Cullinan and Associates, lawyers acting on behalf of the EMS Foundation, by invitation, provided inputs and comments on Cape Nature’s Annual Hunting Notice 2024. In summary, the EMS Foundation objects to the procedure Cape Nature follows in publishing annual Hunting Notices on the following grounds:
CapeNature as the trustee of biological diversity in the Western Cape bears the onus of establishing scientifically that the hunting of each of the species listed in the annual Hunting Notice in the numbers specified is justified from a conservation perspective. The onus should not be on the public to motivate why the contents of the Notice are not not scientifically justified;
The procedure followed ignores the principles in section 2 of NEMA that a precautionary approach must be taken to sustainable development and that the loss of biodiversity must be avoided; and
The commenting period for the 2024 Notice is unreasonably short at 22 days and does not provide a meaningful opportunity for the public to comment;
The EMS Foundation objects to the notion of sport hunting in general on animal welfare grounds;
The EMS Foundation objects specifically to the inclusion of primates on the annual hunting Notices as this is not justified either on conservation or animal welfare grounds.
The EMS Foundation full reasons for the objections are set in out in this document:
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