COMMENTS ON KWAZULU-NATAL ENVIRONMENTAL, BIODIVERSITY AND
PROTECTED AREAS MANAGEMENT BILL, 2014
Many pet shops and animal owners have strong conservation ethics and feel that in
instances where certain species have a strong likelihood of escaping the trade (no
pun intended) into the wild, there is a definite need to have these species controlled
or even banned. This is however only necessary where such species have the
potential to establish a feral population and is likely to have a detrimental effect on
indigenous species and their environment. Such an argument, for example, can be
made for red eared sliders and related species.
That being said, the latest proposed list for restricting the keeping of animals in KZN
appears to be random, non-scientific and in some instances malicious. Some of
these species were quickly removed from the national list which was proposed
several months back and no longer occur on the new, yet to be published list. Some
of the KZN listed species were not even up for discussion on the National list
assembled by top scientists including those from KZN. Surely valid scientific
motivation needs to be introduced before these species can now be considered for
inclusion otherwise thousands of pet owners are instantly and unnecessarily
deemed to be illegal.
Many of the listed species have been imported legally on permits issued by the
Ezemvelo office. Further to this fact many have had EIA’s done proclaiming them to
be free from any risk of being invasive. Many of the species were imported for the
pet trade as they come in a variety of colour and pattern variations making them
hobbyists’ specialties. These colour variations make them even less likely of being
at risk of establishing populations. These species are being bred commercially and
provide much needed employment directly and indirectly through the production and
manufacture of food, cages, accessories, literature, sale of animal’s, maintenance
and other husbandry requirements. These benefits to the economy far outweigh the
very slight and often insignificant risk of a possible feral population.
It must be noted that as with any livestock (including agriculture, domestic and
wildlife) escapes from designated areas do sometimes occur. Activities associated
with such livestock are not threatened with bans as a result, in spite of the fact that
pigs, goats, horses and even warthog have established known feral populations.
Boa Constrictors, corn snakes, carpet pythons, Burmese and many other listed
snakes and lizards have been an integral part of the pet trade for at least 30years, if
not longer. I have personally been breeding them for 25 years. The length of time
that they have been in the trade without establishing feral populations, even though
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no restrictions have been enforced, points towards a low risk of potential
colonisation. A free living individual animal found outside its cage does not amount
to a feral population which breeds, expands, invades and causes a threat to the
environment.
It is generally considered that a minimum of 200 individuals need to be
simultaneously released into a suitable area to create a reasonable chance for a
viable population to establish. This was attempted in the translocation of East
African Gaboon Vipers Bitis Gabonica from Dukuduk area to the Mtunzini area.
This new area was deemed to be suitable on all levels by research teams and
accepted by Ezemvelo them-selves, yet is still to be considered a success.
“In 1995, Ezemvelo Kwazulu/Natal Wildlife (EKZNW) approved a project to translocate as many
B. Gabonica as possible from Dukuduk Forest, to Umlalazi Nature Reserve, since Dukuduk Forest was
under serious threat from habitat degradation. Although outside its known range, Umlalazi was
considered suitable habitat and was under conservation management (Botbijl 1996). Initially the aims of
the project were to capture and translocate 80 snakes (Botbijl 1994b). The translocations were initially
infrequent, but increased in frequency until the project was stopped, by EKZNW (Armstrong, A.,
Ezemvelo Kwazulu/Natal Wildlife, PO Box 13053, Cascades, 3201pers. comm.) in 1998. By this time
approximately 200 snakes had been caught, paid for and translocated. The project was terminated
Due to, among others, concerns about the suitability of Umlalazi, the survival of translocated snakes,
and the creation of a market (at R200 each) for a rare animal. The remaining snakes in captivity were
released on the eastern shores of Lake St. Lucia.” R Kyle, excerpt from Koedoe 46/2 (2003),
The status of and some notes on the Gaboon adder Bitis Gabonica in northern
Kwazulu/Natal, South Africa and southern Mozambique
If Gaboons are so difficult to translocate successfully in suitable habitat, then why
such concerns for Gaboons kept in limited numbers outside of the natural home
range of our protected relic population? Especially when Ezemvelo themselves
issued permits for these animals to be imported legally into the province. Keeping
legally acquired and captive bred Gaboons in captivity, as is currently done, poses
no threat at all to wild populations and the keeping by private individuals should be
allowed. Poaching for the muti trade and any other collecting for any reason, on the
other hand, does pose a direct threat to our indigenous population, as it involves
directly removing wild Gaboons. Removing wild indigenous Gaboon vipers should
therefore be a banned activity.
“In summary, it appears that there is probably a secure, though possibly often low density, population of
B. Gabonica along almost the entire coastal strip from St. Lucia mouth to the Mozambique border.
Attempts to ‘save’ the species in South Africa by relocating all wild specimens to Umlalazi were thus
possibly misdirected and indicative of our tendency to over-manage in situations where data are
lacking.” R Kyle, excerpt from Koedoe 46/2 (2003), The status of and some notes on
the Gaboon adder Bitis Gabonica in northern Kwazulu/Natal, South Africa and
southern Mozambique.
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Most of the area where Gaboon vipers are found falls within the Greater St Lucia
Wetlands Reserve and should therefore be well protected.
I personally motivated for several years to obtain some of the captive born Gaboon
Viper babies produced by the Ezemvelo run croc centre in St Lucia. These
applications were turned down. Instead permits were granted for the same species
imported from Uganda which I still have. Now these permits are to be taken away
and the species no longer allowed under any circumstances. This decision was
made in spite of the fact that they are not of any concern to our local population and
they were acquired legally in the first place. This can surely not be reasonable or
acceptable.
This Gaboon scenario shows how irrational their inclusion is on the prohibited list,
and why this list needs to be re-addressed. There are no doubt instances where
some of the species listed require banning and control measures but this should
only be where it is necessary. I think further close consultation is required with
stakeholders to ensure that this list is both relevant and fair. An unworkable list will
not be in the interest of either conservation bodies, animal rights activists or the pet
trade. It will be unable to be self-regulated, nor controlled by Ezemvelo officials. I
feel registered businesses/members affiliated to an organisation such as SAPTA are
best qualified to ensure self-regulation. SAPTA, or another like-minded body, could
then be accountable for its members, to Ezemvelo and any department charged with
overseeing norms and standards. Non-members can then be managed by
Ezemvelo, or any department deemed necessary, therefore reducing their workload.
Colour mutations are an age long basis for animals in the pet trade. They are not
genetic abboritions but rather the result of selectively line breeding traits that nature
offers in order to make these animals more appealing to the people who want to
keep them. Such animals in captivity are not meant to mimic their wild relatives, nor
be used to restock wild populations. They are a population permanently removed
from the wild gene pool, and as such are not a conservation issue at all.
Many of the animals held and housed in captivity are far removed from their wild
cousins and as such are completely excluded from wild populations and their
conservation. They are no less domesticated than so many other animals which fall
under the banner of agriculture. Wild cattle were originally selectively bred for meat
and milk production, as they still are. Wild horses were originally bred to cater for a
wide range of disciplines, all domestic livestock and pets followed the same
evolution and are acceptable. Food plants such as rice, maize, fruit, veg etc. etc.
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followed the same modification and still do. Why should mankind not benefit on all
levels by allowing this process to continue while still maintaining an endless
reservoir of wildlife in protected well managed areas.
Some of the animals that we now keep as pets were not taken from wild populations
but come from other forms of farming practices such as chinchillas from the fur
trade, domesticated pygmy hedgehogs from the meat trade, where they have
already been bred for size and colour. How is it then that these animals are of a
conservation concern? It appears to me that there is a blurring between the
concerns of conservation bodies, charged with protection of wild populations, and
those of animal rights activists who don’t want any animals kept for any reason in
captivity. On a national scale and in a democracy this very small, but loud, group of
activists are seriously in the minority. The majority of people in the country keep
animals and appreciate those animals being kept. The freedom of this minority
group of people opposed to keeping animals should not be allowed to impinge on
the freedom and rights of the majority who wish to continue to keep and breed
animals as they have done historically.
I have thought for years that common ground must be met between animal keepers
and those opposed to the keeping. The rights to keep animals cannot be taken
away from people unless it poses a real and proven threat to our biodiversity.
Activists are minority extremists and although they have views that they are entitled
to, that is what they are, views. They should justifiably be allowed to contribute their
opinions during the establishment of norms and standards of keeping various
animals. Unfortunately animal rights activists seldom have “hands on” captive
husbandry experience, and as such are not in the best position to give practical
advice regarding the norms and standards for keeping animals successfully. Their
judgement is usually clouded by their single minded and uncompromising aim to
prevent the keeping of all animals. On the other hand, respected and experienced
keepers who are successful in their various fields and understand their respective
animals are in a way better position to make enlightened and invalid contributions
regarding animal husbandry. Of course many of these decisions have little to do
with the mandate of Ezemvelo which is to manage our biodiversity and conserve our
natural heritage. Asking Ezemvelo to manage exotic ex-situ animals puts
unnecessary strain on their employees. They will then be tasked with a work load
that they are ill equipped and unqualified for, unless time and money is invested
towards this end. This can be seen by the backlog in permit issuing, as a result of
their current under-staffing. It seems absurd or even discriminatory that certain
stakeholders were allowed to write their own sections regarding the law and norms
and standards because Ezemvelo staff felt they were not sufficiently qualified, yet
others appear to have been deliberately excluded from doing so. The purpose of
these comments is not to point out and humiliate individuals but rather to highlight
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the need to re-address the new bill and ensure that all stakeholders are treated
fairly.
Furthermore, the economic implication of removing such animal related business is
massive. It affects various animal clubs, breeders, pet owners, food manufacturers,
cage manufacturers, hardware importers and exporters, animal importers and
exporters, substrate suppliers, not to mention non pet shop related activities such as
angling (supply stores, resorts and stockists), hunting, film industry etc. The
economic ramifications will be catastrophic and put many out of work causing untold
stress on extended families dependant on the salaries. This loss of income can
surely not be afforded in the country’s current state of unemployment.
With regards to animals that were brought into the country and province legally as
investments:
- How will these investments be realised?
- Who will compensate these investors and employees for loss of
income?
- How will the resultant job losses be dealt with?
- Will these legal animals be able to be exported to recoup some of
the losses?
Points to ponder regarding Permits:
- The issue must be timeous so not to impede business
- For non-restricted species permits should not be required.
- For permitted species an annual log indicating the distribution of
these animals could be submitted and alleviate unnecessary
workloads.
- Specially protected and permitted animals requiring registered
facilities can then be inspected more easily.
- The Banned list needs serious restructuring and amending.
Therefore should be re-addressed to determine what is permitted
and what not.
- If a species is known to be allowed then why permits or at the
very least why the delay in permits being issued. Some provinces
take 48 hrs to issue permits and some 14 working days.
- Permits can be a source of revenue for Ezemvelo
Permits of mine, Annual Keeping Permits, as well as many of my customers have
not been issued for years. Any queries have just resulted in a “Don’t worry we know
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about you, there is no reason for concern”. Yet we sit officially without permits year
after year, in spite of phoning and emailing asking for a response. If an inspection is
not possible because of understaffing and we have had these animals on permit for
years, then we should have our permits issued. Ezemvelo should not be making
their problems ours. We do not appreciate being labelled “illegal”.
Ex-situ animals from a legal source should be allowed, within reason and as long as
they are not banned, to be kept and bred to supply the demand of others wishing to
keep them. These ex-situ animals are not taken from the wild, do not impact on wild
populations and run no threat of being invasive (unless proven so and listed) and
these animals are therefore not a conservation priority.
With regards to working with animals man has kept and developed relationships with
various wild animals since very early times. Initially, for functional purposes such as
hunting and food production. These purposes have changed with time. Regardless
of the purpose we have always had the opportunity of developing beneficial and
humane uses for various animals. Why curtail future possibilities of using wild life to
better the lives of so many desperate and impoverished people? New developments
such as dogs being used to discover cancer in people, pouched rats for locating
landmines, as well accurately pinpointing TB sufferers, pigeons for finding people
lost at sea, ferrets for pulling optic fibre cables, snake venom for pain and cancer
research etc. etc. would not be possible were it not for the opportunity of tapping into
the incredible hidden talents of captive animals.
Even century old past times of making bonsai’s is allowed while equally old hobbies
of keeping goldfish, koi, canaries and more recently various birds, mammals, ball
pythons and corn snakes is not. Why should emerging hobbies and interests that
are equally harmless to our biodiversity be discriminated against, because a minority
of animal activists disapprove. People who have hobbies and interests divorce
themselves from many social ills and they channel their energies constructively.
Why should this positive and constructive pastime “our right” be taken away from
us?
The number of people drawing a living from animal related industries, although
difficult to quantify, is huge. Unnecessarily stifling this industry would be a huge
economic disaster for many. Targeting pet shops and breeders is not a solution as
it will result in uncontrolled trade. Information pertaining to “best practice”
husbandry will fail to reach the owners of the animals. Information regarding all
aspects of correct husbandry (caging, housing, nutrition, behavioural requirements,
enrichment of the environment, and health issues) provided by reputable pet shops
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and breeders, will no longer be relayed and the result will be the suffering of kept
animals. This in turn defeats the aims of any sane minded and self-respecting
person concerned with animal rights, which we as pet owners are.
As far as my specific shop is concerned, I have a staff compliment of 10 people who
in turn support several extended families. The shop supports 29 regular large
suppliers as well as hundreds of smaller suppliers, who all generate an income from
dealing with shops such as mine. These suppliers have their own staff members
who support extended families. At the risk of sounding arrogant, my shop alone both
directly and indirectly supports hundreds and possibly thousands of people. This
realisation extrapolated across the hundreds of pet shops nationally is significant.
Pet shops alone contribute to the economy by providing livelihoods for thousands of
people.
LET US HOPE THAT SANITY PREVAILS
Regards
RJ Boynton (Owner)
Creatures & Critters Pet Shop
Contact numbers
: Tel (031) 7656338
Fax (031) 7653478
Cell 072-1155022
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