Is the environment minister captured by vested interests?
Don Pinnock
29th April 2020

Everything a costly high-level panel appointed by the Department of Environmental Affairs is tasked to find out about wildlife is already known… so what’s going on?

Millions of rand are being spent by the Minister of Environment, Barbara Creecy, on a high-level panel to advise her on issues regarding lions, elephants, rhinos and leopards. But the scientific advice she’s requesting already exists.

Creecy is an intelligent, competent minister able to do her homework. So why is she ignoring this and wasting taxpayers’ money on an apparently superfluous exercise? Is the panel simply to inform her in her new position, or was it created to get the answers wanted by those pushing for the commercialisation of wildlife? If so, who are they?

It seems necessary to ask whether the minister is being held to ransom by the wildlife industry or by members of her department? If they’re members of her department, then her staff needs an urgent shakeup. If the initiative is hers, then we have a bias problem. Here’s why.

Terms of reference for the panel were belatedly released on 22 April, months after its formation and then only to those NGOs requesting extension of time to make submissions. They’re so restrictively worded that they predetermine an outcome being pushed by only the wildlife trade and hunting fraternity.

The criteria for panel members required that they have “experience in sustainable utilisation” – essentially in the “use” and not conservation or welfare of wild animals. This calls into question any semblance of impartiality and clearly indicates the direction the panel is expected to follow.

In her selection of the Committee of Inquiry into a Possible Trade in Rhino Horn in 2015, even the previous environmental minister, Edna Molewa, (an avowed proponent of sustainable use) and Creecy’s predecessor, never created such a blatantly biased panel.

There’s an admirable number of traditional leaders on the panel, but not a single mention of community issues in the terms of reference.

What are they there for? Simply to give legitimacy to the decisions of a panel focused on the narrow interests of a group of affluent breeders, traders and hunters?

It’s necessary to inquire if Creecy is knowingly party to developments that would rip SA’s already tattered conservation reputation even further through her department’s continued support of canned lion breeding and its attempts to reopen ivory trade and restart the elephant culling debate. Because this is precisely the door opened by the new terms of reference and composition of the panel.

Culling of elephants risks massive international opprobrium – witness the stormraised by Botswana’s opening of elephant hunting and the suggestion that culled elephants could be used for pet food. Are her advisers not aware of this?

So what do the panel’s terms of reference say?


The terms expect the panel of experts to assess and provide policy positions on elephants, yet of 25 members it has only two elephant experts – Rob Slotow and Karen Trendler. Requirements include debate and direction on:

  • Keeping of elephants in captivity.
  • Hunting of elephants: “Should hunting of elephants be permissible and what are the legal requirements and conditions for such?”
  • Population management, including culling, contraceptives and inter-country translocations.
  • Trade in elephant ivory, including “mechanisms of the trade, determination of the quota”.
  • Ivory stockpiling: “What is the value for keeping ivory stockpiles to conservation?”
  • How the variety of management practices like captive keeping, and trading in elephant ivory contribute value to conservation.

But wait! We’ve been through all this before. In 2007, at the invitation of the then minister of environmental affairs, it took around 70 experts to produce a 620-page book covering all these aspects, which led to the norms and standards. Has the current minister read this? She certainly should before starting the process all over again.

It gets worse. For an indecently long time, the minister has had on her desk for signature The National Norms and Standards for the Management of Elephants in South Africa, which are the result of three years’ work by not only DEFF but also all interested parties. These norms and standards are excellent and answer most of the questions posed in the panel’s new terms of reference.

So why doesn’t she just sign that document? Is she seeking to circumvent yet another scientific process? Why?

In addition, DEFF is currently in the process of preparing a National Elephant Plan with input from stakeholders and following due process which should answer any questions not covered in the norms and standards.

The 2007 revised norms and standards specifically exclude the capture of elephants from the wild to prevent new elephants being added to the existing captive population. CITES regulations also preclude trade in live elephants.

This subject was exhaustively examined at a conference in 2019 held in Hermanus which included elephant experts from around the world. DEFF was invited but declined to attend. Most of the answers to the questions now being asked anew by DEFF can be found from the outcomes of that conference. But clearly the department did not like them and now seeks to justify its own actions with the support of a small group with vested interests.

The same year, a series of workshops on elephant policy was held in Hluhluwe-iMfolozi National Park as well as a Conservation Symposium in St Ives, KwaZulu-Natal.  The symposium and workshops set out an extensive elephant policy programme answering most of what the panel is now tasked to re-explore.

The panel will serve only to reopen a debate on the hunting of elephants in the face of international disgust at this practice. Most of this hunting takes place in the Associated Private Nature Reserves (APNR) alongside Kruger Park which has its own protocols. There, national assets are permitted to move from Kruger Park to be shot in order to fund the leisure lifestyles of a group of mainly white landowners with scant benefit to bordering communities. Would a panel of mainly game breeders and hunters ever question this?

Culling is another issue to be reopened by the panel. Between 1967 and 1997, 14,629 elephants were culled in South Africa, mainly in Kruger, to maintain the population at an arbitrary level of 7,000. This had no foundation in science. Culling was stopped and a successful policy of closing down water holes was adopted to control elephant numbers.

In 2014 the park’s large-animal ecologist, Dr Sam Ferreira, said there would be no further culling in the park. He said managing the effects of elephants was not about controlling populations but letting natural processes influence where elephants spend time and what they do when they are in particular places. Kruger’s Elephant Management Plan confirmed that.

So why are we now opening up deliberations about culling? Has the minister not read that report? Instead, she’s paying 25 people an estimated R5- to 6-million to duplicate existing work already done by more qualified people. This at a time when the South African economy is on its knees and the costs of Covid-19 are astronomical. And when the answers she’s apparently seeking are already on the table.


Rhinos are under massive threat from poaching and their protection, particularly in Kruger Park, is costing millions of rand and the lives of rangers. The only way to stop the poaching is to reduce demand in China and Vietnam. Adding the possibility of legal rhino horn simply fans the trade and acts as a cover for illegal horn.

However, the panel is not tasked with this problem, but instead, among other things, to “identify new or additional interventions required to create an enabling environment to create an effective rhino horn trade”.

DEFF has already legalised domestic trade in rhino horn, despite an international ban on this trade by CITES. The panel’s task is not to bring South Africa into line with the UN body, but instead to “review and provide advice on the submission of the Rhino related trade proposals to the next coming CITES COP”.

In other words, to try, yet again, to get international horn trade legalised.

Significantly, there are no rhino experts on the panel unless one considers hunters and breeders to be experts.


In 2018, following a two-day colloquium into the captive lion breeding industry, the Parliamentary Committee on Environmental Affairs recommended that the industry be closed down. This was confirmed by a resolution of the National Assembly. It found that the conservation value of predator breeding was zero and was undermining the country’s tourism brand value.

It noted that, although captive lion breeding for hunting is currently lawful, this did not make it ethically, morally or socially acceptable – especially the manner in which hunted animals are raised and released for hunting.

It also considered SA’s export of lion bones and expressed concern over the health and safety posed by zoonosis – the transmission of disease from wild animals to humans (as with Covid-19).

The task of the high-level panel, however, is not to consolidate the parliamentary instruction on lion breeding or canned hunting, but to “get more insight into the management of lions and trade in lion bone in South Africa”.

It will open the debate afresh as though it has not already been extensively dealt with by Parliament. It is tasked to explore “the genesis of captive breeding of lions in South Africa, methods, size of breeding facilities, euthanasia of lions in captivity, handling of lions in breeding facilities, legal requirements, tourism, interactions and exploitation of tourists, petting zoos and related activities, as well as associated compliance and enforcement protocols and measure”.

It will also re-explore “the hunting rationale in captive breeding facilities, conditions for hunting of captive-bred lions, size of hunting farms, release periods of lions for hunting and legal requirements for hunting captive-bred lions”.

This does not sound like a recipe for closing down captive-bred lion facilities and canned hunting, as per Parliament’s instruction.

Is the minister aware of the 2015 Biodiversity Management Plan for Lions published jointly by CSIR and gazetted into law, specifically to address issues of lion management?

Once again, there are neither lion nor leopard experts on this panel apart from breeders, hunters or supporters of trade. Nor are there any illegal wildlife trade experts or monitoring groups able to advise on the effect and risks of opening legal trade on illegal trade.

The reopening of all these debates about wildlife in the face of solid, scientific guidelines by a large range of wildlife specialists and scientists and parliamentary instructions suggests the existing guidelines and science have not gone in the direction of a lobby group who appear to have considerable influence over DEFF.

Is the department “captured”? Who stands to gain from the commercialisation of wildlife? Why are we wasting money on a panel with terms of reference and composition that virtually guarantees an outcome in favour of a wealthy, privileged group of breeders and hunters?

letter to DEFF from the Wildlife Animal Protection Forum of South Africa signed by 22 environmentalists and scientists lists the above concerns and concludes that the panel runs the risk of being institutionally biased.

“A candidate with vested interests in the continuation of captive predator breeding or captive-origin lion hunting,” they write, “appears unlikely to uphold the parliamentary resolution to put an end to these practices.

“Similarly, those with a vested interest in trading in rhino horn or ivory or trophy hunting may unduly influence the deliberations of the panel to secure an outcome on which their direct and/or future revenue depends.

“Given the urgent nature of the matters to be reviewed, the qualifications, skills, commitment to the Constitution and freedom from institutional bias among this panel should be beyond reproach. This may not have been achieved.”

The apparent duplication of effort and expense is so extreme it should warrant investigation by the auditor-general as possible wasteful and fruitless expenditure and, in the public interest, by the public protector. 

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