Update on state of captive lion breeding in South Africa

Meeting report

Bred for the bullet: Why big cats should not be bred in captivity

Dr Ross Harvey, a freelance consultant for the Elizabeth Margaret Steyn (EMS) Foundation and the Conservation Action Trust, started by introducing the members of his delegation, which included:

• Francis Garrard, Director: Conservation Action Trust;
• Charan Saunders, Volunteer: Conservation Action Trust;
• Stefania Faleou, Interspecies Equity: EMS Foundation; and
• Louise de Waal, Founder: Green Girls in Africa.

He said he was there to brief Members on the state of the captive predator breeding industry, and hopefully to equip them with the information to hold the Department of Environment, Forestry and Fisheries (DEFF) to account, especially with regard to the Parliamentary report adopted by the National Assembly last year in December. He would be talking about the revenue chain that the industry entailed, and giving a summary of two particularly important reports that had shaped the outcomes decided at the August 2018 Parliamentary Colloquium. He would then explain the outcome of the 2019 Gauteng High Court ruling, in which Judge Kollapen had ruled that the 2017 and 2018 lion skeleton export quotas were illegal. He would close with an analysis of that judgment’s implications for DEFF, and why the High-Level Panel (HLP) recently appointed to oversee the matter possessed neither the expertise nor the required terms of reference to give proper effect to Parliament’s resolutions.

Dr Harvey said that an infographic on page 1 of the presentation showed the various layers in the industry, or the “supply chain”. Breeders either rented or sold cubs to interaction facilities. At birth, these cubs were typically removed from their mothers, sometimes within a few hours or a few days. This pushed the lioness into estrous, and was a particularly cruel practice right at the outset. At these interaction facilities, once the cubs had outlived their usefulness, the breeders typically sell the cubs on. The interaction facilities typically sell the interaction to consumers as conservation, or at least conservation education. Animal interaction, in this particular case, had no conservation value, because captive-bred lions could not be reintroduced into the wild. It was clear that no conservation value was gained from holding large predators in captivity, which rendered the industry one that was essentially built on false pretexts, which was part of his objection to the industry, and he was not alone in that, as was witnessed last year.

Since the 2016 US import ban on trophy-import captive-bred lions, some breeders had chosen to breed lions directly for the Asian bone trade, instead of selling them to the hunting industry first, which was how it had typically worked in the past. Once the cubs had outlived their usefulness, they would be sold on to the captive-bred hunting industry, of which there were only eight accredited facilities in the country, but purported to use fair trade. The rest were just hand-reared lions that had been shut in an enclosure.

There had been some impact on that industry, but the bone trade was growing. Excluding hunting and the bone trade, Dr Harvey estimated that interaction alone generated revenues of approximately US$180 million a year, and that accrued to a handful of wealthy owners. This overall figure represents a “tiny” 1.8 % of total annual estimated tourism revenue.

Dr Harvey said that as an economist, he was interested in the opportunity costs of these kinds of activities. He conjectured, with some “well-informed reasoning,” that the future of the South African tourism industry may be jeopardised by South Africa’s continuation of this industry. He asked the Members to bear in mind that tourism alone now employed one in every seven South Africans. Direct employment in the captive lion industry was estimated by Peet van der Merwe and colleagues at North West University to be about 613 people directly, with perhaps another 500 in addition through what economists call a “multiplier effect”, given that it supports other industries such as fence building. As much as the industry was selling conservation under false pretexts and exploiting paying volunteers, it had a limited influence on local employment, “not that anyone should be employed in this industry at all”.

Dr Harvey then drew attention to a report released in July last year detailing the criminality in the industry. He presumed that the Members had copies of the report, which was titled “The Extinction Business: South Africa’s ‘Lion Bone’ Trade”.

He said the argument typically advanced in favour of the captive breeding industry was that it creates rural jobs, and could provide a buffer against wild lion exploitation. This was the language found in the non-detriment finding that South Africa was required to produce, showing that captive breeding had no immediate negative impact on wild lions within South Africa. Captive breeding may also satisfy some of the demand from Asia, where lion bones were sold as “tiger bones”. The argument says that this may prevent exploitation for that purpose. However, as was the case with rhinos, it was less costly, and the economic models showed this very compellingly -- it was less costly for poachers to supply wild-caught products than it was to farm lion bones with any kind of well-being considerations for their bones. This was especially the case if breeders had to comply with health regulations, which they did not give credence to, especially because there was a “governance lacuna”, and the fact that lions had been included in the Animal Improvement Act did not necessarily govern how they were slaughtered, or what kind of health considerations should be taken into effect.

However, it did seem like the Animal Improvement Act was, by design, an effort to reduce South Africa’s wild animals to mere domesticated stock, including rhinos and lions. The possible reputational effect thereof needed to be considered. In Dr Harvey’s view, a legal trade risked the expanding demand through signaling to consumers that predator bone consumption was legitimate, and in so doing it undermined any stigma effect that may currently be in operation, or the stigma that demand reduction campaigns were trying to create to reduce consumption. It also created a laundering channel for illicit supply. He reported that there was growing evidence from Panthera -- the world’s leading big cat conservation group -- that wild lions in Mozambique were increasingly being poached for their derivative parts, thus undermining South Africa’s speculation that captive lions provided a buffer against wild lion exploitation.

To maintain genetic variation and avoid inbreeding, which was an admitted problem by the industry, breeders do require wild stock. In the presence of illegal trade, it makes it incredibly difficult for law enforcement to try and distinguish captive-bred bones from wild-bred bones – they had neither the will nor the capacity to do that. There was “hard evidence” contained in the EMS’s Extinction Business report that showed that the proliferation of criminality in the industry was severe. There was also an abuse of the system, and more bones were probably being exported than what the data suggests.

Those in favour of maintaining the industry tend to argue that a ban would create an incentive to ship lion bone products illegally, creating a parallel illegal market. Dr Harvey found this argument disingenuous, because it was clear that the extensive criminality and links between the rhino horn and lion bone trades were already well-established, with international criminal groups such as the “Xaysavang Network” being implicated and connected to rhino horn trafficking. The EMS and Ban Animal Trading reports, aside from offering hard evidence to this end, also demonstrate the lack of governance pertaining to exports. The weights recorded on airline waybills suggest that far more than the actual number of skeletons permitted were actually being exported from South Africa. There was a deep lack of insight as to whether the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) permits actually reflected accurate and reliable information, especially regarding the import side. It was not currently known whether the addresses on the import permits were ever checked.  Most of them were shown to be fronts or fraudulent. This lack of governance oversight, prevalent throughout the industry, appeared to be breeding open criminality, providing extensive laundering opportunities for wild-caught animals’ bones to be trafficked to Asian markets. Part of this Committee’s oversight role was, Dr Harvey suggested, to ask the Minister what was being done to rectify the lack of governance seen in the industry.

On the economic front, the argument defending the industry was that it earned a large amount of revenue, and that it provided rural jobs -- but at what cost? What were the opportunity costs of maintaining these jobs and maintaining this industry? In a paper done last year, which worked with a number of assumptions, if South Africa did lose some tourism revenue due to negative reputational effects, then it stood to lose as much as R54 billion over the coming decade. This was a significant loss of income to an industry – tourism – that would increasingly compete globally on ethical grounds. There was a rise in ethical tourism, and tourists would not be pleased to find out they had been conned into cuddling wild lions, thinking that they were contributing to conservation, while actually contributing to canned hunting. Opportunity costs were thus something that must be given up in order to maintain something else.

At this stage, South Africa was losing the opportunity to be a leader in conservation-driven tourism for the sake of maintaining a small industry that benefited a handful wealthy people and, it would appear, breeds criminality. Dr Harvey estimated in his paper that if South Africa were to convert just 81 of the known predator interaction facilities to real wilderness landscapes, that would actually have a beneficial impact on ecology and 608 jobs could be created, using a labour absorption figure from ecotourism that was fairly well-established. The jobs that were lost were jobs that would be immediately recreated if South Africa had intact ecosystems. One of the major problems with South Africa’s purported conservation success story was that it had created a multitude of small, fragmented reserves that actually hindered proper ecological function.

Against the backdrop of economic data and the data supporting the view that this industry was actually proliferating criminality, a historic two-day Parliamentary Colloquium had taken place in August last year. (From professional hunters to sustainable use organisations from all over the world -- and notably African sustainable use organisations – the overwhelming consensus was that the captive predator breeding industry had no place in South Africa, or anywhere else. It did not contribute to conservation, and may harm both conservation and tourism. In light of this, the Portfolio Committee had resolved that the Department should initiate the following resolution (slide 1, page 4):

• The Department of Environmental Affairs should as a matter of urgency initiate a policy and legislative review of captive breeding of lions for hunting and lion bone trade with a view to putting an end to this practice, and that the Minister of Environmental Affairs should submit quarterly reports to the Portfolio Committee on the progress of this policy and legislative review.

Dr Harvey wanted to emphasise the point about “putting an end to this practice” because in his opinion, this had been missing from the Department’s response. The other two resolutions listed were:

• The Department of Environmental Affairs (DEA) should conduct an audit of captive lion breeding facilities throughout the country to ascertain the conformity with the current Threatened or Protected Species (TOPS) regulations and other applicable legislation in light of ongoing and increasing disquiet about the Captive Lion Breeding (CLB) industry and should ensure that the current breeding facilities comply with legislation. The Department should indicate whether it was aware of private lion and cheetah petting and walking farms in the country, and further state the courses of action it had pursued against violators of the TOPS regulations dealing with CLB.
• The DEA and the Department of Agriculture, Forestry and Fisheries should present a clear programme of work on how they intend to address animal welfare and health issues that had been raised during the Colloquium, which straddle the mandates of the two departments, outlining clear timeframes for achieving this.

The National Assembly had adopted these resolutions in December 2018. It was also worth noting at this stage that the highly pro-sustainable use organization, the International Union for the Conservation of Nature (IUCN) had submitted motion in 2016 that urged South Africa to terminate the industry, but it was a call that had subsequently been ignored.

The audit of the industry had not been made public. Dr Harvey strongly encouraged the Committee to ask the Department where this audit was.

There were extensive welfare problems in the industry, from “outright cruelty” to in-breeding, that had not yet been addressed. The Department had avoided responsibility by claiming that animal welfare was solely the preserve of the Department of Agriculture. However, the ruling from the High Court had been that conservation and welfare were two intertwined values, and this ruling from 2019 was built on a Constitutional Court ruling from 2016. It was not acceptable for the DEFF to make the argument that welfare was not its concern. It was not true that welfare was only the preserve of agriculture.

Dr Harvey said that he would like to empower the Committee in whatever way possible to ensure that the DEFF conducted an appropriate policy and legislative review of captive breeding, interaction, hunting and bone trade, with a view to terminating the industry altogether. A report filed by the Parliamentary Monitoring Group (PMG) in March this year had captured that, and Dr Harvey was present, along with a few of his colleagues, at a presentation by the DEFF that said that 88 facilities were found to be non-compliant with TOPS regulations, and other provincial regulations that were meant to govern this industry. Apparently 227 lion breeding facilities were inspected, which was short of the 266 facilities that the Minister, in reply to a Parliamentary Committee question this year, claimed existed.

He described a quote from the PMG report as “disturbing” -- 62 facilities in the Free State were found to be non-compliant with both TOPS regulations and permits, and 111 Free State facilities had been inspected. Most facilities were found to be operating with expired permits. Despite this audit, no figures were produced to show exactly how many facilities existed across the country or were involved in breeding, and how many large predators, including tigers, existed across these facilities. He suggested that this in itself provided evidence that there was little to no governance going on in the industry. A response to a Parliamentary question this year suggested 366 facilities and 7 898 lions, which seemed to be an “accurate” estimation, but given the rates at which lions were breeding, this seems to be questionable at best. It was not clear how that figure was arrived at. Dr Harvey encouraged the Committee to question such figures repeatedly.

A joint task team was meant to have been established between the Departments of Agriculture and Environment that would address welfare issues, and were meant to meet twice a year. It was not clear whether any progress had been made on that front.

Dr Harvey said that on 24 June this year, he had attended a meeting in Pretoria at which the scientific authority had explained how it would determine the lion skeleton export quota for this year, which had not been done yet. Despite numerous submissions stating that the quota was not scientifically determined, the coordinator for the scientific authority insisted that, because the survey of industry stakeholders revealed that many had threatened to sell bones illegally if the quota was deemed too restrictive, it was scientifically responsible to keep the quota at roughly the same level it had been at.

In early August, Judge Kollapen of the Gauteng High Court had ruled that the 2017/2018 quotas were in fact illegal and unconstitutional. The upshot of the ruling was that welfare and conservation were intertwined values, and given the evident welfare violations in the captive breeding industry, the Department had no grounds on which to establish a quota, or endorse a trade that had no conservation value.

On 4 October, providing further evidence of the interconnectedness between captive breeding and criminality, lion bones weighing 342kg were seized at OR Tambo International Airport. This was because of a tip-off from the airline, which had noticed suspicious activity. It was revealed last week that the suspect had been released on bail of only R3 000.

A 2012 article in the Mail & Guardian already warned of the risks to wild lions of South Africa’s proliferating captive predator breeding industry. This was not a new problem – wild-caught lions were being smuggled into the industry, it seemed, to maintain genetic variation in the stock. There was not only a risk that wild lions would be poached for their bones, but also a risk that the industry itself, in order to get out of the in-breeding problem, was capturing wild stock.

The Department had responded to the Parliamentary resolutions from last year by indicating that it would establish a High-Level Panel (appointed by Government Gazette, 10/10/2019), which it had now done, to address rhino, lion, elephant and leopard management. The language of the terms of reference were so broad as to be meaningless. Regarding lions, the terms of reference did not address the Parliamentary resolutions from last year at all, and no mention was made of the view to put an end to the industry. No publicly available criteria had been established by which the panelists were chosen. Professor Rob Slotow was the only ecological specialist on the panel, and in the latest version of that Gazette, his name was not there.

In closing, Dr Harvey said it seemed clear that the captive predator breeding industry was a blight on South Africa’s tourism and conservation reputation. That view was shared by the IUCN; it was shared by a number of professional hunting groups; it was also shared by non-governmental organisations (NGOs) that typically promote sustainable utilisation. None of them viewed this as a sustainably utilisable industry. The Department seemed intent on sidestepping the clear resolutions contained in the EMS report, and in light of the High Court judgment, the weight of public opinion against the industry and the need to shut it down, the Department could not resort to hiding behind the establishment of this High-Level Panel; certainly not until its terms of reference were clearer, and the methods behind who was chosen were made public, and at least subjected to some kind of verification process.

Discussion

Mr N Singh (IFP) thanked Dr Harvey for the presentation, and said it had been very useful. Some of the Members who had been involved in the environmental /conservation arena in the past were aware of the problems that existed with captive bred lion hunting and canned lion hunting. He asked if the Members, as a 6th Parliament Committee, had had the benefit of seeing what the Colloquium had produced, or the report of the Colloquium.  Had everyone had the benefit of seeing the resolutions passed by the 5th Parliament, so that they could see the recommendations contained in that report? The Committee could then follow up on those recommendations. It would be important to call on the Department to find out what action plans they had to follow up on those resolutions. Even though the Committee report was adopted in the 5th Parliament, they still remained relevant; but relevant only to the extent that the Members had to empower themselves with that information.

He had attended the Colloquium on one day. He was not a Member of this Committee at that time, but had attended out of interest. He did not know if other Members had also attended the Colloquium. He thought that to respond as a Committee to some of the issues things may be difficult in the absence of information such as the Colloquium report, House resolutions, etc. He suggested calling the Department in and asking them exactly what they were doing.

He commented that canned lion hunting was a major problem. The Committee had received reports in the past of unscrupulous people who were continuing with canned lion hunting illegally. There had been these audits, and non-governmental organisations (NGOs) had come to the Committee and said that they knew who these people were – very rich farmers. However, they had not been able to produce any evidence that the Committee could take to the Department and tell them to send the Green Scorpions to area A or area B, because that was where these things were happening.

Finally, Mr Singh said that he would have preferred that the presentation be made after the screening of Blood Lions, as there had been an invitation to a screening given to Members. He had seen the film twice, and previous Portfolio Committee Members had also seen it. He thought that the film would have given the Committee a good idea of what was really happening out there.

Mr N Paulsen (EFF) said he shared the disgust at the practice of canned lion hunting. He asked if there was an idea of how many facilities were involved in this. Was there a database of how many lions were kept in captivity for these purposes, and records of when they had cubs, etc.? He agreed with Mr Singh that although this matter had been started in the 5th Parliament, there was no reason why it should have died there. The Committee would support Mr Singh as he took matters further. Regarding the economic impact, if South Africa were to outlaw canned lion hunting and put an end to it, what would the alternatives be for those communities who would be affected by the ban on this practice? What options would the communities have? He said that lions should be in the wild for humans to observe without having to hunt them. He asked if Dr Harvey felt that South Africa should allow private people to own wildlife and breed them, and derive profit from whatever means? Should South Africa not outlaw the owning of these big cats?

Ms H Winkler (DA) said the positive spinoffs from the canned lion industry were negligible. Since they were not aware of exactly how many facilities there were, or how many lions there were, why had the government allowed the industry to proliferate without governance for such a long time, considering that there were numerous welfare issues and considerations? She asked why the “buffer argument” did not work. Regarding not taking the evidence of criminality among lion bone traders and organised international crime seriously, she asked Dr Harvey to expand on that and explain how shutting down the industry would help to improve law enforcement.

Ms S Mbatha (ANC) said that for a new person in this Portfolio Committee, the information presented had been difficult to follow. Just following the spoken presentation was going to limit the Committee’s debate on this issue. There were reports that Dr Harvey had referred to that the Committee did not have. It would have been better to bring those reports to the meeting so the Committee could look at them, with the resolutions and recommendations, so that Members could debate, especially seeing as these were the recommendations and resolutions that had not been implemented. She was not familiar with the Animal Improvement Act, but had to know what was being talked about so that she could engage effectively in the discussions. Some of the issues would need the involvement of both the Department of Agriculture and the DEFF. The two Portfolio Committees could meet, and then finalise a response in order to assist the Departments.

The Chairperson said he suspected that there might have been a breakdown in administration. The documents were supposed to be with the Committee. The documents mentioned had been the resolutions, the Colloquium, and the resolutions of the House. The documents were apparently bulky, and had been sent by email. In the end, the Committee was not the Department -- they were doing oversight. There might have been a breakdown of communication which had to be addressed. The presentation was still able to help the Committee, however.

Mr Paulsen said that the Members had been sent all the documentation to read.

The Chairperson said that the Committee would sort out the problem.

Ms Winkler noted that one of the resolutions that came out of the Colloquium stated that the Department should, as a matter of urgency, initiate a policy and legislative review of the canned lion industry with a view to putting an end to this practice. That had been the definitive recommendation of that Colloquium. If the Department had failed to act on that, then it was the Committee’s responsibility to hold the Department to account. She added that it was the responsibility of Committee Members that when issues of this magnitude came to this Committee, that they do the necessary research beforehand. She did not think that the onus was solely on the presenters to provide the entire context, the entire background. She thought that the Committee was there as Parliamentarians, and they needed to take some responsibility for the research before attending Committee hearings,. Canned lion hunting was an important issue, so Members needed to take it very seriously.

Ms Mbatha said that Ms Winkler was out of order.

The Chairperson said that the Committee wanted to understand the issue before engaging with the Department. The session was meant to help the Committee to be equal in terms of understanding what was going on, otherwise the Committee would not be able to do oversight of the Executive.

EMS Foundation response

Dr Harvey apologised for the small print which had made it difficult to read his presentation slides. He did not want Members to be overwhelmed by the information, and Members did have access to his speaking notes. He also wanted to show the media interest in the subject, and what had happened since the resolution of last year. He was aware that there was a lot of information for the new Committee Members to take in. The report on the Committee resolutions was relatively lengthy, but had been sent to the Secretary.

Dr Harvey mentioned that he would get to the assumptions from the paper. He agreed with Mr Singh that a screening of Blood Lions would give a very clear picture of what was going on. Whether a lion was shot after having been drugged and then taken to an enclosure, or shot in a larger enclosure, the ruling by the Supreme Court of Appeal in 2010 said there was no substantive difference in either of those two activities, because the lion had no chance of “fair escape” -- if it had been bred in captivity, it had human imprinting, which completely reduced its fear of humans. This was not a hunt in any meaningful sense of the word, which was why the custodians of professional hunting, who were trying to ensure “fair chase” hunting, were against this practice. These hunters see the industry as a threat because of the number of jobs that could be lost because the public does not see a difference between “fair chase” and canned hunting. The public just sees hunting that is being done abominably and with no governance.

The number of facilities and the number of lions was not known. If one went through the replies to Parliamentary questions, one would see that the Department says that it is not their responsibility, and that this information needs to come from the provinces, because the provinces are the issuing authorities. The Minister had come back, saying that the information the Department had from the provinces was that there were 366 facilities, and that there were 7 898 lions in captivity. Part of the difficulty with this figure was that there was no publicly available audit. That had been an NGO objection to the industry -- it was not known how many facilities were involved. Because the industry was “clandestine”, it was very easy to breed lions in the corner of one’s farm, and to slaughter them and to sell their bones. It was “very easy to get away with”.

The industry had not been well-governed because it was a difficult industry to govern, but as long as the government sent a signal that the industry was legitimate to breed and exploit lions, the practice was likely to continue. He asked how a quota could be set if it was unknown how many lions were being bred in captivity, and how they were being treated. There were only eight accredited hunting facilities, according to the Professional Hunting Association of South Africa. The South African Predator Association and the Professional Hunting Association of South Africa say that these lions were hunted in excellent conditions, but only eight of the nine facilities were accredited by the same institution. It raised the question of what was happening in other facilities. If one looked at the websites of those eight accredited facilities, one would see that some of those still used baiting, explicitly, for instance, baiting white lions. This raised the question of whether fair chase was really occurring, and if it was possible to do fair chase hunting on lions that were bred in captivity.

On the question of what the impacts of shutting down the industry would be, Dr Harvey responded that with the information available at this stage, 613 direct jobs would be lost, and at worst, 500 jobs would be lost in support industries; that would be the immediate cost. However, the majority of these facilities, if there were 366, were hardly contributing to South Africa’s wilderness landscapes. It did not take a large amount of land to breed lions. A more conservation-promoting alternative would be to join some of these landscapes up. If one ran a geographic information system (GIS) mapping exercise to see where some of these facilities were, one could join them up. With a labour absorption figure that had been publicly verified, at least 600 alternative jobs could be produced in ecotourism, which was both non-consumptive and sustainable, because it provides intact landscapes. Ultimately, that had to be the objective: If South Africa could move away from small, fragmented spaces in which lions were being bred for no conservation value and turn those spaces into joined-up wilderness landscapes, that would help to enhance South Africa’s reputation.

Dr Harvey said he could not give a direct answer as to whether South Africa should outlaw private ownership. The breeding of plains game in many respects had contributed to some conservation success in South Africa. The difficulty -- and what was often not recognised -- was that private ownership had incentivized the proliferation of small, fragmented reserves. In many of those small reserves, there were problems with trying to manage lions and elephant in the wild, because those migratory species needed space in which to move. He thought that the solution lay in a form of public-private partnership, in which these fragmented reserves were joined up. The other problem with breeding plains game was that breeders end up “hounding” apex predators who come after their specially-bred impala. This raises the question of whether people should be breeding impala to the detriment of wild animals, just so that a hunter could get a black impala, for example. Those from Gauteng may have noticed that the Cradle of Humankind lion and rhino park had come under new management, and part of the marketing was that the park does not offer interaction facilities. Dr Harvey considered that to be a relatively brave step, because in the past, any attempts to remove human interaction had been met with the response that this undermined profitability. With ethical tourism on the rise, and awareness of the detrimental effects of human-predator interaction and safety risks, that marketing facility as non-interactive was a win.

This raised the question of what to do with lions bred that were bred in captivity. The move of lions to sanctuaries needed to be financed. This was the lament -- if only this had this been done in 2009 when there were a lot fewer lions, and there was a clear and manageable plan to house them. Now it was a lot more difficult.

On why the government had allowed the industry to proliferate, Dr Harvey said this had been partly due to confusion as to what sustainable use actually meant. The government had embraced the idea that captive lion breeding did provide a buffer against wild lion exploitation, and that it satisfied some of the demand for bones in Asia. This was the stance of the scientific authority. He encouraged the Committee to ask the scientific authority to come and present, as their view was typically that they reported to the Minister and not to Parliament. He said that the government’s view on this issue was akin to “giving a cigarette to a teenager and then telling them not to smoke.” It was saying to consumers that the industry was legitimate – “we would grow these bones for your consumption, but please don’t consume them.”

His view as an economist was that the South African government was at risk of sending confusing signals to the market, because there were demand reduction campaigns in progress to stigmatise the consumption of tiger bones to protect tigers in the wild. South Africa was undermining those efforts by actively supporting and supplying lion bones into the market, but then they were sold on as tiger bones. This puts wild tigers at risk in Asia, and puts wild lions outside of Asia at risk.

The non-detriment findings use very specific language. They say that captive breeding in South Africa could provide a buffer against wild lion exploitation within South Africa. That raises the question: what about Mozambique’s lions? They were in the process of being slaughtered for their bones and derivative parts. South Africa’s lions in the wild were “doing just fine”, but countries whose protected areas were less well-protected than South Africa’s were seeing their lions decimated, in part for the bone trade.

The other thing to note about the non-detriment finding – which was a CITES requirement, that one had to show that captive breeding had no obvious and immediate negative impact on wild lion survival – was that it was a “statement of speculation.” That it could provide a buffer was not a statement of science, but a statement of speculation. In Dr Harvey’s opinion, there was a hiding behind science, because something appeared in a scientific journal. There was also the risk that one could exacerbate demand, as one was sending a signal to the retail end of the market that consumption was legitimate. There were potentially one billion consumers, which was “just about more than the entire population of Africa,” and people with disposable income who wanted to “consume tiger bone wine in a rhino horn wine glass”. Why would South Africa exacerbate that risk through allowing legalised trade, especially one which provided a potential laundering channel?

It was incredibly difficult for law enforcement to try and distinguish between legal captive-bred bone and wild bone. As it was, DNA testing of the skeletons was not occurring. It occurred before the skeletons got packaged, and the EMS report showed that 95% of the skeletons exported in 2017 still had the skulls intact. That killed the argument that bone exports were a byproduct of the hunting industry, because hunters keep the skulls. The bones were clearly being exported directly for the bone market, and were no longer just a byproduct of the hunting industry.

On the question of criminality, the evidence in the EMS report showed that the weight of the bones on the waybill was different to that declared on the CITES export permit. It was obvious that no one was checking the import destinations. On the South African side, the CITES permit authority said that all the necessary information had been filled out, but they did not have the capacity to check whether those bones were going to the address it said they were going to. The bone trade was exporting a lot more than what the quota allowed, and what the CITES permits allowed. That was basically “documented criminality.”

The government was still convinced by the argument that it was satiating some of the demand for bones -- it was never going to be able to really change the demand for bones, so the industry should just be allowed to proliferate. Dr Harvey said that he would make the argument that that stance did not consider the opportunity costs of the industry to South Africa’s reputation, especially tourism. If one invited anyone from the Ethical Hunting Association, they would say that this industry posed a massive threat to their livelihoods -- not that Dr Harvey was promoting that either, because he thought that it was ultimately unsustainable.”

The Chairperson said that the responses should suffice. Moving forward, all Members must have the documentation. The sooner they got the documents the better, so that they could interact with this important topic. These would include the report of the resolutions of the Colloquium, the resolutions of the House, and possibly the letter from the Speaker to the Minister, and the response of the Department when they briefed the previous Committee. With the relevant documentation, the Members could understand on their own what they were dealing with.

Regarding action, the Committee would invite the Department to address the subject, because it could not talk in a meeting if it did not know what the Department had done on those issues. The Committee would now be preparing for engagement with the Department to check progress on what had actually been resolved. Unfortunately, how government works was that Parliament passes legislation, and wants to ensure that it gets implemented. It wants to review legislation, as the Committee suggested in the resolutions, so it cannot leave the Department out. The Department had to come before the Committee so that the Committee could be on equal terms with what it feeds back to Parliament as a Committee. For now, the Committee should be satisfied with the information it had been given.

Mr Singh said that an invitation had been extended to all to see Blood Lions, and he hoped that an invitation would be extended to the Minister as well.

The Chairperson said that Ms Mbatha was still trying to understand what the invitation was.

Mr Singh explained that there was a film called Blood Lions, which gave one a sense of how canned lion hunting took place, and some of the unscrupulous people involved in this. He had seen the film twice, and the previous Committee under the current Minister in the Presidency, Mr Jackson Mthembu, had gone to see a screening. He thought that the film would give a better sense of the issue. He suggested that those who were available from the Committee should attend the upcoming screening, and an invitation should be extended to the Minister. A meeting between the Committee and the Department on the lion breeding issue could be scheduled for a time after the screening..

The Chairperson said he hoped that by the next meeting, the Members would be completely different in terms of understanding the issues at hand.  

The meeting was adjourned.