SA reclassifies 33 wild species as farm animals

[Lisbeth]

Twice to be exact, but not particularly linked to lion breeding

[Lisbeth]

South African proposal to breed wildlife for slaughter courts disaster

BY ROSS HARVEY + CHRIS ALDEN - 14TH JUNE 2020 - THE CONVERSATION

There are times of spectacular policy myopia – and promoting a revision to the Meat Safety Act by the South African government is surely one of these moments.

In late February the government proposed adding over 90 local and non-indigenous species to the list of animals regulated under the Meat Safety Act. Prior to this the act allowed for the commercial slaughter of 35 “domesticated animals” and “wild game” species.

The list of 90 included rhinoceros, hippopotamus and giraffe, as well as “all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption”.

The bill is currently being circulated for comment.

The purpose of the Meat Safety Act is to provide measures to promote meat safety and the safety of animal products for human and animal consumption. The effect of the proposed amendment is to make the whole act applicable to any animal to be slaughtered.

It appears that at least part of the reason for these amendments is to regulate the slaughter of captive bred lions, whose bones are exported in growing quantities to Asian markets.

If passed in its present form the act opens up the possibility of massive consumption of wildlife. How? By inadvertently driving up the demand for bushmeat through legitimising the consumption of protected wild animals.

A growing conservation concern

The COVID-19 pandemic has underscored the dangers of the transmission of viruses from wildlife to humans. The same pattern of infectious disease “species jumping” was implicated in the origin and spread of COVID-19, Ebola and SARS.

This zoonotic spillover risk is strongest in “wet markets”, where live animals, fish and birds are butchered and sold to consumers on site (as well as products like skins, scales and horns). A systematic review in 2007 concluded that:

The presence of a large reservoir of SARS-CoV-like viruses in horseshoe bats, together with the culture of eating exotic mammals in southern China, is a time bomb.

Bushmeat consumption across the continent is already a daunting conservation problem. Bushmeat increasingly serves as a supplement to protein from other sources such as cattle, chickens, goats and sheep.

Our fear is that the change in the law could lead to more wet markets being established in South Africa. While the amendments increase regulatory control, it’s not clear that the government will have the capacity to enforce them. More likely is the risk of realising unintended consequences. Individuals and small businesses are likely to see this as an opportunity to enter a sector where start-up costs are minimal, sanitary standards difficult to enforce and oversight non-existent.

Trade in small markets already exists in South Africa, which double as markets for traditional medicine in some instances. One study of the Faraday Market in Johannesburg revealed that at least 147 identified vertebrates were being traded for both bushmeat and traditional medicine.

Preserving scarce wildlife

Putting African wildlife on the menu for mass consumption holds implications that are important for our relationship with the wild and environment. It reduces wild animals to mere consumables.

Remember that these amendments come in the wake of 32 wild animal species having recently been included in changes to the Animal Improvement Act, essentially relegating them to mere agricultural products.

What is being put forward by government signals that it is open season on the country’s national heritage and authorises a great expansion of the legal procurement of wild animals for sale.

As has been demonstrated time and time again, the formal legalisation of wildlife trade provides both a cover and an incentive for the illegal trade in wildlife and its products. For example, the trade in perlemoen or abalone has been legal for generations and harvested on a sustainable basis. However, once permits were issued to unscrupulous front companies from Asia, the systematic stripping of the coast commenced with exports packed and sent out of the Cape and Johannesburg all under the legal guise of a legitimate business.

A significant portion of perlemoen has disappeared from coastal shores, depriving South Africans of employment, valued-add production (such as canning, now performed in Asian countries) and enjoyment of a national resource. Attempts to protect the species through listing on Convention on International Trade in Endangered Species in Wild Fauna and Flora (CITES) appendixes have been thwarted by pressure from a fishing industry subject to corruption.

Defeating public health and conservation objectives

Promoting the consumption of wildlife in South Africa will only intensify the commodification of the country’s natural heritage. And it will potentially create zoonotic spillover health risks for humans as well as from wild animals like wildebeest to domesticated animals such as cattle.

We cannot continue to treat our delicate ecological systems as free capital. They are the vital life support systems without which nothing and no one can survive.

Original article: https://theconversation.com/south-afric ... ter-140399

[Richprins]

But domesticated animals are slaughtered?

[Lisbeth]

By “domesticated animals” they mean farmed animals, I think

[Richprins]

Ja...how must they feel?

[Klipspringer]

https://www.iol.co.za/saturday-star/new ... n-50011976


Govt proposal to add rhino, elephants to list of animals that can be slaughtered for consumption
Time of article published Jun 27, 2020


Johannesburg - The government has proposed changes to South Africa’s meat safety legislation, suggesting that threatened species such as rhinos, elephants and giraffes end up on dinner plates.

The Department of Agriculture, Land Reform and Rural Development (DALRRD) has already received about 30000 comments before the deadline on Tuesday, it revealed in an answer to a recent parliamentary question on its draft amendment to the Meat Safety Act (MSA).

In February, it proposed expanding the 35 “domesticated animals” and “wild game species”, the commercial slaughter of which is already regulated under the MSA to a new list of more than 90 local and non-indigenous species, including rhinos, hippos, giraffes and elephants, as well as “all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption”.

This follows recent changes to the Animal Improvement Act (AIA) which promotes the intensive and selective breeding and cross-breeding of animals, listing 33 wild animal species, including lions, cheetahs and rhinos.

The Endangered Wildlife Trust (EWT) has launched an application in the Pretoria North Gauteng High Court challenging and seeking the review of the decision to list wild animals in the AIA.

Part of the controversy surrounding the proposed amendments to the MSA stems from its perceived linkages to the AIA amendments and associated concerns that the government is “laying the groundwork for the intensive breeding of various indigenous species”, said Dr Melissa Lewis, policy and advocacy programme manager at BirdLife South Africa.

Although the AIA’s expansion does not involve bird species, Lewis said BirdLife South Africa was “monitoring that matter closely due to the harmful precedent it could potentially set”.

Senior manager of the wildlife programme for WWF-SA Dr Jo Shaw said it had submitted its comments on the proposed MSA amendment.

“We are particularly concerned by the inclusion of threatened species, especially rhinoceros, which have not been typically harvested for meat, and the lack of clarity around how ‘animal products’ are covered by the act, especially in relation to conservation implications due to illegal trade in high-value products.

“We are also concerned about the lack of separation within broader taxonomic groups in which some species may be of conservation concern; the lack of clarity relating to the addition of ‘all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption’; and particularly by the lack of clarity relating to overlaps and potential gaps between the mandates of the departments of Agriculture and Environment in relation to species that will be impacted by different pieces of legislation.”

Ashleigh Dore, of the EWT’s wildlife in trade programme, pointed out that the amendment to the MSA as read with the proposed regulations on game meat, if and when they were promulgated, aimed to facilitate and regulate the processing of meat from game animals that had been hunted or culled.

The EWT recognises the value that wildlife ranching and the ecologically sustainable use of wildlife brings to the country, and promotes the value and role of wild animals in natural free-living conditions “as an alternative to the proliferation of captive and intensive breeding facilities which provide limited, if any, conservation benefit”.

“Accordingly, we do not support the increasing tendency for industrial-scale production and management of SA wildlife when these are not in line with the principles of ecologically sustainable use and have no conservation benefit.

“These practices, depending on the operation, may result in acute environmental harm and welfare concerns. While we wholly support the move to create a legal framework to support the commercial sale of game meat from wild animals from natural free-living conditions, we do not support the intensive and selective breeding of wild animals for commercial meat production,” Dore said.

In an article in The Conversation Africa last week, Ross Harvey of the University of Johannesburg and Chris Alden of the London School of Economics and Political Science argued that promoting the consumption of wildlife in South Africa will “only intensify the commodification of the country’s natural heritage”.

“And it will potentially create zoonotic spillover health risks for humans as well as from wild animals like wildebeest to domesticated animals such as cattle.”

Environmental futurist Prof Nick King agreed that the amendments “attempt to further commodify wildlife like so much inanimate manufactured merchandise”.

“The draft is so poor from a scientific perspective that it is wholly unworkable, and unenforceable, which begs the question whether it is intended to be regulated at all It ends with the statement, ‘This Act also applies to all other species of animals not mentioned above, including birds, fish and reptiles that may be slaughtered as food for human and animal consumption’,” said King.

“What then is the point of the list provided, if it applies to ‘all other species’? Thus it is a completely nonsensical and unscientific listing and cannot possibly be legally enforced,” he said.

Lewis said BirdLife South Africa recognised the desirability of ensuring that animals slaughtered by humans for human or animal consumption were encompassed by a regulatory regime aimed at minimising health risks.

“We also accept the sustainable utilisation of wildlife resources and recognise the contribution consumptive utilisation makes to the economic value of wildlife."

Its primary concern for bird conservation is ensuring that any such utilisation occurs in strict compliance with the applicable conservation laws. “DALRRD has clarified that the question of whether or not it is permissible to slaughter animals from particular species of wild animals will continue to be governed by legislation under the Department of Environment, Forestry and Fisheries (Deff). In addition, the draft amendments themselves specify that the slaughter of threatened species ‘must be in line with the relevant conservation provisions’.

“However, this language fails to reflect that the killing of wild animals is governed not only by Deff’s legislation, but also a myriad provincial conservation laws and the annual hunting proclamations published thereunder.".

Lewis pointed out conservation laws did not only regulate the killing of “threatened” species, and conservation laws included requirements concerning not only the killing of animals from particular species but also associated activities, for example trade in certain animal products.

“We will therefore be recommending revised language, which makes very explicit that both the slaughter of all animals covered by national and/or provincial conservation laws, and any associated activities that are regulated by these laws, must occur in compliance with both the laws themselves and any notices, licences or permits issued thereunder,” she said.

Nelson Mandela University zoologist Prof Graham Kerley, said: “The reality is that few of the wildlife species considered can be managed to the point of being slaughtered in an abattoir, but are rather hunted, and typically then the carcasses are processed in a mobile field abattoir.”

Increasing the sustainability of SA's wildlife resources is one crucial mechanism to improve the conservation of its biodiversity, he argued. "Well-managed wildlife systems can be based on and protect natural landscapes. Finding additional markets and mechanisms to safely and sustainably harvest wildlife meat (and other products) is important for the conservation of biodiversity."

The amendment could possibly reduce the risk of zoonoses (diseases). "The devil is really in the details around enforcement of not just the meat aspect, but the entire wildlife industry. SA does not have a good record, as evidenced by the problems around the captive lion industry. So more legislation is not the only solution. We need more trained people and resources on the ground to manage the opportunity and its risks. And the wildlife industry, as the immediate benefactor, needs to take responsibility and contribute to solutions."

Use of venison the healthiest choice

The Constitution explicitly provides for sustainable utilisation of South Africa’s natural resources, says Gery Dry of the Game Ranchers Forum, and this is a “thorn in the side of biocentric NGOs” who have called on the government to ban the slaughter, consumption and export of venison” following the Covid-19 pandemic.

The “venison initiative” will create 110 new processing plants by next year, increasing to 300 plants by 2030. It will strengthen rural economies and create a new market for game farmers through R650m by 2021 and R7 200m by 2030, he says. “This represents sales of 180 000 animals per year by 2021 and 2 million by 2030. It is estimated to create 1700 jobs by next year and 18 400 by 2030.”

SA’s venison value chain is based on proper meat safety standards. “If anyone follows the path of logic they will realise that mankind has historically used game meat long before agriculturally produced beef mutton and pork started. The use of venison was undoubtedly healthier.”

The SA Veterinary Association (SAVA) says it understands the importance of compliance with the standards set out by the MSA.

“Act 40 thus strives to ensure food safety of all meat and of all meat products that are brought into the market, independent of species, and SAVA does support the maintenance of high food safety standards.

“SAVA does of course also support the protection of endangered species and the keeping and breeding under conditions that are taking care of the needs of the different species.”

[Lisbeth]

[Klipspringer]

https://www.conservationfrontlines.org/ ... Y_2020.pdf Page 101


Farming Wild Animals
Is China the model for South Africa?


By Jamie Paterson and Simon Espley
READ TIME 10 MINUTES


Farming wild animals is big business in South Africa—although nowhere near at the scale of the
Chinese wildlife farming industry. Should SA follow China's lead in upping the scale of this industry, as
it seems to be doing?

South Africa is a long-standing and respected leader when it comes to farming wild animals.
Yes, there are instances of bad and biodiversity-damaging behavior (which we condemn via
focused articles), but as an industry, the South African wildlife industry does earn its keep and
its kudos, and it maintains sizeable swathes of land for wildlife and away from intensive crop
and livestock farming. But recent moves by the South African government suggest that the
game is about to change, and not for the better.

In 2019, the Ministry of Agriculture in South Africa quietly (and without public consultation or
scientific research) passed a “minor amendment” to the Animal Improvement Act
that reclassified 33 wild animals as farm animals—including lions, cheetahs, several antelope
species, giraffes, zebras and both black and white rhinos. Now, the government plans to revise
the Meat Safety Act of 2000 by expanding the list of animals to which the Act applies for
slaughter, consumption, import, export and sale. The intent was published in the official
Government Gazette on 28 February 2020. New animals added to this list now include impala,
bushpig, warthog, giraffe, elephant, buffalo and rhinoceros. Is the plan to intensively
manufacture our rhinos and elephants (and others) into burgers, kebabs and pâté?

To be clear at the outset, we offer no blanket objection to all sustainable uses of wildlife,
especially where these uses are legitimately environmentally sustainable and beneficial to
local communities. Instead, this opinion editorial is about the degree to which these activities
are pursued, against a backdrop of demonstrated failure by government to enforce existing
legislation designed to protect biodiversity and human public health.

For example, there is a clear difference between venison/game farming and subsistence
hunting on the one hand, and intensive farming to achieve a maximum yield on the other. The
South African government has been incrementally promoting the “sustainable use” of wildlife
for many years—expressing this approach as a guiding principle behind several policy
decisions.

That seems to be a reasonable strategy on a continent with an abundant biodiversity resource.
That said, these latest proposed amendments to the Meat Safety Act suggest the intention to
stretch South Africa’s wildlife laws to include the large-scale farming of wild animal species
specifically for consumptive purposes. This is where the comparison to China’s journey with
wildlife farming becomes highly relevant.

Proponents of the “sustainable use” ideology argue that it is a conservation tool; by permitting
the captive breeding of wild animals, the products of these animals (meat, horn, skin, scales)
can be used to supply the market—thereby dropping the prices and reducing the pressure on
the animals in the wild. This is the basis of the argument used for both canned and other trophy
hunting and the trade in lion bone. It is also the fundamental approach of Chinese wildlife
laws. The term “sustainable use” is now often underpinned by the phrase “if it pays, it stays”—
which surely has an altogether different meaning.

China’s Wildlife Protection Law (WPL) is the basis of the legal framework of wildlife protection
in that country. Since it came into effect, in 1988, the WPL has been revised four times and the
2016 revision centered around whether or not the law was about “protecting” wild animals or
“using” them. Ultimately, “regulated use” was cemented into the law and made clear
that wildlife is to be considered a “resource,” one of the principal purposes being for
domestication and consumption. The Chinese government has actively promoted the farming
of wildlife over the past three decades—designating it a key strategy for rural development and
resulting in a convoluted industry that was valued at US$74 billion by the Chinese Academy of
Engineering in 2017.

It was this approach that has led directly to the current coronavirus pandemic and catapulted
China’s wildlife markets onto international news screens, ultimately resulting in a temporary
ban in the trade in wildlife products.

While scientists have yet to confirm which species carried the virus and passed it on to
humans, there is no rational doubt that the disease is zoonotic in origin. This is hardly without
precedent—the 2003-04 SARS outbreak that killed at least 774 people in 29 different
countries was traced to farmed civets, though experts believe that they were an intermediate
carrier and that the virus was transmitted to them in one of the meat markets. China
implemented a temporary ban on civet farming, but by the end of 2019, government bodies in
China were promoting the farming of civets once again.

Quite apart from the zoonotic implications exacerbated by the unsanitary farming conditions
and markets, farming wild animals has failed in its purported conservation agenda. There are
believed to be over 200 tiger farms in China, with over 5,000 tigers farmed for their bones, skin
and teeth to feed the enormous traditional-medicine market. Yet in the three decades of tiger
farming, wild tiger numbers continued to plummet, and there are now believed to be fewer
than 50 wild tigers throughout China—despite extensive conservation efforts. Tiger parts
sourced from tigers poached in other parts of Asia also find their way into China to feed the
demand of the largest market in the world. And African lion bones (farmed and poached) are
also finding their way into the Chinese tiger-bone market. The same applies to multiple
pangolin species both within China and throughout the rest of the world.

Given that tigers and pangolins are theoretically species with the highest levels of legal
protection in China, why then is this the case? The answer given by critics such as the
Environmental Investigation Agency is that allowing trade in animal parts for “traditional
medicine” reasons (permitted under Chinese law even for the most endangered species) makes
it impossible for authorities to determine which animal products are legal or illegal, farmed or
wild. Their investigations indicate that the legal trade has created the perfect opportunity for
the laundering of illegal wildlife parts.

Could this be the model that South Africa is destined to follow? Will South Africa (and Africa by
implication because South Africa is a known transit point for continental wildlife trafficking)
see its threatened species go down the same road of intensive farming while wild populations
crash? To better understand the risk of this happening, let’s dig deeper, to compare the
situation in China and South Africa.

It could be argued that South Africa could use this model to learn from China’s mistakes, to
create a much more coherent way of controlling the trade in wild animal parts. The Chinese
legislation has been criticized as being piecemeal and ambiguous, operating through loopholes
without any centralized authority, based on the premise that the Chinese government
promotes farming and consumption of wild animals. To avoid this situation, South Africa would
need clearly communicated and concise laws with an effective method of certification for legal
farmed-animal products.

Yet so far, the South African government’s approach has been anything but clear and
concise. The 2019 amendment was met with widespread condemnation and criticism for its
lack of clarity on the ramifications of such an amendment, particularly with regard to the lion bone farming industry. Indeed, one author of this opinion editorial requested clarity in mid-2019 from Barbara Creecy, South Africa’s Minister of the Environment, on how many wild
rhinos this country has left, when Ms. Creecy requested scientific input to an application to
CITES to reduce the protection afforded to white rhinos. The Minister, unlike her predecessor,
refuses to divulge rhino population statistics against a backdrop of misleading proclamations
of reduced poaching, and yet here she was expecting valid scientific input while keeping us all
in the dark about the most important starting point for such scientific input. Once again, the
announcement of the proposed amendment of the Meat Safety Act to include rhinos offers no
real clarity except to point out “this scheme includes animals that are listed as endangered
species . . . and therefore their slaughter for both human and animal consumption must be in
line with the most relevant conservation indications.” What is meant by “most relevant”
remains to be seen . . .

In addition to unambiguous laws, South Africa would need a centralized authority to manage
the certification and oversee the movement, trade and disease-control of farmed wildlife
products. There would also need to be strong law-enforcement procedures in place to ensure
vendors do not sell illegal products alongside legal ones.

Like many Chinese people, the majority of the South African population has strongly engrained
cultural beliefs surrounding the medicinal values of animal parts, as evidenced by the
flourishing muthi [traditional medicine] markets in main cities such as Johannesburg and
Durban. These markets continue to sell illegal wildlife products such as baboon skulls, skinned
monkeys, vulture heads, pangolin scales and leopard pelts—and the rare police raids do little to
stem the tide. Despite extensive efforts from both government and private initiatives,
challenges in the forms of rhino poaching, bushmeat trade, vulture poisoning and black-market
abalone trade all cast dark shadows of doubt over South Africa’s capacity to successfully police
a legal trade in wild animals.

There would also need to be extensive legal guidelines for the welfare of these farmed animals.
In China, it took years before the outrage regarding the process of bear-bile farming had any
impact on animal-welfare legislation, and even so, there are farms where those practices are
still commonplace. Intensive farming is known to result in animal-welfare atrocities, and as
money and maximum yield become the motivating factors, the same would apply to a wildlife
context.

There is a theory that allowing trade would create income to enable these farms to improve
the living conditions—this is not borne out in reality, as can be seen in the farming of domestic
livestock. As we know from feedlot farming of livestock, this level of commercial intensification
at the expense of moral and health standards becomes commonplace when it is permitted. A
case in point is that once South Africa legalized the farming of lions for bones the cases of
horrific under-nourished, overbred lions crowded together on lion farms throughout South
Africa skyrocketed. Quite aside from the horrendous ethical implications, the cost to the
country’s conservation reputation and subsequent loss of revenue from tourism would
undoubtedly be enormous.

For 20 years, the venison industry in South Africa has been left to interpret the regulations of
the Meat Safety Act without any government assistance and this has resulted in warnings
from meat-safety consultants about potential safety problems. Humans have been fighting to
keep domestic livestock diseases under control since intensive farming became an industry,
and yet disease outbreaks still occur that result in enormous losses.

Wild animals carry diseases. Some of these are capable of mutating and jumping the species
barrier. In a natural environment, a system of checks and balances keeps these diseases under
control. But through intensive farming, these diseases have the potential to spread like
wildfire. This recent article in Farmer’s Weekly emphasizes the importance of venison as an
industry and source of nutrition, but warns that South Africa’s meat-safety regulations are
poorly understood and implemented and that the many zoonotic diseases historically found
mainly in livestock are now increasingly common in wildlife. These diseases, therefore, pose a
growing risk to human health.

The point is this: The South African reality right now is far removed from that of China’s; we
are far from having a multibillion-dollar wildlife-farming industry with wildlife markets offering
anything from bats to tiger bones. But the South African government is relying on the same
reasoning, the same justifications to push through legislation without proper disclosure,
consultation and scientific input. “Sustainable use” is becoming a convenient catch-all phrase, a
cover for the creation of an industry that is being pushed by those who would benefit
tremendously by it. Both South Africa and China have a demonstrated lack of transparency in
their maneuverings, and both seem unable to enforce their own environmental and public health regulations.

The South African government and policymakers need to take a long hard look at China’s
conservation history, its role in the current Coronavirus pandemic and its increasing pariah
status. And they need to honestly assess whether they have what it takes to avoid going down
that same disastrous road when “sustainable use” goes very wrong. When China treated wild
animals as livestock, the animals paid the price, and now the world is paying an even greater
price. Is that a model that South Africa wants to emulate?

This opinion editorial from Team Africa Geographic appeared in Africa Geographic on May 4 and is
republished here with permission. The list of references cited by the authors is attached to the original
article.

Jamie Paterson is Africa Geographic’s Scientific Editor. She has an Honors degree in Law from the University of Cambridge. Her real passion, however, is the African savannah, especially on foot. Simon Espley is an African of the digital tribe, a chartered accountant and CEO of Africa Geographic. His travels in Africa are in search of wilderness, elusive birds and real people with interesting stories.

[Lisbeth]

A WORD FROM THE EWT CEO



Yolan Friedmann, EWT CEO

In recent weeks there has been a flurry of social media posts around some proposed regulatory changes that would, if implemented, have a significant impact on the future management, wellbeing, and conservation value of our wildlife resources in South Africa. As with all news that goes viral, there will be some elements that are accurate and many that are not. Humans appear to need to amplify hard facts to get the attention that they want and perhaps in this day of extreme media overload and noise, this may well be a relevant strategy. Be that as it may, the EWT prides itself on being a science and fact based organisation whose contributions are credible, meaningful and evidence based. We have been inundated lately with messages across all platforms, asking what we are doing about, and what the public can do about, a series of proposed regulatory changes and the following is a brief description of the issues, our concern and our responses:

- 1. The Animal Improvement Act – this act promotes the intensive and selective breeding and cross-breeding of animals. On 17 May 2019, a notice was published to include the following species as landrace breeds in terms of this Act: Lechwe, Giraffe, Zebra, White Rhinoceros, Black Rhinoceros, Lion and Cheetah. We have launched an application in the North Gauteng High Court, challenging and seeking the review of the decision to list wild animals in the Animal Improvement Act. Our grounds of review include legitimate concerns regarding the conservation value of breeding animals that are claimed to be genetically superior animals and the possible detrimental impact on natural selection and evolutionary processes.

- 2. The Meat Safety Act – the amendment to the Meat Safety Act as read with the proposed regulations on game meat (if and when they are promulgated) aims to facilitate and regulate the processing of meat from game animals that have been hunted or culled. We have submitted extensive comments to the Department of Agriculture, Land Reform and Rural Development in this regard, holding that while we wholly support the move to create a legal framework to support the commercial sale of game meat from wild animals from natural free-living conditions, we do not support the intensive and selective breeding of wild animals in general, or for commercial meat production specifically.

- 3. The Threatened or Protected Species Regulations of 2007 have been undergoing amendment since March 2015, when the public was afforded an opportunity to comment on proposed amendments. Early in 2020 we received information of the submission of a version of these regulations to the National Council of Provinces for their approval (the 2019 Amendments). We have extensively compared the 2015 version of Amendments with the 2019 version of Amendments, and found well over 200 changes between these two versions, 56 of which are substantial changes in our view. We have written to the Minister of Environment Forestry and Fisheries, raising concern about the lack of public participation in the finalization of the 2019 Amendments, considering this process has taken five years and the two versions are fundamentally different. We are awaiting feedback in this regard.

The EWT has an experienced and highly skilled team of experts who developed our submissions on all of these proposed regulations, and we are vigilantly watching the process to ensure that our concerns, as well as those of several other specialists, are considered. We will keep our readers updated. We cannot guarantee that our opinions will triumph, but our voice will be heard. Your support keeps the EWT in a position to engage with government and hopefully, improve the outcomes to the benefit of our wildlife. Please keep supporting the EWT during these times, every bit helps.

[Richprins]

we wholly support the move to create a legal framework to support the commercial sale of game meat from wild animals from natural free-living conditions,