The EMS Foundation commends the ground breaking and forward thinking decision reached by SANBI and Minister Barbara Creecy with regard to Charlie. We will continue to offer our unwavering support as we continue our nineteen month transparent process with SANBI to establish the best possible future for Charlie with the support of the elephants experts from the Pro Elephant Network.
ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT FOR A PROPOSED OFFSHORE EXPLORATION WELL DRILLING IN BLOCK 5/6/7, SOUTH WEST COAST OF SOUTH AFRICA: TOTALENERGIES EP SOUTH AFRICA BLOCK 567 (PTY) LTD – COMMENTS ON SCOPING REPORT
The EMS Foundation is a registered Interested and Affected Party in respect of the proposed offshore exploration well drilling in block 5/6/7, South-West Coast, South Africa (“Project”).
SLR Consulting (South Africa) (Pty) Ltd (“SLR”) has been appointed by TotalEnergies EP South Africa Block 567 (Pty) Ltd (“TEEPSA”) as the environmental consultants for the Project and SLR is authorised to take responsibility for the public participation process (“PPP”) and to prepare the Environmental and Social Impact Assessment (“ESIA”) on TEEPSA’s behalf.
On behalf of the EMS Foundation, Environmental Law Firm Cullinan and Associates, provided general overarching comments on the Draft Scoping Report which should be considered during the preparation of the ESIA, as well as
comments on the proposed Specialist Reports and certain additional aspects which the EMS Foundation submits must be considered in such reports during the ESIA stage to ensure that all relevant information on the Project is placed before the decision-maker.
The EMS Foundation−a South African not-for-profit and a social justice organisation that promotes the rights and interests of vulnerable groups, particularly children, the elderly and wild animals−would like to bring to your urgent attention an environmental authorisation application by Total Energies EP South Africa Block 567 (Pty) Ltd (“TEEPSA”), and its partners Shell 40% and PetroSA 20%, to undertake exploration well drilling in Block 5/6/7 off the South West Coast of South Africa.
The area is located offshore roughly between Cape Town and Cape Agulhas, approximately 60km from the coast at its closest point in water depths between 700m and 3200m. The plan includes the drilling of one exploration well and success dependent, up to four additional wells, the objective of drilling exploration wells is to determine whether geological structures contain commercially viable oil or gas reserves.
The area of exploration includes critically endangered eco-systems and benthic habitats, close to eight Marine Protected Areas and twelve Critical Biodiversity Areas, along whale migratory routes and breeding areas and only a few nautical miles away from the penguin colonies of Boulders and Robben Island, and from the seals on Seal Island.
SLR Consulting (South Africa) has been appointed as the Independent Environmental Assessment Practitioner to undertake the Environmental and Social Impact Assessment (ESIA) processes for this proposed project.
The SLR Consulting scoping document indicates that there are predicted impacts and risks, including:
contribution to greenhouses gases (climate change);
reduction in air quality;
reduction in water quality;
displacement of fauna from important feeding and breeding sites;
physical seabed and benthic fauna / habitat disturbance;
destruction of eggs and larvae;
underwater continuous drilling noise;
disturbance of marine mammals;
reduction in fish populations;
displacement of fish;
impacts on local and industrial fishery;
drilling near a WWII explosive dump;
drilling in possible radioactive grounds;
drilling through toxic muds;
loss of equipment at sea;
Risks will also include oil pollution in sensitive coastal habitats and marine fauna, with the probable resultant reduction of income for secondary and tertiary sectors that support the local tourism industry, the fishing and other coastal economies.
Southern Africa was identified as a climate change hotspot in a 2018 Special Report published by the Intergovernmental Panel on Climate Change. Southern Africa is heating up and becoming drier at twice the global average rate, increasing the risks of public safety and food security.
Well-functioning terrestrial and marine ecosystems are crucial for regulating the climate. These systems currently absorb roughly half of all human created carbon emissions. positive role of megafauna such as whales in climate change resilience is the subject of peer reviewed studies.
The EMS Foundation urges you to write to TEEPSAfirstname.lastname@example.org and register as an Interested & Affected Party (I&AP) and raise your objections to the proposed project in its entirety.
The impacts on levels of illegal killing of elephants since the closure of China’s domestic market in 2017
Since 2015, when Chinese authorities first started to talk about imposing a domestic ivory ban (following on from then-US-president Obama indicating that the US would close its market), we saw ivory prices starting to fall. They peaked at about $1,200/kg in 2014 and the latest available data suggests prices for raw ivory at roughly $700/kg.
The latter is still a lot of money, however, the risk: reward ratio remains loaded in favour of poaching. Thus, as expected, we have seen a significant slowing in the rate of poaching since 2014, but the levels of poaching remain high.
The relationship between the ivory price and elephant poaching remains complex. It was evidently positive that China acted to close its domestic trade. It is pointless to impose an international ban but allow domestic trade, as that simply creates an incentive to illegally move ivory into a country with a large domestic market. Border anti-trafficking enforcement costs are simply too high when a legal domestic trade undermines a global legal trade. The problem remains, though, that if only the largest domestic markets close down but neighbouring markets remain open, then the problem is reduced but also displaced.
For elephant poaching to stop entirely, the market value of ivory has to be eliminated. That can only be achieved through global collective action – elephant range states act simultaneously to dispose of ivory stockpiles and stop signalling to the market that they intend to sell ivory; countries demanding ivory need to stop consuming it.
Even if this occurred, however, the problem of stockpiling ivory remains. The disjunct between online ivory sales data and seizure data had indicated that organised criminal groups were likely stockpiling ivory for various reasons. We suspect that this was because they were ‘banking on extinction’ – literally funding poaching to create private ivory stockpiles, which they could then drip feed to the market once elephants had become extinct, or a legal trade reignited (or both). Domestic ivory bans should therefore be indefinite and complete. Unfortunately, if range states keep talking about selling their ivory, the incentive for stockpiling remains.
 Ross Harvey, Chris Alden, and Yu Shan Wu, “Speculating a Fire Sale: Options for Chinese Authorities in Implementing a Domestic Ivory Trade Ban,” Ecological Economics 141 (2017): 22–31, https://doi.org/10.1016/j.ecolecon.2017.05.017.
The summit will also officially announce the inauguration of the aerial elephant survey which has been spearheaded by the Kavango-Zambezi Transfrontier Conservation Area (KAZA TFCA) to take place in Angola, Botswana, Namibia, Zambia and Zimbabwe. The survey will begin in July and end in August 2022, Mr Darren Potgieter, a South African, has been appointed as the aerial co-ordinator.
In 1979 there were an estimated 1.3 million African elephants. Today there are less than half a million. The elephants have primarily been killed for their ivory. The human population has tripled in the elephant range states since 1970. In October 1989, at the seventh meeting of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES CoP7) governments banned the international trade in ivory.
The Zimbabwean Minister of Environment, Climate, Tourism and Hospitality, Nqobizitha Mangaliso Ndlovu has said that the primary purpose for the Elephant Conservation Summit is in preparation for the Convention on International Trade in Endangered Species 19th Conference of Parties (CITES CoP19) scheduled to take place from the 14th – 25th of November 2022 in Panama.
Young elephants being captured by officials in the Hwange National Park in Zimbabwe for export to zoos in China.
According to Zimbabwe National Parks and Wildlife Management representatives from fourteen African Countries, as well as from China and Japan, are scheduled to attend the summit. Media reports claim that the summit will highlight the negative impact of the ban on the international trade in ivory. The Ministerial declaration will contain calls by African governments for CITES to lift the 1989 ban on the international ivory trade to allow countries like Zimbabwe to sell ivory and reduce the elephant population.
POLITICAL BLACKMAIL: ZIMBABWE THREATENS TO RESIGN FROM CITES
Juvenile elephants from Zimbabwe at Hangzhou Safari Park
On the 17th of May 2022 Environment, Climate, Tourism and Hospitality Industry Minister Mangaliso Ndlovu said that that Zimbabwe is prepared to operate outside CITES regulations because “All possibilities of us selling our excess live elephants to those who want to populate their areas have been cut under CITES. They have introduced an amendment to the current CITES provisions which says we can only sell to the African countries most of whom have these elephants in abundance.”
On Monday 17th of May 2022, envoys from the Netherlands, Germany, France Britain, Switzerland, Canda and the United States were given a tour of the ivory stockpiles in Zimbabwe by the Zimbabwe National Parks and Management Authority.
Zimbabwe is seeking international support to be allowed to sell its stockpile of seized ivory stating that $600 million it expects to earn is urgently needed for the conservation of its rapidly growing elephant population which it describes as “dangerous”. Zimbabwe reportedly has 130 tons of ivory and 6 tons of rhino horn.
It is important to note that the stockpile includes seized ivory which may not be sold in terms of CITES regulations and that the value of ivory stockpiles in Zimbabwe and Namibia are greatly overstated in order to justify the sales.
THE AFRICAN ELEPHANT COALITION HAS CALLED FOR THE CLOSURE OF IVORY MARKETS IN JAPAN
In June, in 2008, in Mombasa in Kenya the African Elephant Coalition consisting of West, Central and East African states joined forces to support the a moratorium on the ivory trade. The African Elephant Coalition represents the majority of African nations.
Two months ago the African Elephant Coalition called for the closure of ivory markets in Japan, saying that they contribute to the illegal killing of elephants in Africa at the Convention of International Trade in Endangered Species of Wild Fauna and Flora conference held in Lyon in France.
Dieudonne Yameogo, Director of Wildlife and Hunting Resources in Burkina Faso, stated that the legal markets offered an opportunity for laundering ivory and therefore contribute to the illegal trade and to the illegal killing of elephants.
In 2016 a recommendation was adopted to close ivory markets in ivory-consuming countries such as Singapore, the United Kingdom, China, the United States of America and Japan. CITES resolution 18.117 states that “Countries that have not closed their domestic markets in raw and worked ivory are requested to report to the Secretariart for consideration by the Standing Committee on what measures they are taking to ensure that their domestic ivory markets are not contributing to the illegal killing of elephants or to the illegal trade in ivory.”
Japan was singled out as a country that had done nothing to close its ivory markets.
The African Elephant Coalition stated that when CITES Conference of the Parties (CoP19) takes place in Panama in November, it must uphold resolution 18.117.
THE CITES STANDING COMMITTEE AGREES THAT THE NAMED COUNTRIES MUST CONTINUE OFFICIALLY REPORT ON THEIR DOMESTIC IVORY MARKETS
Israel, the United States of America, the EU and its member states, China, the United Kingdom, Gabon and Burkina Faso called for Decision 18.117 to 18.119 to be renewed in November in Panama.
ZIMBABWE AND THE POLITICS OF CONSERVATION
The Zimbabwean conservation system was conceived during the period of colonialism and reflects the authoritarian norms of those eras, which victimized humans and other animals. Zimbabwe is also well known for its stance on the commercial exploitation of wildlife.
There has been no accountability for abuses by security forces, including the August 2018 post-election violence and killings and rape during the January 2019 protests. Abductions, torture, arbitrary arrests, and other abuses against opposition parties politicians and activists have not been meaningfully investigated.
Corruption in Zimbabwe has become endemic within its political, private and civil sectors. Zimbabwe along with Honduras, Iraq and Cambodia ranks 157th of 180 countries in the 2021 Transparency International Corruption Perceptions index.
Security forces also continued to commit arbitrary arrests, violent assaults, abductions, torture and other abuses against opposition politicians, dissidents and activists.
The United States, United Kingdom and the European Union all renewed targeted sanctions against Zimbabwe for serious rights abuses by security forces, corruption, and failure to ensure justice for past abuses.
Zimbabwe has a history of non-compliance with CITES. Based on similar patterns of denial and secrecy by the responsible authorities in Zimbabwe and the Zimbabwean government, in 2012, 2015, 2016, 2017 and 2019 and from the Zimbabwean embassy in China – which all proved to be false – and assurances from the new Zimbabwe administration in 2018 that it had turned over a new leaf – Parties to CITES have sufficient cause to be sceptical.
Considering the continuing high profile international focus on elephants, and the wealth of scientific data pointing to the extreme sociality and intelligence of elephants, it is also astounding that any government would allow elephants to be killed for their ivory.
We are in the midst of an extinction crisis that could unravel life as we know it. Wildlife exploitation is the leading driver of marine species loss and the secondary driver of terrestrial species loss. The IPBES 2019 assessment – the most comprehensive assessment of its kind – showed that:
Nature’s dangerous decline is unprecedented;
Species extinction rates are accelerating at alarming rates;
Current global response insufficient;
Transformative changes is needed to restore and protect nature;
Opposition from vested interests can be overcome for public good;
1,000,000 species are threatened with extinction.
It can no longer be business as usual and it is therefore compulsory for governments, on a national and international level, to urgently shift their policy base away from consumptive utilisation and extractivism and to redefine our relationship with wildlife to bring about transformative change, harmonious co-existence, respect, one health and welfare, justice and Ubuntuness.
A JOINT STATEMENT ON THE ZIMBABWE ELEPHANT SUMMIT AND THE LEGAL IVORY TRADE
Today the EMS Foundation has signed a joint statement issued by the International Environmental Investigation Agency on the Zimbabwe Elephant Summit and legal ivory trade.