JOINT POSITION ON TROPHY HUNTING

6th July 2022, Brussels

THE EMS FOUNDATION OPPOSES TROPHY HUNTING AND THE ASSOCIATED TRADE IN TROPHIES AND ASSERTS THAT “KILLING TO CONSERVE” IS NEITHER AN ETHICAL NOR A SUBSTANTIAL APPROACH TO WILDLIFE CONSERVATION.

One hundred and thirty-seven organisations have signed in opposition of trophy hunting.

This is the joint public statement of the one hundred and thirty-seven organisations:

©The EMS Foundation 2022. All Rights Reserved.

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EMS FOUNDATION COMMENTS ON TEEPSA BLOCK 567 SCOPING REPORT

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.

Image Credit: Hermanus Whales

©The EMS Foundation 2022. All Rights Removed.

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THE IMPACTS ON LEVELS OF ILLEGAL KILLING OF ELEPHANTS SINCE THE CLOSURE OF CHINA’S DOMESTIC TRADE IN IVORY

WRITTEN BY DR HARVEY ROSS NATURAL RESOURCE ECONOMIST

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.[1] 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.[2]


[1] Chris Alden and Ross Harvey, ‘The case for burning ivory’, Project Syndicatehttps://www.project-syndicate.org/commentary/kenya-ivory-stockpile-destruction-by-chris-alden-and-ross-harvey-2016-04, accessed 1 June 2022. 

[2] 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.

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COMMENTS ON THE SOUTH AFRICAN CLIMATE BILL BILL

27th MAY 2022

The comments submitted by the EMS Foundation and the Wild Law Institute have been endorsed by the members of the Wildlife Animal Protection Forum of South Africa, Animal Law Reform and the Climate Justice Charter Movement.

THE EMS FOUNDATION AND THE WILD LAW INSTITUTE SUBMITTED COMMENTS ON SOUTH AFRICA’S CLIMATE CHANGE BILL

EXECUTIVE SUMMARY

  1. We strongly support the enactment of a Climate Change Act. However, we believe that the Bill requires strengthening to ensure that it can function as an appropriate legal framework for effective climate change responses.

2. In this document we propose various amendments to the Bill and explain why they are necessary. Annex A contains the current version of the Bill which we have marked-up to show the amendments that should be made in order to give effect to the proposals in this document. We have done so in order to facilitate the finalisation of the Bill.

3. Our primary concern with the current version of the Bill is that its scope is too narrow because it does not take account:

3.1 of the deeper systemic causes of climate change which motivate people to act in ways that exacerbate climate change; or

3.2 of the fact that the complex interrelationships between different life forms is responsible for establishing and maintaining the stability of the global climate which means that climate change responses must simultaneously address the protection and restoration of ecosystems and natural processes in order to be effective.

4. We propose that the scope of the Bill be widened by introducing the concept of harmonious co- existence and making amendments to the long title, preamble, principles (among other provisions) to reflect a wider eco-centric approach. We propose that this term be defined as follows:

‘‘harmonious co-existence’’ means a state in which humans relate to other aspects of Nature in ways that are either beneficial to, or do not harm, the integrity and health of ecosystems and the functioning of the natural processes that sustain life and maintain climate stability;”

5. Our other principal concerns are that the Bill:

5.1 does not acknowledge the existence of a climate emergency or provide for the taking of the urgent and far-reaching measures necessary to respond to the current global climate emergency and effect transformative changes in society;

5.2 does not take a comprehensive, holistic and integrated approach to climate change response and that climate change response plans should address adaptation, mitigation and the promotion of harmonious co-existence with Nature as a pathway to climate stability;

5.3 focuses on reducing GHG emissions (Chapter 5) as a mitigation response but it should also encompass the taking of measures to restore the carbon-sequestration capacity of indigenous ecosystems and agricultural land, and to address the forces driving the continuation of activities that exacerbate the climate crisis, including subsidies and the adoption of plans and the authorisation of projects that exacerbate climate change;

5.4 does not impose clear, legally binding duties on the State and other parties to take urgent measures to avoid exacerbating climate change and to take measures to respond to the climate crisis, such as preventing the commencement of activities that exacerbate climate change, phasing out existing activities that do so, ceasing to provide incentives to activities that exacerbate climate change or to prioritise the protection of fundamental human rights over the promotion of economic growth;

5.5 gives insufficient attention to the importance of ensuring that climate change responses are undertaken in ways that uphold human rights and the rights of Nature, and promote harmonious co-existence;

5.6 does not provide for a dedicated funding mechanism that can be used to incentivise desirable behaviour and finance transformative change;

5.7 does not provide for effective enforcement mechanism that would enable swift and effective enforcement action to be taken against those that do not comply.

6. All of these issues can be addressed by making the relatively few amendments indicated in the marked-up version of the Bill that is attached as Annex A to this document.

©The EMS Foundation 2022. All Rights Reserved.

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COMMENTS ON THE BIODIVERSITY OFFEST GUIDELINE

26TH MAY 2022

The EMS Foundation was established in 2014. It is a Trust which is a registered nonprofit organisation and public benefit organisation. EMS is committed to social and inclusive justice, compassion and the advancement and protection of the dignity, rights and general welfare of vulnerable and marginalised groups and individuals in South Africa, with particular focus on youth at risk, the elderly and the conservation and protection of wildlife.

On the 25th March 2022 the national Minister responsible for the environment published a draft National Biodiversity Offset Guideline for public comment.

The attached document constitutes the comments of the EMS Foundation, which have been endorsed by a number of organisations, on the Draft Guideline.

Excerpt from the EMS Foundation comments:

CONCLUSIONS

The concept of biodiversity offsetting does not recognise the right of the individual components of ecosystems to exist and of ecosystems to remain intact and functioning. The Guideline is silent on how the welfare of individual animals is to be protected when a decision is made to authorise the destruction of a habitat, based on offsetting.

The EMS Foundation does not support the use of biodiversity offsetting to allow projects with high or moderate residual negative impacts on biodiversity to be authorised or to allow the public interest in preserving biodiversity and halting the rapid loss of habitats and species to be overridden.

If biodiversity offsetting is to be permitted at all, it must be subject to the strictest of controls, ideally containing in binding legislation, and to effective monitoring and enforcement by the State, not by developers. All interested and affected parties must be consulted during the process of identifying an securing offset sites and developing management plans and implementation agreements.”

©The EMS Foundation 2022. All Rights Reserved.

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