It has been
clear for a long time that – to put it euphemistically – there has been a
catastrophic absence of governance in South Africa’s captive lion breeding
industry. The national Department of Environment, Forestry and Fisheries (DEFF)
is tone-deaf to the global scientific community’s abhorrence of the industry. A
strong indicator of zero governance is that DEFF repeatedly says that it does
not know how many lions are in captivity in South Africa and how many
facilities are involved in the various immoral activities associated with the
industry (such as unregulated slaughter for the lion bone market). For this
reason, in May 2019 the EMS Foundation submitted a request
under the Promotion of Access to Information Act (PAIA), no. 2 of 2000 to get
an answer to these questions.
received in August 2019, is revealing. In response to the specific question of
how many breeders and traders are registered with the department, DEFF
responded that: “The Department is not in possession of information related to
“lion bone breeders”. A section 23 Affidavit is attached.” Similarly, it does
not possess “information related to the vetting and registration process for
lion bone breeders and traders.” In other words, there is no vetting process.
In the words of the affidavit: “Therefore this information does not exist”. The
reason offered in the affidavit for not possessing knowledge of the numbers of
breeders and traders is that “these facilities do not require a permit in terms
of the provisions of [the] National Environmental Management: Biodiversity Act,
2004 (Act No. 10 of 2004)… The registration of such facilities are (sic) the responsibility
of the provincial issuing authorities.” But then it goes on to say that “according
to information submitted [by the provincial authorities] to the Department as
of December 2018, there are 366 registered lion facilities. Such facilities
include zoos, exhibition facilities, sanctuaries and lion captive breeding
facilities.” The responsibility for the vetting and registration process was
similarly fobbed off to the provincial issuing authorities.
were issued for the export of lion bones under the 2018 annual lion export
skeleton quota, with a total of 798 skeletons leaving the country under those
permits. The quota was judged illegal by a High Court Ruling early in August
2019 but obviously cannot be retroactively applied. The damage is done. But at
least there is legal
precedent now to show that the industry is abhorrent, and the quotas were
But the elephant
in the room now is that DEFF said it did not have information about the numbers
of facilities, but then immediately said that it did have information.
This is incoherent at best.
matters is that in reply to a parliamentary question posed by Hannah Winkler of
the Democratic Alliance in August 2019, the Minister of Environment, Forestry
and Fisheries, Barbara Creecy, revealed that there are ‘approximately 7979
lions in captivity in South Africa’ across ‘366 captive facilities’. This is
the first time, to my knowledge, that the government has provided a figure of
this nature without the request having to be made through PAIA. In the past, it
simply claimed that it did not know the numbers, as it had incomplete
information from the provincial authorities.
But the deeper
issue here is that the lack of governance tells a deeper story about the
selective ignorance of science and sustainability to justify the continuation
of an abhorrent industry.
A 2017 study
commissioned by the South African Predator Association (SAPA) and the
Professional Hunters Association of South Africa (PHASA) estimated that there
were between 8000 and 8500 lions across 297 facilities, though it did not
detail how this figure was determined. Lions are generally successful breeders
in the wild, but captive facility owners speed up the process by removing cubs
from their mothers a few hours after birth.
To satisfy growing
demand for tiger parts in Asian markets, South African captive lion
breeding has clearly proliferated since 2017, despite a
recent study arguing that the US import ban on trophies from captive-origin
(canned) hunts had severely disrupted the industry. The number of farms appears
to be growing, along with the number of lions.
A critical question
that arises from this scenario is why, given that captive-bred lions have no
conservation value, the South African government allows the captive predator
breeding industry to continue. It is similarly clear that the opportunity costs
of the industry are significant, given the potential
reputational brand value damage to South African conservation and tourism.
Winkler indeed asked this question of the Minister. Minister Creecy’s response
indicates the need for a more robust engagement with science.
In response, the
Minister cited a 2018
non-detrimental finding (NDF) made by the Scientific Authority, which
indicates that ‘the trophy hunting of captive-bred lions poses no threat to the
wild lion population within South Africa’. Furthermore, such hunting ‘may in
fact serve as a buffer to potential threats to wild lions by being the primary
source of hunting trophies and derived products (such as bone).’ Aside from the
obvious immorality of selling products with no known medicinal value – under the
pretext that it does have such value – into Asian markets, the science of this
argument is highly questionable.
minister is arguing that because there is currently no documented evidence of
increased poaching of wild lions within South Africa as a direct
result of the predator breeding industry, the industry may remain. To
support this view, she has cited a speculation from the NDF that the
industry might have indirect conservation value (a ‘buffer’ effect). It
is critical to understand that a statement in speculation made by a scientific
body does not constitute a scientific statement. Neither the minister nor
her department can continue to hide behind this speculation, pretend that it
has scientific value, and justify the continuation of an immoral industry.
The idea that
bones from captive lions might absorb some of the market demand for tiger bones
in Asian markets first appeared in a 2012
paper by scientists Peter Lindsey and others. They note that ‘if the supply
of bones from captive lions in South Africa was reduced through restrictions on
that industry, demand for bones from wild lions could feasibly increase.’ In
other words, supply from captive sources may be sufficient to buffer
against wild lion exploitation. This notion has been selected out of context
and repeated ad nauseum, ignoring other important considerations – the
epitome of bias, the first casualty of an unscientific approach. The context is
that the same paper also notes that ‘trade in lion bones from captive
institutions in South Africa to Asia would be cause for concern if it were to
stimulate harvest of wild lions or other felids to supply the bone trade. The
market preference in China for bones from wild, rather than captive, felids
could result in such a stimulus.’ In other words, the buffer effect would be
obliterated if the presence of legal supply simply provided a laundering
channel for illegally obtained parts from poached wild lions. Recent research
warns that lion breeders would pursue illegal channels if lion skeleton export
quotas proved overly restrictive. This assumes that illegal channels are
currently minimal, which ignores extensive
evidence of criminality among South African lion bone traders.
selectively overlooked piece of research,
Douglas Crookes and James Blignaut – economists at the University of Pretoria –
bust the myth that rhino farming will create a buffer against wild rhino
poaching. ‘While it is optimal for game farms to harvest after 1.5 years, for
poachers it is optimal to kill a rhino and harvest its horn, even at very low
rotation intervals… This casts further doubt on the effectiveness of a
legalized trade and highlights the importance of further research on farm level
interventions.’ The same logic applies to lion conservation. It is likely a
myth that a legal trade through farmed stock will reduce the demand for
wild-sourced bones. South Africa’s 2018 NDF is very careful to note that the
buffer effect, if it exists, does so only within South Africa. But what
about wild lions and tigers elsewhere?
from the Environmental Investigation Agency found
that the demand for tiger parts is so extensive that wild tigers are still
being poached, despite tigers being farmed. Moreover,
the legal trade in lion parts ‘stimulates demand and perpetuates the
desirability of these products.’ A recent uptick in the poaching of wild lions
in Mozambique appears to be a case in point.
Everatt, Mozambique Project Manager for Panthera, the global wild cat
conservation organization, stated: “There’s no question that there has been a
dramatic increase over the past five years in the targeted poaching of wild
lions for their body parts in Mozambique’s Limpopo National Park – a trend which
is almost certainly linked to the increase in legal lion bone exports across
the border in South Africa.” Where Panthera’s anti-poaching project was active
in Limpopo, bordering Kruger National Park, lions have declined from 66 to now
just 10 individuals over the past six years, with 83% of deaths attributed to
illegal killings with body parts removed. Already this year, 7 lions have been
poisoned and found butchered in the poacher’s signature style.
complexity, the insistence on a buffer effect reappears in a
recent paper by Vivienne Williams and Michael ‘t sas-Rolfes, in which they
write that ‘it is also plausible that [captive lion populations] may provide a
buffer effect against over-exploitation of [wild lion populations]’. Comments
from interview respondents (stakeholders with an interest in the captive lion
industry) shared this belief ‘that the industry plays a positive supporting
role for both lion conservation and the South African economy and also acts as
a buffer against overexploitation of wild lions.’ Interrogation of exactly how
the industry plays this ‘positive supporting role’ is unfortunately absent.
For the buffer
effect to hold, legal supply would have to unequivocally crowd out illegal
supply, something Blignaut and Crookes show is highly unlikely given that
poaching is cheaper than farming. And we know that there is no direct positive
conservation effect to keeping lions in captivity. Another argument in favour
of its indirect conservation value is that trophy hunting estates (which shoot
captive lions) maintain ecological diversity on land that would otherwise be
converted to agriculture. But this is also mere speculation, as canned hunting
hardly requires large estates. If anything, it further fragments landscapes
that could plausibly be joined up for ecotourism with real ecological
Williams and ‘t sas-Rolfes closed their report – which appears to have been the primary informant of the government’s position – with a warning that ‘policy-makers should take care to avoid price shocks, i.e. sudden upward spikes in market prices that would boost incentives for poaching and illegal trading activity, with potential adverse consequences for wild lions.’ This assumes that a ban on the industry (and its bone export component) would create such a spike. But that is also untested economics. If the price spiked, it may not affect wild lion poaching levels; that would depend on whether poachers are paid in proportion to the retail price, something we know relatively little about. Secondly, the demand curve may shift down following a ban, as a ban would strengthen demand reduction efforts through creating a stigma effect. A second-round impact of a ban might therefore be a significant price reduction. Far from creating a buffer effect, every possibility exists that the continued legal trade has an exacerbating effect on demand for tiger products in Asian markets, placing pressure on wild tigers there and wild lions in southern African range states outside South Africa. The minister can also no longer overlook the ethical or welfare implications of breeding lions in captivity for human interaction and/or for canned hunting and/or bone exports. As Judge Jody Kollapen recently ruled, continuing to do so violates the spirit of Section 24 of our constitution – the right to have our environment protected for future generations through ensuring ecological sustainability. He ruled that the 2017 and 2018 skeleton export quotas were illegal and constitutionally invalid. This should be grounds enough on which to terminate the industry as quickly as possible, something that the International Union for the Conservation of Nature (IUCN) – bastions of the ‘sustainable use’ doctrine beloved of DEFF – called for as far back as 2016.
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