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An Open Letter to the Minister of the Environment, Forestry and Fisheries Barbara Creecy


Dear Honourable Minister Creecy,

Since at least as far back as the late 1990s, various NGOs have warned your department about the harmful and negative effects of breeding lions (and other big cats) in captivity. Yet, the South African government has done nothing to slow the growth of the captive lion breeding industry, nor has it given any indication of wanting to do so. This letter lays bare the facts and calls for immediate action.

First, it details the risks embedded in captive lion (and other big cat) breeding and why the industry should be terminated.

Second, we note that letter after letter to your Ministry and Department goes unheeded. It seems that industry voices – those with a vested interest in acquiring short-term benefits from exploitative breeding of lion (and other big cat) cubs for human interaction, canned hunting and the lion bone trade – provide the tune to which the policy fiddle dances.

Finally, tourism – the goose that lays the golden egg in the South African economy – is dead for the foreseeable future. Not only has South Africa’s willingness to supply Asian wildlife markets created zoonotic disease spillover risks, which have led to the need for travel bans, but the imposition of the latter means that thousands of captive lions (and other big cats) will now be left to starve to death without tourism dollars. Had the government acted in 2009 (when a plan was presented to your Department) and when there were far fewer lions (and other big cats) in captivity, this catastrophe would have been avoided.


Covid-19 can seem like a black-swan – a low-probability, high-risk event – but it has been crouching in plain sight since at least as far back as the Severe Acute Respiratory Syndrome (SARS) Corona virus. The risk of zoonotic disease spillover – transmission from wild animals to humans during the slaughtering process – is well documented. Specifically, the risk that lion TB will contaminate South African slaughterhouse workers is significant. Our healthcare system is already at breaking point in the functional provinces. In the dysfunctional provinces, where the majority of lion slaughter takes place (Free State, for instance), one more TB patient will likely be sent home to die. So much for the jobs purportedly supported by the captive breeding industry. Not only are workers at risk of disease contraction, but there is no legislation that governs the slaughtering or export process. On the demand side, South Africa risks exporting disease. We are almost certain that the intermediary host for Covid-19 was pangolin, an endangered mammal that continues to be the most trafficked in the world. Meanwhile, South Africa seems to be going out of its way to encourage trade in endangered wild animals, to the point of promoting captive lion (and other big cat) breeding under the banner of ‘sustainable use’. The ideology of commoditisation and consumption animates this policy and it needs to be abandoned.

Beyond the risk of exporting disease (given that South Africa exported a lion ‘carcass’ in 2019 – not a dry skeleton), we also seem to be satisfied that promoting captive lion (and other big cat) breeding is inadvertently promoting criminality. The 2019 export fell outside the legal 2017 and 2018 quotas. We were told that the 2019 carcass went out on a ‘replacement permit’ as quotas did not carry over. We also know that a number of carcasses exported out of South Africa during 2017 and 2018 were far heavier than the average weight of a skeleton, strongly suggesting that either more bones than an average skeleton were going out with those shipments, or the carcasses were still ‘wet’ (the spillover contamination risk being highest here). Also, South Africa’s known lion bone traders have strong links with criminal organisations. Despite extensive documented evidence of this, the government, along with the Scientific Authority that informs the minister’s decisions, appears to have ignored it as minor.

The risk to South Africa’s tourism and conservation reputations is also extensive and well documented but continues to be ignored. Despite a parliamentary resolution passed in December 2018 that the captive lion (and other big cat) breeding industry should be terminated, the minister has chosen to appoint a high-level panel (HLP) to address issues of lion, elephant, leopard and rhino management. But the panel is loaded with people who subscribe to the consumptive use paradigm that we have been at pains to point out is partly responsible for injecting Covid-19 risks into an already vulnerable system. Moreover, the terms of reference explicitly exclude the parliamentary instruction to terminate the industry. Indeed, how could the HLP follow that resolution when the CEO of the South African Predator Association is on the panel?

2. Who Is Calling The Shots?

Minister, we note that our policymakers appear eager to please industry players and indeed are willing to be held ransom to them. At a meeting hosted on the 24th June 2019, before the High Court declared (in August) the lion bone skeleton export quotas retrospectively illegal, the Scientific Authority decreed that it would accept as influential only scientific journal articles with an impact factor. Expert opinions came next, followed by ‘grey literature’ (even those reports with meticulous research). The only serious journal article on the captive lion breeding industry that counts in respect of the first ‘box’ is a PLOSOne article written by Michael ‘t sas-Rolfes and Vivienne Williams in 2019, which defended the industry as a kind of necessary evil, essentially on the grounds that survey respondents – purportedly industry players – had indicated that if the legal quotas were too restrictive, breeders would find ‘alternative markets’ for their products. This sounds to us like policymakers are more willing to be held ransom by industry interests than to be guided by the potential risks to South Africa’s reputation of condoning an industry that trades in false pretexts and death. Volunteer tourists are invariably lied to about the origin and future destination of captive-bred cubs, and facilities offering human interaction with lions invariably defend the practice on ‘conservation’ grounds despite there being no evidence to support such assertions.

Even the International Union for the Conservation of Nature (IUCN), along with almost every global conservation group, has called for termination of the captive lion breeding industry. Letter after letter is ignored, and the strategy appears to be ostrich like, but one cannot bury one’s head in the sand and hope that this problem will simply disappear.

3. The Welfare Fallout of COVID-19 on Big Cats in Captivity

The tourist industry is currently non-existent. This is why it is best to leave wild lions to be wild instead of attempting to domesticate and/or exploit them to satisfy human greed. The entire captive lion (and other big cat) breeding industry relies on tourism in one form or another. From renting or selling of cubs to facilities that attract tourism on interaction marketing, to canned hunting, tourists feed the industry. And the bone trade, at least initially, was a by-product of the canned hunting sector of the revenue chain.

At least as far back as 2009, various organisations proposed plans to the government for how best to terminate the industry. It was difficult but possible to do so in a humane way, then, when there were only three or four thousand lions. But the government ignored the recommendations. With an estimated 8,000 – 12 000 big cats now, it is far more challenging.

Minister, your government has chosen to view captive lions (and other big cats) as mere ‘faunal biological resources’ instead of as living beings with their own interests. The industry was allowed to flourish because a few peoples were making money (while employing less than 600 people, according to the best available estimates available). Now, without tourism revenue, and an already appalling welfare record, thousands of captive lions are going to be left to starve. This is a catastrophe that could have been avoided.

Minister, a major part of the point of this letter is to ask what your actual plan is to address the serious welfare risks that are now in play and is now an emergency. Your past strategy has been to defer welfare issues to the Ministry of Agriculture, which appears to have snuck the listing of lions and over thirty other wild animals onto the domestication list in the Animal Improvement Act amendments. But the Ministry of Agriculture does not want to deal with captive lions (and other big cats) as it doesn’t see it as its problem. On the health risks posed to consumers and workers, your strategy appears to be that the Health ministry should deal with the matter. But the health ministry is dealing with Covid-19, a direct result of the kind of consumptive mentality that animates your government’s policy position towards wildlife.

Ultimately, captive lion (and other big cat) breeding is a problem that sits squarely in your Department, as it issues the permits for captive lion (and other big cat) breeders or owners to operate. It is imperative that the departments of health, environment and agriculture come up with a plan to deal with the massive fallout that is about to occur from the absence of tourism through the nationwide lockdown. Please do give the nation some idea of what will be done to care for these captive lions (and other big cats) that have been reduced to faunal biological resources in callous policy documents.


Michele Pickover Director of the EMS Foundation