My Comments on the Biodiversity Management Plan (BMP) for Lions in SA
The SA government has finally released a proposed lion management plan (BMP)
Prepared by consultants, the 66-page report contains much useful information and is well worth the time taken to read it.
In essence, the BMP separates lions in to three categories:
1. Wild lions (Kruger National Park, Kgalagadi Transfrontier Park)
2. Managed 'wild' lions (in 45 private nature reserves, roaming free in large fenced areas, but culled and hunted to control their numbers)
3. Captive-bred lions (in 200 lion farms breeding lions for canned hunts)
Each group is treated differently.
The report sets out to meet certain Objectives, which are listed, and here is our first complaint. Whether or not lion farms and canned hunting should be allowed at all has been left out of the objectives. So the most important issue affecting lions in South Africa is excluded from the BMP.
You can read the full BMP here:
https://www.dropbox.com/s/dupfrbztm9fson6/17%20December%202014%20Vetted%20%20draft%20%20BMP%20for%20SA%20Lion%20Panthera%20Leo%20clean%20copy_1.pdf?dl=0
We urge you to read it, look at our comments below, and then send your input to the stakeholders listed in our website here:
http://www.cannedlion.org/what-you-can-do.html
The result is extremely superficial treatment of the whole issue of lion farming and canned hunting. One or two vague references to controversy around lion farming, vague sub-objectives about tightening up some (unspecified) permit conditions sometime before 2019(!!) and that is it.
There are more than twice as many tame lions being bred for slaughter than wild lions in SA. Yet this BMP focuses on how to manage the small population of wild, or semi-wild lions, and really just touches upon the far larger captive bred lion population in passing.
We would describe the BMP as a disaster for the African lion, and when lion farming for trophies and lion bones is proved to be contributing to the extinction of the African lion, it will be cold comfort to say to the complacent bureaucrats who mis-manage our wildlife: we told you so.
Never mind the consequences of fostering an animal welfare nightmare that will certainly have unexpected consequences (eg a boycott of SA agricultural produce, since lion farming has now been adopted by the Department of Agriculture DAFF)
Extracts from the BMP are in Italics, and my comments are in plain text below.
Objective 1
Ensure a well-managed captive lion population.
Why such a superficial objective? Why assume that lion farming has a valid conservation purpose when everyone, including the lion farmers' legal representatives, deny that this is so? Surely the first objective ought to have read: Whether lion farming for canned hunting ought to be allowed, and, if so, under what restrictions.
Consider the related issue of Tiger conservation.
The Tiger Comparison: Even CITES realised that the farming of tigers would cause the extinction of wild tigers. CITES realised:
a. That the tiger trade, being illegal, cannot be measured accurately;
b. That the effect of tiger farms on wild tigers could not be measured;
c. That farming would provide an opportunity for laundering wild specimens that would accelerate poaching;
d. That tiger farming would distract from tackling loss of habitat, loss of prey species and other illicit activities.
Accordingly, in Decision 14.69 the COP adopted this regulation:
Parties with intensive operations breeding tigers on a commercial scale shall implement measures to restrict the captive population to a level supportive only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives.
So here is the question that calls for an answer: if CITES has banned tiger farming for trade, why has the farming of lions for commercial purposes not been banned? All the same considerations apply to both species.
Objective 2
Encourage the development of opportunities for economic and social benefits from responsibly managed wild, managed wild and captive lion populations.
Translation: explore ways to exploit wildlife, to make more money out of the animals. The word 'responsibly' is suitably ambiguous.
Sub-objectives:
2.1. Prevent illegal trade in lions and lion products while promoting and safeguarding sustainable legal trade; and
2.2. Promote sustainable legal trade in lions and lion products.
This oxymoron mirrors the confusion and muddled reasoning that characterises the debate on whether or not to legalise the trade in Rhino horn, with those who stand to make money out of rhino (rhino farmers, the SA government) being opposed by virtually every expert who understands how a legal trade will grow the illegal trade. Just as legalising the trade in Rhino horn will be the death knell for wild Rhino, so permitting the exponential growth of the lion bone trade will contribute to the extinction of wild lions.
As explained above with the example of the Tiger trade, you cannot promote a legal trade in lion parts without ipso facto promoting the illegal trade. The one feeds the other.
The species is well managed( sic!!!) and the Scientific Authority does not have any current concerns relating to the export of lion in accordance with Article IV of the CITES as the South African lion population is included in Appendix II of CITES. In terms of Article IV of the CITES, an export permit shall only be granted for an Appendix II species when a Scientific Authority of the State of export has advised that such export will not be detrimental to the survival of that species.
The assessment only considered wild and managed wild populations of the African lion and did not consider captive populations.
Well-managed? Well managed? Do they actually believe their own propaganda? So actually, almost all of the CITES tags for exports of lion bones and trophies are in violation of CITES, because the Scientific Authority has never issued an NDF (Non-detriment finding) for farmed lions. How well managed is that?
The Convention on Biodiversity(CBD) addresses conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising from the use of biological and genetic resources. The CBD also provides guidelines to manage biodiversity, but does not provide specific protection for the African lion or any individual species. The only international agreement that offers specific and significant protection to the African lion is CITES.
No protection for lions? What an understatement! Actually the Convention on Biodiversity lumps lions, elephants etc in with bacteria and any other 'organism' in its definition of biological resources and then proceeds to treat lion and elephants as if they were bacteria. Is this 'well managed?' Or 'responsible?'
Permits for wild and managed wild lion hunts in South Africa are obtained on application from the appropriate provincial conservation authority, as are permits for hunting captive-bred lions. Clearly permits are not limited, given the number of captive lions hunted. Furthermore, many of the captive hunts are being reported as wild or managed wild lion hunts, and the relevant authorities are in the process of addressing the incorrect use of source codes in the issuance of permits.
How 'well managed' is this? Here we see false reporting on a broad scale. Between 1999 and 2008 CITES reports show the export of at least 5000 lions of which nearly 3000 (2962) were exported as 'wild' lions, but we know that the number of wild lions hunted in SA every year to be less than ten. So the correct total for that period should be not more than 100 wild lions. Where have all the other 2,862 'wild' lions come from?
Clearly the statistics reveal the massive extent of fraud in the SA permit system. It is easy to guess why.
Roland Ward trophy book refuses to recognise the trophies of captive bred lions - for obvious reasons. So to get around the Roland Ward ban, trophies of tame lions are being exported as 'wild' with corrupt provincial conservation officials eager and willing to certify the trophy as 'wild' - for a fee.
We have also been told by eyewitnesses, who do not wish to become involved, that some lion farmers fly their lions at night over the border in to Mozambique to be shot by canned hunters there on arrival. The trophy is then exported fraudulently as that of a wild Mozambique lion, in order to circumvent the Rowland Ward Trophy Book refusal to recognise trophies of captive bred lions.
What a disaster for the African lion this management plan is!
The SA government has finally released a proposed lion management plan (BMP)
Prepared by consultants, the 66-page report contains much useful information and is well worth the time taken to read it.
In essence, the BMP separates lions in to three categories:
1. Wild lions (Kruger National Park, Kgalagadi Transfrontier Park)
2. Managed 'wild' lions (in 45 private nature reserves, roaming free in large fenced areas, but culled and hunted to control their numbers)
3. Captive-bred lions (in 200 lion farms breeding lions for canned hunts)
Each group is treated differently.
The report sets out to meet certain Objectives, which are listed, and here is our first complaint. Whether or not lion farms and canned hunting should be allowed at all has been left out of the objectives. So the most important issue affecting lions in South Africa is excluded from the BMP.
You can read the full BMP here:
https://www.dropbox.com/s/dupfrbztm9fson6/17%20December%202014%20Vetted%20%20draft%20%20BMP%20for%20SA%20Lion%20Panthera%20Leo%20clean%20copy_1.pdf?dl=0
We urge you to read it, look at our comments below, and then send your input to the stakeholders listed in our website here:
http://www.cannedlion.org/what-you-can-do.html
The result is extremely superficial treatment of the whole issue of lion farming and canned hunting. One or two vague references to controversy around lion farming, vague sub-objectives about tightening up some (unspecified) permit conditions sometime before 2019(!!) and that is it.
There are more than twice as many tame lions being bred for slaughter than wild lions in SA. Yet this BMP focuses on how to manage the small population of wild, or semi-wild lions, and really just touches upon the far larger captive bred lion population in passing.
We would describe the BMP as a disaster for the African lion, and when lion farming for trophies and lion bones is proved to be contributing to the extinction of the African lion, it will be cold comfort to say to the complacent bureaucrats who mis-manage our wildlife: we told you so.
Never mind the consequences of fostering an animal welfare nightmare that will certainly have unexpected consequences (eg a boycott of SA agricultural produce, since lion farming has now been adopted by the Department of Agriculture DAFF)
Extracts from the BMP are in Italics, and my comments are in plain text below.
Objective 1
Ensure a well-managed captive lion population.
Why such a superficial objective? Why assume that lion farming has a valid conservation purpose when everyone, including the lion farmers' legal representatives, deny that this is so? Surely the first objective ought to have read: Whether lion farming for canned hunting ought to be allowed, and, if so, under what restrictions.
Consider the related issue of Tiger conservation.
The Tiger Comparison: Even CITES realised that the farming of tigers would cause the extinction of wild tigers. CITES realised:
a. That the tiger trade, being illegal, cannot be measured accurately;
b. That the effect of tiger farms on wild tigers could not be measured;
c. That farming would provide an opportunity for laundering wild specimens that would accelerate poaching;
d. That tiger farming would distract from tackling loss of habitat, loss of prey species and other illicit activities.
Accordingly, in Decision 14.69 the COP adopted this regulation:
Parties with intensive operations breeding tigers on a commercial scale shall implement measures to restrict the captive population to a level supportive only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives.
So here is the question that calls for an answer: if CITES has banned tiger farming for trade, why has the farming of lions for commercial purposes not been banned? All the same considerations apply to both species.
Objective 2
Encourage the development of opportunities for economic and social benefits from responsibly managed wild, managed wild and captive lion populations.
Translation: explore ways to exploit wildlife, to make more money out of the animals. The word 'responsibly' is suitably ambiguous.
Sub-objectives:
2.1. Prevent illegal trade in lions and lion products while promoting and safeguarding sustainable legal trade; and
2.2. Promote sustainable legal trade in lions and lion products.
This oxymoron mirrors the confusion and muddled reasoning that characterises the debate on whether or not to legalise the trade in Rhino horn, with those who stand to make money out of rhino (rhino farmers, the SA government) being opposed by virtually every expert who understands how a legal trade will grow the illegal trade. Just as legalising the trade in Rhino horn will be the death knell for wild Rhino, so permitting the exponential growth of the lion bone trade will contribute to the extinction of wild lions.
As explained above with the example of the Tiger trade, you cannot promote a legal trade in lion parts without ipso facto promoting the illegal trade. The one feeds the other.
The species is well managed( sic!!!) and the Scientific Authority does not have any current concerns relating to the export of lion in accordance with Article IV of the CITES as the South African lion population is included in Appendix II of CITES. In terms of Article IV of the CITES, an export permit shall only be granted for an Appendix II species when a Scientific Authority of the State of export has advised that such export will not be detrimental to the survival of that species.
The assessment only considered wild and managed wild populations of the African lion and did not consider captive populations.
Well-managed? Well managed? Do they actually believe their own propaganda? So actually, almost all of the CITES tags for exports of lion bones and trophies are in violation of CITES, because the Scientific Authority has never issued an NDF (Non-detriment finding) for farmed lions. How well managed is that?
The Convention on Biodiversity(CBD) addresses conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising from the use of biological and genetic resources. The CBD also provides guidelines to manage biodiversity, but does not provide specific protection for the African lion or any individual species. The only international agreement that offers specific and significant protection to the African lion is CITES.
No protection for lions? What an understatement! Actually the Convention on Biodiversity lumps lions, elephants etc in with bacteria and any other 'organism' in its definition of biological resources and then proceeds to treat lion and elephants as if they were bacteria. Is this 'well managed?' Or 'responsible?'
Permits for wild and managed wild lion hunts in South Africa are obtained on application from the appropriate provincial conservation authority, as are permits for hunting captive-bred lions. Clearly permits are not limited, given the number of captive lions hunted. Furthermore, many of the captive hunts are being reported as wild or managed wild lion hunts, and the relevant authorities are in the process of addressing the incorrect use of source codes in the issuance of permits.
How 'well managed' is this? Here we see false reporting on a broad scale. Between 1999 and 2008 CITES reports show the export of at least 5000 lions of which nearly 3000 (2962) were exported as 'wild' lions, but we know that the number of wild lions hunted in SA every year to be less than ten. So the correct total for that period should be not more than 100 wild lions. Where have all the other 2,862 'wild' lions come from?
Clearly the statistics reveal the massive extent of fraud in the SA permit system. It is easy to guess why.
Roland Ward trophy book refuses to recognise the trophies of captive bred lions - for obvious reasons. So to get around the Roland Ward ban, trophies of tame lions are being exported as 'wild' with corrupt provincial conservation officials eager and willing to certify the trophy as 'wild' - for a fee.
We have also been told by eyewitnesses, who do not wish to become involved, that some lion farmers fly their lions at night over the border in to Mozambique to be shot by canned hunters there on arrival. The trophy is then exported fraudulently as that of a wild Mozambique lion, in order to circumvent the Rowland Ward Trophy Book refusal to recognise trophies of captive bred lions.
What a disaster for the African lion this management plan is!