In response the CapeNature ‘agreement’ mentioned in the previous blog post:

Speak Out: Should South Africa issue permits to hunt predators?

Landmark Leopard & Predator Project – South Africa has this to say:

Please find attached a detailed submission and formal objection to the above stated “agreement” that was put out to public comment by CapeNature. (http://www.capenature.co.za/permits.htm?sm%5Bp1%5D%5Bcategory%5D=733 – see the original draft agreement on CapeNature website under the permit section.) This agreement will see the massacre of biodiversity across the Western Cape being institutionalised and sanctioned by the Western Cape Government. This is simply wrong.

We object to the content, the manner of its origin, and actions proposed stemming from the agreement. We believe this is a demonstration of mal-administration and unaccountable statutory conduct, and as such call for the abandonment and withdrawal of the agreement.

The believe the agreement is a carte blanche agreement to destroy indigenous, free-ranging faunal species from the landscapes of the Western Cape and to a return of hunt clubs, hot pursuit actions and indiscriminate barbaric culls, much like the Oranje Jag of old. This follow on the Bredell Cull of 2011, wherein CapeNature authorised through permits the largest cull of biodiversity in the history of the African continent- a total of 894 250 animals was permitted for destruction in 2011 alone. What is being proposed here, is a further grand-scale wiping out of some natural occurring species, while the management and execution it is being outsourced to the agricultural lobby groups!

We also call for access to the document drafted by Professor Koos Bothma (completed in September 2011), and paid for by public funds, that was supposed to inform this agreement. It has been withheld from public scrutiny – why?

Please feel free to distribute, cut and paste, and submit your own objection by 5 June 2012 to the above address – that is this week Tuesday! Email Address: dca@capenature.co.za

Kind regards

Dr Bool Smuts

Director

Landmark Foundation

083 324 3344

www.landmarkfoundation.org.za

Facebook: Landmark Leopard and Predator Project

CONTENT OF THE OBJECTION – Full copy can be obtained from bool@landmarkfoundation.org.za

Objecting to the agreement between Cape Nature, Western Cape Government and the agricultural lobby group (the “Predator Management Forum”), aimed at destroying our biodiversity.

1 June 2012

Purpose: Formal objection to the “cooperative agreement between the Predator Management Forum and the Western Cape Nature Conservation Board: guidelines for the management of bushpig, black-backed jackal and caracal that are responsible for agricultural losses within the boundaries of the Western Cape Province”.

This “agreement” will further be called Western Cape Biodiversity Massacre-2012.

The Landmark Foundation formally objects to the content of the agreement, its proposed modus operandi and manner in which it was arrived at, and we call on all stakeholders in this matter to start the process from the start. In the interim we call on a moratorium on the issuing of any further permits or permit exemptions for hunting damage-causing animals.

Context: In 2011 the Democratic Alliance administration of the Western Cape and CapeNature implemented the largest state sanctioned and permitted cull of indigenous wildlife in the history of Africa by permitting for destruction 894 250 caracal and jackal. It became known as the Bredell Cull. This occurred after political coercion from DA ministers (MEC Anton Bredell and MEC Gerrit van Rensberg, and supported by Premier Helen Zille) and subsequent capitulation of CapeNature officials and Board to abide by their political masters. This remains a disgrace of unparalleled proportions.

On 12 January 2011 Dr Kas Hamman, now acting CEO of CapeNature, confessed in writing: “Yes, political pressure has certainly been brought to bear on us and in no uncertain way. Let’s talk about how LF (sic, Landmark Foundation) could possibly assist us in the most effective way.” This was followed by a year of cloak and dagger “engagements” and behind the scenes political deals that have resulted in the agreement now out for public comment in the form of this “agreement”. CapeNature staff have been forced to toe the line and even the Board of CapeNature has approved the tools put forward in the agreement in October 2011 in a CapeNature Board resolution. This occurred while all stakeholders that may object to this agreement have been shunned and any engagement with them has been rejected, despite requests for such. Even as late as April 2012 only sweetheart organisations have been included in any discussions with DA run institutions. The Premier even appointed a sweetheart forum to advise her on welfare issues, actively excluding critical stakeholders.

This agreement is thus a “blank cheque” to the agricultural lobby groups to assault indigenous occurring species and to self-regulate themselves to do so. It is a replica of the disastrous bounty funded Oranje Jag in the Orange Free State Province of the Apartheid regime of South Africa of the 1950s – 1990s that saw hundreds of thousands of animals exterminated over the agricultural landscapes, together with even greater numbers of by-catch kills of innocent animals.

We believe the consultation whereby CapeNature and the DA administration of the Western Cape have handed over the management of our biodiversity to an industry lobby group with a demonstrable atrocious record in biodiversity management, especially top trophic level species, amounts to biological asset striping of our natural heritage. We strongly object to the “public participation” process by which this agreement has been struck, and the political coercion used to come to this agreement and the exclusion of interested and affected parties in this process. We believe this to amount to gross maladministration.

(CapeNature have refused to release a report and literature review of Prof J du P Bothma that was to scientifically inform management and the way forward. This report was paid for by public funds but for some reason it is not being released.)

Objection: The overall issues that we object to in the proposed Western Cape Biodiversity Massacre 2012 are:

1. Outsourcing of biodiversity management and oversight

CapeNature’s actions have effectively absolved themselves of their responsibility to managing biodiversity on farms, despite their better judgement and knowledge is objected to and alleged to be contrary to their legislative mandate.

By CapeNature’s own version their mandate with regards to the management of DCAs includes the following:

• The formulation, administration and application of legislation;
• The prevention of unacceptable or unselective management methods; and
• The promotion and support of research into DCA’s.

This agreement sees the outsourcing of that responsibility and the selective engagement of one grouping in the manner in which these functions are to be implemented. Only parties that have promoted large-scale indiscriminate lethal controls of predators were consulted, and the mechanisms of implementation agreed to runs contrary to targeting only individual damage causing animals, related to specific events that have had mitigation measures fail. It is inappropriate to hand over the management of DCA to agricultural unions and even farming groups that have stated objectives to exterminate top trophic level species.

In the 1950s – 1990s a province-wide cull of predators was managed across the Orange Free State Province through a bounty incentivised cull with organised hunt clubs called the ‘Oranje Jag’. This Oranje Jag saw the decimation of faunal diversity in that part of the country. This agreement is a fall back to and emulation of such draconian times and will see the same results in the decimation of biodiversity across the province. This political coerced action and outcome is objected to and the Western Cape Biodiversity Massacre must be stopped.

The parties have disregarded the general public interest, and specific stakeholders in having a healthy environment and ecosystems conserved, which is the very reason for spending taxpayers money on the legislative mandate of CapeNature.

2. Blanket approval for species assault

While the agreement document starts with appropriate principles, everything that follows in the mechanisms of execution of the agreement flies in the face of these principles. The principles that at promoted are that actions must be:

• Humane;
• Selective (target the individual responsible for the losses);
• Ecologically acceptable;
• Within the legal framework; and
• Efficient and cost-effective.

The use of gin traps (now euphemised to “soft traps”), hunting dogs, 1080 poison collars, helicopter hunting, uncontrolled cage traps, daytime hunting (inclusive we assume of denning, conibear traps and other barbaric means) and call and shoot hunting are contrary to these principles. Further too, this document goes into extensive detail of how the killing must only target damage causing individual animals, but extensive latitude is given to approval of killings in advance of any damage actually having taken place, and large-scale hunting permissions being given in advance of damage having taken place. It is clear that the agreement is rather a smokescreen for entire species extermination efforts.

For example, the “agreement” stipulates that the parties are:

• “To apply management methods in such a manner that the balance between commercial agriculture (food security) and biodiversity is enhanced.
• To ensure that landowners act in such a manner that:

o        non-target species are not negatively affected in the process; and

o        the natural environment (soil, water, vegetation and naturally occurring wildlife) are not prejudiced in the process.

• To promote the sustainable and economic utilisation of all resources.
• To take decisions jointly in order to determine which management methods achieve the best results.”

While the above principles and stated objectives seem sensible, the modus operandi flies in the face of these: Firstly the oft quotes issue of food security is a rather desperate attempt for the parties to extract some political relevance. Animal fibres and wildlife production methods of the producers involved play NO part in food security, and what relevance lamb and mutton has in the food security debate when these products retail at up to R150/kg in stores is highly questionable. The notion of sustainability is void for vagueness, and is used by all when they want to defend any indefensible position.

The methods approved will for certain, by virtue of their non-selective, indiscriminate, inhumane (=barbaric) and ecologically damaging nature kill off non-target species, kill off non-culprit individuals, target entire species for decimation and thus ruin the ecology of the entire province.

The joint decision making of this political expedient and coerced partnership of this agreement excludes an entire constituency that have an interest and right in healthy ecosystem management.

This agreement is nothing less than a global indigenous species extermination effort. It’s clear that the modus operandi of the permitting system approved is not targeted at individual animal removals that may cause damage, but a prospective, species wide (and anything that gets in the crossfire or caught as by-catch) extermination cull cloaked in nice principle statements.

3. Open season hunts

The permitting system promoted is nothing less than a province wide extermination cull of several species. It mimics the “Oranje Jag”, encourages hunt clubs through the agricultural unions and clearly aims to promote the hot-pursuit tactics of the pre-1994 hunts that left biodiversity over much of South Africa decimated. The one year prospective permit, together with renewal options, is thus aimed at a sustained assault on the biodiversity of the province.

The platitudes of reporting outcomes of hunts has been demonstrated over and over again to yield scant, if not negligible, reports of the actual decimation that takes place on a daily basis. The example of only some 200 – 300 kills reported in the almost 900 000 CapeNature’s Bredell Cull approved kills in 2011 just proves the disregard this industry and lobby group has for the accountable governance associated with permitting.

The allowed hunting of jackal and caracal during the day without permits demonstrates that the agreement has no intention of placing any controls whatsoever on landowners as it is nigh impossible for the institutional governance organisations to know what time of day animals are killed. It proves that the entire agreement is a sham.

4. Self-regulation

The handing over of the management and governance of biodiversity management to farmers is an absolution of responsibility and clear neglect of statutory duties that the Western Cape Government and CapeNature have to all the citizens, not just the political connected elite of the DA administration. This will fail and will misrepresent the actual decimation of wildlife in the province. We call of the provincial authorities to exercise their control over the devastation of biodiversity taking place on farmlands that is done in the name of the management of damage causing animals. To simply hand over the management of this fraught problem to farmers through this atrocious agreement is shameful and clearly demonstrates that the Western Cape’s DA administration only panders to the agricultural lobby groups that make up their power base, and has scant respect for biodiversity conservation.

5. Approval of methods of mass species destruction

The approval of gin traps, hunting dogs, helicopter hunting, 1080 poison use, and prospective hunting (uncontrolled in daytime) and night time call and shoot hunting is indiscriminate, unethical, ecologically damaging and flies in the face of the principles the agreement ambiguously espouses.

It is clear that this agreement hands the right to the agricultural lobby groups to prospectively and systematically exterminate naturally occurring species across the Western Cape with methods known to damage biodiversity, that are unethical and demonstratively unselective.

It is all together cynical to rebrand conventional gin traps as “soft traps” and killing dog packs as “sniffer” dogs. This is a deliberate deceit of the public and dishonest.

6. Hunt Clubs & Hot-pursuit actions

It is patently clear that the Western Cape Government and CapeNature aims to re-establish hunt clubs and hot pursuit actions of old, through group issued permits “managed and controlled” by the agricultural unions/farmers associations. (Hot pursuit was practiced in the draconian Apartheid years whereby predators could be pursued on anyone’s land).The de facto coercion of neighbours to sign consents will be immense and thus will become the norm.

7. The draft National Damage Causing Animal management regulations being used as the basis of action

The agreement is said to be based on the published draft Norms and Standards for the Management of Damage-Causing Animals (Government Gazette Vol 545, Pretoria, 26 November 2010, No 33806) – General Notice (1084 of 2010), herein after referred to as the Norms & Standards. It fails to note that this draft national regulation has not been finalised by the national department, as on publication is was subject to the largest objection ever in the environmental legislative process. These regulations inexplicably had massive alteration after drafting by specialist teams after intense lobbying by the same groups in the so-called “Predator Management Forum”, now subject to this agreement. The full objections of the Landmark Foundation to these regulations are contained here below – see annexure 3.

The gin traps that this agreement now rebrands as soft traps are the conventional traps used in South Africa and made by Peter Schneekluth of Prince Albert.

To claim that hunting dogs are only sniffer dogs is frankly deluded and a dishonest representation of the realities on farms, never mind contrary to the Animal Protection Act, as are the use of baited traps.

8. Bizarre consultative process that preceded unprecedented coercion of conservation staff and stakeholders to allow this “Bredell’s Oranje Jag”

The long history of political coercion in the development of this agreement to artificially and wrongfully promote the interest of a certain lobby group in cahoots with political power brokers is wrong. It has actively excluded other stakeholders, and even at the conclusion of the agreement a shammed process of co-opting sweetheart organisations to give legitimacy to this agreement is an abuse of power and unconstitutional. Stakeholders in the field were even excluded through abuse of police officials on 4 April 2012 after a publicly announced meeting on the topic by the DA administration and hosted by Premier Zille refused them access to discussions.

The calling on public comment on this agreement is a bizarre manner to try to give legitimacy to outsourcing of state functions.

Please find here a detailed submission and formal objection to the above stated “agreement” that was put out to public comment by CapeNature.