The EMS Foundation has 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 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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