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Environmentalists and hunters slam government over proposals for the trophy hunting of elephants, leopards and rhinos

By Don Pinnock

16 Nov 2021

Last month, with little publicity, the Department of Environmental Affairs gave the public 30 days to object to or comment on its proposed hunting and export quotas for elephant, black rhino and leopard hunting trophies. It turns out to be the mere tip of a hunting iceberg.


Proposals to licence the hunting of 150 elephants, 10 black rhinos and 10 leopards have raised objections from environmental NGOs who slammed the environment department (DFFE) for expecting public comment on the basis of a two-page notice with no supporting information.

Elephants are listed by the IUCN Red Data Book as endangered, black rhinos as critically endangered and leopards as vulnerable.


“The Draft Quota,” says the EMS Foundation, “contains no information in relation to how the quotas have been determined, other than stating the quotas for leopard and black rhino are proposed ‘as per the recommendations of the Scientific Authority’. [It] cannot be finalised and any final decision made in the absence of providing the public with the information on which the proposed quotas are based is flawed.”

The call for public discussion on the hunting quotas of three iconic species ignores the recommendations of a High-Level Panel policy paper which is currently under review on the welfare and use of those three species, as well as lions. Setting quotas before the High-Level Panel process is finalised not only preempts, but actually undermines the ultimate recommendations of the DFFE’s own Draft Policy position.

“The quotas are arbitrary and not rationally connected to the information before the department,” said Michele Pickover of EMS.

Humane Society International-Africa and EMS have called on the DFFE to withdraw the draft quota until it can put in place a procedurally fair process which includes publication of all the scientific and policy information on which the quotas were determined.



The quota, says EMS, appears to have been determined without taking relevant information into account and is “irrational and arbitrary”.

The setting of trophy hunting quotas for leopard, black rhino or elephant are therefore unsupportable, it argues. The NGOs also noted a number of fundamental procedural and legal flaws in the process for proposing the quotas.

Here’s the puzzle. The proposed quotas are specifically for the calendar year 2021, which is nearly over. And public inputs still have to be assessed. But throughout this year, elephants have already been extensively hunted. So we’re effectively talking about a quota set in, at best, December, for December. Will the decision be retrospective in order to regularise hunts that have already taken place, or are quotas going to be rolled forward into 2022?


This is also a problem for hunters. Stewart Dorrington of Custodians of Professional Hunting and Conservation — South Africa says the problem his organisation has with the quota process is the timing.

“It will come too late in the year. It’s illegal to market a leopard hunt without a permit, so there’s no way to market beforehand. This makes it difficult to find clients and match them to a leopard at such short notice,” said Dorrington.

The proposed quotas, however, are merely small windows into a vast business of wildlife destruction which is generally unknown to the public.

Each year, professional hunters have to submit kill statistics to provincial departments which are then collated by the DFFE. This excludes hunting for the pot, biltong and, of course, poaching. It also, for some reason, excludes certain enclosed properties.

The Professional Hunters Association of SA submits the statistics to the department — which doesn’t publish them. They are, however, available on request if you’re persistent enough.

Those for 2020 were not available, but hunt stats from 2016 to 2019 tell a startling story. During those years, 190,468 wild creatures were “bagged” as trophies — that’s 171,748 wild mammals, 15,233 birds, 742 reptiles and 2,745 non-indigenous animals. It works out to 130 kills a day. Add hunting for meat plus poaching and the number could be double that, but these aren’t listed anywhere.

Impala top the animal list, closely followed by warthogs, kudu and zebra (pretty mats?). Turtle doves, speckled doves, laughing doves and ring-necked pigeons are the most hunted birds (are they mounted above the fireplace or just eaten?). Then there are some extremely odd trophies such as snakes, llamas, mouflon sheep and emus. Of concern are a number of endangered species, some critically, including those for which the DFFE proposes to provide quotas.

The EMS Foundation, which put in a 51-page objection to the rhino, elephant and leopard quotas, provides a grisly list of animal part “mementos” for which export licences were requested.


For leopards, these included floating bones (?), rug mounts, skull shields and claws. For elephants it was more varied: scapula bowl, leather skin panels, mounted tails, ears, footstools, part or whole trunks, foot umbrella, blood plasma, bagpipes (?), bracelets, skin duffle bags, feet ice buckets, ivory keys, a penis, teeth, belts and, of course, tusks and mounted heads.

Setting hunting quotas for rhinos risks an international perception problem, says the EMS report. “While the illegal hunting of rhino continues unabated, men and women are risking their lives trying to protect this species. It will be embarrassing to try to persuade an international audience to fund emergency rhino protection funding while at the same time promoting the legal killing of rhino on private land.”

Hunting licences are issued by the various provinces and are subject to certain restrictions and seasons. But when DFFE officials sit around a table to discuss the public inputs on the hunting of black rhino, leopards and elephants, there will necessarily be different criteria.

Elephant populations have crashed throughout Africa; black rhinos have hovered on the brink of extinction for many years, and there’s no formal census or adequate information on leopards, so it’s not known what impact hunting will have on their future. They are all in decline, facing increasingly disappearing and fragmented habitats.

Hunting also poses problems of genetic weakening, says HSI-Africa.

“Hunters generally target the biggest and strongest males, meaning that trophy hunting removes these animals from the breeding pool, leaving smaller or weaker animals for mate selection.”

Black rhinos are in even greater danger, says the NGO. The species declined by 85% between 1973 and 2017. In 1960, there were an estimated 100,000 black rhino; by 1973, there were 37,807, and at the end of 2017 there were only 5,495.

Recent census figures for Kruger National Park reveal an alarming decrease, with only an estimated 268 black rhino remaining, down from 415 in 2011.

Leopard populations are thought to be declining at around 11% a year, but this is based on inconclusive and fundamentally inadequate information. Estimates of the size of the national population vary widely from 2,185 to 3,400.

The DFFE’s proposal to set the age at which a leopard can be hunted from seven years upward is also flawed. According to HSI-Africa, “it is highly unlikely that ages can be reliably estimated by hunters, especially as rapid and rash decision-making in poor light conditions is a hallmark of leopard trophy hunting”.

So if hunting elephants, leopards and rhinos will be permitted, the decisions cannot be made on the grounds of conservation. Will they be influenced by hunting organisations, gun traders, commercial game farmers, political pressure or concerns about litigation if permits are blocked?

According to HSI-Africa, even the economic argument does not stand up to scrutiny. “Trophy hunting brings in just 0.78% or less of the overall tourism spending and has only a marginal impact on employment in those countries, providing approximately 0.76% or less of overall tourism jobs. As little as 3% of trophy hunting income trickles down to local communities.”

According to EMS, leopards, black rhinos and elephants are not resilient to trophy hunting because they have lower reproductive rates, more complex social organisations and their body parts are illegally traded in international criminal markets.

“These species, because they are the most charismatic, rare and sought after by trophy hunters, means that the issuing of hunting permits for them could lead to market speculation, creating the conditions for extinction.” DM/OBP