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POSITION PAPERS AND MEDIA STATEMENTS.


Position Statement

Members of the Game Rangers Association of South Africa agreed to the following position regarding the proposal by Eskom for a nuclear power station to be erected at Bantamsklip in the vicinity of Pearly Beach on the Agulhas Plain.

  1. GRAA supports the development of technology for clean substitutes for the burning of fossil fuel for power;
  2. GRAA recognises the need to utilise current alternative cleaner technology which includes nuclear power generation to reduce the impacts of waste from the burning of fossil fuel;
  3. GRAA encourages continuing research and development into technology which could be a substitute for nuclear technology in order to eradicate the generation of radioactive waste which has long-term implications for life on this planet.

    However:

  4. GRAA opposes unequivocally the construction and operation of a nuclear power station at Bantamsklip, since this is a globally and nationally recognised biodiversity hotspot, is in an area of irreplaceable lowland fynbos, and situated in a region known as the Agulhas Plain, the site of a world-renowned sustainability study focussed on the integration of conservation and development. The reasons for this stance are as follows:
  5. The devaluation of the multi-million rand investment into the Agulhas Plain over the past five years by international bi- and multilateral aid agencies, national, provincial and local government, philanthropic organisations as well as the private sector.
    1. The Agulhas Plain was selected by the SA Government in 2002 to serve as the model for an innovative approach to conservation and human development. The Agulhas Biodiversity Initiative (ABI), was thus launched to address conservation and development at an ecosystem level to ensure a sustainable future for communities of the area.
    2. This new approach requires that all parties which own, manage and utilise natural resources and land are included in planning and implementation. ABI has been a response to the government's call to encourage local ownership, responsibility and socio-economic benefits through the optimal use of the natural and human assets of the region. ABI is being championed by SANParks in partnership with all the major agencies in the area i.e. Agriculture and Land Affairs, CapeNature, the Municipal structures, public benefit organisations and commerce. The latter focuses in particular on eco-tourism. ABI is contractually bound to its many investors to develop and promote a sustainable model for the whole fynbos biome through the Cape Action for People and the Environment (C.A.P.E.).
    3. The ABI partners - and indeed the government itself - are not at liberty to put the achievements of the past five years at risk. For five years the Agulhas Biodiversity Initiative has promoted sustainability, progress and prosperity through ecotourism, sustainable use and the marketing of the region's natural assets and resources aimed at responsible and sustainable development. A nuclear power station has not been included in the Spatial Development Plans and the Integrated Development Plans of the region simply because such an installation is not regarded as a compatible land and resource use.
  6. Impacts from the peripheral development are not covered in the scoping and EIA process for the construction of the power station.
    1. GRAA challenges the fact that the potential impacts of the power line and road networks, the water cooling system, the transport and disposal of nuclear waste, as well as the changes in community and social structures are not being weighed against the socio-economic benefits being touted. GRAA would expect that the needs of the indigenous flora, tourism development and quality of life of the towns and communities of the region should outweigh short term gain in employment levels being advertised. This objective assessment needs to take place to be true to the principles of sustainability.

    Therefore:

  7. GRAA recommends that all current and new players, including Eskom, who are concerned with the sustainable maintenance of biodiversity in the region should;
    1. Focus resources in the Agulhas Plain and the broader Overberg on research and development of “green” energy. Included in such a “green” energy R&D programme would be wave, wind, solar, buy-back schemes from household produced energy and the development of biogas powered turbines;
    2. Strengthen the integrated approach to conservation and development by working with established partners and institutional arrangements within existing frameworks;
    3. Plan a strategy and put in place an implementation plan that builds on the achievements of these programme in the field of sustainable resource use, natural resource economics, biodiversity business and others.
The Game Rangers Association of Africa supports the WWF call for lucid thinking regarding the future of Tsitsikamma Marine Protected Area

The Game Rangers Association of Africa (GRAA) supports the call by the WWF Sanlam Marine Programme for rational, transparent and science-based decision making regarding the future of Africa’s oldest Marine Protected Area (MPA), Tsitsikamma. This is in response to recent announcements in the press that the Department of Environmental Affairs and Tourism (DEAT) intended opening parts of the MPA to recreational fishing.

The rational logic of such a decision is questioned from an ecological, fisheries management as well as a socio-economic perspective. The organizations also question the inclusiveness of the process undertaken to arrive at what appears to be a parochial and political decision to appease highly vociferous local stakeholders. Finally, the DEAT’s resolve to implement international commitments made by the South African government and its people at the World Summit for Sustainable Development (WSSD) is questioned.

Firstly, from an ecological and fisheries management perspective: The Tsitsikamma National Park is South Africa’s oldest and largest marine protected area which is a priceless national asset that has enjoyed total protection since 1964. It is the marine equivalent of the Kruger National Park and a major tourist draw card. The park provides a breeding reserve for reef fish that reseed adjacent line fishing areas. This service is made all that more important due to the absolute failure of traditional management of linefish in adjacent areas. These fish are already in a state of crisis from over-fishing, with most stocks estimated at below 5% of their pre-exploited biomass. So much so that the previous Minister of Environmental Affairs and Tourism (Vali Moosa) declared the line fishery in a state of emergency (Government Gazette, 29 December 2000 No. 21949, Notice 4727 of 2000). For many of these linefish species, the only places in which they survive in sustainable numbers are in our MPAs. The Tsitsikamma MPA lies in the heart of the distributional range of many of the most embattled species (a group of species known as the spariids), thus serving a nationally important role. These facts make it very difficult to understand the DEAT decision. In fact, it is common knowledge that DEAT has acted against the advice of its own fisheries scientists in arriving at the decision it has.

Secondly, from a socio-economic perspective: WWF recently commissioned a report to better understand the socio-economic value of these MPAs and the economic implications of changes in protection. This study estimated that the total economic value of the MPAs in the garden route at R421 million. Most importantly, however, the study estimated that opening of parts of Tsitsikamma will result in an overall nett economic loss of R31 million. Based on interviews in the park, it is estimated that relaxation of protection will result in a 16% decrease in visitation, or a direct economic loss of R4,7 million per annum. Conversely the value of fish extracted from these previously closed areas was only likely to yield a once off value of R4 million, before fish stocks are degraded to levels comparable to those outside the park. These benefits would also be short lived, and it is estimated that the natural capital built up in these areas would be fished down in approximately 33 fishing days.

Furthermore, the value of the Tsitsikamma MPA in terms of reseeding adjacent areas and thereby supporting surrounding commercial line fisheries, was estimated at some R33 million. Opening up parts of the MPA will greatly derogate from this reseeding function. What is even more puzzling is that the DEAT appears to intend opening up parts of the Tsitsikamma to a small group of recreational fishers. By definition ‘‘recreational fishing’’ means, any fishing done for leisure or sport (Marine Living Resources Act 18 of 1998). Therefore the DEAT intends allowing people fishing “for leisure” to derogate from a critically important fisheries management tool, that is supporting the livelihoods of ‘bona fide’ fishermen and their families to the tune of R33 million.

The South African government has publicly committed itself to increasing the marine areas under protection of MPAs to 20% of our Exclusive Economic Zone (EEZ) by 2012. Although some 19% of our coastline is in MPAs, currently less than 1% of our EEZ enjoys such protection. Opening up parts of our oldest and most valuable MPA is therefore in stark contrast to this commitment. It is also particularly disappointing that we appear to now be moving backwards on what was always an ambitious yet achievable goal.

It is also believed that due process has not been followed to date in arriving at what appears to be a predetermined outcome. Tsitsikamma MPA is South Africa’s oldest and most valuable MPA, is a national biodiversity asset, and serves a nationally important fisheries management role. As such it is entirely inappropriate that decisions regarding its future are made exclusively between government officials and highly vociferous local stakeholders. The national importance of this asset calls that such a matter be subject to national debate and input. The question therefore being asked of DEAT is, what have they done to achieve meaningful public participation of all role players in this matter?

The reason why people want to fish, hunt, chop wood, collect medicinal plants and other natural resources for consumptive purposes within a protected area is because they have depleted the resource outside of the area. In the view of the GRAA, conservation organisations should be educating and training populations outside of protected areas how to manage their resources correctly and sustainably before allowing consumptive utilization within. The fact that it may be easier to adjust legislation to accommodate demands than to make a concerted effort to apply education, awareness and law enforcement is possibly indicative of the weakening powers and will of official environmental and conservation organizations.

Ends

Enquiries: Wayne Lotter
Chairman: Game Rangers Association of Africa
waynelotter@iafrica.com
Mobile: 0794987086
www.gameranger.org

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GRAA POSITION ON COMMERCIALISATION AND PROTECTED AREAS

The conservation of a nation’s natural and cultural heritage is a primary function of the government of the day. In South Africa the government currently partly subsidizes its National Parks to the tune of 18% of its total operational budget. However, inflation has been eroding the government subsidy over the last number of years and plans are in the pipeline to eventually cut this subsidy grant and make SANParks financially independent from Treasury (Mabunda, 2004). The trend is similar with many other national, provincial and local governments and protected area (PA) agencies in Africa. According to Mabunda (2004) there is no conservation agency the world over that is not supported financially by the state and it is unrealistic to expect PA agencies to cover these costs. As per the findings of Kumleben et al. (1998) government and other authorities should understand and accept that protected areas will, by and large, not be able to pay for themselves.

Commercialisation is seen as an approach that will integrate business ethics in natural resource management and make PAs pay for themselves. The word commercialisation is a noun derived from a verb commercialise which means “manage or exploit in a way designed to make profit”. This word should therefore be treated with circumspection whenever it is used in the context of conservation because it is contrary to the principles thereof.

Uncontrollable expansion of PA facilities as a result of tourism demand affects the PA’s values. Management of all development needs to give priority to conservation of the core values of the PA, on which sustainable tourism and high quality tourist experience depends (Mabunda, 2004).

PAs are a means to an end, and that end is the protection and maintenance of all forms of wild biodiversity (Locke & Dearden, 2005) and to provide environmental goods and services to society. Many forms of biodiversity would otherwise be eliminated from the landscape by competing human activities. Ideally, humanity should be able to accommodate these other species without formal PAs but global experience shows that this is not the case and that PAs of the traditional kind are needed (Locke & Dearden, 2005).

The GRAA is therefore concerned wherever core business in PA management is not receiving priority attention from PA management authorities: e.g. filling of conservation positions (Field Rangers, General Workers), supply of equipment (sometimes depends on “soft money” e.g. Honorary Ranger support) and more. Sustainable utilisation of natural resources is acknowledged as an objective in certain categories of PAs, where it was included in their original objectives. However, these activities and developments should not be done at the expense of the core business of PAs.

Ideally, the new IUCN PA categories V (culturally modified landscapes) and VI (managed resource areas) should be reclassified as sustainable development areas (SDAs). To do so would better serve both the protection of wild biodiversity and those seeking to meet human needs on more modified landscapes where sustainable development is practised. Reclassifying categories V and VI as SDAs would promote complementary goals to those of categories I-IV PAs of the IUCN system, while eliminating the confusion and distraction caused by the drive for a new paradigm for PAs. Fundamentally, all PAs should share the trait that they put the needs of other organisms over those of humans, although they can accommodate a range of human activities compatible with that overriding objective. The vision of humanized PAs will lead to a biologically impoverished planet, which would represent a tragic failure of the PA agenda (Locke & Dearden, 2005).

The pressure on the PAs ecosystems and ecological processes as a result of the increase of tourist use threatens the natural attractiveness of PAs as nature-based holiday destinations. The lack of indicators and measurement instruments to assess profound tourism impacts on the PA values is cause for concern. PAs should be managed conservatively and sustainably to ensure that their values are not degraded. Tourism in PAs is not managed in an integrated and professional manner and there are clear reasons to be concerned about the manner in which commercialisation is being implemented. All of the above views directly reflect findings from the study by Mabunda (2004) of tourism and the Kruger National Park.

New forms of income-generating activities and developments for formal protected areas (trophy hunting, cycle races, luxury lodges offering off-road driving experiences, etc.) should therefore not be introduced to proclaimed PAs of the long-established kind without thorough stakeholder participation and assessments of cumulative impacts, but should/could preferably be used as incentives to help African countries reach national targets towards expanding their PA network. This can be done through partnerships with stakeholders with conservation motives, for initiatives such as creating buffer zones/SDAs on the periphery of PAs, corridors between PAs, transfrontier conservation areas, for untransformed private sector or community owned land neighbouring PAs, or other conservation compatible activities. This proposed approach aims to keep governments committed to paying for/towards the management of the current PAs as they have done until now, and to help make the goal of creating new conservation areas (whether they be in partnership with local communities, abutting existing reserves, or not) more attainable because it would not place a further burden on governments to pay for the upkeep of these new areas.

The further commercialisation of existing PAs (which have the advantages of having all the biodiversity assets that they already contain, of being state subsidized, etc.) may be counter-productive in so far as it weakens the potential viability of proposed new PAs to vie financially. Approved new commercial products/ opportunities should thus be preferentially given to new areas to maximize their potential to generate an income for their own upkeep. This approach also decreases the risks to us as GRAA members with respect to us “becoming party to the diminishing of the assets” of our natural areas (as per our Manifesto), and may even lead to us helping to increase the “natural estate” and its assets.

In summary, the GRAA supports and encourages the following:

* The GRAA, as an active member of both the IUCN and IRF, offers its expertise to implement these recommendations.

PAs should be accessible to all sectors of society but the line should be drawn when it comes to supporting the further development of long-established PAs for primarily commercial reasons – particularly when this creates precedents.

It is suggested that the proposed GRAA Position on Commercialisation and PAs makes good sense from a) an ecological perspective, b) a financial viability perspective for the desired new conservation areas and community partnerships etc. (avoiding the stronger and larger reserves from strengthening the monopoly they already have in terms of other forms of tourism), and c) from a Precautionary Principle perspective – ie. for affording maximum protection to our core traditional PAs and best preserving their sense of place (especially protecting them against ecotourism impacts such as off-road driving, new roads, etc. which are insidious and very difficult to measure and to manage).

Primary Reference sources:
Kumleben, M.E., Sangweni, S.S. & Ledger, J.A. 1998. Board of Investigation into the Institutional Arrangements for Nature Conservation in South Africa. Pretoria: Government of South Africa.
Locke, H. & Dearden, P. 2005. Rethinking protected area categories and the new paradigm. Environmental Conservation 32 (1): 1-10.
Mabunda, M.D. 2004. An Integrated Tourism Management Framework for the Kruger National Park, South Africa, 2003. PhD Thesis, University of Pretoria, Department of Tourism Management.

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GAME RANGERS ASSOCIATION OF AFRICA’S POSITION ON HUNTING IN SOUTH AFRICAN PROTECTED AREAS

There is more wildlife on private land in South Africa today than there was before wildlife became an economically viable form of land use. In areas that are not suitable for non-consumptive tourism, the hunting industry has created the basis for many livestock production units to convert to extensive wildlife production. Hunting is both a revenue-earner and a tool to support conservation management objectives. The societal, economical and environmental gains that this industry has created merits support and protection.

In the African Indaba eNewsletter and elsewhere there has been an increased level of lobbying for hunting inside protected areas in South Africa. Opposition to these views has come from various quarters, including the SA Hunters’ and Game Conservation Association (SAJWV) who published an official statement totally rejecting hunting in national parks. SAJWV also mentioned that only about 0.5% of South Africans are hunters and that the parks system belongs to all people. In their official statement SAJWV cited, inter alia, ecological impacts of hunting in national parks and ethical considerations as reasons why they can not endorse the proposed hunting in national parks.

In the Game Rangers Association of Africa’s (GRAA’s) comment on hunting in South Africa dated 3 July 2005 the view was put forward that the South African professional hunting industry has not been policed as well as it should have been. The GRAA also recommended that the Minister of Environmental Affairs and Tourism (hereafter referred to as the Minister) take steps to ensure that the standards in the professional hunting industry are raised and maintained and, if possible, an independent body should play a role in policing the industry.

A statement by the Office of the Minister on 25 October 2005 read: “It seems as if the central overarching problem in South Africa is that there is no coherent and comprehensive oversight of the hunting industry in South Africa, and a lack of clear national norms and standards for sustainable hunting.” As a result of the economic opportunities presented by potential trophy animals, the Minister’s Panel of Experts on Recreational and Professional Hunting (hereafter referred to as the Panel) found that there is a tendency for these economic objectives to override the conservation management objectives!

The Panel emphasized that the system of national and provincial parks in South Africa accords the highest level of conservation to areas of unique biodiversity significance. These parks are mostly on publicly owned land, although the Protected Areas Act does provide for the incorporation of privately owned land into such parks on a contractual basis. The national and provincial parks systems are vitally important for biodiversity conservation and they also provide a unique experience for the persons visiting them. There is “sense of place” and an experience of nature that should be protected in these areas.

In principle the GRAA supports the recommendation of the Panel (on which the Professional Hunters Association of South Africa was represented) that commercial hunting practices should be prohibited on publicly owned land in national and provincial parks - this includes special nature reserves, national parks and nature reserves as per the Protected Areas Act definitions. However, commercial hunting has already been allowed in some publicly owned protected areas in South Africa for some time, such as in former Bophutatswana (apartheid era independent state) national parks which are now managed by the relevant Provincial protected area agency. In recognition of the important role that hunting plays in these areas, the GRAA therefore recommends that the principle should be applied that there should not be hunting in protected areas except in those that were/are originally established with hunting as one of their primary founding objectives.

In determining a hunting policy for South Africa it is fitting to compare and consider the policies in other African countries. Tanzania is Africa’s leading hunting destination. In that country a clear distinction is made between Game Reserves (i.e. Selous), where hunting is allowed, and National Parks (i.e. Serengeti), where hunting is prohibited. In Kenya, hunting is not allowed in any public protected area. In Namibia hunting is recognized as a legitimate land use that makes an important contribution to the economy – it creates jobs and funds the management of areas that are not suitable for non-consumptive tourism - but hunting is also not allowed in national parks. In the case of South Africa where hunting is allowed in certain protected areas, perhaps a clear distinction should be made between these parks and other protected areas, as is the case in Tanzania?

GRAA Position on related issues pertaining to hunting in South Africa:

The GRAA supports the views of the Panel which acknowledges that there is a need to manage population numbers in protected areas and recommends that where culling is required it should be undertaken by the public authority in charge and not made available on concession. Furthermore, that where contractual parks have been established with private landowners and community, or where fences between private land and national and provincial parks have been removed, limited forms of hunting can be allowed on that private land, subject to the agreement of the conservation authority in charge of the park, the establishment of a proper management plan, and scientifically based off-take. Similar arrangements should apply to hunting in protected environments outside of the parks system.

Damage-causing animals (DCAs):
While damage-causing animals are a significant problem for communities and farmers living adjacent to parks and game reserves, efforts to solve the problem by contracting it out to commercial hunters have led to some DCAs being declared artificially. The GRAA supports the recommendation of the Panel which states that DCAs be dealt with under a separate policy process, and that no DCA should be hunted or be dealt with through a hunting concession.

“Green” hunting:
In terms of so-called “green” hunting, the repeated darting of an animal for commercial purposes is considered an inhumane practice. There needs to be a clear distinction between darting for scientific and management purposes, and the practice of hunting for commercial gain.

Self-regulation and accreditation:
There is a need for the formal recognition of national representative organizations that stand for the interests of the professional hunting, recreational hunting and associated industries. The role of these organizations would be to ensure that members of their respective sectors adhere to acceptable codes of conduct and ethics. The establishment of a suitable independent accreditation system is recommended. This system could become the basis for granting permits to professional hunters and outfitters, and could ensure accurate and verifiable reports are submitted to the Minister on an annual basis in a manner that is consistent with the national reporting system. The GRAA has previously and pro-actively supported regulated, responsible and sustainable hunting in appropriate areas. Where possible, the GRAA is willing to provide voluntary assistance to the Minister in any implementation of the recommendations of the Panel.

Disclaimer: This statement was prepared by members of the Executive Committee of the GRAA and was circulated to its members for comment. While the majority of members support the contents of this statement, there are some who may not be in complete agreement, and the statement may thus not represent the opinions of all its members.

Note: The above statement was endorsed by all GRAA members present at the 2006 AGM.

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MEDIA STATEMENT ON SOUTH AFRICA’S ENVIRONMENTAL FISCAL POLICY

Game Rangers Association of Africa suggestion for funding

Much has been said and written in recent months about the very healthy state of the South African economy and Finance Minister Trevor Manual has even invited Civil Society to make suggestions regarding where and how excess funds should be invested and spent.

In a recent article in The Witness entitled “SARS owed R35 billion” (dated April 4, 2006) it was stated that “Finance Minister Trevor Manuel has announced that SARS collected R1 billion more than the revised budget of R417 billion for the last financial year. The R418 116 billion collected was also R45, 3 billion more than the original estimate of R372,8 billion … The preliminary revenue result we announced today gives further credence and justification to the mood of optimism and confidence in the country and our ability to fund our ambition for a better life for all South Africans, Manuel said.”

The Game Rangers Association of Africa (GRAA) therefore suggests that Minister Manuel strongly re-considers the budgets allocated to the protection of protected areas in South Africa.

In an article published in Earthyear in 2004, SANParks CEO David Mabunda rightfully questioned whether it is realistic to expect conservation agencies to be self-supporting or financially self-sufficient. Conservation agencies suffer from chronic financial problems that prevent them carrying out their conservation mandate adequately. In developed countries around the world the cost of managing protected areas is mostly fully borne by the state, whereas in developing countries there is a mix of donor-dependency and heavy reliance on tourism development. In South Africa, it is understandable that the past apartheid imbalances in our society should be addressed, including the lack of adequate housing, health care systems, water and electricity as well as infrastructure development. However, as Mabunda pointed out, this should happen alongside other constitutional imperatives including the protection of the environment!

Although SANParks generates approximately 80% of its operational revenue from tourism and is a world leader in this regard, there are limitations to tourism performance, if the biodiversity mandate is not to be compromised. Tourism in protected areas is not the panacea for the survival of nature conservation and enhancement of local economies. In spite of the controversial commercialisation programme implemented by SANParks since 2000 (which generates approximately 8, 5% of SANParks total tourism income of over R200-million), not all national parks generate a surplus or break even. Only five out of the total of 20 parks do, whereas the 15 loss-making ones are of biodiversity value and most will probably never break even. The same is true for the majority of our provincial protected areas. It should be recognized that the Kumleben commission of inquiry into the state of conservation in 1988 concluded that “nature conservation as such can never be self-supporting … it is therefore short-sighted and fallacious to expect a protected area to become economically self-sufficient”.

South Africa’s national park estate expansion of approximately 140 000 hectares since 1994 has not been followed by an increase in the state operational grant. Furthermore, the cost of conservation (fencing, resource protection, restocking of species, disease-control, monitoring, construction of management roads, administration, etc) has increased markedly in the last decade or so, yet state operational grants have decreased in relative terms. Protected areas should not be declared without providing for the accompanying operational and capital costs.

Over-dependence on tourism to fund protected area management can lead to unsustainable tourism practices. As Mabunda cautioned, we could see the Kruger taking the Disney World route, and in fact many argue that South Africa’s flagship park has already commenced along this route. The risk of introducing tourism products that will compromise the aesthetic and ecological attributes (including wilderness qualities) of protected areas to achieve “financial self-sufficiency” is a very real one. Over-development of tourism facilities to the extent that they alter the ecological integrity of the protected area is another danger. Within this picture, many South Africans are excluded from conservation areas because of the tourist based pricing structures. To counter these risks, the state must fulfill its primary obligation to fund environmental protection adequately!

Society does not create protected areas for financial profit but to conserve the natural, cultural and historical landscapes for the benefit of present and future generations. To evaluate a protected area’s success and value in terms of the financial bottom-line alone is simplistic and disingenuous. Financial prudence in resource utilisation should not be confused with financial self-sufficiency. The state will always have a constitutional obligation to fund the public good, which includes the protection of the environment in terms of section 24 of the Constitution.

End

Chairman
Game Rangers Association of Africa
PO Box 78, Rosetta 3301 KZN,
South Africa
Telefax +27(0) 33 2677171;
Mobile +27(0) 82 4634104

8 th May 2006

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