On the 10th of March 2017, Wild Tomorrow Fund submitted a letter of objection to the Director-General of South Africa's Department of Environmental Affairs. A copy of our letter is available below.

March 10th, 2017

Dear Director-General

Written Objection to Notice 74 of 2017: “Draft regulations for the domestic trade in rhinoceros horn or a part, product or derivative of rhinoceros horn” with regards to the National Environmental Management: Biodiversity ACT, 2004 (Act no. 10 of 2004).

Wild Tomorrow Fund (WTF) is a US-based non-profit organization dedicated to the protection of threatened and endangered wildlife and the landscapes they depend on for survival. We work on the ground in KwaZulu-Natal, a province facing escalating rhino poaching pressure. Together with Ezemvelo KZN Wildlife Reserves and several private reserves we are directly supporting anti-poaching measures including rhino dehorning projects.

We appreciate and respect the efforts of the Republic of South Africa’s Department of Environmental Affairs (DEA) in facing and combating wildlife crime. While we appreciate and respect the desire for communities to be able to benefit from the sustainable use of South Africa’s natural resources, we write with deep concern in objection to your draft regulations proposing a domestic trade in rhinoceros horn and international export of rhino horn by foreign individuals.

We oppose the draft regulations as we believe that:

● Legalization of the trade in rhino horn will act to legitimize the trade,undermining demand reduction efforts both nationally and internationally. We believe that legalization of rhino horn products will undo work that has been hard won to change the hearts, minds and practices of rhino horn users in major markets of demand. We believe it will reduce the negative incentive to consume rhino horn while creating new consumers and increasing overall demand.

● Legalization of the trade in rhino horn will undermine South Africa’s national enforcement efforts. It is well reported that a legal market often provides cover for the illegal market, including in well-regulated markets. This has been the experience in the US which has resulted in concerted and strengthened efforts to shut down the domestic trade in both ivory and rhino horn. The laundering of illegal rhino horn into the legal market raises the cost and complexity of enforcement. For example, how can already overburdened law enforcement personnel distinguish between legal and illegal horn in the domestic market? Anyone caught carrying horn can claim it is legal and produce an easily forged permit document. It is unlikely and prohibitively costly to carry out expensive DNA testing to prove illegality.

● Legalization of the trade in rhino horn will further enrich international wildlife traffickers at a time when the world must unite to strongly tackle the illegal wildlife trade. Although South Africa’s recently announced 2016 official rhino poaching statistics indicate a decline in rhino poaching, this average of three rhinos per day remains unacceptably high. This indicates a continuation of high demand for rhino horn by international criminal syndicates. Many rangers have been injured and killed both in South Africa and internationally defending rhinos from poachers. Recent events including the shocking attack on Thula Thula rhino orphanage and the poaching of Vince the four-year-old rhino at Paris Thoiry Zoo further demonstrate the criminality and violence of those currently involved in the rhino horn trade. There is extremely limited demand within South Africa for rhino horn product. Major end-use markets lie far beyond South Africa’s borders in Vietnam and China. It is undeniable that legal domestic rhino horn will make its way to these markets. The international trade in rhino horn has been banned under the United Nation’s Convention on International Trade in Endangered Species (CITES) since 1977. Given that rhino horn trade is banned internationally, we believe that the only potential buyers of South African rhino horn will be illegal wildlife traffickers. We urge stronger international cooperation to fight and pursue the criminals involved in international illegal wildlife trafficking, and do not support a proposed trade that will serve to benefit these networks.

● Legalisation of the trade in rhino horn risks increasing demand for wild rhino horn resulting in increased poaching pressure. Assessment of consumer appetite for rhino horn strongly suggests that total demand cannot be met by a combination of natural mortalities, current and future stockpiles, or farmed horn under current conditions for all of the potential major supply countries. We believe that even in a well-regulated legal market, legal farmed horn will create demand for ‘wild’ product and will not decrease demand for wild-poached rhino horn. The legalization of a rhino horn trade was discussed less than six months ago as a headline item of debate at the CITES 17th Conference of the Parties (CoP17). At this international forum, the proposal put forward by Swaziland to permit a regulated trade in white rhino horn was rejected overwhelmingly by the international conservation community and other stakeholders (100 against, 26 Parties in favor and 16 abstentions).

We believe that this sudden and unexpected proposed regulation by the DEA to legalize the domestic trade in rhino horn is against the prevailing views and consensus of the international conservation community. South Africa should not act alone as rhinos also range in other countries including in Asia where rhino populations are even more critically endangered than in South Africa.

South Africa is home to the largest population of rhinos remaining in the world. It is critically important for South Africa to stand strong for rhinos and oppose in clear terms the international trade in rhino horn. It is imperative that a global norm is set to reject the usage of rhino horn as traditional medicine and to reaffirm that a rhino horn has utility only for a rhino. There may be no second chance for South Africa’s rhinos if poaching does not decline, or even worse, escalates. We believe that legalizing the domestic trade in rhino horn is a risky strategy that will undermine urgent international efforts to protect rhinos.

Sincerely,

John Steward, Founder

Wendy Hapgood, Chief Operating Officer

Wild Tomorrow Fund

Seized rhino horn, New York 2015 at Times Square Ivory Crush.

WRITTEN OBJECTION TO DRAFT REGULATIONS ON DOMESTIC RHINO HORN TRADE