Subject: objections to Biodiversity Management Plan for the African Lion

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1 Department of Environmental Affairs Attention of: Ms Humbulani Mafumo Private Bag X447 Pretoria 0001 Netherlands, Etten-Leur, 12th of May 2015 Subject: objections to Biodiversity Management Plan for the African Lion Dear Ms Humbulani Mafumo, My name is Simone Eckhardt, director of the Dutch NGO SPOTS. We are focusing on the protection of the wild big cats, one of them being the lion. In this light I have been reading your published Biodiversity Management Plan for the African lion in South Africa. In the letter attached to this plan was stated that objections could be made until 30 days after publication. Here are our objections. First objection: Lack of legislation to ban lion farming Although mentioned in your BMP, there are no plans for the South African government to stop this industry. These captive lions have no conservation value and are considered to be of economic value only. This is also mentioned in the BMP; Captive lions are used exclusively to generate money and currently have limited conservation value (page 9). We at SPOTS think that the breeding of lions is unethical. As well we feel that the public is being consistently misled by the lion breeders to the ultimate fate of these lions. In spite of what many lion breeders state, namely that the captive-bred lions are being set back in the wild, or retired or used principally for research, this is not the case. Surely the very least we can all expect is a proper, accurate, transparent publication of where every ranch lion ends up? Furthermore we consider lion breeding to be a danger for wild lions, considering the growing lion bone trade (see further below, objection 3). CITES has banned tiger farming for trade (Decision 14.69) since conservationists realized that the farming of tigers would promote the illegal trade of wild tigers.

2 We therefore call up on the South African government to stop this commercial breeding of predators. Furthermore, which is also being recognized in your BMP, there is an international move to ban the import of lion trophies. If this will continue, which might be very likely with the public pressure, you will end up with a surplus of captive lions which will be a public relations disaster for SA. The earlier you start with legislation to stop this industry, the better chance you have that you won t be faced with an abundance of bred lions (now already more then 6000) which are useless. Acting pro actively and more so, following CITES as what they did with the tiger breeding, will also lead to a positive image for South African conservation. And have a positive impact on the trade of lion bones. Second objection Lack of regulation for captive lions in BMP In the BMP, 1.4, is mentioned Ensure a well-managed captive lion population. As measurements are mentioned: Develop national standards for the captive keeping and breeding of lions Execute an audit of the lion keeping facilities of all current permit holders and cancel the permits of those that are not complying with their permit requirements Develop a set of material for the education of the public at captive facilities, so that the correct message can be transferred to the public Intended outcome: The captive bred lion industry is established on an ethical and economically sustainable basis Provincial differentiations are superseded by national norms and standards By 2019 all permit holders have to comply to minimum standards or be closed down permanently Again we would like to emphasize that in our eyes lion breeding is never ethical. So this is a futile objective since it is fundamentally unethical to start with. Furthermore, we think that intended regulation of captive lions is inadequately dealt with in your BMP. The intended outcomes are too vague. We request that you implement our comments below: Set up a proper studbook for captive lions, under the supervision of an objective, independent party (so not in the hands of lion breeders). It is the expectation and suspicion that many captive- bred lions are in-bred, leading to diseases and deformities. A publicly available studbook would give more clarity. Although you recommend a studbook in your BMP, it is not stressed as an intended outcome. The public is routinely misled by the lion breeders to where the bred lions end up. If educational material is developed, we urge you to give the correct message. Lion breeders never speak out the truth. So the only correct message to the public

3 can be what you already say in your BMP that captive lions do not have any value for wild lions but are purely bred for commercial reasons. We call upon the South African government to put more emphasis on this in the BMP regarding the educational measurements. Take up in the BMP that you, regarding the captive bred lions, will work together with NGO partners such as Campaign Against Canned Hunting. In order to provide balanced and objective information to the public it is essential to include NGOs who are focusing on lions instead of working only with pro-hunting orgs and governmental structures. Only then will you be able to provide correct information. The word partner should therefore including lion-focused NGOs. You want to introduce the mandatory marking of captive bred lions through micro chipping and/or tattooing. We think you should not go for tattooing alone but only for micro chipping which is easier to trace. We would like this database to be public. This applies as well for the database of permitted lion/keepers/breeders. This database should be public as well and taken up as an outcome of this BMP. We want to call upon the South African government to demand more insightful information from the lion breeders to where their lions are going. Cub petting is a profitable spin-off, and misleading information is routinely given to volunteers and tourists who enquire into the fate of the cubs. This is fraudulent and damaging to the image of South African conservation. You mention in the BMP that correct information has to be given to the public. So this should include factual information on where the bred lions end up. Third objection: We strongly oppose to what is stated in the BMP: Reassessment of the conservation status of lions in South Africa and re-allocation of lions to a more appropriate category on the IUCN Red Data list (page 34). In the BMP is mentioned the lion is listed as Vulnerable on the IUCN Red List. It is also listed as Vulnerable on the South African list of Threatened and Protected Species (ToPS). Furthermore the lion is protected under Appendix II of the Convention of the international Trade in Endangered Species of Wild Fauna and Flora (CITES). In South Africa the lion may soon be listed as Least Concern due to population recovery and the large combined number of wild and managed lions. We are worried by the fact that the South African Government and other stakeholders are only looking at the technical definition to qualify for near threatened the wild population has to have less than 1500 mature individuals. It the populations exceed this number, the species should be listed as being of least concern. The combined wild and managed wild populations in South Africa comprise about 1600 mature individuals. In terms of number of adults, the South African lion populations should therefore be listed as Least Concern. You estimate that about 3000 lions are living in South Africa, 800 of them being wild managed. That makes your wild lion population about That in our eyes is still a vulnerable population. For several reasons: also mentioned in your BMP, the lions are very much isolated from each other and totally fenced in (and thus genetically vulnerable) as well they might carry a lot of diseases (also mentioned in your BMP). This may lead very easily to a poor healthy population of wild lions. One outbreak of disease can diminish this population easily.

4 You mention in the plan (page 26) that Risks of genetic impoverishment of managed wild lions are low and easily mitigated through robust management interventions. But in the BMP is also stated that there is too little cooperation between all the stakeholders who have lions. So in our eyes at this point, you should not change the status before all parties are working satisfactory with each other. Only once you have a robust and working plan, it is sensible to possibly reassess the status on the lion. We as well are very worried about the objectives in table 4.3 (page 34): Re-allocation of lions to a more appropriate category on the IUCN Red Data list. The lion is listed as Vulnerable on the IUCN Red List. Because of this, the lion is taken up in CITES as an appendix II animal. This in our eyes is already worrying since the lion numbers are declining rapidly worldwide and thus to us, should be listed as an appendix I animal. This would lead up to a general ban on trophy hunting - but still gives individual countries the possibility to ask for quota. Such as the cheetah: an appendix I animal but still Namibia is able to get hunting quota for this animal. Putting up the lion as an appendix I animal, will give this ionic creature the chance to restore its population. Your plans or suggestion to put up the lion in the red list as less than vulnerable, that would categorize the lion in the IUCN red list as near threatened or least concern, will for sure have a negative outcome for all lions worldwide. We are highly opposed to this objective and urge you to take this out of your BMP. We feel that the South African government is merely pushing for the Least Concern status for non-conservation purposes; namely, that it opens the way to more legal trade such as hunting and lion bones (BMP, objective 2.2: promote sustainable legal trade in lions and lion products ). We believe that reducing the status of the lion as status Least Concern will lead to more (illegal) trade. In your BMP, page 13, you state Although there are no specific figures on the illegal trade in lions and lion products in South Africa, provincial conservation authorities indicated that illegal use or trade is generally small to negligible. We think this is rather naive. Since one of the traits of illegal trade is that it is secret, it is not surprising that your officials know little about it, and we are surprised to see the conclusion in the BMP that you think this is negligible in South Africa. You state: it would also appear that wild lions in South Africa are safe from the body parts trade for as long as captive bred lions are the source of the derivatives. Since you are talking about promote sustainable legal trade in lions and lion products we wonder how you can consider breeding lions to be sustainable. We believe that there will be a growing demand for lion bones from Asia as tiger numbers are too low and the demand for product has to be met by lion parts. This is reconfirmed by the figures of

5 CITES, expressed on page 29 of the BMP, where the growth of export of lion bones is to be seen. Since people in Asia believe that wild lion bones/body parts are more potent, legal trade will grow the illegal trade. This is also understood by CITES. Conclusion: we feel that reducing the status of the lion as Least Concern is not sensible at this point since the wild lion population at this point is fragile - and lion numbers are declining in the wild. It is to be expected that the demand from out Asia will grow initially and thus put more pressure on both captive and wild lions. We urge you to take out of your BMP: - Re-allocation of lions to a more appropriate category on the IUCN Red Data list. - Reassessment of the conservation status of lions in South Africa Best Regards, Simone Eckhardt Director SPOTS Spinetstraat XT Etten-Leur Netherlands T: 0031 (0) Website: This letter and content is also subscribed by: Campaign Against Canned Hunting (CACH) P.O. Box 356 Wilderness 6560 Western Cape South Africa.

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