Dear Rhino Owners and Reserve Managers
DEA decision not to table an international trade proposal in rhino horn at CoP18
Sadly, I must inform you that South Africa will not table an international trade proposal at the next CITES CoP. This in contradiction with statements made by the late Minister and DEA of the need to incentivize and assist private owners, the recommendations of the Scientific Authority to table a trade proposal and totally ignoring requests for international trade from the wildlife industry (PROA).
I outline below a summary of events to demonstrate the obstructive conduct by DEA against rhino owners:
- The Domestic Moratorium of trade in rhino horn was imposed without correct consultation on the 13th February 2009 by DEA. That despite numerous approaches to the then Minister, DEA refused to lift what was intended to be a temporary arrangement. Finally, in desperation two rhino owners instituted litigation against the Department to have the Moratorium removed. In every court case and ultimately the Constitutional Court, DEA lost but remained as obstructive as possible until it was set aside as illegal legislation in 2017.
(DEA took every court decision on appeal and in the process, wasting millions in tax payer’s money in legal fees)
- Gazette Notice 74 published for comment by DEA in February 2017 contained illogical, restrictive and unacceptable content related to domestic trade that PROA and the Wildlife Industry objected to.
- On 21 September 2018 Gazette Notices 986 & 987 were published for comment with new and even more idiotic trade restrictions (some in violation of the Constitution) that again PROA objected to.
- In violation of DEA’s own legislation (NEMBA and TOPS), DEA do not issue permits in the required time frame related to domestic trade in rhino horn.
- That again it took an urgent Court Order for DEA to release permits for the first online auction and they continue to delay issuing of permits on pedantic issues.
DEA has over the years appointed various commissions, held public consultation and numerous workshops. It is worth noting the outcomes:
- The RIM Report recommended immediate international trade in 2013.
- The Committee of Inquiry (COI) recommended that SA considers a proposal once certain conditions had been met in 5 key areas in 2015.
- The then Minister supported the Swaziland proposal at CoP 17 in 2016 (this after at the last minute deciding not to submit a SA proposal??)
- The Rhino Lab held in 2016 described the need to offer incentives to assist private reserves including International Trade.
- The Non-Detriment Finding (NDF) carried out in early 2018 shows that our White Rhino population belong in an Appendix II status with no Appendix I annotation (this based on CITES own criteria).
- From the CITES Public Participation consultation, the recommendations of the Scientific Authority to DEA were to submit a trade proposal allowing for regulated trade from registered reserves at CoP18.
- In March of last year PROA met with the late Minister and her executives to present a ‘Why the need to trade’ and ‘How to best proceed’ in preparation for CoP18.
- PROA followed this up with very detailed documentation, illustrating the huge economic potential that trade would bring to South Africa and at the same time collapse the illegal trade, by legal regulated supply from stockpiles and removing the need to illegally kill our rhino.
PROA met with the new DEA Minister Nomvula Mokonyane MP on the 18thDecember 2018 to again motivate a CoP18 trade proposal and within hours of the meeting submitted a very detailed explanation on how best to approach CITES. The deadline for submission for CoP18 was the 24th December.
The above must be noted in the context that PROA members now own over 7 350 White Rhino and some 450 Black Rhino. A most conservative calculation indicates 46% of the national population and more than the rest of Africa combined are held on South African private reserves.
Our key role in rhino conservation cannot be disputed domestically or internationally.
Per the PROA/RMG survey carried out in August 2018, 85% of owners called for trade, 14% were undecided and only 1% anti trade.
BUT a few obstructive DEA officials have chosen to play ‘God’ over our industry and our conservation needs. That their actions are in violation of our Constitutional Rights seem not to worry them. That the Department has not provided a single constructive or supportive act benefiting private reserves from 2009 to date is a disgrace. The direct result of this bizarre decision will be the continuation of poaching, added security and judicial burden and the killing of another 3000 rhino. Our annual rhino security costs are estimated at R2 billion a year (National, Provincial and Private Reserves combined expenditure).
In summary the questions have to be asked;
- Why is DEA blatantly obstructive to the needs of private reserves and remain supportive of the 1977 CITES trade ban that has not saved the life of a single rhino (23 out of 33 African range states have lost all their rhino).
- Allow a vast Trans National illegal trade to continue and the slaughter of our rhino through the failed ban?
- Why has DEA ignored the Species Survival Business Plan PROA presented, which outlines conservation funding amounting to R billions for job creation, rural poverty alleviation, community rhino programs, tax benefits etc. but most important ‘Saving Rhino Lives’? (All key outcomes from the Rhino Lab)
DEA have consulted widely, appointed commissions, held public participation events but ignore all recommendations including that of private owners and the Scientific Authority. We expected a trade proposal in 2016 at CoP 17, now again to be let down for CoP 18 means our next chance is CoP 19 in 2022!
This is a terrible decision and will have far reaching negative effects to our rhino conservation burden.
The PROA Board will meet on the 23rd of January to review the unacceptable, irrational and indefensible conduct of DEA and decide on the way forward.
Kind Regards
Pelham Jones
