Comments On The New Regulations For The Wildlife Industry

Ron Thomson has compiled a number of comments on the new draft regulations governing the hunting industry and threatened and protected species. (The letter below has been edited and shortened)

One of his first comments relates to the management of endangered species. He feels that South Africa has a chance to lead the world in managing endangered species, but would like to see a change in mindset regarding these animals.

Looking at animals that are typically regarded as endangered, he calls for them to be categorised into 'safe' and 'unsafe' populations. In safe populations, a species that is threatened elsewhere is thriving, and can be managed by means of capture and translocation, culling or hunting.

However, the same species in an unsafe population would require preservation management, where they are protected from all harm. By using these criteria, rather than an overall endangered criteria, the species as a whole could be better managed. Thomson then looks at factors to be taken into account when considering hunting applications, specifically when there is an objection to an application by an interested person.

Here he calls for the authorities to ensure that any potential objectors are prepared to swear their support to South Africa's overarching National Conservation Strategy, which was created using the principles of the IUCN's World Conservation Strategy.

He feels that this is necessary to prevent some animal rightists, who are opposed to any form of sustainable utilisation of species and ecosystems (a concept entrenched in the World Conservation Strategy), from clouding debates, such as the Kruger culling debate. Thomson says that this will "sift the wheat from the chaff" and regulate contributions from the public floor.

Another issue from the hunting regulations that Thomson comments on is the issue of hunting on private land adjoining nature reserves. He calls for a better public understanding of how animals come to move into and occupy territories and home ranges.

He feels that this is necessary to reeducate people about the idea that animals 'stray' from a national park onto the adjoining land, where they are hunted. He points out how animals "stick to these pieces of real estate [territories and home ranges] like butter sticks to a slice of bread", and how vagrant animals "are surplus to the populations that created them."

He asks that the game ranches be allowed to manage their animals in accordance to their own objectives, "without interference from 'big brother'. These game ranches have different management objectives to those of the national park and you need to acknowledge this and you need to help them achieve their own objectives.

You should not try to make these private game ranches mini-Kruger National Parks." Thomson then moves on to the matter of damage causing animals, saying "the provisions of this section of the bill are cumbersome and will not work efficiently". He feels that landowners with the required experience should be able to dispose of damagecausing animals themselves without calling in local government for help..

"We need to get away from the old 'verkrampt' bureaucratic attitude towards private land owners and allow them to exercise proper management actions on their own land where and when they can." Finally, he looks at the issue of poison, traps and spotlights. Saying that these are management tools, he says that legally banning their use will not stop them being used. Thomson suggests that their use is regulated rather than prohibited, so that it can be controlled.

Comments On The Threatened And Protected Species Regulations

In his preamble to his comments on the threatened and protected species regulations, Ron Thomson challenges the minister of environmental affairs and tourism to take a close look at Cites (Convention on the International Trade in Endangered Species of Flora and Fauna), which he says is not functioning with "honour and responsibility."

Thomson believes that NGOs, specifically animal rights NGOs, have been given too much leeway in Cites discussions.

He says he personally knows of two African delegates to Cites meetings whose votes were bought with all expenses paid trips, and he alleges that animal rights groups are buying votes to swing the results of debates. "This is happening all the time at every Cites meeting that takes place."

He calls on the minister to investigate these claims and then do something about rooting out the problems in Cites, otherwise it is meaningless for South Africa to comply with Cites, as "Cites has allowed itself to be hijacked by its accredited animal rightist NGOs."

Thomson then reiterates his stance on safe and unsafe populations of species commonly regarded as endangered, and questions how, in light of this, a "hunting off-take limit" can be drawn up for a species, "when a species can only be effectively managed population by population."

He draws the minister's attention to the fact that most game farms in South Africa are well fenced, and "even if the impala on one game ranch can rub noses through the fence with other impala living on the adjacent property, the impala on those two properties must be considered different populations" as the animals cannot breed with each other.

He adds that different ranches can have different legitimate management objectives (eg biltong hunting versus ecotourism), which changes how they manage their animal populations. This makes the proper government regulation of a hunting take-off difficult, and Thomson concludes that "The only way it can be done with any degree of honesty and integrity - and effectiveness- is on a ranch by ranch basis."

He believes that the only workable solution to the problem is to place more faith in landowners and those who run the wildlife industry, saying "the person who lives and works and relies upon a natural resource for his livelihood is the person most concerned with the proper management of that resource." In conclusion, he writes, "One last thing. I cannot understand why the porcupine has been given so much national protection - when I know it is still plentiful and a major crop pest in many agricultural areas?"


Ron Thomson worked in the Rhodesian/Zimbabwe National Parks Department for 24 years where he rose to the rank of Provincial Game Warden i/c., Hwange National Park - Zimbabwe's premier game reserve. After leaving Zimbabwe in 1983 he worked as Chief Nature Conservation Officer for Ciskei and then, for three years, was the Director of the Bophuthatswana National Parks Board.

He is a university-trained ecologist. For twenty years, before retirement, he was a registered Member of the Institute of Biology, London, and a Chartered Biologist for the European Union. He can be contacted at tel./fax. (012) 2530 521; or

Kruger National Park - South African Safari