1. POLICY UNCERTAINTY DYSFUNCTIONAL FOR GAME INDUSTRY
Presentation by Dr. G. C. DRY
to the Portfolio Committee on Environmental Affairs
on behalf of a Consortium of Interested and Affected Parties
on the 2015 NEMLA Bill

2. ORIENTATION: GAME RANCHING SECTOR RSA Baseline
20m ha marginal agricultural land
20m head of farmed game
R2,300bn embedded Capex
20% of red meat (150k tons p.a.)
Reference
Absa Report 2015: Game Ranch Profitability in RSA

3. ORIENTATION: GAME RANCHING SECTOR AFRICA
Reference
Craigie, I.D. et al. 2010, “Large mammals population declines in Africa”, Biological Conservation 143:

4. POLICY UNCERTAINTY
Draft Biodiversity Bill: Preservation (biocentric) ideology
Subordinate legal instruments:
Regulations, Norms & Standards, Guidelines and Permits
Policy Incoherence:
DEA gazetted 33 “draft legal instruments” (2005 – 2018) which have not been promulgated into law
Insurmountable differences
Historic distribution ranges & maps
Extra-limital
Indigenous species definitions
Single AIS definition for mammals, plant & vegetation
Sub-speciation ecological approach vs Biological Species Concept (BSC)

5. POLICY UNCERTAINTY Cont.…
Biocentric ideology on Institutional Mindset
Hybridization, genetic bottlenecks etc.
HOWEVER
Successes of farmed game totally ignored
DEA Jurisprudence not “enabling” for farmed game
Preservation ideology and legislation do not save a specie from declining / extinction
Illogical / arbitrary distribution ranges across biomes ignores specie composition on game ranches

6. Amendment to section 3 “ownership of game”
New section 3(2)
“The Minister may, by notice in the Gazette, specify the species and the circumstances under which the State remains the custodian of faunal biological resources that escape from land under its control.”
Inserted after public consultation closed. No stakeholder engagement.
Contrary to common law and recent SCA decision in EC parks vs Medbury
Introduces one law for the state and other for private citizens.
At common law wild animals cannot be owned if they are not sufficiently contained.
What is sufficient containment is determined as a matter of fact.
Animals in State parks may be owned by the state if sufficiently contained.
DEA wants the right to legislate special rules for itself that conflict with established law.

7. AIS SPECIFIC JURISPRUDENCE
Listings now extremely off-track
Ignores Socio-economic benefits
Humanity not seen as a part of Environment
Insufficient Information
Ignores SANBI Draft AIS Report
CoP17, CITES, IUCN, NEMBA do not count farmed game, given their definition of “wild animals” in the “wild”.

8. RED LISTING PROCESS: NOT COUNTING FARMED GAME
1. SABLE ANTELOPE (Hippotragus Niger Niger)
2004 Red List Status: - Vulnerable
2014 Red List Status: - Vulnerable
477 mature individuals (<1000)
No sub-population larger than 250
Most sub-populations are declining
Note however individuals (97%) on private game ranches
Reference
2014 Revising the Red List of mammals of South Africa, Swaziland and Lesotho

9. RED LISTING PROCESS: NOT COUNTING FARMED GAME
1. ROAN ANTELOPE (Hippotragus Equinis)
2004 Red List Status: - Vulnerable
2014 Red List Status: - Endangered
445 mature individuals (<250)
No sub-population larger than 250
50% of sub-populations declining
Note however 4500 individuals (92%) on private game ranches
Reference
2014 Revising the Red List of mammals of South Africa, Swaziland and Lesotho

10. OPERATION PHAKISA AND DEA LABS
DEA BIODIVERSITY ECONOMY LAB
Review unsupportive legislative regimes:
SPUMLA vs PDALB
NEMBA: No “enabling” provisions for farmed game
Misalignment between DEA and Provinces
Game meat value chain
DAFF OPERATION PHAKISA
Unsupportive legislation and jurisprudence
SPUMLA and PDALB conflicting
Misalignment between DEA, DAFF and DRLD legislation

11. R. M. Tolba, Executive Director: UN Environment Programmes, 1992
CONCLUSION
Not self-correcting without Body Politics intervention
Insufficient weight in respect of Biodiversity Economy and Sustainable Use.
“There are loud complaints from a number of developing countries that the rich countries are only interested in making Third World countries into a natural history museum. They are not giving food to their people”
R. M. Tolba, Executive Director: UN Environment Programmes, 1992