EMS FOUNDATION COMMENTARY ON THE PROPOSED 2021 BLACK RHINO HUNTING QUOTA

The number of rhinos in South Africa is at an all-time low. On World Rhino Day, the 22nd of September 2021, SANParks admitted, that for the first time South Africa’s population of rhino had declined by nearly two-thirds, in just the last 10 years, and that that it is likely that there are fewer than 3000 rhinos left in the Kruger National Park. Due to the lower number of rhino in the Kruger National Park, the number of rhino being illegally killed in other parts of South Africa is rising, this after the borders were reopened and COVID-19 lockdown restrictions were lifted. This, coupled with on-going illegal killings and the uncertain effects of climate-change, means that DFFE is required to take a precautionary approach. Given all these existing threats, trophy hunting of rhinos is detrimental to their survival. Allowing the killing of any rhinos in this dire situation is not only unconscionable but unequivocally irresponsible and will not contribute to conservation.

Whilst the illegal hunting of rhino continues unabated, men and woman are risking their lives trying to protect this species, it will be embarrassing to try and persuade an international audience to fund emergency rhino protection funding whilst at the same time promoting the legal killing of rhino on private land.

The so-called strict approval criteria and approval process for legal hunting is in sharp contradiction to the fact that there is a shortage of suitable secure habitat for the black rhino in South Africa.

As indicated in the Draft Rhino NDF, the conservation benefit associated with black rhino trophy hunting is low, and trophy hunting itself is predominantly economically motivated. Further, the species is considered rare and although offtake in the form of trophy hunting is allowed, it is subject to strict biological criteria. In our view, these are uncompelling reasons to permit the continuation of trophy hunting in circumstances where trophy hunting often fails to deliver demonstrable conservation outcomes We have already detailed why trophy hunting should not be considered at all, and that the only quota which may be determined for any of the species under consideration should be a zero quota.

In this regard, in its comments on the Draft Rhino NDF in 2019, Wild Animal Protection Forum South Africa (“WAPFSA”) noted as follows: “That hunting will improve black rhino population growth and provide incentives for private rhino ownership is loaded with untested assumptions. First, it assumes that trophy hunting offers incentives that are socio-ecologically preferable to the next-best alternatives, such as photographic tourism. Private rhino ownership is described in such a way as to suggest that the only incentives for expanding it are through consumptive uses such as breeding, trading in horns and trophy hunting. This ignores the fact that a significant number of South Africa’s privately-owned rhinos are on reserves that do not offer hunting and do not trade in horns. Second, it ignores alternatives to trophy hunting that do not entail consumptive use and may therefore prove more sustainable. If it is deemed ecologically necessary to remove black rhino males from any given population (to prevent lethal brawling for instance), then translocation to appropriate destinations may be preferable, especially where photographic tourism would be bolstered by the presence of rare black rhinos.

In short, it has not been sufficiently demonstrated that trophy hunting of black rhino is more viable as a conservation tool than alternative non-consumptive uses. To the extent that trophy hunting is justified on the basis that (as recorded in the Biodiversity Management Plan for Black Rhino) “[a] strong case has been made on demographic and genetic wildlife management grounds for the removal of the odd specific individual and usually older male black rhino from some breeding populations (Emslie 2004)” we reiterate the comment of WAPFSA above that this conclusion is based on a number of untested assumptions, and that alternative methods such as translocation must rather be explored.

In terms of setting the quota for black rhino to be trophy hunted in 2021 at 10, we reiterate that there simply isn’t any information available in or accompanying the Draft Quota on which we may meaningfully comment in relation to this proposed quota. We are aware that CITES agreed, at the 18th meeting of the Conference of the Parties held in Geneva in August 2019, to South Africa’s proposal to increase its export quota for black rhino hunting trophies, from five adult males (subspecies Diceros bicornis), to a total number of adult male black rhino not exceeding 0.5% of South Africa’s total black rhino population. However, given that no information has been provided with the Draft Quota relating to inter alia the black rhino population size, it is unclear how the Minister arrived at a quota of 10 black rhino to be trophy hunted. Has the upper limit of 0.5% been applied? If so, on what scientific basis? Without having had sight of the Scientific Authority’s recommendations in this regard (and other relevant information pertaining to the Minister’s determination), we are unable to meaningfully comment on the proposed Draft Quota. There is no information which suggests that a quota of 10 black rhino will (when factoring in illegal poaching) keep harvesting of rhino to sustainable limits (as indicated in the Draft Rhino NDF).

Trophy hunting of black rhino is entirely undesirable and should not be continued. In this regard, the Draft Quota should set the quota for black rhino hunted at zero. From a conservation perspective, non- consumptive ecotourism, a fundamentally more ecologically sustainable practice that provides more jobs with higher quality and greater security, should rather be explored if the argument in favour of trophy hunting assumedly that it generates income for conservation.

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

As stated above, 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. In 2019, the Draft Rhino NDF was published was published for comment.

The Draft Rhino NDF was never finalized and there is no indication as to when this may occur. In the circumstances, a key informant of whether or not to determine a quota based on whether the survival of the black rhino species will be irreversibly impacted, 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 black rhino) 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 black rhino that may be trophy hunted in any given year.

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 black rhino must be finalized before any determination of quotas can be made.

Conclusion

The persistent issue with the Draft Quota is that no information has been provided to stakeholders in relation to how the various quotas, including the black rhino quota, have been determined. In the absence of such information, it is impossible to meaningfully comment on the quota of 10 black rhino for 2021. The only logical conclusion is that the Minister did not have the relevant information before her when determining the Draft Quota. In the circumstances, the Draft Quota cannot lawfully and rationally be made final.

Be that as it may, we submit that for the reasons outlined above, no trophy hunting at all for black rhino should be tolerated. The quota for black rhino must accordingly be set at zero.

Image Credit: The Mirror and Sciencephoto.com