South Africa’s new environmental policy – a positive shift or a licence to kill?
Michael Chèze

Our much-heralded new White Paper on Biodiversity establishes a much higher duty of care towards wild animals, but another strategy document makes a mockery of the minister’s promise of ‘a prosperous nation living in harmony with nature’.

The right to life is enshrined in our Constitution. Yet this right is precarious – every living moment is completely dependent on our environment. The truth is that we cannot exist independently of nature. 

In the face of our catastrophically denuded natural world, the Department of Forestry, Fisheries and the Environment, which is responsible for the protection of this precious resource, has released a White Paper on Conservation and Sustainable Use of Biodiversity for public comment. Its stated intention is to provide a single, overarching legal and policy framework to guide future strategy and implementation of conservation efforts. 

However, at the same time, and with a much shorter window for public comment, the department has issued a separate strategy document (the Game Meat Strategy) which advocates for the industrial-scale breeding, farming and slaughter of wild animals. As an implementation plan, the Game Meat Strategy is required to adhere to the principles laid out in the White Paper, but the two are irreconcilable.

Although it is complex and sometimes conflicted, in many ways, the White Paper is a progressive document. It establishes a much higher duty of care towards wild animals as part of the ecosystem, recognising both their “sentience” and their ability to “suffer and feel pain”. It recognises, too, that nature has a right to exist independent of its economic value to us humans. The department describes the White Paper as “South Africa’s New Deal on the conservation and sustainable use of biodiversity, aimed at achieving a South Africa where people live in harmony with nature, resulting in thriving people and nature”.

Despite being a policy document for the conservation of biodiversity, the White Paper puts “people first” as a guiding principle. However, recognising the damage done through the exploitative colonial model of conservation, the department includes the concept of Ubuntu as another fundamental guiding principle. Ubuntu provides for “harmonious relations, based on nature for nature’s sake”, is an “African social compact for just relations between humanity and the whole of creation”, and is a “unifying vision of community built upon compassionate, respectful, interdependent relationships”. The “very essence of Ubuntu hinges on consolidating the human, natural and spiritual tripartite”. In other words, the well-being of our people is dependent on our spiritual and natural health. Ubuntu makes it clear that to put people first means simultaneous healing of our relationship with spirit and nature.

The Animal Improvement Act 62 of 1998 was originally intended for agricultural livestock, yet under the amendment, wild animals including lions, cheetahs and rhinos can be genetically modified. (Photo: Gallo Images / Volksblad / Mlungisi Louw)

Wild animals, as an intrinsic part of natural landscapes, are significant to “living in harmony with nature”. For this reason, the paper defines the well-being of animals as “the holistic circumstances and conditions of an animal which are conducive to its physical, physiological and mental health and quality of life, including its ability to cope with its environment”.

The paper goes on to recognise that the concept of “biodiversity” implies intact ecosystems which exist in all their natural complexity and balance. The paper defines this biodiversity as “the variability among living organisms from all sources, including terrestrial, marine, and other aquatic ecosystems” and “the ecological complexes of which they are part; including diversity at genetic, species and ecosystem levels”. The implication of this definition is that any sustainable use of our biodiversity must maintain the ecological integrity of the whole system and not just its individual parts.

This definition of biodiversity is in line with Section 24 of our Constitution which states that we all have a right to have our environment protected, not ecologically degraded or polluted, and that any use of our natural resources and development must be “ecologically sustainable” while promoting justifiable economic and social development.

The White Paper incorporates ecological sustainability into its definition of Sustainable Use, which has four pillars. Any component of biodiversity may only be used in a manner that:

  1. Does not contribute to its long-term decline in the wild; or disrupt the genetic integrity of the population;
  2. Does not disrupt the ecological integrity of the ecosystem in which it occurs;
  3. Ensures continued benefits to people that are fair, equitable and meet the needs and aspirations of present and future generations; and
  4. In the case of animals, is humane and does not compromise their well-being.

Given all the progressive elements in the draft White Paper, it is indeed disconcerting, and even shocking, to discover that another paper issued for public comment by the department, the Game Meat Strategy, paves the way for a very different future landscape, for both wildlife and humans.

Unlike the White Paper, the Game Meat Strategy treats wildlife merely as a resource to be ruthlessly, systematically and efficiently exploited. 

In discussing various business models for the expansion of the game meat industry (presented as the solution to South Africa’s economic woes and food shortages), the department’s strategy is strongly considering a “Large Scale Game Production and Harvesting Commercial Focus Business Model”. This model advocates the practices used in commercial livestock production, to “increase scale in order to be competitive”. It presents a slippery slide from game ranching to the intensive breeding and agricultural farming of wildlife.

Unlike economically successful regenerative farming models which are leading global conservation strategies today, the Game Meat Strategy is a ramping-up of the old paradigm industrial model of agriculture, which has all but laid waste to our planet. Regenerative farming restores the health of the whole, while old-style industrial farming profits through taking species out of their natural environments and overexploiting them, thereby causing damage to the integrity of the animal and the environment. Industrial farming with its crowding of animals in environmentally degraded circumstances, use of antibiotics and growth hormones, toxic waste and the massive carbon footprint of animal feed production, has been identified internationally as one of the most serious causes of habitat degradation and climate catastrophe as well as being a practice associated with great cruelty. 

Not only is this model morally questionable, it also poses a multitude of risks. Following concerns raised in 2009 within the scientific community about the growth of selective breeding and intensive management of game within the South African wildlife industry and its effect on biodiversity, the environmental affairs minister commissioned a report, released in 2018, which emphasised many risks, including the loss of genetic integrity, zoonotic disease and further environmental degradation. In defiance of these findings, the department’s Game Meat Strategy is based on the very practices that have been cautioned against by its own experts. 

Equally disturbing, in 2019, the Department of Agriculture, Forestry and Fisheries amended the Animal Improvement Act 62 of 1998 to reclassify 33 wild animals as subject to its regulation. This act was originally intended for agricultural livestock, yet under the amendment, wild animals including lions, cheetahs and rhinos can be genetically modified. 

‘Genetic pollution’ and reputational damage

Driven by a financial imperative, the agricultural industry breeds for characteristics demanded by market forces rather than necessitated by nature. Bigger rumps, softer hides, enlarged livers, and increasingly tender muscle meat soon result in animals that differ markedly from their wild counterparts, losing their ability to survive in the wild and risking what has been termed “genetic pollution”. 

Unlike the White Paper, the Game Meat Strategy treats wildlife merely as a resource to be ruthlessly, systematically and efficiently exploited. (Photo: Gallo Images /Alet Pretorius)

South Africa recently suffered moral and reputational damage caused by the intensive breeding of lions in captivity for the canned hunting and bone trade industry. In the light of the “progressive” White Paper on Biodiversity, with its recognition of animal sentience, as well as its clarity on healthy biodiversity requiring intact ecosystems, the Game Meat Strategy demands particular scrutiny. The concept of Ubuntu – representing harmonious, respectful and compassionate relationships between ourselves and nature – is incompatible with the goals of the Game Meat Strategy. 

The window for public comment on this critically important Game Meat Strategy is about to close. The government has rolled out a fast and furious public participation campaign ending on 26 August 2022. The fact that the Game Meat Strategy has been issued for public comment before the White Paper has been finalised, indicates that it is being strategically pushed through to avoid being encumbered by the White Paper’s progressive principles, and effectively makes a mockery of the minister’s promise of “a prosperous nation living in harmony with nature.” See the venues where the White Paper and the Game Meat Strategy are being presented simultaneously and make your opinions heard. DM/OBP

Michael Chèze is a former investment banker and a South African filmmaker. He is currently authoring a book promoting a more equitable international monetary system.

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