ESAG Letter re Elephant introduction to Lamloch Game Farm
Dr Michelle Henley, Dr Marion Garaï, Dr Lucy Bates
28th March, 2019

To Whom it May Concern,
Re: elephant introduction to Lamloch Game Farm

We are writing to express our concerns over the proposal to move eight African elephants to the Lamloch Game Farm. We would like to state at the outset that we do not represent any ‘animal rights’ or welfare organisations. Instead, we are each scientists with decades’ experience of studying elephant behaviour and ecology. We hope you will seriously consider and reflect upon our concerns set out below, which are based upon our combined expert knowledge of elephants.

1: Elephants will not be ‘free-ranging’, as claimed in the Basic Assessment Report

The Basic Assessment Report for the Lamloch Game Farm states eight “previously captive elephants…[will be]…given the opportunity to be free ranging within the proposed camps”. Let’s be clear, these elephants can certainly not be considered ‘free-ranging’: They will “be taken into the … ranch under the care of the handlers”, and will only have the opportunity to “move across the whole property” “during certain structured programmes”, being “taken back to the holding camps at the end of each day” (p.33). The report goes on to state that “the availability of suitable natural habitat for elephants is irrelevant in this case” because they will be guided by handlers, and “the size of the game ranch in terms of typical elephant requirements is also irrelevant because the elephants will be supervised in terms of their feeding impact”.

‘Structured programmes’, limited ranging guided by handlers, and supervision of foraging do not equate to free-ranging! This system of constant supervision does not allow the elephants any autonomy in their daily actions or choices, which is considered to be a key element of well-being and good welfare for captive animals. Put bluntly, this constant supervision and guidance is not consistent with good welfare practices.

2: Captivity and interactions with tourists involve cruelty for elephants

Elephants are known to adapt poorly to captivity, having shorter life-spans and a poor reproductive output compared to wild populations (Clubb & Mason 2002; Clubb et al. 2009). We understand that there will be no direct interaction between tourists and the elephants in this proposed development, unlike at Mr Saunders’ other properties. However, even guided-walks involve handling of elephants, which necessitates training and the carrying of an ankus by the handlers. We argue that such training naturally involves cruelty.

Positive reinforcement training with elephants is possible, and we note that Mr Saunders does use positive reinforcement in his training and handling. But sole use of positive-reinforcement methods naturally precludes free contact (i.e. contact between elephants and people without any barrier in between): Institutions that only use positive reinforcement training, only allow protected-contact (i.e. with a fence between elephant and person at all times) because elephants remain – despite all claims to the contrary* – wild animals. Whilst positive reinforcement training is to be encouraged and we are pleased Mr Saunders partly adopts this method, given the free- contact with his elephants and the fact that his elephant-handler employees carry an ankus, negative-reinforcement training must also be part of his training and handling repertoire. Much has already been written about the cruelty of negative reinforcement in training of captive elephants, and we urge you to review such information.

3: The introduction of the eight elephants could involve breaking established social bonds

In compliance with the Norms and Standards for the Management of Elephants (N&S), only elephants already in captivity within the Republic may be moved to new captive facilities. We have not been able to verify which existing elephant facilities the proposed eight elephants will be sourced from, but Mr Saunders has been quoted as saying they will come from Mpumulanga, North West and Western Cape provinces. As Mr Saunders already owns elephant facilities in these locations, we assume they will be taken from his own existing elephant groups.

Whether this is the case or not, it is likely that from whichever facility the elephants are moved, the relocation will involve separating elephants who know each other and who may have strong social bonds. Severing such bonds in elephants is ill-advised, cruel, potentially dangerous, and not permitted according to the N&S. Even if the elephants earmarked for relocation do not ‘get along’ with their current social partners, as can often be the case in captive elephant populations, there is no guarantee they will form bonds with the new elephants they will be placed with, so they will undergo the stress of a move for no tangible social benefit to themselves.

4: Suitability of the habitat

The premise of the game farm proposal is to allow visitors to experience observing elephants “in the wild”, in their natural habitat. However, as quoted above, the Basic Assessment Report states that the “availability of natural habitat is irrelevant for this game farm”, as the elephant movement and foraging will be guided and supervised, and concentrated in areas of transformed pasture and areas with invasive alien plants. Despite the claims made in Appendix G2: Game Management Plan (p.9), which state that “elephant…would have been attracted to the wetland system for the grazing that it contained”, we argue that this site and the habitat it entails is entirely unsuitable for captive elephants, and it is not clear that wild elephants ever inhabited this area.

The site is very exposed, with scant large tree cover and therefore little natural shade. For elephants being moved from Mpumulanga and North Western province, the harsh winter weather and windy conditions experienced in the Kleinmond area is another factor making the habitat unsuitable, and previous experience from other animal translocations has shown that such moves from hot, arid veld conditions to colder coastal areas in cape provinces can even result in premature death of the animal [cite thesis].

5: Questionable educational value

Seeing elephants in a habitat type in which they historically probably never took up permanent residence (Skead 1987), in a 20 ha camp or under the constant guidance of handlers has little or no educational value. Under these circumstance the public are far from viewing the complex social structures of the elephants or their role as ecosystem engineers. Instead, any tourist will get to see a couple of bore elephants with a broken down social structure, which may manifest as dangerous behaviour or aggression towards their handlers and the viewers.

In an age of growing recognition that animals are not here simply for our pleasure, for us to manipulate at will, we applaud the good record of wildlife management across the Western Cape, particularly the policy which prohibits unnecessary interactions between humans and wild animals for commercial gain. In light of that policy, and the information presented here, we urge you to reject any applications for facilities to house captive elephants, and instead be the leaders that other South African provinces can follow to encourage a phase-out of captive elephant facilities across the Nation.

Mr Saunders was quoted in The Village News (13th March 2019) as saying:
“Over the past 10 years I have made my intentions known to my staff and to the NSPCA that I would, when possible, be relocating all of my elephants, on a phased basis, to larger areas where there would be a lot more space available for them to roam and be at home in a more natural environment.”

If he is serious about the welfare of his elephants, and genuinely wants them to roam and be at home in natural environment, this facility in Kleinmond – where their ‘roaming’ will be accompanied and guided, and the environment is not natural for them – is not the answer. The only course of action he should really consider is moving his elephants to a genuine free-ranging wildlife system, where they can successfully be rehabilitated as a ‘wild’ herd.

Thank you for your consideration in this matter.

Yours faithfully,

Dr Michelle Henley,
Co-Founder and Director, Elephants Alive Management Board Member, ESAG

Dr Marion Garaï
Founder and Chairperson, ESAG

Dr Lucy Bates
Management Board Member, ESAG

Clubb R. Mason G. 2002. A review of the welfare of Zoo Elephants in Europe RSPCA Report; University of Oxford.

Clubb R., Rowcliffe M., Lee P., Mar K.U., Moss C. & Mason G. 2009. Compromised Survivorship in Zoo Elephants. Science 322: 1649. Skead, CJ. 1987. Historical mammal incidence in the Cape Province. Vol 2. Dept. Nature and Env. Cons., Cape Town