Government trying to slam through plan that will result in massive exploitation of wildlife
Don Pinnock - Daily Maverick

By Friday, 22 March, the public is expected to have commented on a detailed plan by the Department of Forestry, Fisheries and the Environment to massively exploit and monetise South Africa’s wildlife. The public was given just 14 days to respond.


The Department of Forestry, Fisheries and the Environment (DFFE) has released a 48-page plan to create integrated “mega landscapes” on land and sea encompassing extensive areas where hunting, bioprospecting and tourism would monetise wild animals and plants for “consumptive use”.

To do this, the government will attempt to mobilise state and private resources, starting with an indaba in Gauteng from 24 to 26 March. The Birchwood Hotel and OR Tambo Conference Centre have been hired for the event at a cost of R3,698,859.

The plan was released on 8 March and gives the public until 22 March to comment, a 14-day deadline that many see as a box-ticking exercise to claim that the public has been consulted before the plan goes on show at the indaba.

wildlife exploitation government plan

Schematic for a government plant for the creation of mega-landscapes. (Image: Supplied)


The proposal is to grow areas under conservation — called mega living conservation landscapes — from 20 million hectares to 34 million hectares by 2040, an area equal to seven Kruger National Parks. Five mega landscapes are suggested, with proposals including:

  • iSimangaliso/Ezemvelo/uMkhanyakude in KwaZulu/Natal;
  • Waterberg/Limpopo River/Makapan Valley in Limpopo;
  • Lekgalameetse/Wolkberg/Thabina in the Tzaneen area;
  • Addo/Camdeboo Corridor and Grasslands National Park in the Eastern Cape;
  • North West; and
  • Northern Cape.

What happens within the new areas, however, would be nothing like Kruger’s wilderness but would involve “biodiversity business”.

“Consumptive use” of wild animals within these landscapes is predicted by the plan to increase from R4.6-billion to R27.6-billion by 2036, bioprospecting and plant trade from R1.85-billion to R11.6-billion and marine and freshwater exploitation to rise by 10% a year. This represents a massive monetisation of South Africa’s wild ecosystems.

wildlife exploitation government plan

Areas for displays at the upcoming indaba on mega-landscapes. (Image: Supplied)

Included in the figure of R4,6 billion is R1,8 billion from 6,242 international clients who killed 36,500 animals in 2022 Since the local hunting market is unlikely to grow, the planned increase would need to come from international hunters. This will require an increase of 155% more international hunters to 15,900 hunters killing 93,000 animals. Where these animals will come from is not explained.

The strategy envisages an increase in the number of Big Five animals available for fair-chase trophy hunting, an expansion of recreational and traditional hunting, wild meat harvesting and fishing, and the increased use of indigenous plants, and of insects for food.

The plan says that until the international sale of ivory and rhino horn is favourable (though it’s unclear why the department thinks this will ever happen), domestic trade could be stimulated.

“For example, health clinics to administer traditional remedies using rhino horn for health tourists from the Far East or ivory carving done locally for sale and export for personal use.”

What is being suggested appears to be linked to the Game Meat Strategy published in 2022 which seeks to agriculturalise wild animals.

A document supporting the plan that was supplied following a request to the DFFE this week says game meat has not been efficiently utilised for livelihood and economic growth, and has been identified as an alternative, cheap and readily available source of protein, especially for rural communities.

“The implementation of the strategy will ensure safe and sustainable harvesting of game meat, job creation and rural economic development… There will be new business, investments, jobs and value chain opportunities that will have secondary benefits related to the commercialisation of this commodity. These benefits far outweigh the costs.”

Government trying to slam through plan that will result in massive exploitation of wildlife

A herd of elephants at the Numbi Gate of the Kruger National Park in Mbombela, Mpumalanga. (Photo: Gallo Images / Daily Maverick / Felix Dlangamandla)


Alarm bells

The plan puts forward a form of extractive conservation, based on the idea that what you consume you will conserve. This type of thinking is essentially a farming ethic, ranging from sacrificial animals being hunted to provide funds for the conservation of a species or biome, to cattle feedlots and chicken and pig batteries.

It makes sense in relation to a puzzling proposal in 2019 when there were attempts to list more than 30 species of wild animals, including lions, giraffes, white and black rhinos, lions and cheetahs, under the Animal Improvement Act. This would have effectively rendered them farm animals subject to manipulation and consumption. It was overturned following a court challenge by the Endangered Wildlife Trust.

Shortly afterwards, 98 more species were proposed to be listed under the Meat Safety Act, including rhinos, hippos, elephants and crocodiles. According to the Act, they could then be “slaughtered for food for human and animal consumption”. At the time, the reasons for these reclassifications by the Department of Agriculture, Land Reform and Rural Development were unclear, but they are now obvious.

The plan has rung alarm bells at environmental NGOs.

According to Dr Ross Harvey, the director of research at Good Governance Africa, a plan to commodify wildlife “ignores the biological reality that trophy hunting removes prime males (never ‘surplus’ males, which is a convenient myth). It also ignores robust research which shows that the opportunity costs of trophy hunting in SA render the practice unsustainable.

“All this comes on top of providing no proper time for public participation. This makes the whole thing look like a foregone conclusion that the government wants the public to rubber-stamp without really engaging.”

Taylor Tench, a policy analyst at the US Environmental Investigation Agency, said the idea of developing a market for domestic trade in animal parts such as carved ivory or rhino horn as traditional medicine for Asian tourists was particularly shocking. It would stimulate the export of objects and substances illegal under Cites regulations and which are merely aspirational and have no discernible medical value.

“If such markets and products were to take hold in South Africa,” he writes, “it would result in severe negative impacts for rhinos, elephants and potentially other species. The proposed creation of domestic markets for rhino horn and ivory targeted at international tourists contradicts — and would undermine — South Africa’s reputation as a destination for sustainable wildlife tourism.”

The environmental lawyers Cullinan & Associates, acting for the EMS Foundation, have served notice on the DFFE for a 45-day extension to submit comments on the plan, failing which it will take legal steps.

“A comment period of at least 30 days, but more often 60 days, is accepted as being the minimum to allow meaningful and effective public participation,” the notice says. “No reasons are given for deviating from accepted practice.”

The timeframe has also been questioned by Wildlife Ranching South Africa.

Trophy hunters

The plan appears to favour the conservation of wildlife and massively extends areas under a form of protection, which is a definite plus. But by embracing consumptive use it seems to cut across the considerable advances made by Environment Minister Barbara Creecy and her department regarding the welfare of wild animals, her stand against captive-bred lions, the progressive findings of the high-level panel on lions, elephants, rhinos and leopards, and the White Paper on Conservation and Sustainable Use of Biodiversity.

It would also make South Africa one of the world’s top destinations for trophy hunters at a time when that practice is coming under increasing disapproval internationally. This could have a negative impact on brand South Africa and international tourism.

There is also a problem with expecting hunting revenue to increase within the new mega landscapes when it is declining as a sport.

An article in Africa Geographic quoted research showing that between 1991 and 2016 the number of hunters in the US fell by 18.5%, from 14.1 million to 11.5 million. In France, it dropped by half in 40 years.

South Africa saw a 60.5% drop in eight years, from 16,594 in 2008 to 6,539 in 2016. The number of trophies exported fell from 5,049 in 2014 to 1,993 in 2018. Lion trophies during this time dropped from 1,160 to 259.

According to the EMS Foundation, “South Africa will be attempting to turn the country into a trophy hunting destination … for a privileged few trophy hunters.”

The plan also raises questions about the future of captive-bred lion farming, which Creecy has vowed to close down and has appointed a team to plan this. There are an estimated 10,000 to 12,000 lions on these farms. Will they be euthanised or offered to hunters within the new mega landscapes?

The proposal may be a reaction to huge pressure from the hunting fraternity, or incongruity between her department and the Department of Agriculture, which has been accused of dragging its heels on a draft Animal Welfare Act. There have been suggestions that it’s the wrong department to be doing this, particularly with regard to wild animals.


Much is made in the plan about ecosystem connectivity, the halting of species extinction and leveraging natural systems to alleviate rural poverty among formerly disadvantaged people. This would be funded, it says, through tourism, hunting, bioprospecting and funds from the government plus local and foreign grants.

It would also leverage public/private partnerships linked to communities for the rehabilitation of degraded land. The plan also envisages a Biodiversity Trust Fund for community conservation and development of resource use.

To do this, it says, would require the removal of barriers to entry into game ranching for emerging black entrepreneurs and an expansion of benefits to previously disadvantaged individuals and rural communities.

Unfortunately, the redistribution and protection of reclaimed areas and redistributed land has not fared well in South Africa and often devolves into squabbles between claimants and rural groups. It tends to be insufficiently policed and is often plundered.

A big problem with hunting — as many countries in Africa that allow it have found — is that it permits poaching to be laundered within the legal framework. As for bioprospecting, South Africa doesn’t have a police force knowledgeable or large enough to prevent it from leading to rare plant poaching. There has also been poor performance in the curbing of marine poaching.

The possibility of the present administration keeping control and preventing plunder of an extended natural habitat the size of seven Kruger Parks seems unlikely. The massive commercialization of natural resources implied in the plan is unprecedented and its underlying assumption is disturbing. Nature is far more than simply a store of natural resources.DM


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