The EWT calls for a revision and republication of a completed Draft Biodiversity Economy Strategy for public comment
By Eleanor Momberg
The Endangered Wildlife Trust (EWT) has called for a revision and the republication for public comment, for a period of 30 days, of the government’s National Biodiversity Economy Strategy (NBES).
The Strategy was published for a 14-day public comment period on 8 March 2024. The comment period was later extended to 16 April 2024.
The EWT submitted extensive comments in two parts to the Department of Forestry, Fisheries and the Environment (DFFE) on 16 April 2024 outlining its general arguments regarding the NBES and detailed comment on specific issues contained in the document.
An initial NBES was published for implementation by the Department in 2016 outlining the steps necessary to ensure the success of the commercial wildlife and bioprospecting industries, as well as the transformation of both sectors of the South African economy. The 14-year plan’s aim was to provide a basis for addressing constraints to growth, ensuring sustainability, identifying clear stakeholder’s responsibilities and monitoring progress of the Enabling Actions. In terms of the first NBES, the goal has been to achieve an average annualised GDP growth rate of 10% per annum by 2030 in the biodiversity economy.
The Draft National Biodiversity Economy Strategy gazetted in March 2024 (link to the gazette) is a revision of the existing NBES and aims to “optimise biodiversity-based business potentials” across most economic sectors “for thriving people and nature”.
“In reviewing the NBES, the Strategy has been broadened to respond to the White Paper on Conservation and Sustainable Use of South Africa ‘s Biodiversity (the White Paper) as well as the Kunming-Montreal Global Biodiversity Framework (GBF), whilst incorporating the outcomes of the National Operation Phakisa Oceans and Biodiversity Labs, and addressing opportunities associated with all ecosystems,” the NBES Executive Summary states.
By broadening the terms of the Strategy, it has been “completely reconceptualised as a broad strategy to guide the whole of the biodiversity economy”.
The EWT, in its comments on the latest iteration of the NBES (link to the laws document), recognises the value that ecological sustainable use of wildlife brings to South Africa, and supports conservation practices that, within the scope of the law in the country, promote the ecologically sustainable use of wild animals in natural free-living conditions to the benefit of all.
While the EWT upholds the provisions of the environmental right contained in the Constitution, it does not support the industrial-scale production and management of South Africa’s wildlife when these activities are not in line with the principles of ecologically sustainable use, animal well-being and do not benefit the conservation of the species in the wild.
“These practices may also result in environmental harm and wildlife well-being concerns,” the EWT submission states.
In welcoming the opportunity to play a constructive role in developing an appropriate and equitable biodiversity economy strategy as part of the broader development of a sustainable green economy, while ensuring the enhanced protection of the country’s biodiversity, the EWT submits that the NBES itself is lacking in both content and clarity. Unless revised, it risks impeding ecologically sustainable use.
More information is required on the business cases underpinning the actions listed, and the economic information that has been considered in motivation for these activities.
“Critically, the NBES as it stands lacks SMART objectives, objectives that are specific, measurable, achievable, realistic and time bound.”
Detailed comments by the EWT deal with the goals outlined in the NBES highlighting various shortcomings requiring attentions. In almost all instances, the EWT points out a lack of clarity on the goals proposed, whether these can be justified, or considered realistic.
The EWT’s response to the first goal related to leverage biodiversity-based features to scale inclusive ecotourism industry growth in seascapes and in sustainable conservation land-use, points out the lack of explanation to justify targets provided, as well as the lack of clarity on what type of ecotourism infrastructure is to be developed in the buffer zones.
Similarly, with the goal to prioritise infrastructure development and viable enterprises in community reserves and areas adjacent to fauna/ Biq 5 areas. Here the EWT states the prioritising infrastructure development on the edge of protected areas undermines the principles of establishing ecological buffers around protected areas, a core principle for retaining the integrity of these areas as illustrated by the spatial structure of biosphere reserves, as well as Ecological Support Areas surrounding Critical Biodiversity Areas. These projects in must comply with environmental regulations to mitigate potential negative impacts on ecosystems, habitats, or protected areas, ensuring compliance with relevant laws and regulations and avoiding residual impacts where possible.
The EWT points out that the second goal of consumptive use of game from extensive wildlife systems at scale that drives transformation and expanded sustainable conservation compatible land-use lacks clarity. It is unrealistic and could potentially undermine sustainable management efforts to expect consumptive use of game from extensive systems at scale to “drive” transformation.
Questioning how realistic the hunting targets proposed are, the EWT points out that the NBES is silent on whether there is in fact a market for the degree of hunting indicated, adding that the quota targets have not been justified with an economic motivation that explains their contribution towards national tourism and or socio-economic revenue. The same applies to the actions related to so-called traditional hunting. If these hunting methods are illegal, unsustainable or do not ensure the well-being of the animal, the EWT cannot supported the action, even if it is considered traditional.
Regarding legislation to guide the implementation of the game meat industry, the EWT states that while it supports initiatives to advance game meat consumption, “we are wholly opposed to the slaughter of wild animals in abattoirs as this fundamentally infringes on their well-being”.
Until the Game Meat Regulations are promulgated and the exception to section 11(1)(i) of the Meat Safety Act 40 of 2000 becomes effective, game meat production as an economic opportunity is not viable. Game meat production can only be commercialised if the legislation governing the slaughter, processing and sale is promulgated, implemented and enforced.
The NBES is also silent on how the well-being of the individual animals will be considered and ensured. It is critical that the well-being of the animals utilised have been addressed with respect to their nutritional, environmental, physical, behavioural and mental health, when placed within these areas for ecologically sustainable harvesting.
The EWT adds that while it recognises the importance of a more inclusive fisheries sector, most of the country’s commercial marine harvesting is already at capacity and there is very little room to sustainably expand this without compromising the stocks and detrimentally impacting vulnerable ecosystems and threatened species. Thus, any strategy developed around sustainable marine harvesting would also need to account for maintaining fish stocks at a viable level to sustain species dependant on them such as the African Penguin.
The organisation also argues that abalone poaching cannot be attributed to “non-transformation of the sector,” stating that enhanced regulation and stringent enforcement is required to curb these illegal activities.
With regard to identifying mechanisms to scale cultivation of indigenous medicinal plants for sustainable use within the traditional medicine sector, the EWT submits that without the inclusion of market evaluations and financial data, it is difficult to evaluate how the number of nurseries identified in the NBES is warranted and can be sustained.
With regard to the resolution of outstanding land claims, the EWT submits that this is a critical barrier to protected area exapansion and proposes that a target be included for provincial proclamations of protected areas It would be beneficial, the EWT statesm if all undeveloped governmentproperties are collated and published for more insight and a review into the realistic opportunity for long-term conservation security.
Clarity is sought to what the NBES regards as “large community owned conservation areas”, as without this it would not be possible to determine whether this objective has been achieved or not.
Commenting on the enabler related to financing of the biodiversity economy, the EWT expressed its concern with the suggestion that this action would pay for conservation alone, without an assessment of the contribution of the full value chain of biodiversity and for the value of all ecosystem services towards the national economy and for human well-being being considered.
Alternative and more creative means of finance needed to be sourced and implemented to ensure the success of the biodiversity economy, and related Strategy.
Although the EWT supports the intention of DFFE to explore and develop economic opportunities relating to the ecologically sustainable and ethical use of biodiversity resources, the draft NBES requires extensive amendment. It is hoped that through the public comments received the present draft NBES would be enhanced before being published for a new round of public participation.
“The NBES needs to be revised, fully completed and republished for public comment for a minimum of 30 days,” the EWT submission reads.