

m. The Western Cape hosts a considerable variety of urban wildlife14 including

endangered species, such as the Western Leopard Toad15. There is no mention in the

Bill of any measures to protect urban ecosystems and wildlife in urban landscapes and

contests, nor of the restoration of ecosystems that have been impacted by humans

within or near cities. Urbanisation can degrade and destroy complex webs of life. The

Bill should be clear of the measures that will be taken to avoid further impact by way of

any future developments and the management of remnant patches of urban nature.

Urban streams and rivers should be included in all efforts of restoration.

n. There is no mention of measures that will discourage human/wildlife conflicts in urban

surroundings. It is our submission that implementation of preventive strategies must be

included in the Bill, e.g the supply of baboon-proof rubbish bins in hot-spot areas.

Such programs cannot be left in the hands of municipalities or other institutions and

must be included in this Biodiversity Bill. The Bill should further include non-lethal

methods for controlling so-called damage causing animals, with the option of

relocation to safer areas before resorting to lethal methods of 'control'.

o. The lack of specific regulations in terms of hunting, fishing and other consumptive

activities is concerning, as the Bill only mentions the need to hunt with a PH.

12 Annexure III – Submission Humane Society International 13 Annexure IV - Submission Landmark Foundation 14 https://africageographic.com/blog/cape-towns-urban-wildlife-nine-species/ 15 https://www.capenature.co.za/fauna-and-flora/western-leopard-toad/

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(Professional Hunter) The Bill does not say what mechanisms are in place for fish

restoration, management and conservation, or for that matter, indigenous wildlife, or

how this restoration will be funded. These important issues must be addressed.

p. There are no indications in the Bill with regards to the depletion of wildlife through

activities such as:

Land Development

Ranching and livestock grazing in wildlife habitat

Deforestation due to ranching, livestock grazing and growing feed for livestock

How will this activity be monitored and managed in order to lessen the further

loss of biodiversity?

q. The Bill does not address the impact of animal farming on the environment16, nor the

impact of pollution, the use of pesticides, herbicides, insecticides, toxic chemicals,

antibiotics and fertilizers resulting in the serious loss of insects, fish and wildlife, and

forests17. The water systems (oceans, rivers, lakes, wetlands and streams) are under

threat too. Ecosystems are being destroyed to make way for animal farming on a

growing scale, and if South Africa is to achieve its SDGs targets by 2030, these issues

must be addressed urgently. According to Climate Change Tracker, South Africa’s NDC

includes an overarching goal for emissions to “peak, plateau and decline” from the end

of 2020 -the emphasis being on carbon dioxide, methane and nitrous oxide. The

introduction of investment in renewable energy and the implementation of a national

carbon tax is now more urgent than ever. We submit that the implementation of an

eco-tax on meat and dairy products will contribute to harnessing the harmful effects of

animal agricultural. The Bill must address these matters.18

r. It is noted with concern that this draft normative fails to address other disturbing

issues with regards to the different departments addressing certain matters, e.g.

Urban wildlife is regulated by the Cape Town City Council, but sometimes

responsibility is devolved to CapeNature, and vice versa.

16 http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&ved=2ahUKEwil89a_kujjAhWTo3EKHTtXB10QFjADegQIAhAC&url=http%3A%2F%2Fwww.fao.org%2Fag%2Fagainfo%2Fhome%2Fevents%2Fbangkok2007%2Fdocs%2Fpart2%2F2_2.pdf&usg=AOvVaw1_cvpJFcJfjh858pl0OpfR 17 https://www.google.com/search?ei=VEJGXdbEDYL6wALAvqaoCA&q=effect+of+pesticides+on+environment+pdf&oq=impact+of+pesticides+on+environment&gs_l=psy-ab.1.0.0i71l8.0.0..57654...0.0..0.0.0.......0......gws-wiz.jwUeIQKjJiw 18 https://climatepolicytracker.org/countries/south-africa/

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Farmed animals including wildlife is regulated by the Department of Agriculture.

Rhinos, Crocodiles, Ostriches (wildlife) are farmed as commodities, yet exported

via CITES. But domestic farmed animals (sheep, cattle goats) do not need

permitting under CITES.

The lion bone trade is regulated by the Department of Environmental Affairs

and exported via CITES, but welfare issues are addressed by the Department of

Agriculture.

The Health Department regulates the exports of meat and animal products for

export.

We submit that the authority on wildlife and environmental management should see

CapeNature prevailing over other departments so as to be accountable on all issues.

4. THE FORGOTTEN OCEANS

We are extremely concerned by the lack of regulation of marine systems and oceans.

We submit that the Sea Shore Act 193519 is outdated, and that a new act should be drafted

urgently.

In the recent UN “11 years left”20 report lists that:

· 33% of marine fish stocks in 2015 have been harvested at unsustainable levels;

· more than 55% of the ocean area is covered by industrial fishing;

· there will be a significant (25%) decline in ocean species in the next few decades;

· 90% of global fish catch is done by big scale fisheries; e. 33% of the world’s reported

fish catch is illegal, unreported or unregulated.

Among the more urgent actions the Bill should include:

a. An increase in the monitoring of our oceans and enforcement to avoid illegal

activities;

b. Regular Assessment of biodiversity and populations through independent

monitoring;

c. Drafting of specific procedures to prevent destructive events like oil spills, pollutant

leaks and contaminations;

d. Setting adequate infrastructures to mitigate the effects of such incidents;

e. Drastically reducing industrial fishing and permits in favour of local small fisheries;

19 https://www.gov.za/documents/sea-shore-act-10-apr-2015-0000 20 https://www.un.org/press/en/2019/ga12131.doc.htm

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f. Protecting whale breeding routes, which will have a positive impact on the growth

of the tourism industry and employment creation;

g. Giving conservation authorities the power to restrict and enforce limitations to

industries regarding the use and disposal of items identified as environmentally

harmful, such as chemicals, oils, non-bio-degradable gears for land and marine

use. This must include, barriers, nets, trapping devices or materials as food nets,

plastic, polystyrene, etc.;

h. Addressing the issue of cities’ raw sewage fallouts: off Cape Town coasts (and

supposedly near other cities), 40 million litres of untreated sewage per day21 with

all the added content of chemicals, disinfectants and oils, pour straight into the

ocean from the submerged outfall pipes located about 1.4 km offshore Sea Point,

Camps Bay and Hout Bay. A Council of Scientific and Industrial Research (CSIR)

report in 2017 indicated that no immediate ecological disaster was imminent as a

result of effluent discharge through the Cape Town outfalls, but specified that this

did not mean that there were no ecological impacts and human health risks

associated with this practice. We submit that conservation authorities must be

given the authority to monitor, restrict and ban activities that degrade the

environment and biodiversity;

i. Addressing plastic pollution: Whales, seals, birds and microscopic marine

organisms are affected and plastic is destroying biodiversity. According to the

National Oceanographic and Atmospheric Administration, plastic debris kills an

estimated 100,000 marine mammals annually, which is one mammal every 8

seconds, as well as millions of birds and fish. The report states that fishing nets

accounted for 46% of all ocean plastic. (Add Reference here). Conservation

authorities and legislators must support the government in implementing as a

matter of urgency a ban on single-use plastic; and

j. Addressing cigarette butt pollution, which is one of the most commonly

discarded types of litter and the most frequent item of litter found on beaches. Of

particular environmental concern is the fact the filters used in cigarettes are not

biodegradable because they are made out of cellulose acetate -a form of plastic.

They can take months or even years to break down into smaller pieces, but will not

biodegrade. The tobacco remnant is biodegradable because it is made of plant

material, but it is still poisonous to humans, animals, aquatic organisms and the

environment.22

21 https://www.bigissue.org.za/how-we-are-soiling-the-sea 22 https://www.who.int/en/news-room/detail/30-05-2017-world-no-tobacco-day-2017-beating-tobacco-for-health-

prosperity-the-environment-and-national-development.

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5. SPECIFIC COMMENTS TO THE DRAFT

Paragraph Page Draft Comment

Scope of the

Draft

Page 2 To provide for the framework and institutions for

nature conservation and the protection,

management and sustainable use of biodiversity

and ecosystems in the Province; and for matters

incidental thereto.

It should read: To

provide for the

framework and

instruction to face the

current crisis in eco-

systems, to allow only

environmentally and

biologically

sustainable

development and

implement protected

areas for the resilience

and recovery of

biodiversity and for

the responsible use of

essential resources.

Preamble Page 2 secure ecologically sustainable development and

use of natural resources while promoting

justifiable economic and social development;

See above

Preamble Page 2 the different organs of state must act in

accordance with the principles of cooperative

government and intergovernmental relations and

make decisions that affect the environment in a

coordinated and holistic manner;

This is very important

but it often becomes a

tool to shift

responsibilities and

accountability.

Normative should

define clearly roles

and duties.

Preamble Page 2 to ensure long term ecological resilience Add: and biodiversity

recovery

Chapter 1,

Definitions

Page 13 “resilience”, in relation to an ecosystem or

ecological infrastructure, means the ability of the

ecosystem or ecological infrastructure to

withstand disturbances thereto while retaining

the same basic structure and functioning, the

capacity for self-organisation and the capacity to

adapt to stress or change;

We submit that the

concept of

Biodiversity

“Recovery” must be

included, since it

should not simply be

an adaptation process.

Chapter 1,

Definitions

Page 14 “sustainable” means the use of, or impact on,

biodiversity or ecosystems or ecosystem services

in a way and at a rate that— (a) will not lead to

The expression

“sustainable use” is

not in our constitution

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its long-term decline and which can be sustained

indefinitely without causing adverse effects

thereon; (b) will not disrupt its ecological

integrity; and (c) ensures its continued

persistence to meet the needs and aspirations of

present and future generations of people

as earlier commented

in this submission.

Expressions such as

“sustainable use of

minerals” “sustainable

oil drilling, mining,

fracking” have been

largely used and

abused by privately-

owned companies.

Once minerals, oil,

gold etc are removed

they cannot be

farmed or grown.

These activities cannot

be termed

‘sustainable’. A tree is

sustainable if it

matures at the same

time one is harvested.

These practices are

destroying natural and

vital resources and the

expressions are

incompatible with the

scope of this bill.

Chapter 1

Objectives

Page 15 (c) ensure the long-term ecological sustainability

and resilience of biodiversity, ecosystems,

ecosystem services and ecological infrastructure

through implementation of the principles of

ecological sustainability contemplated in section

6

Add: “Recovery” of

biodiversity.

(e) enable reasonable and sustainable access to

benefits and opportunities emanating from the

conservation of protected areas, biodiversity,

ecosystems, ecosystem services and ecological

infrastructure;

Opportunities must

not create disturbance

or be harmful.

Chapter 2,

Principles of

ecological

sustainability

Page 16 6. Every organ of state whose decisions or actions

may affect biodiversity or the environment in the

Province must apply the principles of ecological

sustainability, which are to– (a) take account of

the benefits and intrinsic and use value of natural

resources and ecosystems; (b) ensure that

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biodiversity and ecosystems are protected,

maintained and rehabilitated in a manner that

enables the attainment of biodiversity targets for

conservation set by the Province; (c) promote the

resilience of biodiversity, ecosystems and

ecological infrastructure; (d) ensure that

development does not undermine the long-term

persistence and resilience of biodiversity,

ecosystems and ecological infrastructure; (e)

ensure that the conservation and resilience of

biodiversity for the benefit of present and future

generations are given priority over the interests

of any member or members of any community;

(f) avoid, or minimise and remedy, the

disturbance of ecosystems and loss of biological

diversity; (g) ensure that a risk-averse and

cautious approach is applied, so that where there

is insufficient evidence that an activity will not

cause a long-term adverse effect, it should be

avoided.

Include marine

Include:

Reduce consumptive

use

Disturbance should be

avoided, not simply

minimized.

Preventative and

rescue measures and

infrastructures to

practically enforce

such mitigation

actions should be

carefully planned.

Chapter 3,

Duties of

Head of

Department

Page 17 (d) promotion and development of the

biodiversity economy

Add: for the

protection, versus the

consumptive use of

biodiversity.

Chapter 3,

Duties of

Head of

Department

Page 17 (d) (i) the alignment of strategic and annual plans

and associated programme budgets for nature

conservation, biodiversity, and coastal and

estuarine management, and the promotion and

development of the biodiversity economy in the

Province

The coasts are

important but

budgets should

include the

monitoring of marine

reserves, surface,

under surface and sea

beds’ biodiversity,

even out at sea.

There are major issues

with illegal activities

carried out in our

waters.

Chapter 4,

Establishments

Pag 18 9. The Western Cape Nature Conservation Board

as established by the Western Cape Nature

Not only conservation

but also resilience.

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Conservation Board Act continues in existence as

a juristic person and a provincial public entity

responsible for the conservation of biodiversity in

the Province, and is known as CapeNature.

The theory announced

in the previous

chapters is not

included here, where

the duties of CN are

listed

Chapter 4

Duties of Cape

Nature

Page 18 10. (1) (b) manage provincial protected areas and

other areas where it is designated as the

management authority;

It should read:

Manage and promote

the recovery and

resilience of …

Chapter 4

Duties of Cape

Nature

(g) establish a system for monitoring and

reporting on—

(iii) the sustainable use of indigenous biological

resources;

It should read: the

biologically

sustainable and non-

consumptive use of

essential biological

resources.

Chapter 4

Duties of Cape

Nature

(g) (iv) the management of provincial protected

areas, protected environments, private nature

reserves, mountain catchment areas and

biodiversity stewardship areas;

Add wildlife in urban

context , rivers,

beaches and the

ocean .

Chapter 4

Duties of Cape

Nature

Page 19 (h) prepare biodiversity management plans as

contemplated in section 43 of the Biodiversity

Act;

Also emergency plan

Institute bodies for the

rescue / mitigation.

Chapter 4

Duties of Cape

Nature

Page 19 (j) advise the Provincial Minister on the export of

indigenous biological resources for research;

Problematic

statement, because

research could include

also the trade in wild

animals for breeding

programs / zoos. This

must be deleted, as

there is no actual

need to research our

indigenous species

abroad.

Chapter 4

Duties of Cape

Nature

Page 19 (1) (l) report to the Provincial Minister on the state

of biodiversity in the Province within two years of

this Act coming into effect and at intervals of not

more than four years thereafter, as required by

the Provincial Minister

We are in a crisis, it

must be every year.

Chapter 4

Duties of Cape

Nature

Page 19 (1) (m) on land managed by CapeNature,

manage, conserve and promote natural and

related cultural heritage resources through best

practice, access and benefit sharing, and

More specific in

favour of fragile

communities, and not

for the benefit of

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sustainable use practices. industries and private

interests.

Again, “sustainable

use” is an incomplete

and problematic

expression.

Chapter 4

Duties of Cape

Nature

Pag 19 (4) (d) environmental awareness, education and

youth development.

This should be

emphasized and

described more in

detail.

Chapter 4

Powers of

Cape Nature

Page

20

(11) (2) (j) in areas under its control, take

measures that are necessary for the safety of

visitors and the conservation of biodiversity;

Non Invasive

measures, also for the

safety of indigenous

species.

Chapter 4

Powers of

Cape Nature

Page

20

(11) (2) (k) maintain, construct or erect

infrastructure

Eco-friendly non

disruptive

infrastructures,

attention should be

given to the use of

only non-invasive

fences and to the

removal of

abandoned fences.

Chapter 4

Powers of

Cape Nature

Page

20

(11) (4) CapeNature may at any time, in relation to

any specimen of any species, undertake or

authorise any action, including a restricted

activity or restricted method if the specimen—

(a) poses an imminent threat of injury or death to

humans or any domesticated species;

This is problematic.

Compensation for

damage can be

arranged. Government

and NGOs can work

together on such

issues and find

solutions.

Owners should have

the obligation to

protect domestic

animals in their care.

There should be a

documented history

of repeated damages

and incidents and

non-invasive

procedures should be

followed before the

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

15 | P a g e

removal, including the

relocation of DCA

carried out by

external NGOs with

the expertise on

different species.

Chapter 4

Powers of

Cape Nature

Page

20

(b) is wounded, diseased or injured;

(c) is causing damage to crops or plants on

cultivated land or other property;

(d) has or may have an adverse effect on

indigenous species, ecosystems or the

environment; or

(e) should be captured or killed in the interests of

conservation.

Killing should be a last

resource, see above.

Killing of such animals,

when all measures

have been

unsuccessfully applied,

should be carried out

by rangers and not by

hunters.

Chapter 4

Powers of

Cape Nature

Page

20

(5) If a wild animal is captured or injured during a

hunt, CapeNature may, if it is not able to

establish the identity of the owner, kill the animal

and destroy the carcass.

This is problematic,

especially in terms of

TOPS species and

especially when there

are external

organizations able to

help.

Why is there a need

for such rapid

destruction of

animals?

Chapter 5

Purpose of

Biodiversity

Spatial Plan

Page

28

35. The purpose of a Biodiversity Spatial Plan is

to—

(d) environmentally sustainable development,

resource use and ecological and spatial resilience

in the Province

It should read:

environmentally

biologically

sustainable

development and

spatial acquisition for

the resilience and

recovery of

biodiversity and for

the responsible use of

essential resources.

Chapter 6

Part 1

Provincial

Protected

Areas

Page

29

(2) CapeNature must, after consultation with the

Head of Department, prepare a draft Provincial

Protected Areas Expansion Strategy within two

years of the commencement of this Act and

submit it to the Provincial Minister for adoption.

It is crucial to define

the difference

between Protected

Areas, Private Game

Farm and Sanctuaries.

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

16 | P a g e

Expansion

Strategy

Permits should

evaluate impacts,

biological and welfare

/ reputational

implications.

Chapter 6

Part 2

Declaration of

mountain

catchment

areas

Page

29

(2) The Provincial Minister may make a

declaration in terms of subsection (1)(a) if the

control and management of activities and

resources in the area concerned are required

to—

(b) sustain the provision of ecosystem services,

particularly water provisioning;

Investments should be

done to manage alien

species which cause

water resources

reduction.

Restrictions to water

extractions must be

applied.

Chapter 6

Part 2

Declaration of

mountain

catchment

areas

Page

29

(2) (c) ensure that the use of ecosystem services

in the area is sustainable.

Ecologically and

biologically

sustainable

Chapter 6

Part 3

Declaration of

Private Nature

Reserves

Page 31 (42) (6) The Provincial Minister— (a) may approve

an application contemplated in subsection

(5)(b)(i) with or without conditions, or refuse it;

Due to the ecological

impact and welfare

implications, formal

Public Processes must

be implemented and

followed for the

approval of any

private reserve which

exploits wildlife for

commercial returns.

Also, a clear

distinction must be

made between

Sanctuaries and

Private Game

Reserves and Wildlife

Farms.

Chapter 6

Part 3

Declaration of

Private Nature

Reserves

Page 31 (42) (5) The owner of a private nature reserve

may— (a) advertise the private nature reserve as

a private nature reserve;

Advertisements

should be regulated

since the use of

misleading words is

common practice and

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

17 | P a g e

this badly affects our

reputation as a

touristic destination.

Private zoos and

breeding farms are

constantly advertised

as sanctuaries and

rehabilitation facilities,

when they are in fact

commercial

businesses.

Chapter 6

Part 4

Biodiversity

stewardship

Page

32

(43) (3) CapeNature must monitor the status of

biodiversity stewardship agreements and

biodiversity stewardship areas and report

annually to the Provincial Minister thereon.

(4) If a landowner who is party to a biodiversity

stewardship agreement breaches that agreement,

the Provincial Minister may impose an

administrative penalty in terms of section 73.

This paragraph is

concerning as it does

not include any

serious enforcement

strategy and no

accountability.

Chapter 6

Part 5

Management

of biosphere

reserves

Page

32

(2) The management committee must—

(a) ensure that the biosphere reserve fulfils its

conservation, sustainable development and

operational functions;

It should read:

Conservation,

protection, restoration

and resilience through

only biologically

sustainable

development and

ecological low impact

operational functions

Chapter 7

Species in

need of

protection or

posing threat

to

environment

Page

35

(50) (4) No person may carry out a restricted

activity or restricted method involving a listed

species, unless authorised to do so in terms of

section 53(1)(a).

There are numerous

NGOs which have the

expertise and financial

power to

professionally and

humanely relocate

animals who pose

threat to humans or

the environment.

These organizations

must be appointed to

do so.

Chapter 8

Professional

Page

35

51. (1) No person may provide any service as a

professional hunter, hunting outfitter or Director

Hunting is a

controversial issue

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

18 | P a g e

Hunting of a Professional Hunting School unless he or she

is authorised to do so in terms of section 53(1)(a).

and it is poorly

addressed in the draft.

Hunting must be

amended to include

recreational fishing.

Chapter 10

Enforcement

Part 1

General

powers of

nature

conservation

officers and

nature

conservation

rangers

Page

39

(64) (k) seize and remove any trap, holding pen,

poison or other device which is reasonably

suspected to be used to hunt or capture a wild

animal unlawfully or, if it cannot be seized and

removed, destroy it or render it harmless;

The accountability of

such infractions is not

specified. The

potential damage

should be clearly

quantified, and those

involved must be

charged, since placing

harmful devices is a

deliberate action.

Chapter 10

Enforcement

Part 1

General

powers of

nature

conservation

officers and

nature

conservation

rangers

Page

39

(64) (l) seize and remove any livestock or other

animal trespassing on land under the control of

CapeNature;

There are numerous

NGOs that have the

expertise and financial

power to

professionally and

humanely relocate

animals who pose

threat to humans or

the environment.

These organizations

must be appointed to

do so.

6. RECCOMENDATIONS

The diminishing of biodiversity, and the ongoing climate change emergency, is caused

directly by human interference and increasing demands on our resources, and if these issues

are not addressed and managed by the authorities in government who are mandated to

protect these resources in a sustainable manner for future generations, we are failing in

playing our part in the global village of contributing to the planets’ ability to ensure human

survival.

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

19 | P a g e

We endorse the recommendations of Whale Coast Conservation:

a. CapeNature must receive adequate funding from government to fulfil its primary

purpose of protecting biodiversity.

b. The proposed Bill must uphold the priority given in the Constitution to the protection

of the environment before development, and CapeNature should be an institutional

example of doing so.23

Furthermore, we recommend the following:

c. Restrict future land development for farming and urban development and encourage

restoration of ecosystems damaged or degraded by said developments.

d. Restrict livestock grazing in wildlife habitats.

e. Restrict deforestation due to ranching, dairy farming, livestock grazing and growing

feed for livestock

f. Halt the pollution from sewerage, trash, plastics, agricultural toxins and waste,

industrial and commercial waste, exhaust and emissions.

g. Stop overfishing of aquatic species.

h. Halt the use of pesticides, herbicides, insecticides, toxic chemicals

i. We encourage CapeNature to improve and enhance associated law enforcement

departments.

j. We encourage CapeNature to engage with NGOs.

It is vital that South Africa works with United Nations Environmental Programme, United

Nations Agenda 2030, African Union Agenda 2036, and all other organisations including

national stakeholders. Importantly, we urge CapeNature to veer away from consumptive

utilisation and international trade in wildlife, taking into consideration that the international

communities are mounting pressure on irresponsible countries to make better decisions on

these issues and the negative implications these issues are causing to our continued,

sustainable biodiversity in the country, which is strategically placed as one of the most

important countries in this regard.

23 Whale Coast Conservation Submission to the WC Biodiversity conservation – Annexure I

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

20 | P a g e

Please acknowledge receipt of this submission to:

Stefania Falcon

stefania@emsfoundation.org.za

Mobile 0027 733012107

IN BEHALF OF THE FOLLOWING WAPFSA MEMBERS:

Baboon Matters Founder Jenni Trethowan

Ban Animal Trading Director Smaragda Louw

Baboons of the South Founder Lorraine Holloway

Beauty Without Cruelty (South Africa) Chairperson Toni Brockhoven

Centre for Animal Rehabilitation and Education Director Samantha Dewhirst

EMS Foundation Director Michele Pickover

Four Paws (SA) Director Fiona Miles

Future 4 Wildlife Founder Stefania Falcon

Global March for Elephants and Rhinos Vice - Director Megan Carr

Global White Lion Protection Trust CEO Founder Linda Tucker

Institute for Critical Animal Studies (Africa) Director Les Mitchell

Landmark Foundation Director Bool Smuts

Monkey Helpline Co-Founder Steve Smit

OSCAP (Outraged South African Citizens Against Poaching) Director Kim Da Ribeira

Sea Shepherd South Africa Nat. Coordinator Prathna Singh

Southern African Fight for Rhinos Director Lex Abnett

Vervet Monkey Foundation Founder Dave Du Toit

Voice 4 Lions Director Linda Park

WildAid Southern Africa Director Guy Jennings

WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

21 | P a g e

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