To: Ms. M.E. Nana Magomola, Chairperson, Committee of Inquiry
Cc: Minister Edna Molewa, Department of Environmental Affairs (DEA)
All rhinoceros species are threatened by poaching, loss of natural habitats, and other anthropogenic pressures.
The poaching crisis is a matter of national and international concern, and decisions made in South Africa will have global repercussions on biodiversity, security of countries and countrysides, livelihoods in rural areas and economies at broader scales.
We offer the following for consideration by the Committee of Inquiry.
- We recognize that:
- Rhinos have evolved over many millions of years to play a unique and irreplaceable role within ecosystems.
- Rhinos are the targets of organized wildlife criminals across their range, particularly in South Africa and Namibia and Zimbabwe. These criminal syndicates are heightening local and international insecurity, creating corruption, threatening livelihoods and destroying valuable national and global icons of ecological and social significance.
- The drivers of the current problem are economic growth and demand for rhino and elephant body parts in China and Vietnam. Increased poaching might also be due to increased criminal activity that ‘invests’ in the potential future value of products.
- South Africa is committed to securing the perpetuation of rhino populations.
- Existing efforts to reduce the poaching of rhinos in South Africa are falling short, and record rates of killings have been documented since 2007. Efforts need to be enhanced to match the organized criminal threat with intelligence-led targeting of priority criminals and their networks, enhanced investigations including but not limited to financial investigations and national and international cooperation.
- There is a human cost in terms of lives lost and put at risk daily in the front line against poaching.
- South Africa is considering, as a potential solution to the rhino poaching crisis, a legalised international trade in rhino horn.
- A process of inquiry has been initiated by the South African government, including stakeholder dialogue meetings.
- We are deeply concerned that:
- While there has been a process of dialogue, this process has not fully considered crucial information or taken into account the expertise of international, relevant stakeholders.
- Our analyses, some of which have been presented at a series of meetings in Cape Town (May 2015), have exposed flawed assumptions, lack of evidence, and the absence of a full, open discussion on the potential efficacy of a trade mechanism as a means of reducing poaching.
- A decision to propose trade by South Africa at CoP17 (to be hosted in Cape Town) will almost certainly increase current as well as future rhino poaching risk.
- Any trade – or even a proposal to trade – in southern white rhino horn will have negative consequences for other, less common rhino species, subspecies, and populations, including the black rhino populations still extant in other parts of Africa, and all Asian rhino species. In Africa, the western black rhino was declared extinct in recent years, and the northern white rhino now stands at only 5 individuals. In Asia, the Javan rhino is the most threatened at an estimated 35 individuals remaining.
- Expansion of sustainable use programs including trade should not be an option when a species is declining or under unprecedented poaching pressure.
- To initiate trade in a declining species that is already 1) the target of organized criminal cartels, 2) trophy-hunted, 3) sold as live specimens, and 4) expected to attract wildlife watching tourism, might add yet another further “use” and therefore pressure on a single taxon.
- There are serious regulatory and ethical implications for organizations and governments who actively promote the international trade in a product that has no proven medicinal benefits, but which is sold to people suffering from acute and chronic illnesses.
- Existing international and national legal provisions prohibiting international trade in rhino horn already make it impracticable for South Africa to find a legitimate trading partner. A proposal by South Africa for legalizing trade in rhino horn would undermine the enforcement of trade bans and demand reduction efforts in China and Vietnam. A proposal that fails to receive the support of the Parties, due to unsound justification, could result in reputational damage to South Africa.
- We propose that the Committee consider the following before making its recommendation to the DEA:
- The lack of a full, scientific, and peer-reviewed evaluation of 1) the existing market structures involved in the rhino horn trade; 2) the dynamic supply-and-demand processes by which market prices for rhino horn are formed; and 3) the probability (on which trade proposals are based) that a legal supply could – on anything beyond the very short term – undercut current prices and outcompete criminal syndicates that currently control the entire supply chain.
- The financial and opportunity costs of setting up and managing a legal, regulated trade.
- The potentially flawed assumption that revenue generated from a legal trade in rhino horn would necessarily deliver significant community and species conservation benefits, given the governance challenges associated with ensuring and sustaining its appropriate distribution.
- The almost certain detrimental impact that such a trade would have on efforts to reduce demand and to make the purchase of rhino horn socially unacceptable.
- The risk that trade would detract funding and attention from the underlying issues, which we believe to be criminality and demand. As such, we believe the real solutions are elimination of demand and working to strengthen law enforcement and successful prosecution of poachers, middlemen and end-traders. The organized criminal networks and military groups involved in wildlife product supply chains destabilize governments and have a huge human cost in rural areas and amongst enforcement personnel.
- The high likelihood that de-stigmatization of horn ownership would awaken significant demand currently dampened by social stigma or legality status.
- The increased risk of extinction of the rare and endangered rhino species if poaching escalates including as a result of illegal horn being laundered into a legal trade; taking such a risk on the unsupported, hypothetical benefits of an opened trade runs counter to the precautionary principle.
We ask that our concerns be considered alongside the current set of public submissions, and urge the Committee to deliberate on available options including those other than trade.
Dr. Paula Kahumbu OGW, CEO WildlifeDirect; former head of Kenya’s CITES Office, Kenya
Will Travers, President Born Free Foundation, UK
Francis Garrard, Conservation Action Trust (CAT), South Africa
Ian Michler, Invent Africa, South Africa
Colin Bell, Mkambati Matters and Africa’s Finest, South Africa
Don Pinnock, Southern Write, South Africa
Adam Cruise, Author and Journalist, South Africa
Adam Welz, WildAID, South Africa
Allison Thomson, Outraged South African Citizens Against Rhino Poaching (OSCAP), South Africa
We sign here in personal capacities and not on behalf of our respective institutions.
Professor Alejandro Nadal, Centre for Economic Studies, El Colegio de Mexico, Mexico; Chair, Theme on the Environment, Macroeconomics, Trade and Investment (TEMTI), with the Commission on Environmental, Economic and Social Policies (CEESP), IUCN
Ross Harvey & Romy Chevalier, South African Institute of International Affairs (SAIIA), South Africa
Antoinette Ferreira, National Prosecuting Authority, South Africa
We wish to endorse the concerns raised by the authors of this Statement:
Professor Cristian Bonacic, Pontifical Catholic University of Chile, Chile; IUCN South American Camelid Specialist Group
Cormac Cullinan, EnAct International, South Africa
Dr. Trevor Jones, Southern Tanzania Elephant Project, Tanzania
Beverly and Dereck Joubert, National Geographic, Great Plains Foundation
Alexandra Kennaugh, Natural Resources Defense Council, U.S.A
Dr. Winnie Kiiru, ConservationKenya, Kenya
Professor Phyllis Lee, University of Stirling, UK; Amboseli Trust for Elephants, Kenya
Dr. Peter J. Li, China Policy Specialist, Humane Society International, U.S.A.
Mokgatla J. Molepo, Nelson Mandela Metropolitan University, South Africa
George Monbiot, Journalist and Author, UK
Dr. Fortunata Msoffe, Conservation Ecologist, Tanzania
Professor Benezeth M. Mutayoba, Sokoine University of Agriculture, Morogoro, Tanzania
Fredrick Nzwili, Journalist, Kenya
Dr. Patrick O. Onyango, Maseno University, Kenya
Mary Rice, Executive Director, Environmental Investigation Agency (EIA)
Dr. Aliza le Roux, Zoology & Entomology, University of the Free State, Qwaqwa, South Africa
Professor Claudio Sillero, WildCRU, University of Oxford, UK
Professor Raman Sukumar, Centre for Ecological Sciences, Indian Institute of Science, India
Dr. Kirsten Wimberger, Zoologist, South Africa
Dex Kotze, Global March for Elephants and Rhinos