May 1st, 2011 - All Smoke and Mirrors

ALL SMOKE AND MIRRORS
THE NEW CANNED HUNTING REGULATIONS

by

CHRIS MERCER.
Co author of the Books
“For the Love of Wildlife” and “Canned Lion Hunting - A National Disgrace”

These are my submissions as part of the Public Participation process announced by the Minister in respect of the proposed Norms and Standards for the Hunting Industry, 2006, and the new Regulations in respect of Listed Endangered Species and Large Predators.

OVERVIEW
I believe that the new hunting regulations are nothing but an elaborate public relations exercise.

The two new government publications, one on general hunting standards, and one on, inter alia, large predators, are fundamentally flawed in two critical respects:
First, there was never any intention to stop the cruelty, so what we have is a formula of pious, unenforceable aspirations, all designed to stifle public criticism. But it is the cruelty which offends the public, and until that is addressed by a complete ban on all trophy hunting, international pressure will continue to mount against South Africa.
Second, the attempt to infiltrate hunting industry notions of fair chase into biodiversity protection is transparently flawed. All trophy hunting is genetically and environmentally devastating, whether the hunter shoots like a colonial fop from a vehicle, or like Rambo on foot after a long stalk. The result is the same, pain and death for the animal, and a loss of biodiversity. You cannot love or respect Nature with a gun. And nowhere do the new regulations/standards recognise that trophy hunting causes stunting in species. Compare the slight Karoo springbok and Cape Leopard (who have been hunted hard for 350 years) with their much larger Kalahari cousins (who have only been hunted hard for 50 years).

The new regulations certainly look very impressive on paper, but just look who is going to enforce them - the very same conservation officials who have caused the problem in the first place. As Einstein reminds us “problems can never be solved at the level at which they were created”. I for one would have no problem getting around them, especially if I had cronies in the conservation services, and I am sure that many lion breeders are much smarter than me.
Nothing less than sweeping out of our conservation services all the hunting thugs who wear conservation uniforms will stop the cruelty. Expecting such officials to enforce the new restrictions is as absurd as asking Al Capone’s henchmen to monitor his activities. Employing hunters in Conservation is like appointing serial rapists to look after a Girl’s Hostel. This is simply industry self- regulation in a new disguise.

So far from stopping the cruelty, the new regulations seek to extend the grisly business of killing wildlife for profit to black empowerment groups. Our nation and this world need fewer killers, not more.

There is a major moral issue here, which is being studiously ignored - whether the infliction of suffering and death upon unoffending animals for pleasure is acceptable. If it is criminal to beat a dog or a donkey, why should trophy hunters be allowed to do much worse to other animals?

As for the Minister’s fine rhetoric about the new regulations being ‘the end of canned hunting,’ I predict that his extravagant boast is going to suffer the same fate as George W Bush’s boast three years ago that ‘the war in Iraq is over.’ Forget fair chase, Minister. Just stop the cruelty.

EXECUTIVE SUMMARY

1. All Trophy Hunting falls within the definition of Canned Hunting in South Africa.
2. Trophy hunting is Colonialism, making SA a hunting colony.
3. All trophy hunting is un-Christian, un-Islamic and unethical.
4. Trophy hunting has no place in Conservation. It is socially, genetically and environmentally devastating to species.
5. In pure financial terms, Trophy hunting is a liability, not an asset to SA.
6. The new Standards and Regulations are misdirected, and will harm SA if adopted:-
7. They impose expensive bureaucratic burdens upon legitimate wildlife rehab centres and sanctuaries, but will not deter hunters.
8. They provide exceptions which will become the rule. Eg hunting with dogs.
9. The breeders and hunters will easily evade the paper restrictions.
10. They seek to draw a line between ethical trophy hunting and ‘environmental thugs’ whereas no relevant difference exists.
11. They will deliver our remaining wildlife heritage into the hands of the very people who have damaged it - the hunters.
12. They rely for enforcement upon a Conservation Service which is notoriously corrupted to hunting.
13. Attempting to enforce these new Standards and Regulations will drain conservation resources whereas a total ban on trophy hunting will be cheap and effective.
14. Because the new laws will do nothing to stop the institutionalised cruelty to wildlife, merely the context in which the cruelty continues, public and international opprobrium will continue to grow.
15. The Regulations and standards must be re-drafted to ban all trophy hunting, to ban the export of wildlife trophies, and to rid our Conservation services of all officials who are themselves professional hunters, or otherwise connected to the hunting industry.

Prescript.

SUBMISSIONS.

1. All Trophy Hunting falls within the definition of Canned Hunting in South Africa.
It is important to define Canned hunting accurately in order to meet public concerns:
Canned hunting is the hunting of an animal where the target animal is unfairly prevented from escaping the hunter, because of either physical constraints (fenced in) or mental constraints (habituation to humans.)
If this definition is adopted, it can be seen that no captive bred animal should ever be targeted, and all trophy hunting is canned because there is no true wilderness left in South Africa and all hunting takes place in fenced off areas from which the animal cannot escape.
The notion that a captive bred lion can be hunted once ‘rehabilitated’ to a bigger camp (extensive wildlife system) violates the definition above on both grounds. Such an animal is not wild; it is merely alternative livestock, and no one would allow farmers to charge around their farms shooting their sheep and cattle with bow and arrow or guns for fun.

2. Trophy hunting is Colonialism, making SA a hunting colony.

No doubt hunters persuade African governments that killing animals is poverty alleviation. Actually, it is Colonialism.
Look at trophy hunting. Chucking a few dollars at local landowners in order to plunder our wildlife heritage is not conservation, it is Colonialism. When organisations such as Safari Club International in U.S.A. patronise this industry, they export US dollars and colonialism to Africa, and they import misery and bloodshed in the form of trophies. Their dollars are a corrupting influence in the third world, perverting conservation policies away from preservation towards the cruel exploitation of wildlife.
Somalia banned all trophy hunting in 1973 on the ground that it was a barbaric relic of colonialism, and Kenya followed suit three years later. Why is SA so backward in this respect?

3. All trophy hunting is un-Christian, un-Islamic and unethical.

There are a number of books by theologians which maintain that inflicting pain and death upon God’s creatures for pleasure (fun, recreation) is against the Scriptures. Buddhists and Hindus have for centuries maintained devoutly that this is so. The issue is succinctly dealt with in Tony Campolo’s book ‘Twenty Hot Potatoes that Christians are Afraid of’, entitled “Is Hunting a Sin”, and ending with the warning that “Woe Betide those who kill God’s creatures for fun.” A copy of the chapter “Is Hunting a Sin?” is attached to this submission.
The billions of people in the world who find all cruelty to animals objectionable, and cruelty for the sake of pleasure, like trophy hunting, particularly offensive, are therefore supported by all the major religions.

4. Trophy hunting has no place in Conservation. It is socially, genetically and environmentally devastating to species.

The evils of sport hunting are apparent to most decent people. Yet hunters have formidable accomplices in the United Nations Environment Program and pro-hunting groups within the IUCN. It was these groups who conceived the Dogma of Sustainable Use. What this establishes is that natural resources may legitimately be used, provided the use is ‘wise’ in the narrow sense of not being excessive. This doctrine makes sense when it is restricted to inanimate resources such as tin or copper. But including sentient beings within the scope of mere ‘resources’, which may be harvested, was far from wise, and probably closer to collective insanity. How could any sane person possibly lump gorillas, elephants and lions in with bacteria and then treat them as mere organisms?
South Africa has adopted the doctrine of Sustainable Use, and now believes that it is licensed by the IUCN and the United Nations to treat sentient beings as if they were bacteria.
What the public should know is that the IUCN is a pro hunting organisation founded by hunters. Although it has expanded considerably and now includes some animal welfare organisations, the IUCN is dominated by the pro-hunting lobby, and Animal Welfare organisations find it virtually impossible to get animal welfare issues onto the agenda. The IUCN is directly responsible for one of the cruellest and most destructive policies ever devised - the doctrine of ‘Sustainable Use’ - whereby sentient beings such as gorillas, elephants and lions etc are classified and treated as if they were bacteria.
IUCN CLAIM: Hunting is not to blame for the decline in lion numbers in Africa.
What? Such hypocrisy! Hunters wiped out the Continent’s wildlife in an orgy of reckless destruction, forcing the hunting industry to turn to captive breeding in order to maintain a constant supply of living targets. Now that new threats like habitat loss from poor land management have arisen, the IUCN uses these as a shield to deflect culpability away from the hunters. Trophy hunting is part of the problem, not part of the solution.
1. IUCN CLAIM: Hunting will help African governments deal with problem animals.
If the IUCN knew anything about livestock farming, it would know that there is no such thing as a problem animal; there are only problem people. Poor management in farming causes stock losses to predators. Bringing in hunters to kill predators merely reinforces poor management. If poor land use and land management is causing African farmers to kill lions, then surely the IUCN should be promoting better land use, not the killing of lions by hunters.
3. IUCN CLAIM: Trophy hunters can minimise the impact of hunting on the social lives of a pride of lions by targeting only older males.
This ‘expert’ paints the misleading picture of a geriatric pride male who should be removed in the interests of the pride. There is no such thing. Pride males are displaced by stronger competitors long before they can become geriatric. The truth is that trophy hunting causes stunting, and is both genetically and socially catastrophic.
4. IUCN CLAIM: Lions are a threat to rural humans in Africa, and hunters of lions help to protect people.
Once again, if poor land use and management is causing human-lion conflict, the solution is to fence off reserves effectively to remove the conflict - not to bring in hunters to act as the military wing of the livestock farming industry, and to further diminish lion numbers. That is not Conservation.
5. IUCN CLAIM: Trophy Hunting ‘generates benefits for poor people to build their support for lion conservation.’
This is merely a re-statement of the misleading old mantra ‘Give it a value and it will be preserved.’ The truth of course as we know from whaling and the ivory trade, is that if you give it a value, it will be ruthlessly exploited at any cost. That was the whole reason for the ivory ban - to protect elephants by removing their market value. And it worked.
Look at the IUCN’s logic. Game reserves were established to protect the wildlife from the slaughter of hunters. Now that African governments are not protecting their wilderness areas or their wildlife adequately, what is the IUCN’s remedy? Bring back the hunters! This is as absurd a standpoint as arguing that only whaling can save the whales. It is like putting Dracula in charge of the blood bank. Save them from whom? The solution is surely to assist African governments to improve their land use and management - not to hand over the remaining wilderness areas and wildlife to the tender mercies of the hunting industry.
Probably the most knowledgeable people on this subject are Dereck and Beverley Joubert, the award-wining wildlife documentary filmmakers, who have lived, studied, counted and filmed wildlife in Botswana for almost fourteen years. They describe the hunting industry as ‘ethically bankrupt’ telling, for example, of a male lion who was actually mating with a lioness when he was shot dead by a trophy hunter.
Professional hunting operations continue to shoot full quotas of animals over the years despite the obvious decline in the numbers. Between 1985 and 1992 - only seven short years - nearly 500 lions were lost to trophy hunters. The Jouberts estimated that in the area in which they lived and worked, almost every male lion was shot by trophy hunters. They observed the devastating effect on the pride and social harmony. The Jouberts began to observe an increase in single male prides, which indicated that the second pride male had been hunted. Some prides were even observed to be without a male for up to periods of four years.

It is now undisputed that trophy hunting detrimentally affects entire wildlife families in a variety of ways, not just the hunted individual. The IUCN should know this.

Our message to African Governments is this: Do not be deceived by this little propaganda exercise. Just like the tobacco industry, the hunting industry is obscenely wealthy and able to conceal its harmful activities behind a public relations facade. Kenya banned trophy hunting thirty years ago because it was a barbaric relic of colonialism and elitism. Follow the Kenyans. Stop perpetuating colonialism .

5. In pure financial terms, Trophy hunting is a liability, not an asset to SA.
Trophy hunting accounts for a tiny fraction of the income from eco-tourism. Kenya which banned trophy hunting thirty years ago has a tourism industry that most African countries envy. In the age of the Internet where millions can be mobilised at the touch of a button, it would be foolish to risk tourism and trade boycotts, disruption of events such as the 2010 World Cup soccer tournament by prolonging support for a hunting club which is despised by hundreds of millions of people in Europe alone. (Polls consistently show that 4 out of 5 people in UK are opposed to any form of sport hunting.) The potential damage to South Africa from being regarded as one of the Rogue Nations for cruelty to animals (along with Canada for its slaughter of Harp Seals) far exceeds the income from hunting.
Unlike eco-tourism which gives real careers to previously disadvantaged people, trophy hunting benefits only a few cruel soldiers of fortune, leaving only menial work like skinning for employees. In truth, hunting is a wasteful use of land. See the article “To Snap or Snipe” annexed hereto, which explains why.
Unlike eco-tourism where a large number of tourists bring vast sums of foreign currency into SA, trophy hunting offers ideal opportunities for tax fraud and foreign currency swindling. If a wealthy businessman has siphoned off funds from his business and needs to hide this hot money, he can ‘invest’ in a hunting farm or operation, and then leave the foreign income outside the country in some tax haven. Before allowing this industry to continue, the SA government should at least do a comprehensive forensic audit upon it.

6. and 7. The new Standards and Regulations are misdirected, and will harm SA if adopted:-
They impose expensive bureaucratic burdens upon legitimate wildlife rehab centres and sanctuaries, but will not deter hunters.
It is notable that the Panel of so-called ‘Experts’ contained no one who knew anything about wildlife rehab or sanctuary work. Of course, sanctuaries have been and are still banned in SA, and one cannot help feeling that the main reason for recognising sanctuaries now is to provide canned lion breeders with an avenue to get around the restrictions on captive breeding. Because of this (studied) ignorance, the policies proposed are impractical and onerous on legitimate sanctuarians (who presently have to operate under Zoo or Rehab permits to do Sanctuary work.)
Hunters have the money to employ lawyers and consultants who will quickly build up an expertise in filing all the necessary forms, risk assessments etc which soon become standard form and meaningless. But real sanctuarians are far too busy looking after animals to find time to familiarise themselves with complicated forms, nor do they have the money to employ consultants to do the work for them. They will struggle with the annual bureaucratic burden, which is completely unnecessary for bona fide sanctuaries. I have prepared a Sanctuary Policy, copy annexed to this document, and there is a case for making Rehab Centres and Sanctuaries Self-governing within the limits of this Sanctuary Policy. It would remove an onerous burden for both the Rehabbers and the Conservation Services.
Take the microchipping requirement. This is an expensive and life threatening exercise when applied to dangerous animals like lions, who have to be darted. Darting damages the kidneys and cannot be done too often, or inexpertly. Allow R500 for darting costs per lion and you see how prohibitive it becomes for honest sanctuary charities. (The hunters can afford it easily) Aged and infirm animals should be exempted from being microchipped (and darted) anyway.

8. They provide exceptions which will become the rule. Eg hunting with dogs.
The new Regulations are full of bold-sounding bans, but for every ban there is an exception, which will allow the hunter to circumvent the ban.
Take the use of dogs for hunting. Several trophy hunting operators use a pack of dogs for all their hunting purposes. See eg Mr Strydom’s operation www.africancats-hounds.co.za which features a photo on the home page of a leopard being savaged by a dog pack. Of course, a total ban is called for to end this barbaric form of hunting, but instead, the new policy permits dogs to be used ‘to follow up a wounded animal.’ Now, Mr Strydom will be able to drive a coach and horse through this loophole. First, who can possibly tell from the carcase whether the wounds were inflicted before or after the dogs were set upon the victim? Second, even in the unlikely event of an un-corrupt conservation official actually attending a hunt, there is nothing to stop the hunter from starting the hunt by deliberately wounding the animal slightly, in order to permit the dog pack to be released. Because it is a rule which is impossible to enforce, the prohibition on hunting with dogs becomes meaningless - just like all the other bans in these new policies. (which is why they have the approval of the hunting industry.)
And what about the bow-hunters, who shoot arrows into the alternative livestock for fun? Minister Van Schalkwyk says that bow-hunting has been banned. This is not true - the section allows exceptions where the province allows it. Permitting individual provinces to opt out of the new Regulations and Policy makes the Minister’s statement that the new policy will bring uniformity another overstatement.

9. The breeders and hunters will easily evade the paper restrictions.
First, it is notable that Zoos are not mentioned in the new policies. If both Zoos and the hunting industry are allowed to be self-governing, why are the rehab centres and Sanctuaries not allowed to be self-governing? After all, they know more about their work than the officials do and are better able to enforce proper ethics among their members. Is it because ethical sanctuaries would surely exclude captive lion breeders from their ranks, and this would contradict hunters/breeders plans to call themselves rehabbers and sanctuarians in order to circumvent the breeding-for-hunting restrictions?
Under the new policies, any canned hunting breeder can circumvent the prohibition on captive breeding for hunting by registering himself as a sanctuary (for his breeding lions) and a rehab centre (for the progeny), on the basis that he intends to release the progeny animals ‘back to the wild.’ (not real wilderness, of course.) He then ‘releases’ his young lions into a big camp (referred to in the new Regulations by the grand title of ‘an extensive wildlife system’) keeps them there for two years as required, and then he can get a permit to hunt them.
He can continue to feed and habituate them during the two years subject to the vague and utterly unenforceable requirement that it should be ‘minimal’ (whatever that means)
The two year period has obviously been chosen to suit the hunting industry, since it takes at least three years for a lion(ess) to reach huntable size.
Notice that the term ‘extensive wildlife system’ has deliberately been poorly and vaguely defined to assist the hunting industry.
These regulations can be seen by anyone with experience in legal drafting to have been carefully framed so that they can be circumvented.

10. They seek to draw a line between ethical trophy hunting and ‘environmental thugs’ whereas no relevant difference exists.
There is only a difference between ‘ethical’ hunting and ‘environmental thugs’ in hunting circles (this includes conservationists in SA). No one else cares about stupid hunting rituals. No one in DEAT or other conservation structures seems to understand that the concern of the public is firstly for the welfare of the animal. Unless government learns to look at conservation from the same perspective, it will always be engaged in bitter, protracted battles in which the government is always the loser. Win or lose, every issue fought tarnishes the image of conservation, and the integrity of officials. Tahrs, Enkosini, Rita Miljo, trophy hunting, problem animal slaughter, culling, SASealalert - the list of grievances grows daily. Eventually this conservation regime will be so prostituted that it will be overlooked and unrespected by the public, and South Africa will become a targeted rogue state for the powerful animal rights and welfare organisations in the developed world. No one in government seems to understand the dangers to SA tourism and trade of continually offending hundreds of millions of people overseas.
Animal welfare must be placed at the top of the agenda on every issue, because the public who pays your salaries requires it. Regardless of how skilfully or otherwise the animal is stalked, the result is always the same - agony and death for the animal. And for no good reason. We will not allow the government to use fair chase as a diversion from the institutionalised cruelty which is called Conservation in SA. The lion breeders deserve no sympathy, but they are no more cruel to the animal than any other trophy hunters, and are being used as scapegoats. Ethical hunting is an oxymoron, a contradiction in terms. How does one sadistically inflict pain and death on unoffending animals for pleasure in an ‘ethical’ manner?

11. They will deliver our remaining wildlife heritage into the hands of the very people who have damaged it - the hunters.
By treating hunting farms as if they were part of the nations nature reserves, government errs badly. Hunting farms are not complete eco-systems. Going down to the ‘Game’ sales (demeaning term!) to buy fifty animals, and then putting them into a 200 hectare camp and shooting them out over the next six months is not conservation. It is using wildlife as alternative livestock. When the animals are originally removed from their natural wilderness environments, they are lost to conservation. They now become livestock in a farming business. This is the domestication of our wildlife. Taking the children to see the lions at the lion farm or the giraffes at the giraffe farm has nothing to do with conserving our natural resources holistically. Wilderness and wildlife are no longer wild. The hunters have chopped up the real wilderness into little fenced camps to commit sadistic acts of cruelty upon semi-domesticated animals. It is the destruction of our wildlife heritage, and the numbers of these prisoner-of-war animals is irrelevant. The wild species is being destroyed regardless of the numbers of prisoners.
Instead of rectifying this national catastrophe, the new policies seek to make hunting self-regulated. What a joke! Instead of throwing the hunters off the land, taking out the fences, appropriating the land for public nature reserves and joining all the little inadequate fragments of parks to form extensive national parks, here is government saying to the destroyers: “Go ahead, regulate the destruction yourselves.” What a dereliction of duty.

12 thru 15.

South Africa has always been a paradise for hunters. The flip side of this dubious claim is that for the wildlife, SA is Hell on earth. Captive breeding is the inevitable consequence of over-hunting. After wiping out the trophy animals in the wild, the industry has to turn to captive breeding to keep a constant supply of targets. It has nothing to do with conservation.
So let us sum up: TROPHY HUNTING (CANNED HUNTING) IS THE ASSET STRIPPING OF OUR ENVIRONMENT.
‘Hunting is conservation!’ they claim righteously.
This is absurd. It is like saying that only whaling can save the whales.

Canned lion breeders are wealthy landowners. Millions of honest South Africans have to survive without the privilege of land ownership, and it ill suits wealthy landowners to complain that they cannot find any use for their land which is both harmless and constructive.
The culture of hunting contaminates our whole conservation regime. No one questions the legitimacy of the vicious treatment of animals. That is why hunters are a protected species in SA. Many so-called Nature Conservation officials are actually themselves professional hunters. They have financial, family, social and cultural links with the hunting industry. They justify their support for hunting in financial terms. Officials boast proudly that hunting generates 150 million rands annually in Limpopo province alone. Think about the obscenity of this boast for a moment. Here are civil servants whose statutory duty is to “preserve fauna and flora” and yet they are proud to tell us how many animals are being killed every year.
The evils of sport hunting are apparent to most decent people. Yet hunters have formidable accomplices in the United Nations Environment Program and pro-hunting groups within the IUCN. It was these groups who conceived the Dogma of Sustainable Use. What this establishes is that natural resources may legitimately be used, provided the use is ‘wise’ in the narrow sense of not being excessive. This doctrine makes sense when it is restricted to inanimate resources such as tin or copper. But including sentient beings within the scope of mere ‘resources’, which may be harvested, was far from wise, and probably closer to collective insanity. How could any sane person possibly lump gorillas, elephants and lions in with bacteria and then treat them as mere organisms?
****************************
END
Chris Mercer
Campaign Against Canned Hunting, Inc. May, 2006