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THE NINETEEN YEAR REUNION: SAFARI CLUB INTERNATIONAL AND THE GRATUITOUS INFLUENCE ON AFRICA’S TROPHY HUNTING POLICIES

KASANE, BOTSWANA

NOVEMBER 2021

This week Safari Club International brought its fight against trophy import ban proposals from around the world in to Kasane in Botswana where the nineteenth anniversary of SCI’s sponsored Southern African Wildlife Consultative Forum (AWFC) meeting, which started in Botswana in 2002, is taking place.

According to their published marketing information, the annual African Wildlife Consultative Forum is Safari Club International’s premier activity in Africa. These annual events bring together senior government officials and the professional hunting leadership, amongst other, to discuss the sustainable use of wildlife across Africa. According to SCI, a pro trophy hunting, pro gun lobbying organisation based in the United States of America, the AWCF provides African representatives with a platform to unite in an effort to combat and end the intervention of African wildlife conservation programs by misinformed Western activists and politicians. 

Laird Hamberlin, the SCI CEO, has said in the aforementioned September 10th publication, that Safari Club International is the only organisation with the right resources and relationships with established leaders on the ground from Botswana, Cameroon, DRC, Eswatini, Ethiopia, Malawi, Mozambique, Namibia, South Africa, Uganda, Zambia and Zimbabwe that could successfully beat the trophy hunting bans. “This year African conservation has faced numerous attacks by way of proliferation of trophy import ban proposals.”

He is referring to the Jane Goodall Act which is intended to ban elephant trophy imports to Canada.  A proposed ban on all CITES listed animals has been introduced to Switzerland’s National Council.  In the United Kingdom, DEFRA is considering the ban on all or selected trophies.  The Cecil Act in the USA will ban elephant and lion trophy imports from Tanzania, Zambia and Zimbabwe and will require that all species proposed for listing the US Endangered Species Act be treated as if they are already listed. It will also require public notice and comment for all trophy imports of listed species, making importation more difficult. State trophy import and possession bans have also been considered or have been introduced in Connecticut, Illinois and California. 

TROPHY HUNTING IS NOT UBUNTU

Two years ago, on the 28th of November 2019, the EMS Foundation published an article called The Long Tentacles of Safari Club International Undermining Conservation Efforts in AfricaThe article was published during the 2019 AWCF meeting which took place in Victoria Falls in Zimbabwe, last year the event had to be held virtually from Botswana, due to the global COVID_19 pandemic and this year the event returned to Kasane in Botswana, it is a hybrid event, supposedly limited to fifty persons attending in person.

In the research article called Neo-Colonialism and Greed: Africans’ Views on Trophy Hunting in Social Media Dr Muchazondida Mkono examines the views of Africans on trophy hunting. Dr Mkono says that the cultural concept of Ubuntu offers insight into an African concept of sustainability and this can inform the Western sustainability model and make it relevant to Africa. In the Ubuntu philosophy, the wellbeing of all humanity and of all nature takes precedence, before the rights of the individual trophy hunter. 

NEO-COLONIALISM

Neo-colonialism is the use of economic or political pressures to control or influence other countries especially former dependencies. It is the practise of using economic imperialism and conditional aid to influence a developing country instead of the previous colonial methods of direct military control or indirect political control. 

Beyond the negative ecological effects, trophy hunting is rooted in colonial modes of extraction. Trophy hunting continues to perpetuate a neo-colonial chauvinism and the flow of resources from the South to the North. Alternative conservation activities exist that reject and avoid a colonial practice of extraction in favour of more ecologically sustaninable and dignifying activities.

Trophy hunting inflicts and perpetuates notions of abuse, subjugation and control, and importantly, research has shown that Africans find trophy hunting objectionable because of its complex historical and postcolonial associations – the dominant pattern was resentment towards what was viewed as the neo-colonial character of trophy hunting, in the way it privileges Western elites in accessing Africa’s wildlife resources.

Research shows that trophy hunting is not an effective tool for conservation in Africa – the trophy hunting industry is rife with mismanagement and corruption, harmful to animal populations, is grounded in in colonial systems that have marginalized, and continue to marginalize local African populations.  This comprehensive research combines the knowledge of anthropology, ecology, economics, ethology, history, indigenous studies, literature studies and political science. 

It is so utterly disappointing that the new democratic South African government continues to support the events organised by Safari Club International whose questionable strategy in Africa plan has been highlighted by Jared Kukura.  

“For instance the strategic plan raises concerns about the indigenization of Zimbabwe’s hunting industry, stating that if not properly implanted indigenization will eliminate the old-line hunting families and the traditional knowledge necessary to assure a quality hunting experience by overseas spot hunters and management concessions.”

The content of the article, titled Safari Club International’s Plan to Colonize Africa’s Hunting Grounds includes further reference to SCI’s strategy in Africa which “casts blame on indigenous Africans for decreasing financial viability of trophy hunting in Tanzania, adding one of the biggest problems are smaller indigenous companies who have inside connections to people in town.”

https://safariclub.org/sci-welcomes-new-ambassador-from-botswana-to-washington-dc/

Botswana has auctioned elephant trophy hunts since President Mokgweetsi Masisi lifted the five year hunting  ban in May 2019, but according to the SCI strategic plan it was recommended that Botswana’s citizen hunters be banned from hunting trophy hunting animals. 

African countries still have wildlife and biodiversity – albeit dwindling – and foreign countries continue to scramble for these. We have to assume that the recolonisation of Africa is being assisted by African rulers. This exploitation process continues in Kasane at present – white trophy hunters are meeting with African governments to try to control the future of Africa’s wildlife.  African leaders are seemingly satisfied to allow, for a price,  the white hunters desire to kill and adorn their walls with trophy’s signifying their conquest of wild Africa. 

Image Credit: Safari Club International and

https://www.facebook.com/AYEEI.AREWA/posts/615557988476803/

©The EMS Foundation 2021. All Rights Reserved.

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EMS FOUNDATION COMMENTARY ON THE PROPOSED 2021 ELEPHANT TUSK HUNTING QUOTA

THE SUGGESTED 2021 ELEPHANT TUSK QUOTA

EXCERPT FROM THE EMS FOUNDATION SUBMISSION:

Elephant status quo in the current NDF

Elephant are listed as ‘protected’ in terms of the TOPS Regulations. They are accordingly “indigenous species of high conservation value or national importance that require protection.”

Elephant populations in South Africa are listed on Appendix II of CITES for the purposes of trade in trophies for non-commercial purposes only.

There is no current final published NDF for elephant. The Summary Report: Non-detriment findings made by the Scientific Authority published on 5 April 2019 indicates that a draft NDF dated December 2015 was to be submitted to the Minister for her to publish for public input.

However, it also notes that there is a “growing market for the trophy hunting of large-tusked bulls” which “could decrease the average tusk size of elephants within South Africa and potentially result in a loss of genetic diversity. Over exploitation of older bulls may socially disrupt elephant populations. Furthermore, the hunting of females has behavioural consequences not only for the individual’s offspring but for the entire family unit. It is therefore recommended that guidelines for the trophy hunting of elephants be developed.”

The NDF also found that the then current offtake of bulls as DCA from the Greater Mapungubwe Transfrontier Conservation Area (GMTFCA) elephant population exceeded the 10 trophy bulls that could be harvested sustainably per annum for the entire population (inclusive of Botswana and Zimbabwe). It therefore recommended that DCA or hunting trophy removals from this population in South Africa be reduced to no more than 5 bulls per annum, while the offtake from the entire GMTFCA elephant population must be addressed.

The NDF noted that the Scientific Authority was aware at that point of increased poaching of elephant and the illegal trade in ivory in other parts of Africa and indicated that it would review the NDF assessment “should the number of poaching incidents in South Africa increase.”

There has in fact been a well-documented, marked increase of elephant poaching in South Africa. In 2012 two elephants were killed for their ivory in South Africa’s flagship Kruger National Park. In 2015 twenty- four elephants were killed for their ivory. In 2016 forty-six elephants were killed for their ivory. In 2017 sixty-seven elephants were killed for their ivory. In 2018 seventy-one Elephants were killed for their ivory, and according to Minister Creecy, thirty-one elephants were killed in the Kruger National Park in 2019. These figures demonstrate the intentional targeting by organised criminal syndicates of elephants in eastern South Africa, specifically in the region bordering Mozambique.

The NDF argues “that local and international trade in elephant poses a low and non-detrimental risk for the species in South Africa. The species is well managed in South Africa and the Scientific Authority does not have any current concerns relating to the export of elephants in accordance with Article IV of CITES.”

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EMS FOUNDATION COMMENTARY ON THE PROPOSED 2021 BLACK RHINO HUNTING QUOTA

THE SUGGESTED 2021 BLACK RHINO QUOTA

EXCERPT FROM THE EMS FOUNDATION SUBMISSION:

Black rhino status quo as contained in the NDF

Black rhinos are included in Appendix I of CITES. In terms of Article Ill of CITES, an export permit shall only be granted for a specimen of an Appendix I species (e.g. in the case of a hunting trophy) when a Scientific Authority of the State of export has advised that such export will not be detrimental to the survival of that species. In accordance with Article III and the CITES Regulations, a Draft NDF for black rhino was published for comment in 2019 (“Draft Rhino NDF”).

In terms of threats to the black rhino population and the impacts of trophy hunting on the survival of the species, the Draft Rhino NDF notes that:

  • Ongoing loss of rhino to poaching for their horn is currently the most immediate threat to South Africa’s black rhino population.
  • Permanent removal of black rhino from the national population through trophy hunting is predominantly economically motivated…
  • The current overall species conservation benefit associated with trophy hunting of black rhinoceros is low.

Trophy hunting of black rhino should not be contemplated

The African Black Rhino remains Critically Endangered according to the IUCN Red List of Threatened Species, and there is no room for complacency. There is an urgent need for them to be protected not killed. It is counter intuitive therefore, to suggest a hunting quota for black rhino in South Africa especially while private rhino owners and the government are seeking ways to lobby for funds locally and abroad in order to protect the last remaining South African black rhino.

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EMS FOUNDATION COMMENTARY ON THE PROPOSED 2021 LEOPARD HUNTING QUOTA

THE SUGGESTED 2021 LEOPARD QUOTA

Excerpt from the EMS Foundation Submission:

Decision to determine a quota for leopard hunting made in the absence of an NDF

In terms of Article III of CITES and the CITES Regulations, export of species listed in Appendix I or II may only take place once the Scientific Authority (SANBI) has made an NDF and advised the Management Authority accordingly.58 In 2015, the Draft NDF was published which made a positive NDF finding, provided certain conditions were met, namely:

  • Guidelines for the allocation of leopard trophy quotas must be developed and provided to all provinces by the end of January 2015 (the requirement for such guidelines was again reiterated at the Leopard Workshop).
  • A conditional leopard trophy quota allocation must be issued for 2015, whereby provinces must indicate compliance with the guidelines recommended above. Provinces showing non-compliance with these guidelines must not be allocated a quota for 2016.
  • National norms and standards for the management and monitoring of leopard trophy hunting and putative DCAs in South Africa must be developed in terms of section 9 of NEMBA and published by the end of 2016.
  • The norms and standards recommended above must be fully implemented by the end of 2019.Without the satisfaction of the above conditions, the Scientific Authority would not have found that the trade in leopard is non-detrimental to the survival of the species and would not have issued a Draft NDF. It is critical that the management measures proposed, including guidelines and norms and standards in relation to leopard trophy hunting are in place before there is any consideration of whether a quota may be determined.The Draft NDF was never finalized. At the Leopard Workshop, the DFFE indicated that at the time of the publishing of the Draft NDF, there was no reliable estimate for the South African leopard population, and thus this required this NDF to be revised because it is outdated. Plans to revise the Draft NDF are allegedly underway.58 Regulation 4, CITES Regulations.

In the circumstances, a key informant of whether or not to determine a quota, namely a revised NDF, has not been finally gazetted or circulated for public comment. The purpose of an NDF is to determine whether trade in an Appendix I or II species (including leopard) will be detrimental to the survival of the species. Its contents are thus critical to rational decision-making in relation to the number (if any) of leopard that may be trophy hunted.

We therefore submit that in the absence of a finalized NDF which has been circulated to stakeholders for comment, there is no rational basis for determining the Draft Quota. The NDF for leopard must be finalized before any determination of quotas can be made.

We further submit that the management measures contemplated by the conditions of the Draft NDF, namely norms and standards for the management and monitoring of trophy hunting (the draft Hunting Norms and Standards having been published for comment in 2017) and guidelines for the allocation of leopard trophy quotas are critical to the determination and implementation of any trophy hunting quota. At the Leopard Workshop, it was recorded in DFFE’s presentation that guidelines for the allocation of leopard hunting quotas are to be developed. DFFE evidently construes the development of guidelines as an important mechanism for the determination of a trophy hunting quota. To the extent that the Draft Quota was determined before guidelines and the Hunting Norms and Standards have been circulated for public comment and finalized, we submit that the Draft Quota is irrational, and has been determined without taking relevant considerations into account.

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EMS FOUNDATION COMMENTS ON THE PROPOSED LEOPARD, BLACK RHINO AND ELEPHANT TROPHY HUNTING QUOTAS FOR THE 2021 CALENDAR YEAR

THE PROPOSED HUNTING AND EXPORT QUOTA FOR ELEPHANT, BLACK RHINOCEROS AND LEOPARD FOR THE 2021 YEAR

The EMS Foundation has herewith provided comment on the proposed hunting and export quota for elephant, black rhinoceros and leopard for the 2021 calendar year which was published for public consultation in terms of section 99 and 100 of the National Environment Management: Biodiversity Act, Act 10 of 2004 (NEMBA) and sub regulation3 (2)(k) of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Regulations, 2010.

THE EMS FOUNDATION VIEWS THE PROCESS FOLLOWED BY THE MINISTER OF FORESTRY, FISHERIES AND THE ENVIRONMENT PROCEDURALLY UNFAIR

THE NOTICE DOES NOT COMPLY WITH THE REQUIREMENTS OF SECTION 100(2)(b) of NEMBA in that the Minister has not provided sufficient information, or indeed any information about how the quotas were arrived at to enable members of the public to submit meaningful representations or objections.

The Draft Quota contains no information in relation to how the quotas have been determined, other than stating the quotas for leopard and black rhino are proposed “as per the recommendations of the Scientific Authority”. No information at all is referenced in relation to the proposed export quota of 300 elephant tusks. There are no reasons for the proposed decision, or any information whatsoever to enable the public to meaningfully comment on the Draft Quota. In the absence of such information, the Draft Quota cannot be finalized, and any final decision made in the absence of providing the public with the information on which the proposed quotas are based (including the Scientific Authority’s recommendations) would be fatally flawed. The Draft Quota should be published again for comment, accompanied by all the relevant information on which the decision to determine the proposed quotas is based.

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