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.
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
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 CoP17https://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