Have a look at what we do for wildlife and then explain to us in plain words why we are not supported by conservation officials. Indeed, why they proactively undermine our efforts.
Even though our Karoo Wildlife Centre is a project of the international award-winning NGO, Campaign Against Canned Hunting, and we followed procedures to obtain permits as much as possible until the excessive bureaucracy defeated us.

Far away from the paper world of government policies and regulations, in the real world, here is how rehab sanctuaries work. An animal is orphaned or injured and taken by good samaritans to the local vet. She attends to its wounds and needs, and then what? She has a veterinary surgery in a built-up area. She needs a wilderness facility with large natural camps where the animal can be fed and nurtured until it is fit for release back to the wild. It then needs a soft (gradual) release into suitable habitat where it can survive and flourish.
​
The rehab centre is therefore an essential part of the rescue process. Without it, the vet would have no choice but to put the animal down.
So here is a perfect example: seven orphaned bat eared fox pups were delivered to the Karoo Wildlife Centre recently.

Check out the videos: look how well fed and cared for they are in spacious natural surroundings. When ready, they will be released in to the surrounding wilderness by merely opening the gate of the camp. They will not disperse immediately and we'll continue to put food out for them after release. Some foxes released a year ago still come back every night for their food.
https://www.youtube.com/watch?v=qKfLSKtjI80
https://www.youtube.com/watch?v=iUokGs7f5Og
https://youtu.be/iUokGs7f5Og

So why on earth should we have to work outside the permit system? Surely, we should be welcomed by conservation officials as complementing their efforts to save our wildlife heritage?

Because hunting involves cruelty, killing and adverse impacts upon biodiversity, you’d expect hunting to be heavily regulated and monitored.   And you’d expect animal protection and rehab centres to be lightly regulated, to encourage public participation.

But this is South Africa, where the hunting fraternity controls conservation.
To start a hunting farm:
All the landowner needs is a Certificate of Adequate Enclosure to confirm that his perimeter fence is strong and high enough and Presto!  all regulations vanish like smoke.  No need to apply for any re-zoning, or obtain EIAs, or file complex business or management plans, or be restricted by hunting seasons; the landowner is free to do what he likes with his ‘alternative livestock.’ Indeed,  he can turn the land in to a battlefield, like the infamous driven hunt at Alldays in Limpopo. See this illustrated report on the Alldays hunt, showing how hunting is to conservation what pornography is to art.
https://www.thedodo.com/hunters-hide-their-faces-1347803434.html?utm_source=HuffPo&utm_medium=referral&utm_campaign=pubexchange_facebook

Now compare the regulatory burden on wildlife sanctuaries or rehab centres.

1. To start a Wildlife Sanctuary and/or rehab centre for animal rescue, a re-zoning application is called for.  Now the bureaucracy runs riot.
A one-size-fits-all re-zoning application means that the mind-numbing requirements designed for large scale developments such as a new golf course complex or a five star ten story hotel all have to be met by the poor wildlife rehabber.

Really!!??  All this – and much, much more - just to rescue a bundle of fur or feathers??

2.      An E.I.A. (environmental impact assessment) - for which yet another expensive consultant is required.  An EIA can only be done by a registered qualified EIA practitioner, and the whole process can take months,  and cost tens  of thousands of rands.

3.      Formal standard operating procedures (SOPs) for every aspect of the rehab process; use of vehicles, use of equipment, cleaning, etc .etc – all of which must be signed by staff and volunteers. The detail required is so overwhelming that even where to park the car at night must be included in the SOP!

4.      Expensive and unnecessarily high and strong fences for enclosures, even those designed to hold small, harmless animals.
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5.      Explain mission and vision, species and number of animals kept (how on earth to know this in advance?), how you are going to meet the physiological, physical and psychological needs of the animals that you do not yet have, transport facilities, veterinary facilities, fire management plans, personnel training, public liability insurance for millions, escape plans, exit strategies, letters of support from all neighbours, an essay on how the centre will add value to conservation, research, education etc, risk assessment, ecological impacts etc etc.
Oh and membership of PAAZAB.
(Logic?? PAAZAB is a zoo association. Why on earth should a rehabber be forced to join a Zoo association?  Zoos exist for human entertainment; the rehabber has no interest in human entertainment.   Some of PAAZAB’s rules, such as the requirement to be open to the public at all times, are bizarrely inappropriate to a rehab centre, which is closed to the public at all times.)

The point is this: not only are these excessive bureaucratic obstacles discouraging people from exercising their legal right to participate in wildlife management, but the fact that none of these onerous obligations are imposed upon game hunting farms is partial and discriminatory and therefore unlawful in terms of Section 3 of the Promotion of Administrative Justice Act.

Is this burdensome bureaucracy really necessary for conservation purposes?

1. If these onerous bureaucratic demands were really important, then they would apply to game farming and the hunting industry – much more so because hunting impacts the environment far more than rescuing and rehabbing orphaned and injured wildlife. Despite the anti-conservation antics of an out-of-control hunting fraternity, such as cross-breeding mutant freaks for hunting trophies, or turning the land in to a battlefield like the driven hunt at Alldays in Lipopo, no EIAs are required. 
2. In the conservation sub-culture, ‘welfare’ of animals is almost a swear word.  There is open hostility to the whole idea of animal welfare, and anyone who speaks out against cruelty to wildlife is pejoratively labelled a ‘greenie,’ a ‘rightist’, a ‘radical’ and ‘an‘extremist.’ 
3. In seeking to control every aspect of sanctuary/rehab activity, the conservation authorities are acting ultra vires ie outside their legal powers.  In short, unlawfully. The Supreme Court of Appeal decided in the Predator Breeders case that breeding lions for canned hunting or other human entertainment fell outside the authority of conservationists.

So why are conservationists so obsessed with controlling every aspect of animal welfare facilities when they have no legal right to do so? They themselves never miss an opportunity to deny that animal welfare is their responsibility.

Authority and responsibility go together - conservation officials cannot claim that they have no power to regulate animal welfare - and then proceed to try to regulate it.   

I hope we shall not have to go to the High Court for relief before this saga is over.

 
An outrageous article calling for animal-rights groups to be excluded from conservation has been published here:
https://www.dailymaverick.co.za/opinionista/2019-11-08-how-to-save-cites-if-its-worth-saving/?tl_inbound=1&tl_groups[0]=80895&tl_period_type=3&utm_medium=email&utm_campaign=Afternoon%20Thing%20TGIF%208%20November%202019%20UCT&utm_content=Afternoon%20Thing%20TGIF%208%20November%202019%20UCT+CID_62cebdb18adff3246ca53b59d5eedb59&utm_source=TouchBasePro&utm_term=How%20to%20save%20CITES%20if%20its%20worth%20saving

The author of this intemperate rant is well known for his habit of pouring petrol on burning issues and then relishing the consternation he causes.

The article is a lengthy and wordy litany of misleading statements, calculated to support his bizarre conclusion that the only way to save CITES is to kick out all the animal-rights groups. He describes them as follows:
 Animal rights groups, however,.. do not support utilisation of wildlife, sustainable or otherwise, and believe they have a right to dictate, from the comfort of their elitist perches in rich countries, what poor countries are entitled to do with their own wildlife. Their policy is one of preservation, not conservation.

First, I and other conservationists, have explained in the past how CITES is a white elephant, a creaking bureaucracy that diverts millions in funds that ought to go to conservation. CITES should be abolished, and replaced with a more effective body which is based upon conservation, not on trade.

The author advances facile arguments such as the following:
In South Africa, about 72% of wildlife ranching revenue comes from hunting, while only 5% comes from eco-tourism, according to Wouter van Hoven of the Centre for Wildlife Management at the University of Pretoria.
Wow! Let me restate his argument in plain simple English: most people who visit hunting farms are hunters. How trite is that?

His whole theme is that hunting is wonderful conservation and anyone against hunting, such as animal-rights groups, is anti-conservation.

Any intelligent person can see that he has confused the victim with the perpetrator. Conservation should be aimed at preserving natural functioning ecosystems. He reverses that logic, and argues that preservationists are anti-conservation.

He believes fanatically that cramming as many wild animals as possible into a fenced hunting camp and breeding living targets for the hunting industry, is conservation.
It’s not. It is farming with wildlife - not conserving it. He can’t see the difference.

Like all good hunting propagandists, he compares South Africa to Kenya. He says Kenya has lost 85% of its wildlife since it banned hunting in 1977.
From that statistic, he concludes that it was the hunting ban that caused the decline in Kenyan wildlife. In other words, according to him, the only way to save Kenya’s wildlife is to hunt it.

This is such rubbish. The decline in Kenyan wildlife has everything to do with the reckless human population increase from about 4 million at the end of WW2, to nearly 50 million, most of whom have expanded into wilderness areas and decimated the wildlife.
To promote hunting would not solve the problem, it would aggravate it.

His conclusion:
To save the CITES treaty, however, will require decisive action.
First, CITES needs to kick out the animal rights groups.

Actually, it is CITES that needs to be kicked out of conservation. And replaced with a proper international  conservation body.
​
This whole article is tendentious nonsense and conservationists should pay it no regard.
 
 
 

There has been an interesting and positive development in the South African tourism industry. SATSA, the South African tourist Association has launched a guide for tour operators and tourists to evaluate captive wildlife interactions.
​
The excellent and well researched guide can be downloaded here:
https://www.satsa.com/wp-content/uploads/SATSA_HumanAnimalInteractions_Final5_Interactive.pdf

This guide will enable foreign and local visitors who wish to interact with animals, tour operators and others to make informed decisions that support responsible tourism in South Africa.

There is a visual guide in the form of a line in the sand, a curve going from red through orange to green. Those facilities that fall in the red category should be avoided and the line of acceptability progresses through orange to green, which includes genuine ethical establishments such as rehab centres and sanctuaries.

This is a wonderful initiative and all involved should be complemented.

I see two problems with the proper implementation of this guide:
First, lion farmers are very astute and convincing to pose as genuine sanctuaries. Only someone experienced in animal welfare and conservation in South Africa would be able to separate the good from the bad especially since there are often shades of grey.

Second, the guide establishes an excellent system for raising awareness and making better informed decisions on which facilities to support and which to avoid. But it raises the question of how conservationists and animal lovers are going to move from being better informed to having the decision made for them by some kind of certification process. 
There is clearly a need for an accreditation process in which knowledgeable inspectors could decide whether a facility should be promoted by SATSA, or not.
​
Notwithstanding, this is a praiseworthy step in the right direction for promoting responsible tourism and giving tourists the power to promote ethical treatment of animals in their spending of tourist money. Well done SATSA.

The hunting industry has been very successful in foisting the hunting narrative onto the conservation community. Using stalking horses such as WWF the hunting fraternity has persuaded most of global conservation structures that hunting is a tool of conservation.

In particular the hunting fraternity has infiltrated the IUCN and ensured that this pre-eminent scientific authority makes no decisions that impact adversely upon hunting privileges.

Now for the first time, a careful, comprehensive report by the IUCN ethics committee, an eminent international group of distinguished scientists, has reported that hunting and in particular trophy hunting, has no place in conservation. Hunting agencies which currently control the narrative in IUCN should logically therefore be thrown out of the IUCN.

The reasoning of the committee was impeccable. The report pointed out that the primary aim of conservation is to preserve the integrity and diversity of nature. In order to achieve that primary goal, any use of natural resources and wildlife must be sustainable. Notice that the doctrine of sustainable use is subsidiary to the primary purpose of conservation.

The scientists analyse the effect of trophy hunting upon the environment and conclude that it is not sustainable, and, even if it were, it fails to preserve the diversity of nature.

Hunting is therefore a form of farming of wildlife and it has nothing whatever to do with conservation.

This report was dynamite, but you will not be surprised to hear that when the media approached IUCN headquarters for comment, the report of the ethics committee was very swiftly deleted.
​
However, our colleague Eduardo saved the report and you can read it in full hereunder:
 https://webcache.googleusercontent.com/search?q=cache:mKQYvyCt5YMJ:https://www.iucn.org/news/world-commission-environmental-law/201909/compatibility-trophy-hunting-a-form-sustainable-use-iucns-objectives+&cd=4&hl=en&ct=clnk&gl=uk
 
The Daily Telegraph have run this story about it:
https://www.telegraph.co.uk/news/2019/10/03/anti-hunting-groups-seek-oust-big-game-hunters-global-conservation/
 
1. Introduction
For IUCN, the issue of trophy hunting recently arose in the context of whether organizations that are supportive of trophy hunting may be eligible for IUCN membership under the IUCN statutes. Of central importance to determining membership is whether, at least, one central purpose of an organization meets IUCN’s objectives. The Council has to determine, in particular, whether:
“the objectives and track record of the applicant embody to a substantial extent (i) the conservation of the integrity and diversity of nature; and either or both: (ii) the aim to ensure that any use of natural resources is equitable and ecologically sustainable: (iii) dedication to influencing, encouraging and assisting societies to meet the objectives of IUCN.”1
In determining whether an applicant meets this test, the Council cannot rely on claims or representations made by the applicant, but has to consider whether the applicant’s “objectives” and actual “track record” make it likely that the applicant is dedicated to advancing the objectives of IUCN. Hence, a mere intention or willingness of the applicant to advance IUCN’s objectives would not be sufficient. The “dedication” to influencing, encouraging and assisting societies involves a credibility assessment. This may include a closer look at the membership of the applying organization, for example, the motives and actual conduct of its members and the overall impact that the organization has had, and would have as an IUCN member, on IUCN’s dedication to meet its objectives.
The central question for the Council is - or should be - whether or not an applicant adds to the potential of the IUCN’s overarching objective, i.e. “to influence, encourage and assist societies throughout the world to conserve the integrity and diversity of nature and to ensure that any use of natural resources is equitable and ecologically sustainable.” (Art. 2). This objective cannot be interpreted in a way that emphasizes one aspect (e.g. “sustainable use”) at the expense of other aspects. Nor would it be appropriate to liken the objective with “sustainable development” or any abstract idea of promoting conservation. Rather, Article 2 contains a certain hierarchy: the conservation of integrity and diversity of nature is the overall concern. The use of natural resources has to occur in a manner that it is equitable and ecologically sustainable so that the integrity and diversity of nature will be conserved (and restored where necessary). This clearly implies that sustainable use and sustainable development are both subservient considerations to the overarching aim of ensuring ecological integrity.
It would be wrong therefore to measure trophy hunting purely against “sustainable use” as it is commonly referred to in domestic environmental laws and international hard and soft law. Nor could it be measured against statements on sustainable use of wildlife as, for example, provided by WWF which contends: “WWF is not opposed to hunting programs that present no threat to survival of threatened species and, where such species are involved, are part of a demonstrated conservation and management strategy that is scientifically based, properly managed, and strictly enforced, with revenues and benefits going back into conservation and local communities.”2 Trophy hunting is not mentioned here, and even it were, it would have to be measured against a “demonstrated” conservation strategy and against “revenues and benefits going back into conservation and local communities”.3 Furthermore, the overarching concern, for IUCN at least, is to conserve the integrity and diversity of nature (globally and locally) and to educate (“influence” etc.) societies (nationally) how this can be achieved. Is trophy hunting an acceptable means to achieve this end?
In answering this question, we need to consider not just sustainable use requirements and practices, but also the general debate around trophy hunting. There are pro-arguments in favour and arguments against. The former are largely based on economic benefits for local conservation efforts, while the latter is critical of such ‘trickle-down’ effects and emphasizes the ethical dimensions of trophy hunting.
For the Ethics Specialist Group, ethical grounding of conservation laws, policies and practices is critical and arguably consistent with IUCN’s overall objective to ensure integrity and diversity of nature. In the next section we outline some ethical considerations before addressing the actual question at hand.
2. General debate around trophy hunting
The debate about the justifiability of trophy hunting ranges from stressing economic benefits at one end of the spectrum to fundamental ethical objections at the other. Supporters base their argument largely on the perceived virtue of economic benefits and advantages for conservation. The claim is that local communities financially benefit from hunting and funds raised can be directed toward conservation efforts. These claims are based on financial, empirical evidence, but the benefits appear to be nowhere near as widespread as claimed. For example, in Zimbabwe as little as 3% of the income for trophy hunting actually reaches local communities.4
Hunters as a group tend to privilege an abundance of the species they are interested in killing over the existence of biologically diverse ecosystems.5 Despite claims by trophy hunting organizations that hunting promotes wildlife conversation in Africa, there is evidence that trophy hunting causes populations of African lions to decline.6
Apart from uncertainties around verifiable benefits generated by trophy hunting, there are basic concerns with cost-benefit analysis (CBA) used for the evaluation of wildlife conservation, particularly with respect to trophy hunting.
First, we can never identify all the direct and indirect benefits and costs of any action. This is especially true for wildlife conservation with its many unknowns. How to quantify the benefits of trophy hunting? Aside from possible benefits for local communities, the benefits of human-induced culling of wildlife are questionable given that trophy hunters often remove individuals with the highest breeding value from wildlife populations.7 Proof that hunting can have measurable conservation-related benefits for a species may be a possibility in principle, but is hard to come by given the complexities involved. Species development is not just affected by direct human action, for example, motivation of private landowners to increase the numbers of a certain species such as the white rhino.8 There are important environmental factors to be considered including ecological interdependences, habitat stability and impacts of biodiversity loss and climate change. There are too many uncertainties to justify trophy hunting by pointing to benefits for wildlife conservations.
Secondly, in light of the debate about ‘valuing nature’ and ‘monetizing nature’ it can be questioned whether a monetary value can be placed on life.9 It is unethical to place a monetary value on human life. On what grounds then should this be different with respect to animals? Even if an ‘intrinsic value’ of animals (biocentrism) is denied, an assumed mere ‘instrumental value’ of animals (anthropocentrism) still requires justifiable reasons for killing animals. These may include essential human needs (food, clothing, cultural identity etc.), but certainly not killing for fun (‘experience’, sport, trophies). At the very least, the onus for justifying trophy hunting must lie with those who claim that the ‘benefits’ for wildlife conservation are greater than the ‘costs’ of loss of life. Again, it must be stressed that the assumption of justifiable trophy hunting could only be made on the grounds of ethical anthropocentrism - a position that arguably is not consistent with IUCN’s overarching conservation ethics (see further below).
Thirdly, there are practical difficulties of compatibility. As economic benefits are easier to quantify than ecological benefits, there is a tendency to neglect ecological benefits and harms that are far more difficult to quantify, whether in economic/financial terms or in terms of conservation efficiency. Policy positions based on economic considerations often neglect critical ethical issues such as ecological justice, human rights and human responsibilities. The implication is that a preconceived level of economic benefit justifies (a degree of) ecological harm; especially if that benefit could be used to advance the human development project. If the economic benefit, as perceived by humans, is sufficient, then any ecological harm can be justified, whereas the “value” of maintaining ecological integrity is never stated or used as a counter-balance to economic value. This trade off approach raises the question of what the limits are – and that has to be determined or guided by ethical concepts.10
Opponents of trophy hunting tend to argue from a moral and ethical perspective.11 Typically, they refer to social ethics (i.e. rich-poor disparities, trickle-down ideology, intra-generational justice, equality) and environmental ethics (inter-generational justice, inter-species justice, ecological sustainability). Both social and environmental ethics are relevant here as Articles 2 and 7 refer to them. It is important, however, to stress that environmental ethics offers the key to understanding the relationship between human needs and inspirations, on the one hand, and the sustainability of ecological systems on the other. The latter is a precondition to the former.12
As far as the general debate around trophy hunting is concerned, there is a certain emphasis on assessing benefits against possible risks (e.g. economic benefits for communities vs endangering of species and/or ecosystems). Such emphasis looks at the consequences of human conduct – in our case trophy hunting - and is known as ‘consequentialism’. From a consequentialist perspective, the good outcome, or consequence, of a morally motivated conduct is crucial. If the outcome has more benefits than harm, then the conduct is justified. In the extreme, consequentialism amounts to “ends justifying the means”.
Contrasting with the consequentialist perspective is the deontological perspective. Here rules and moral duty are central. Deontology derives the rightness or wrongness of human conduct from the character of the behavior itself (at least since Immanuel Kant). Typical for deontological ethics is the idea of human rights or sustainability. Neither human rights nor sustainability can be entirely explained as protection measures against undesirable outcomes (typical for consequentialism), although they may be part of the reason why human rights or sustainability ought to be guiding rules for humanity. Essentially, if something is recognized as a (fundamental) rule, then any behavior not following the rule is unethical (and often, but not necessarily so, illegal).13
For IUCN’s position on trophy hunting to be credible, it is important to reflect on both, economic (utilitarian) and ethical (consequentialist and deontological) considerations bearing in mind that IUCN typically derives its position from its own normative rules (e.g. statutes, resolutions, policies, guidelines etc.). Neither purely economic or utilitarian reasoning, nor purely ethical reasoning may satisfy all the stakeholders involved, although it has to be stressed that ANY human behavior is ultimately motivated by ethics, whether consciously or unconsciously. Arguably, IUCN is inherently motivated and shaped by ethical, not economic or utilitarian concerns for conservation,14 although it has to be said that the development of IUCN’s current policies and programmes has considerably lacked in this regard.15
3. IUCN’s Current Position
As mentioned earlier, Article 2 of the Statutes charges IUCN with the commitment to “influence, encourage and assist societies throughout the world to conserve the integrity and diversity of nature and to ensure that any use of natural resources is equitable and ecologically sustainable.” Accordingly, the IUCN has an overarching commitment to ecological integrity assisted by a form of use of natural resources that is both socially equitable and ecologically sustainable. Neither socially unjust nor ecologically unsustainable practices could be tolerated, so the onus has to be on an applicant to demonstrate that their objectives and practices serve this commitment in order to justify IUCN membership. Again, the dedication to influence, encourage and assist societies and the ability and credibility to do so are crucial here.
In furtherance of its overarching commitment, the IUCN has passed over 100 resolutions that directly link conservation science (and practice) with justice and equity. Examples include: the World Conservation Strategy (1980), World Charter for Nature (also adopted by the UNGA in 1982); Caring for the Earth: A Strategy for Sustainable Living (1991); the Draft International Covenant on Environmental Development (1995/2015); Resolution 3.022 endorsing the Earth Charter as “an ethical guide for IUCN policy” (2004); Resolutions 4.098 Intergenerational Partnerships: Fostering Ethical Leadership for a Just, Sustainable and Peaceful World and 4.099 Recognition of the Diversity of Concepts and Values of Nature (2008); 3.020 Drafting a Code of Ethics for Biodiversity Conservation; and 004 Establishment of the Ethics Mechanism (2012).
The resolutions concerning the Earth Charter and the Ethics Mechanism are major recent landmarks. The first because the Earth Charter is the world’s most widely endorsed ethical guide for sustainability. It articulates the values of care, respect and responsibility for each other with ecological integrity at its core, and has been endorsed by civil society, governments and UNESCO. In addition to guiding policy, the IUCN has undertaken to “work to implement its principles” through its programmes. The second resolution (calling for effective implementation of Ethics Mechanisms) is crucial because it recognises the central importance of global ethics to the IUCN’s mission, and delivery of its programmes and activities.
With respect to sustainable use of wildlife, Resolution 011 Closure of Domestic Markets for Elephant Ivory (2016) effectively bans trophy hunting of elephants as it “threatens the survival of many populations of savannah and forest elephants and undermines the ecological integrity of savannah and forest ecosystems”.16
Against these overarching commitments and resolutions, other IUCN documents including guidelines and statements from specialists groups need to be assessed. With respect to trophy hunting, the Species Survival Commission has developed ‘Guiding Principles for Using Trophy Hunting as a Conservation Tool’, and IUCN has published a Briefing Paper (updated version prepared for CITES CoP17. These documents recognize that, when well managed, trophy hunting can deliver important benefits for species protection and recovery, habitat conservation, and reducing illegal hunting and illegal wildlife trade, as well as delivering important livelihood benefits to rural communities (e.g. in Namibia, Zimbabwe, Tanzania, Tajikistan, Canada, Pakistan and several European countries).
The documents do not explain, however, how “well managed” trophy hunting may be consistent with IUCN’s commitments to promoting ecological integrity and diversity, as expressed in IUCN’s objectives and many resolutions seeking to implement the objectives in policy and programme development. Given the hierarchy of norms that IUCN is guided by, it would fall upon the authors of subordinated documents such as the SCC’s ‘Guiding Principles’ or the IUCN’s ‘Briefing Principles’ to demonstrate their consistency with generally adopted objectives and resolutions or, if they aim for deviating from them, seek a status that binds IUCN at large, typically in the form of a resolution adopted at a WCC.
In the absence of such clarifications, the interpretation of trophy hunting as an acceptable form of “sustainable use” has to follow the guidance that Articles 7 and 2 provide. As shown above, Article 2 defines “sustainable use” with respect to IUCN’s overarching concern to conserve the integrity and diversity of nature (not economic benefits for communities or conservation practices).
For the purposes of the question at hand here, the onus is clearly on an applicant for IUCN membership to demonstrate that its own objectives and track record would serve IUCN’s overarching objective. In the light of the appropriate interpretation of Article 2 and the many resolutions (mentioned above) that further elaborate on the importance, meaning and implementation of Article 2, the ‘Guiding Principles’ and ‘Briefing Paper’ are insufficient to serve as a guide for a decision on the eligibility of organizations supporting trophy hunting. Instead, the objectives of such organizations are prima facie inconsistent with IUCN’s objectives.
4. Conclusion
This report addressed the issue of “sustainable use” as a possible criterion to determine the eligibility for IUCN membership of organizations supportive of trophy hunting. It also addressed the more general issue of IUCN’s position on trophy hunting. Bothe issues are intertwined and need to be considered simultaneously.
Trophy hunting is not consistent with “sustainable use”. And even if it were, “sustainable use” is not the sole criterion for the decision on eligibility of organizations seeking IUCN membership. The critical question is whether trophy hunting as it is practiced by individuals and promoted by certain hunting organizations may be consistent with IUCN’s general objectives as expressed in Articles 2 and 7. This is clearly not the case. Any other view would threaten IUCN’s credibility for providing moral and ethical leadership in conservation policies. It would certainly undermine the many efforts of IUCN members to promote a just and sustainable world.


This report has been provided by the following members of the WCEL Specialist Ethics Group (ESG), all professors of environmental law: Klaus Bosselmann (NZ/Germany), Peter Burdon (Australia), Prue Taylor (NZ), Ngozi Stewart (Nigeria), Louis Kotzé (South Africa) and Thiti Waikavee (Thailand).
1 Art. 7 (c) IUCN Statutes and Regulations (as last amended on 10 Sept. 2016); emphasis added.
2https://www.worldwildlife.org/pages/sustainable-use-of-wildlife
3 Ibid.
4 S. Wiggins, The Economics of Poaching, Trophy and Canned Hunting, 2015; https://iwbond.org/2015/09/02/the-economics-of-poaching-trophy-and-canned-hunting/.
5 R. Holsman, “Goodwill Hunting? Exploring the Role of Hunters as Ecosystem Stewards,” Society Bulletin28, no. 4 (2000), 808–16.
6 C. Packer et al., “Sport Hunting, Predator Control, and Conservation of Large Carnivores,” PLOS ONE 4, no. 16 (2009), http://journals.plos.org. S. Wiggins, How can ‘we’ save the African Lion?, 2016; https://iwbond.org/2016/01/05/how-can-we-save-the-african-lion-panthera-leo/.
7 This phenomenon is called "unnatural selection.” F. Allendorf and J. Hard, “Human Induced Evolution Caused by Unnatural Selection through Harvest of Wild Animals,” Proceedings of the National Academy of Sciences 106 (2009): 9987–94.
8 N. Leader-Williams, S. Milledge, K. Adcock, M. Brook, A. Conway, M. Knight, S. Mainka, E.B. Martin T. Teferi (2005). Trophy Hunting of Black Rhino: Proposals to Ensure Its Future Sustainability, Journal of International Wildlife Law & Policy, 8 (1) 1-11.
9 G. Monbiot, ‘The Pricing of Everything’, 2014 SPERI Annual Lecture University of Sheffield https://www.theguardian.com/environment/georgemonbiot/2014/jul/24/price-nature- neoliberal-capital-road-ruin; ‘Can Nature be Monetized?’, Capital Institute Forum http://capitalinstitute.org/braintrust/can-nature-monetized/
10 It is worth noting that IUCN’s practices tend to favour CBA approaches over ethical approaches for the evaluation of biodiversity conservation measures. A report by the International Centre for Integrated Assessment and Sustainable Development at Maastricht University examined IUCN’s perspectives, policies and practices with respect to biodiversity conservation for the period between 2007 and 2013 (“IUCN and Perspectives on Biodiversity and Conservation in a Changing World”, Biodiversity and Conservation, December 2013, Vol. 22, Issue 13-14, pp 3105-3120) and found that anthropocentric, economic and market-based approaches far dominated genuine ethical approaches to evaluating biodiversity conservation measures.
11 There appears to be only one voice arguing in favour of trophy hunting from an environmental ethical perspective: A. Gunn, ‘Environmental Ethics and Trophy Hunting’, Ethics and the Environment , Vol. 6.1 (2001), 68-95; https://muse.jhu.edu/article/11197.
12 This is also true in light of the needs of indigenous and local communities in poor (“developing”) regions of the world. Their livelihood was always dependent on a harmonious relationship with nature. This has not changed by the fact that the (over-)developed world has imposed existential threats to their livelihood with respect to both, social and environmental conditions.
13 A recent example of opposition against trophy hunting from a deontological perspective is A. Ahmad “The Trophy Hunting Debate: A Case of Ethics” Economic & Political Weekly, Vol 51, Issue No 26 – 27, 2016.
14 See, for example, R. Engel (with K. Bosselmann), The Contribution of IUCN to the Ethics of World Conservation: Chronology from 1948-2008.
15 An example is the lack of implementing specific ethical resolutions such as the endorsement of the Earth Charter at the 2004 IUCN WCC or the adoption of Ethics Mechanisms at the 2012 IUCN WCC. See also P.E. Taylor, P. Burdon and D.A. Brown, ‘Moral leadership and Climate Change Policy: the role of the World Conservation Union’, Ethics, Policy and Environment (forthcoming 2017).
16 Notably, the International Council for Game & Wildlife Conservation expressed a disclaimer “for the record” stating that “legal elephant trophies are not subject of this Motion.” (WCC-2016-Res-011-EN; last paragraph).
 

The Rhino and Lion reserve in South Africa has come under new management and the new management has taken the courageous step of deciding not to offer lion cub petting to tourist visitors any longer.

The reason of course is the difficulty that tourist facilities run into for when the cubs grow older, there is no market for them other than the canned hunting industry.

This ethical position has been taken before so this is not unprecedented. Some years ago, the Lion and Safari Park tried to abandon cub petting only to find that they lost so much tourist traffic that they were obliged to reinstate cub petting.

So the public should not underestimate the cost of making such a morally courageous decision. The rhino and lion reserve will lose some tourist traffic as a result of taking this principled stand and we can only hope that they do not lose so much that they are obliged to reverse it.

The new manager at Rhino and Lion Park is Mike Fynn, who is no doubt primarily responsible for this courageous decision.
Especially since he was the manager at Lion and Safari Park and very much responsible for that facility attempting to take the same principled stand.

For good measure, Mike was an active member of the captive carnivore working group, a broad cross-section of all sectors interested in lion conservation, which was seeking to fill the gap in government regulation by drafting suitable regulations which government could adopt and enforce in order to improve the conditions of lions at lion farms in South Africa.

An unsung hero indeed, quietly working away to improve the lives of lions. 

https://www.sapeople.com/2019/09/09/rhino-and-lion-reserve-in-south-africa-will-no-longer-offer-cup-petting/?fbclid=IwAR0u6B689RdUhi-bild-yH8EkK7Abj9WhU0yIvaP97T7yBdNqzbLIVqUjs4

I was reading the response by the Minister for the Environment in South Africa to parliamentary questions on the status of lions, when, to my horror, I came across this old canard which ought to have been discarded years ago. 

I quote:
2) A non-detrimental finding (NDF) made by a Scientific Authority, in respect of African lion and in terms of section 61(1)(d) of the National Environmental Management Biodiversity Act, 2004 indicates that there are currently no major threats to the wild and managed lion populations of South Africa, whereas minor threats include over-utilisation, disease, poaching and conflict with communities around protected areas. The NDF further states that trophy hunting of captive-bred lions poses no threat to the wild population within South Africa, and “it is thought that captive lions may in fact serve as a buffer to potential threats to wild lions by being the primary source for hunting trophies and derived products (such as bone)”. The NDF was published in the Gazette, No. 41393, on 23 January 2018.

The “scientific authority” referred to is the very same one which was thoroughly discredited during the recent parliamentary colloquium when it was quite apparent that it had no idea at all what it was talking about, consisted for the most part of a bunch of ivory tower academics who had as much understanding of the blood and guts of the hunting industry is that of a dog watching a passing aircraft, and was prepared to stand behind an assumption made by another academic from Oxford University. A personal assumption for which there was not a shred of evidence.

It is hunting propaganda repeated by academics as if it were a scientific truth. Yet the moment it is subjected to scrutiny it collapses like a pricked balloon. But pricked balloons have an amazing unscientific ability to re-inflate themselves and be promoted as scientific truths by the Department of Environment.

Some academic at Oxford made a personal assumption and mentioned in passing, with no scientific evidence at all, that:
“it is thought that captive lions may in fact serve as a buffer to potential threats to wild lions by being the primary source for hunting trophies and derived products (such as bone)”. 

And now here is this personal assumption being put forward by the Minister as if it were an established scientific fact.. Disgraceful!

In reading the quote of the Minister’s reply you might have missed the critical three words - within South Africa.

So, even if lion farming in South Africa is stimulating the poaching of wild lions in neighboring territories to the extent of causing regional extinction, the Department of Environment and what passes muster for nature conservation in the provinces continue to eagerly promote lion farming and canned lion hunting.  
Yet the threat posed by SA lion farms to lions in Southern Africa is not mere assumption. Read for example what is happening in Mozambique:
https://abcnews.go.com/International/lions-menu-now-inside-legal-lion-bone-trade/story?id=64827468

So, all conservationists know of CITES Decision 14.69 which bans the breeding of tigers for the trade in their body parts. Why? Because everyone in the conservation universe understood that permitting Tiger farming for the trade in body parts would not only stimulate the poaching of wild tigers it would make it impossible for customs officials and other authorities to be able to determine whether the bones they were looking at were legal ones or from a poached wild animal. The bones all look the same.

Now, if Tiger farming is banned because the trade in body parts is going to adversely impact wild tigers, why is the farming of lions not banned for exactly the same reason? But no in the case of lions, lion farming should be legal and promoted by government, because some foreign academic mentions that tame lions might provide a buffer to protect wild lions from hunters.
And what does this baseless assumption say about the hunting industry?
That trophy hunters are so rabidly determined to kill lions that if they can’t find a tame one they’ll move heaven and earth to kill a wild one?

So pity the poor lions. South African conservation officials who are paid by the taxpayer to protect our wildlife instead use public money to subsidise the hunting industry.
​And they are so inept that they cannot tell the difference between assumption and scientific fact.
 

Lion bone trade: justice delayed is justice denied
Hot off the press, the decision of the High Court in the matter of the National Council of the SPCA against the lion farmers and their stooges in government, is causing quite a stir.
The NSPCA challenged the legality of the way the SA government determined the export quotas for lion bones. In particular, it challenged the minister’s conservation dogma that animal welfare had nothing to do with the Department of Environment.
You can read the full judgement of the High Court here:
https://emsfoundation.org.za/wp-content/uploads/Judgment-Lion-Bone-case-6-August-2019.pdf
So as you can see, the High Court decision was essentially moot; it related to the 800- carcass quota for 2017 and the 1500- carcass quota for 2018, both of which quotas had already been exported. Clearly though, the decision that the quotas were determined illegally and without taking all relevant factors into account will have a salutary effect upon future quota settings.
Much of the judgement relates to the importance of the government taking animal welfare considerations into account in all aspects of conservation but specifically here in the setting of export quotas. Many lions are kept in appalling conditions in South Africa. The lion bone trade wants bones so a skeletal lion is much more profitable than a healthy animal who needs to be fed better to remain healthy.
Had I been arguing the case, I would have pointed out that it is quite impossible to effectively manage the lion population or indeed any wildlife population without including animal welfare considerations within the current conservation paradigm of sustainable use.
(Sustainable use is the theory; sustained abuse is the practice)
The reason is this: I have personally been told by any number of conservation officials: “don’t bother us with animal welfare. Animal welfare is no part of our mandate. We are only concerned with population numbers.”
So as far as they’re concerned, they just count the numbers. If the numbers of animals go up they pat themselves on the back and say what a wonderful job they’re doing. If the numbers go down, then they pretend that they have to do something about it.
The inevitable result of this narrow numbers based approach to sustainable use is that the condition of the animals composing the wildlife populations becomes irrelevant. This is so wrong.
It is highly relevant to conservation and to sustainable use that three quarters of the species are now in miserable captive conditions being starved to death for the lion bone market where as conservationists are treating them as if they were part of the ecology/environment.

​So what happens now?
My guess is that this judgement will be honoured more in the breach than in the observance by South African government conservation structures. They will continue to support lion farming and the export of lion bones and rely on the fact that anyone challenging their thumb- suck quotas will have to take them to the High Court, a remedy which is obscenely expensive, coin- tossingly uncertain and slower than cancer.
 
 

                                    
​                With the heart of a lioness
       One volunteer’s journey of discovery in the dark heart of the canned lion hunting industry.

The three day animal advocacy course which I offer at the Karoo wildlife centre has the advantage of bringing me into contact with volunteers who know much more about cup petting then I do.

One of the attendees of my recent course was a lady who I shall call Ronnie and she is the author of the book titled “With the Heart of a Lioness.)

 She was kind enough to give me a one-minute video clip about her book. https://youtu.be/a7sV8MJRML4

I am frequently approached by volunteers to South Africa wanting advice on ethical destinations. I always say that the rule of thumb is: avoid any facility where breeding takes place.

Unfortunately, there seems to be an insatiable demand - in particular among the tender gender - to cuddle a lion cub.

Ronnie’s book is a scrupulously careful and detailed account of her experiences at a lion farm in the Free State province of South Africa. On one level it is a guidebook for volunteers; where to go, what to do, how to behave around animals, particularly lions, and everything else that a serious volunteer would need to know.

But on a deeper level the book relates a journey of discovery; how one dedicated animal lover who believed that she was doing conservation work eventually opened her eyes to the ugly reality of lion farming and canned hunting in South Africa.

Little by little she describes how she comes to understand that she has been duped. Here are some of the grandiose claims and fine sounding sentiments which one sordid and squalid lion farm puts out to volunteers to entice them to bring their money and come:
“all cubs are hand raised which boost their survival rate and creates a manageable and sustainable program.
We conserve the Bengal tiger and increase awareness about tiger conservation.
Our mission is to sustain the genetic pool of the lion”…. 

With such skilful and astute deception, lion farms continue to attract gullible animal lovers from overseas. Too late they discover that the extortionate fees that they are charged, which they thought were promoting conservation, in fact enable lion farmers to externalise the cost of rearing their lions to huntable size. And in the process, put local previously disadvantaged South Africans out of work.

The author relates a litany of abuse at every stage of the doomed lions’ lives; reckless breeding, appallingly cruel and amateurish animal husbandry, neglect , cruel exploitation - and all under the cloak of ‘conservation.’

Everything about this sick industry is fraudulent. Volunteers are fraudulently deceived into thinking that they are promoting lion conservation; canned lion hunting is fraudulently claimed to be ‘saving wild lions’; the lion bones that are sold to Asia are fraudulently represented as tiger bones in order to produce tiger bone wine and cake which is then fraudulently passed off to the consumer as a health medicine.

All in all lion farming is a business model built upon routine cruelty to animals which flourishes behind a Bell-Pottinger facade of conservation.

To animal lovers who are thinking of volunteering at any facility in South Africa where breeding takes place and there are cubs to pet, I urge them to read Ronnie’s book first, and then take the time to come to the Karoo wildlife centre for three nights in order to be educated on how the hunting industry has invaded and occupied conservation space in South Africa.
            www.cannedlion.org/volunteers.html
 
 
 

                                               Logic and irrelevance.

A critique of the recently published article titled “The Ethics of human -animal relationships and public discourse: a case study of lions bred for their bones.”

• All cats have four legs
• my dog has four legs
• therefore my dog is a cat.

This is a syllogism which I frequently use in argument to expose the logical flaws in the hunting narrative which runs something like this:

• all conservationists wish to preserve wilderness
• hunters wish to preserve some aspects of wilderness so that they can hunt and kill
• therefore hunters are conservationists.

As you can see hunters’ claims to be conservationists are not even logical let alone factual.

Recently a herd of academics associated with Oxford University put out an article on the use of logic methodology, using the lion bone trade as a case study. They take a few of the arguments used to justify captive lion breeding for the lion bone trade as well as some opposing arguments and point to the lack of logic on both sides in seeking to make definite claims where only uncertainty exists.

I was looking forward to read the article because I offer a three- day course at the Karoo Wildlife Centre on animal advocacy with particular reference to lion farming, canned lion hunting and the lion bone trade. I hoped that I might get some useful course material.

I was disappointed.  Twenty-one pages of dense text was enough to give me a headache - and leave me no wiser than before.

I don’t know who this article was aimed at, unless it is a mere academic exercise. I can’t think of anyone in South African conservation who would derive any benefit from reading it.

Calling it a case study with reference to the lion bone trade is a misnomer because the few references to the lion bone trade were superficial - nothing new there - and completely overshadowed by the mentally suffocating mass of academic verbiage.

That would have been bad enough but the article has clearly suffered from a heavy edit to remove or restate anything which could cause the slightest offence to any person living on our planet or within our galaxy.

The result is political correctness run wild leaving a piece which is so bland as to be virtually non-existent.

If you want to learn about logic to improve your ability to see through false claims being made in politics or conservation, then read a book on how to identify flawed logic. I recommend a little book by Professor Thouless titled  ‘Straight and Crooked Thinking’ which is probably out of print, but there are others.

This article will not help you at all. And if you were hoping for some wisdom on the lion bone trade then all you will get is the realisation of how far away from the blood and guts and dust and flies of real conservation is the academic world.
​
Don’t waste your time reading this article.