SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Wed Feb 08, 2017 3:24 pm

-- BREAKING NEWS --
SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN
Environment Minister Edna Molewa has given notice of her intention to make regulations on trading in rhino horn domestically.
The document below has been published in the Government Gazette today and the public have 30-days to write written representations or objections to the matter.

https://www.greengazette.co.za/notices/national-environmental-management-biodiversity-act-10-2004-draft-regulations-for-the-domestic-trade-in-rhinoceros-horn-or-a-part-product-or-derivative-of-rhinoceros-horn_20170208-GGN-40601-00074

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Fri Feb 24, 2017 4:21 pm

A really brilliant response!!!!!!!!!!!!!!!!!!!!!
‘Molewa’s Rhino Apocalypse’
NICK P LYNCH·FRIDAY, FEBRUARY 24, 2017

On the 8th of February South Africa’s Department of Environmental Affairs (DEA) gave public notice in the ‘Gazette’ for ‘Draft Regulations’ for the proposed Domestic Trade of Rhinoceros Horn.
https://drive.google.com/file/d/0B0z4Ip ... RCeE0/view
These regs include a clause that allows foreigners to export horns for “personal purposes.” This is largely viewed by the conservation world as a sneaky attempt to activate international trade which all but guarantees the extinction of the species in the wild.
Members of the public were invited to submit their written representations and objections – these are mine.
The Director-General
Department of Environmental Affairs
Att. Ms. Magdel Boshoff
Cc Dr. Edna Molewa
Re: Representations and objections to Notice 74 2017 ‘Draft regulations for the domestic trade in rhinoceros horn..’
Dear Director-General Nosipho Ngcaba,
Hon. Minister Edna Molewa
Ms. Boshoff,
I believe the draft regulations for ‘Domestic trade in rhino horn’ which includes the clause for ‘personal purposes’ export - are ill conceived and reflect poorly on the DEA and on South Africa’s commitment to the CITES treaty. Many of your fellow CITES member states will be viewing your policy hack job maneuver promoting quasi legalized international trade with disgust, most of whom voted overwhelmingly against trade for Swaziland at CoP17.
The DEA’s drafted regulations amount to a South African unilateral decision that threatens all of the remaining wild rhinos throughout Africa. Any supply of horn to the insatiable market, even 3D printed horn substitute, will fan more demand. This is the consensus of the organizations involved with studying market demand in Vietnam, where it is estimated 90% of rhino horn ends up, often to be purchased by visiting Chinese tourists who have come to view Vietnam as a wildlife wholesale depot.
· Political Considerations
On the political front I believe it is safe to stay that trade in rhino horn and lion carcasses are abhorrent practices in the opinion of most South Africans.
These decisions to trade both horn and lion carcasses, are of such a serious nature and have such disastrous far reaching consequences for both species throughout Africa, that the decisions cannot and MUST not solely be made by the DEA or Minister Molewa or a handful of commercial rhino farmers or a bunch of canned lion hillbillies.
These decisions have to first rightly be democratically decided upon by the South African public at large. To this end a logical solution to these problems would be to have these issues thoroughly debated in Parliament by South Africa’s body politic in order for the fair democratic representation of the publics opinion to be made.
To this end I have copied into this correspondence to various conservation groups as well as opposition parties in South Africa in the hope that these disastrous schemes can be halted; in the national interest and also for the sakes of both rhinos and lions throughout Africa.
I attended CITES CoP17 as part of a USFWS endorsed WildiZe Foundation ‘CITES Observer Team’ - a part of our mission was to investigate rhino conservation in South Africa. I write here not officially representing any organization, but on my own accord as someone who feels your decisions place both species at higher risk throughout Africa.
I also believe that your decisions have usurped the democratic will of the majority of South Africans who trust you to safeguard their wildlife heritage.
I do not believe your draft regulations are positive for the following reasons:
· The proposed “personal purposes” export clause in your draft Domestic Trade regulations are effectively a sly attempt at sneaking into place international trade of rhino horn, against the wishes of the majority of your fellow CITES member states.
· Your proposed trade system will unavoidably fan demand for more rhino horn in general, which will exponentially increase poaching throughout Africa after South Africa’s first “personal purpose” exports.
· The DEA cannot guarantee that the “personal purposes” scheme will not be blended into the illegal market because criminals will find weaknesses in the permitting system in order to launder poached rhino horn aka ‘masking.’
· The potential financial costs attached to South Africa’s intransigence must also factor trade penalties like sanctions that could ultimately be imposed by bodies like CITES. The DEA’s maneuver to introduce this scheme could be viewed as South African disdain for international cooperation.
· Understanding the Market
The amount of detailed professional market research that has been conducted in Vietnam by both international and local Vietnamese organizations is impressive, even by corporate marketing standards.
The leading expert groups in this field such as Breaking The Brand and Traffic Southeast Asia and Education for Nature - Vietnam (ENV) and WildAct and WildAid to name a few, have been studying this subject for years.
As part and parcel of these organisations continued efforts in rhino horn demand reduction campaigning, they have formed a sharp clear picture of how the market works and what the buyers of rhino horn want and even what personally motivates them.
Researchers can even pinpoint the five main suburbs around the country where the estimated twenty five thousand odd Vietnamese who can afford to buy rhino horn actually live. The market and its demands are not an unknown quantity – on the contrary, it is a market that is extremely well understood.
It is peculiar then that this freely available research seems to be willfully ignored by South Africa’s DEA, and in particular the ‘pro-trade’ lobby.
Research that says the ‘top tier buyers’ of rhino horn, those who pay the highest premiums, are demanding that the horn be hacked out of the face beneath the base of the horn and must be accompanied by the ears, the tail and more recently the feet, as proof of ‘wildness’ and ‘potency.’
Does that sound like a commodity you can sustainably supply?
Farmed and neatly cropped rhino horn, will never fetch as high a price in the marketplace as the ‘hacked out of the face’ variety.
In the same way sparkling white wine is still not Champagne.
In the South African pro-traders case, they assume that placing ‘legal’ (sparkling white wine) into the market will deter consumers from seeking out the Champagne. In fact all that will happen is that the buyers of sparkling wine, when wealthier, will eventually move over to Champagne.
South Africa’s farmed and neatly sawn off rhino horns exported under the dubious guise for “personal purposes” will create more desire in the market place for ‘the real’ more ‘fresher’ more ‘wild’ more ‘potent’ horn. The few remaining rhino’s that exist in the wild will become even more sought after with their horns fetching an even higher premium.
Some stockpiled rhino horn in South Africa has been treated with sprayed diesel to discourage parasites – this horn holds the least appeal for purchase and should trade at the lowest prices because it is considered ‘less safe’ to consume and therefore its use would mostly be for ornamental purposes.
The least prominent buyer in the market place is the one seeking to buy rhino horn for ornamental or carving purposes.
· Market ignorance by Commercial Farmers and the State
For the commercial farmer intending to breed rhino’s in order to some day sell the horns to make profit, these market nuances are absolutely critical to grasp.
Having discussed these nuances with several rhino owners and ‘pro-traders’ and even senior SanParks veterinarian staff, I was amazed by how little was really understood about market demands.
For the most part – the bulk of the people I spoke with on this matter were still stuck with an outdated notion that “the Asians want rhino horn as an aphrodisiac” – which is nonsense.
Quite honestly it would be a good idea to have a bespoke education program set up for South Africa that details market demand for everyone dealing in anything to do with rhino.
The DEA has failed by not understanding the market and by not analyzing the abundant researched data that is freely available from the aforementioned organisations.
The core value attributed to the product by consumers is for its perceived mystical medicinal attributes – not so much its ornamental value. Rhino horn is a unique and nuanced product that the commercial farmer will find fraught with marketing difficulties that cannot ultimately be serviced; basically you cannot successfully Coca-Colarise magic potions that are preferably hacked out of a rhino’s face.
· Jeopardizing All of the Remaining Wild Rhino in Africa
Your unilateral decision to place the entire species at risk must be viewed dimly by your neighboring SADC states. What a relief it will be for Namibia, Zimbabwe and Botswana etc. to know that John Hume and a small handful of South African ‘pro-trade’ rhino farmers are making a fortune out of their ‘stock.’
Does South Africa now intend to subsidize its neighbors with financial aid? Countries who must now invest more heavily in anti-poaching and law enforcement to counter the demand you fanned.
With only 25 000 odd rhino’s left in the wild, we can no longer play economic gambling games with their fate as the species has gone beyond the point of being commercially viable to exploit.
· Do you really want to set off the Rhino Apocalypse?
I am certain that if your proposal for domestic trade and international ‘personal purposes’ export is enacted that within a few short years the conservation world will be able to point to your administration as the one that pulled the trigger, which finally saw the rhinoceros, disappear in the wilds of Africa. You will be remembered as the DEA management team that was responsible for setting off the rhino apocalypse.
· Unenforceable monitoring of ‘personal purposes’
In an article that appeared in Africa Geographic on the 8th of January: ‘Rhino Bombshell: SA Minister plans to permit trade in horn’ - the author notes how the proposed “personal purposes” export “..looks like a loophole big enough to drive a tractor through.”
It seems impossible that this loophole has been created by mistake and thus it means its design is deliberate – something that in itself should be investigated and debated in parliament. It is ridiculous to expect other governments to check up on “personal purpose” importers to ensure they haven’t sold their horns.
What happens when the importer has finished grinding and consuming both of his rhino horns? How do you expect Vietnamese or Chinese authorities to police “personal purposes” importers? How could Vietnamese importers be stopped from selling their horns to say visiting Chinese tourists? How is the DEA expecting the Vietnamese or the Chinese to undertake rigorous DNA testing to ensure these countries comply with your lists?
Your Chief Director of Bio Diversity Thea Carroll who was interviewed by Sunday Times ZA conveyed how the proposed regulations are bolstered by new marking and DNA sampling techniques and through better checks and balances that will thwart villains attempting to ‘mask’ or laundering poached rhino horn – as was done previously when your trade systems was overwhelmed by these issues that lead to the last trade ban. Gov. Gazette No. 31899, Notice No. 148, 13 February 2009.
Domestically however there are concerns, as reported in HeraldLIVE - Port Elizabethive where World Wildlife Fund rhino program head Dr. Jo Shaw said they too would be submitting a report and had identified a number of associated risks.
Says Shaw: “We do not believe the necessary control mechanisms are in place at a national or provincial level to enable law enforcement and permitting staff to regulate legal domestic trade alongside the existing levels of illegal trade in rhino horn. We are particularly concerned about the apparent inclusion of international exports within these regulations, given known challenges around law enforcement and compliance in consumer countries, such as Vietnam.”
· Does the DEA have the capacity to monitor this scheme?
Despite the DNA stuff and the apparently well thought out monitoring systems …there are those in the conservation community that feel you are under equipped and under staffed and under budgeted to meet the challenge of proficiently monitoring these regulations.
The DEA is already un-able to deliver in other areas – such as the timely provision of poaching figures. Unconfirmed reports indicate horrendous poaching in the Kruger NP with an alleged average of two rhino a day being poached since January.
Says OSCAP’s Allison Thomson: "The Department’s capacity or lack thereof with regards releasing the stats timeously raises the question: If the Department is not in a position to validate and report back on poaching figures on a regular basis how then do they believe they have the capacity to monitor trade?”
· Democracy and the Environment
Through my work in wildlife advocacy I have come to realize that a country’s environmental management is like a barometer for measuring the democratic and managerial health of a nation.
By postulating this ‘pro-trade’ position in horn and also in lion carcasses the South African government has distanced itself from the democratic will of the majority. Is the African National Congress through the DEA intentionally striving to do the direct opposite of what most South Africans want?
On the day before CITES officially opened my team and I followed and recorded the Global March for Elephants and Rhinos and Lions.’
https://www.facebook.com/17004931969082 ... =2&theater
What struck me was how so many people from every cross section of the community and from all walks of life had banded together in unison to protest their anxieties with how they view their wildlife heritage is being mismanaged.
One wonders why you prefer to curry favor with a handful of questionable Chinese and Vietnamese expats who wish to trade critically endangered species or with the minority of ‘pro-traders’ and or a handful of canned lion hunting hillbillies. Why do you covet these peoples ‘friendship’ and not the friendship of the general public at large?
· Put these issues to the vote and let the people decide
There most certainly should be open debate on these proposed regulations by the South African body politic who must decide for the people the fate of rhino and lions.
I believe that the average South African thinks this lion bone exports to China thing is crazy and shouldn’t be allowed – and that this rhino horn business is equally mad! Enough is enough! It should no longer be up to Edna Molewa and the DEA to determine what happens next rhino’s and lions – not until it is thoroughly debated in parliament.
This is why I have CC’d a variety of opposition groups in South Africa as well as various conservation orgs and personalities to this letter – in the hope that it sparks debate and encourages your South African body politic to seriously and urgently address the fate of rhino’s and lions in your country - and for the remaining rhinos and lions of Africa.
· Retarding law enforcement
In the press Allison Thompson from ‘Outraged South African Citizens Against Poaching OSCAP’ called the proposed regulations: “reckless and irresponsible” and went on further to highlight the risks of encouraging transnational organized crime:
“We need to remember that the rhino-poaching crisis is a transnational organised-crime issue which flourishes in South Africa thanks to rampant corruption. Trading in rhino horn does not solve the problem, it exacerbates it.”
To buttress what Ms. Thompson is saying it’s now known that the criminal syndicates who smuggle rhino horn are not exclusively dedicated to rhino horn as the single product that they deal in. The same syndicates are involved in arms – drugs – human body parts trafficking as well as people smuggling and a host of other black market activities.
· Economic Miscalculations of Market Demand
A renewed economic viability study for rhino horn trade is required because it appears South Africa’s strategy ignores all the market dynamics involved. Your strategies are guided by ‘pseudo economics’ put to you by the ‘pro-trade’ lobby who have inaccurately excluded the other revenue streams in use by criminal syndicates as commented on by the economist Alejandro Nadal at CoP17
https://www.facebook.com/17004931969082 ... =2&theater
The entry of South African “quasi-legal horn” into the market will have no effect in taking power away from the bad guys – in fact they’ll simply view your legal horn as an advertisement designed to entice more customers who will go to them to place orders for ‘the real thing.’
· South Africa and the creeping hand of organized criminal influence in wildlife contraband
The creeping hand of international criminal syndicates has already worryingly established itself in South Africa and it’s anyone’s guess how far up the ladder the rot actually goes. As the recently aired Al Jazeera English expose ‘Poachers Pipeline’ highlights by showing us that now infamous photo of State Security Minister David Mahlobo allegedly hanging out with a Chinese organized crime figure who traffics rhino horns.
No State Security Minister from any country should ever ever ever be photographed in a chummy embrace with Chinese organized crime figures hanging out in a brothel.
These kinds of alleged affiliations by senior government ministers and supposed organized crime members involved in wildlife contraband are exactly the types of scandals the public has a right to demand resignations over. If not complicit of any wrongdoing, then Mahlobo should still resign for his incompetence.
· Accelerating Extinction – how long does the rhino in the wild have left?
The consensus by some South African rhino experts is that if the current rate of poaching persists, then the rhino could be extinct in the wild in South Africa in as little as five to ten years. South African attempts to enact international trade could give all the remaining wild rhino in Africa the same sort of time frame to survive.
Noting South Africa’s previously sound approach to banning trade and its efforts to save the species through more determined law enforcement strategies, it is perplexing that the DEA would now do such a sharp turn about face in the opposite direction from where it appeared your policy was once progressively going.
I am sorry to say that despite the earnest and best efforts by many professionals working for the DEA including SanParks – that should the rhino become extinct in the wild in South Africa, then that extinction will be placed squarely and rightly at the feet of the ANC government who are entirely responsible for the loss.
· Re-evaluating the value of iconic national identity species
Considering the endangered status of rhino’s and lions, these iconic national identity species - shouldn’t their urgent preservation be a national priority? The value of these species should no longer be calculated in monetary terms alone, for how could you place a dollar sign on your national identity?
The value of the species must now be viewed from a national perspective and how the South African public feels about losing the rhino in the wild? It is not about whether or not the price of rhino horn is up or down – it’s more about making the decision to have rhinos or not have them.
· ‘Undermining Years of Progress’ in Vietnam
At the same time you’ve annoyed seasoned Vietnamese campaigners who have been successfully lobbying the Vietnamese government in order to have the penal code amended so that harsher penalties are put into place for those dealing in wildlife contraband – in the view of one Vietnamese organization ENV your decision has ‘undermined years of progress.’
On a recent podcast by Annamiticus titled “South Africa’s Latest Rhino Horn Trade Shenanigans” Founder of ‘Education for Nature - Vietnam (ENV) Quyen Vu remarked how your proposed regulations undermined Vietnams sincere efforts.
Says Vu: “If they want to legalize domestic trade then don’t talk about import export to other country’s. If they want to protect rhinos then don’t try to sell rhinos to us to a country like Vietnam or China”
She went on to explain how your proposed regulations would result in a wave of newly “permitted” rhino horn pouring into Vietnam.
“Once South Africa legalizes domestic trade that mean you can expect a large number of rhino horns would come into Vietnam with legal permits – and, nothing we can [now] do about it.”
“Vietnam has been taking responsibility and working hard and making progress – South Africa can no longer blame country like Vietnam for not doing anything – the next CoP (CITES meeting) countries should blame South Africa – they should no longer focus on Vietnam because now they legalize the trade on rhino horn the blood will be in their hands”
· Failing South Africa’s Rhino Farmers
You and your ANC government have even failed much of the ‘pro-trade’ lobby.
At the end of the day most rhino farmers will tell you that all they’re looking for is the financial means with which to defend themselves and their game stock – from constant criminal attack.
Theirs is a constant outcry for their ability to cash in on their investments in order to pay for more private militarized security to protect their ‘endangered’ stock.
It occurs to me that the security of a country is firstly the responsibility of the State!
Why is your government refusing to protect these tax payers and their investments?
Looking at it from their point of view they are under constant attack by armed poachers and in some cases are paying out R80 000 a month in defending their rhino livestock. As you no doubt are aware the farming community in general has apparently been under virtual siege from violent crime over many years. Horrifically it was reported in AfriForum that:
“Thirty farm attacks have already been recorded in South Africa since the beginning of February 2017, in which eleven people were brutally murdered. How many more people will have to lose their lives in this country before something decisively is done? It seems that Government is not prepared to protect citizens,” says Ian Cameron, AfriForum’s Head of Community Safety.”
With such a catastrophic onslaught in place is it little wonder why the farmers, game farmer or otherwise, are pleading for better protection? So desperate are they that they continue to push the need to sell their cropped rhino horn – irrespective if legal supply fans demand or not – they must make money out of having those rhino’s otherwise they can’t afford to protect their investments.
It is unreasonable to expect the tax paying citizens of South Africa to have to defend themselves up to such levels that it equates to fighting low-intensity guerrilla warfare. At some point or another – the government is going to have to get serious about these security problems.
Finally – please do not set off the Rhino Apocalypse or any apocalypses for that matter, and instead please focus on ways to secure the country from rampant banditry and armed robberies and concentrate on how to stop your poaching issues and especially through poverty alleviation and addressing inequality.
Sincerely, Nick P Lynch

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Sun Feb 26, 2017 5:43 pm

At the moment rhino horn trading is banned, end of story... -O-

The Vietnamese certainly mustn't play the "holier than thou" card...they partly started the mess! :X:

http://thediplomat.com/2016/02/vietnams ... n-problem/

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Mon Feb 27, 2017 10:54 am

Excellent Mr Lynch!! ^Q^ ^Q^

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Wed Mar 01, 2017 10:20 am

Rhino sale bombshell hidden in new draft regulations

ImagePhoto by Steve Evans via Flickr.

The public has until March 10 to respond to draft regulations by the South African Department of Environmental Affairs (DEA) which seek to make widespread sale of rhino horn legal and could undermine attempts by CITES to save rhinos. Speaking in a Parliamentary portfolio committee on Tuesday February 21, Minister Edna Molewa and DEA biodiversity director Thea Carroll spoke to the regulations in terms of legalising the sale of two rhino horns per person, but failed to mention the devil in the detail which a closer reading of the regulations later revealed, writes DON PINNOCK.

It turns out the two-per-person discussion was a red herring which effectively diverted attention of the few attending MPs from the fact that this only applied to “a person from a foreign state”. South Africans wanting to buy or sell rhino horn, on obtaining a permit, would have no such restriction and could trade and export as much horn as they pleased. Foreigners owning rhinos could also do so.

Because the paragraph concerning the two-horn restriction referred to
“a person contemplated” in another part of the regulations, it was easy to miss the key point that the “person” referred to was only a foreign national not domiciled in South Africa or not owning a rhino. No such restriction was placed on locals.

South Africa has the greatest number of rhinos in the world and a huge poaching problem. Legalising trade and export is likely to collapse international attempts to protect rhinos. If the trade regulations become law, the decline and possible extinction in the wild of rhinos will be in the interest of rhino breeders, who will then control the world market.

The back story to the announcement is that last year the moratorium on sale was challenged by private sector rhino breeders who won on a technicality. Molewa took the result on appeal to the Constitutional Court. Then, on February 8 – possibly anticipating losing the Constitutional Court appeal – she announced new draft regulations, giving the public a mere 30 days to make representations or objections.

The effect, if the regulations become law, is that South Africa will be an almost open market for trading and even exporting rhino horn. This is a slap in the face for the overwhelming majority of countries that voted against the trade in horn at the CITES CoP17 meeting in Gauteng last year and a huge victory for the very few, extremely wealthy, rhino farmers and potential traders who have been lobbying Molewa for years.

The draft regulations seek to justify the trade through the fiction that it may only be traded for personal purposes, but leaves out what “personal” may mean. In a lengthy statement on Monday February 27, none of these issues were addressed by the DEA.

In terms of Article III of the CITES Convention, as long as the import is “not for commercial purposes”, import and export permits are allowed. If the purpose is “personal” there is no limit to the number of specimens involved. There is also the exception (for residents) allowing for export of personal and household effects (Article VII).

According to Environmental attorney Cormac Cullinan, “by requiring exports to be for ‘personal purpose’ (whatever that means) the DEA is obviously trying to create the impression that it is not contravening CITES by permitting trade for commercial purposes”.

In answer to my question about the difference between “trade” and “for commercial purposes” upon which the export regulations would hang, the DEA responded:

“An import permit can only be issued if the CITES authority of the state of import is satisfied that the specimen (rhino horn) is not to be used for primarily commercial purposes.

“Primarily commercial purposes are defined in a CITES Resolution adopted at the 15th Conference of the Parties, which requires that the terms ‘commercial purposes’ should be defined by the country of import ‘as broadly as possible’ so that any transaction which is not wholly ‘non-commercial’ will be regarded as ‘commercial’. It is … not the South African government’s responsibility to prove that a country has the necessary legislation.”

As the CITES definition goes, you could fly a Boeing through that without touching sides, which seems what the DEA plans to do. The only place the SA draft regulations clearly exceeds CITES’ dictum is by stating that an export permit can be issued on the basis of a letter from the importing country rather than a proper import permit. This not only contradicts CITES but South Africa’s own CITES Regulations.

A possible scenario in terms of the regulations could be that a private owner in South Africa wants to sell a large number of horns to a buyer in Vietnam. To avoid the restrictions regarding foreigners, he sells the rhino to the buyer. The rhinos, of course, stay in South Africa.

Once the foreign buyer has title to the rhinos, he can then, once the required import and export permits are in place, import their horns without being bound by the two-horn limit. He may even (this is not clear) be able to import horns previously removed from the rhinos he owns as part of a dehorning operation.

Of course, the possibility of ensuring use is personal and tracking this use into foreign countries after export is another fiction. What rhino traders will hope for is that the regulations will give the appearance that the trade is under control and non-commercial, but that once the horns reach (say) Vietnam, everyone will nudge, wink and look the other way. The huge black market value of horn will ensure that uncontrolled cheating will take place.

A 2014 report by the DEA warned that “one of the most important hurdles South Africa will need to overcome in order to legalise national trade in rhino horn is to prove to CITES that internal effective trade controls have been implemented and are sufficient to prevent the laundering of illegally obtained rhino horn”. The DEA appears to now consider that they are sufficient, but has not detailed what they are.

In Parliament, Molewa explained there had been a moratorium on rhino horn sales since 2009 simply because the department needed to “clear its house”. But all the orders and regulations “are now in place and people are asking why we need a moratorium”. Those people are clearly rhino farmers.

Molewa did not give details of the “orders and regulations” that would warrant ending the moratorium. In fact, the draft regulations suggest a need for future regulation, calling for a limiting of exit ports to OR Tambo Airport and a raft of DNA, microchip and document checking which the DEA has still to put in place.

Its presentation failed to answer a number of pertinent questions:

Who did the minister consult in drawing up the draft regulations and how did she arrive at a figure of two horns per person?
How will an already stretched and under-funded regulatory and policing force cope with monitoring internal trade?
How will she ensure that the horns will not enter the illegal international markets?
Is this the first step towards South Africa putting forward a proposal for full international trade in rhino horn at the next CITES conference in 2019?
Much appears to hinge on the Constitutional Court finding on the legitimacy of the private challenge to the moratorium. If it finds against the minister, it is probable that the moratorium on rhino horn sales will be lifted and trade will begin.

According to Cullinan, “When you consider that South Africa, as a signatory to CITES, has undertaken to work with other countries to ensure that international trade does not threaten endangered species like rhino, these regulations are particularly nefarious as they directly undermine CITES. We should be trying to eliminate demand for rhino horn, not stimulate it.”

Lifting the trade ban would, of course, not be good news for rhinos because there’s a demonstrable link between the sale of farmed wildlife and poaching. It would serve to stimulate almost limitless Asian markets through the sale of limited goods which would not take long to bleed into illegal procurement through poaching.

Read original article: https://www.dailymaverick.co.za/article ... LWUyoVOLIU

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Wed Mar 01, 2017 6:17 pm

0:

CITES must sort this out...they are a bit toothless! 0*\

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Wed Mar 01, 2017 6:50 pm

and slow @#$

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Mon Mar 13, 2017 9:33 am


Despite poaching, SA plans for rhino horn trade


Image

South Africa is moving ahead with plans to allow a domestic trade and limited export of rhino horns, alarming many international conservationists who believe rhino will be more vulnerable to poachers who have killed record numbers in the past decade.

Draft regulations would allow a foreigner with permits to export "for personal purposes" a maximum of two rhino horns. Critics argue that any exported horns would be hard to monitor and likely would end up on the commercial market, defying global agreements to protect threatened rhino populations.

Most of the world's rhino live in South Africa. An international ban on trade in rhino horns has been in place since 1977, and South Africa imposed a moratorium on the domestic trade in 2009, when rhino poaching was accelerating to meet growing demand for horns in parts of Asia, especially Vietnam.

South Africa's government has lost court battles to preserve the 2009 ban, which was challenged by rhino breeders, and has leaned toward trade, backing a failed proposal by neighbouring Swaziland at a UN wildlife conference in Johannesburg last year to legalise the international sale of rhino horn.

A 30-day period during which the public was invited to express opinions about the draft legislation on rhino horn trade ended on Friday, the Department of Environmental Affairs said.

"The comments will be evaluated, the draft regulatory provisions will be revised based on the comments received, and the process for approval of the final legislation will be set in motion," the department said in an email to The Associated Press.

Foreigners

A foreigner who takes rhino horns out of the country must do so through OR Tambo International Airport in Johannesburg and cannot carry them in hand luggage, according to the draft provisions. They say authorised freight agents must provide authorities with DNA data and other information related to exported horns. Sceptics believe the system would be open to corruption.

Some consumers in Asia believe rhino horn in powder form can cure illnesses, although there is no evidence that the horn, made of the same substance as human fingernails, has any medicinal value.

Critics say legalisation will spur poaching as illegally obtained horns are laundered into the legal market, similar to the exploitation of elephant ivory. Rhino breeders, however, believe poaching would be undercut by a regulated trade, which likely would allow the sale of horn stockpiles and the harvesting of horns from living rhino.

The poaching is not confined to South Africa. This month, a 5-year-old white rhino was shot three times in the head by poachers who broke into the Thoiry Zoo near Paris and used a chain saw to remove the rhino's horn.

"Banning the trade in horn has made the horn more and more and more valuable. Had we never banned it, the price of horn would never have got to where it is now," said John Hume, a rhino breeder in South Africa. "And that Parisian rhino would have been safe in its zoo because its horn would have been worth a fraction of what it is."

'Step in the right direction'

Hume described South Africa's draft legislation on the domestic rhino horn trade as "a step in the right direction".

But Allison Thomson, a South African campaigner against legalisation, said putting rhino horns on the market would increase demand and that South Africa is sending "conflicting messages" about how to deal with poaching, jeopardising its lucrative wildlife tourism.

"The risk we run at the moment is that if we open up trade and poaching escalates we will have no rhinos in the wild. We will only have rhino on farms, being farmed like cows," Thomson said.

Poachers killed 1 054 rhino in South Africa last year, a 10% drop from 2015, according to the government. While authorities attributed the decrease to increased security and other anti-poaching measures, some conservationists speculate that there are fewer rhino to kill. Drought also killed some rhino in the past year.

By some estimates, South Africa has nearly 20 000 rhino, or 80 percent of Africa's population. Asia has several rhino species, including two that are critically endangered.

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Mon Mar 13, 2017 9:41 am

Stop SA Government legalizing domestic and international trade in Rhino horn

GLOBAL MARCH FOR ELEPHANTS AND RHINOS Image

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South African Environmental Affairs Minister Edna Molewa has declared that she plans to permit the trade in Rhino Horn domestically and to allow the export internationally of Rhino Horn for 'personal purposes'.
The South African Government has in the past been accused and found guilty of corruption at the highest levels. Informed conservationists fear that the implementation of the proposed permits for trade will be less than perfect. The South African Government has not even been able to release any official poaching figures for more than six months.
Rhino in South Africa are facing extinction. Conservationists have confirmed figures that on average three Rhino per day are losing their lives to Rhino poachers. Opening of trade in horn will escalate the extinction of this iconic species.
The South African Government are curators of an enormous Rhino Horn stockpile. The black market value of Rhino horn is £51 000 per kilogram. This black market value makes Rhino Horn more valuable than Gold, Platinum for Diamonds per gram.
At CoP17 held in Johannesburg in October 2016 the international community voted overwhelmingly AGAINST the trade in Rhino Horn.

https://www.change.org/p/stop-sa-govern ... rhino-horn?

Re: SOUTH AFRICA PROPOSES DRAFT REGULATIONS FOR THE DOMESTIC TRADE IN RHINO HORN

Wed Mar 15, 2017 11:16 am

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The big problem with legalising rhino horn sales

BY MELANIE VERWOERD - 15 MARCH 2017 - NEWS 24

Last month Environmental Affairs Minister Edna Molewa made two announcements relating to rhinos in South Africa.

The big news was that there had been a 10% decrease in the number of rhinos killed in South Africa for their horn. This was largely due to a drop in killings in the Kruger National Park and even though the killings in the rest of the country and poaching incidents overall increased, it was truly good news.

Except that in the same month she also published draft regulations to legalise the sale of rhino horn under certain conditions. I was totally gobsmacked.

While I was in Parliament I served on the environmental portfolio committee so I am familiar with the need for political compromises and balancing diverse demands – sadly even when it comes to the environment. But this proposed change in the regulatory framework around rhino horn is truly ludicrous and what is worse it is not new.

The exact same arguments were put to us over and over years ago around elephant ivory. In the end there were a couple of “fire sales” of stockpiled ivory and we saw what happened.

The research was done – and no one can refute today that it resulted in more elephants being poached and killed – despite the arguments from the pro-sell advocates at the time that it would reduce the price and thus the demand for poached ivory.

Yet, here we are again. Same arguments – except this time round it is about an animal that is far more endangered than even elephants.

So what is going on? The regulations came about largely as a result of pressure by some farmers, who farm with rhinos on privately held land. They have stockpiles of rhino horn that they want to sell – as does the government.

Selling rhino horn is a very lucrative business. It is estimated that rhino horn can sell for between $60 000 and $100 000 per kilogram. And with a horn weighing between one and three kilograms – well, you do the math.

The advocates for selling the horn argue that by selling it legally the price will drop as will the demand for illegally obtained horn. They also say that the money that will be made can be used to increase anti-poaching efforts. It is also argued that the regulations are very limiting and that the sale will be strictly regulated.

In a nutshell the regulations allow rhino horn and products to be sold and exported if the necessary export and import permits are held and under certain conditions. The main condition, strongly emphasised at the briefing to the parliamentary committee, is that only two rhino horns per person would be allowed.

Firstly, what was not made clear at the briefing, but is in the regulations, is that this restriction only applies to foreign citizens who travel to South Africa. South Africans or foreigners who own rhinos in South Africa can export an unlimited number. Secondly, the regulations do not mention over what period of time these numbers are applicable – so whether it is two per visit, two per month or two per annum.

The regulations also state that it can only be for personal use. Now one has to ask why on earth would people want rhino horn for personal use? Even though rhino horn really is only of use to the rhino since it is made out of keratin (the same material as our nails), people in Asian countries use it mainly for medicinal purposes. So are we really suggesting that people will sit in their kitchens and every night file a little more of the horn to put in their drink?

Of course people also want rhino horns as trophies, but I have yet to hear of anyone who is interested in a horn as a trophy if they did not shoot the rhino themselves. “Personal use” will almost always result in only one thing – the horn will be sold on to underground commercial traders.

It is clear that this part of the regulations is there purely to circumvent CITES which has banned all forms of rhino horn sale since 1977. And while I am on CITES, it is worthwhile noting that South Africa will go against the wishes of 100 other countries who voted last year against the sale of rhino horn.

So what then about the argument that a regulated sale will reduce demand and thus reduce the price and so make it less profitable for poachers? This is where we have to learn from what happened with the limited sales of stockpiled ivory.

All reputable studies and conservationists have shown that demand went up and poaching increased during and after the sales. It is really economics 101 – supply fuels demand. If people see others having it or using it – they want it too. To argue that the sale of horn from a few farms and parks in South Africa will be able to satisfy the enormous existing and increasing demand in Asia and thus saturate the market is just ridiculous.

Secondly, I have no doubt that those with stockpiled rhino horn will want top dollar for it. Otherwise why bother? Now if they agree to a fixed price of say R100 per kilogram, well then perhaps there might be some validity in their argument. But of course they won’t and so, as we have seen with the elephants, the prices won’t fall.

And even in the very unlikely scenario that the prices do decrease, it will only mean that the poachers will poach more. After all, it is not as if the poachers are going to sit back and politely allow the rhino farmers to sell only their stockpiles.

Lastly, if the money from the sale does go toward poaching prevention (a lot of money from the ivory sales did not end up in poaching prevention as was promised), but the poaching increases as a result of the sale, it seems pretty much like a zero sum game.

The only way to curb rhino poaching (as we learnt from elephant poaching) is a sustained campaign to ban all sales and consumption of rhino horn. After decades the Chinese government has finally made the carving, buying and selling of ivory illegal from the end of this year. We have to seek the same outcome for rhino horn and not fuel the demand and confuse consumers with these kinds of sales.

The only people that will benefit from this sale of rhino horn are the rhino farmers, the speculators/traders and possibly officials and politicians who might get illegal kick backs. The one stakeholder that won’t is the rhinos.

So if you are one of the thousands of people who have continued to give money to save the rhinos – know that these regulations are really making a laughing stock of us all.

At the same time as we have been spending our hard earned money to save the rhinos our minister is willing to allow the sale of their horn – an action that will put them right back into more danger than ever before.

Read original article: http://www.news24.com/Columnists/Melani ... s-20170315