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:
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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