A lot has appeared in the media arguing the toss about whether the proposed development of a Game Farm or “Wildlife Sanctuary” outside Kleinmond is a good or bad idea. Most of the arguments have related to whether the keeping of elephants and other “wild” animals for tourists to view is a good or bad thing. Whale Coast Conservation (WCC) is of course concerned about the morality of keeping “wild” animals captive in small camps where tourists can view them at close quarters, but we are focusing on the detrimental effects the proposed development will have on the sensitive ecosystems on Lamloch Farm No. 892.
From a moral perspective we need to get clarity from the developer on a number of issues. Firstly, is the proposal for the creation of a ”wildlife sanctuary”, which is a place created for the benefit of the animals where they are protected from harm, or is it a “game farm”, which is a place where animals are bred for commercial purposes? From the Pre-Application Basic Assessment Report (PBAR), which gives the intention as “The Applicant wishes to introduce eight elephants and other wild life for tourism purposes”, clearly, the purpose is for the commercial exploitation of the animals, so the Wildlife Sanctuary signs erected on the property are misleading and should be amended to read “Game Farm”.
Continuing with the moral issues, can the animals to be housed be truly referred to as “wildlife”? The animals will have been in captivity and have been acquired through commercial transactions. They are going to be enclosed in camps separated by electrified fences. Unable to forage for food, they will be fed by keepers, habituated to the point where they will be incapable of being returned to the wild. This is the antithesis of environmental conservation; a practice that internationally is being forced out of existence because of the deleterious, cruel effect on the captive animals.
Do we want to allow the introduction of a game farm, masquerading as a wildlife sanctuary, that will exhibit animals that are not endemic to the Overstrand and risk destroying sensitive and endangered ecosystems critical to endemic fauna and flora?
While society must deal with the moral issues involved, these are subjective and may be difficult to resolve. The clearly detrimental environmental effects of the proposed game farm on Lamloch Farm No. 892, and the interpretation of environmental law relating to the fencing of “coastal public property”, can be objectively assessed and can form the basis for deciding the merits of the proposal.
The property has been enclosed by an electrified game fence on the cadastral boundary. On the false assumption that the new fence simply replaces former fences, the developer was allowed to erect the fence across the watercourse that connects the Bot River Estuary with the Kleinmond estuary, a watercourse that WCC argues is defined in the Integrated Coastal Management Act as “Coastal Public Property” and should not be fenced. It is proposed that part of the area of the Bot River Estuary that has been enclosed by the boundary fence will have a tourist accommodation camp built over the water on stilts. How can this be contemplated in this sensitive environment? Surely the interests of the whole community dictate that the preservation of this watercourse must be protected from damaging development for the financial benefit of the developer?
The PBAR gives an understatement of the extent of the development relative to the area of the total property. It proposes that the footprint of buildings and infrastructure be the extent of the development. In truth, the whole of the area over which animal encampments will be created, and the area over which animals will be allowed to trample, should be included in the area deemed to be disturbed by the proposed Game Farm. That puts a very different perspective on the extent to which the proposed development will impact the property.
Environmental specialists have investigated the potential environmental impacts of the proposed game farm. The overwhelming majority of the environmental aspects considered will result in negative impacts, the only positive being removal of invasive alien vegetation, which was largely performed by Working for Water at taxpayer’s expense. A killer concern is that an adaptive approach is being proposed for the management of damage to endangered plant species, when the National Environmental Management Act prescribes the implementation of the “precautionary principle”.
In an adaptive approach, the philosophy is “try it and monitor the results, make changes according to what happens”. The precautionary approach requires that, if the risk of damage is present, don’t implement until or unless it can be shown that there will not be damage to biodiversity. This property is classified by the South African Biodiversity Institute as a Critical Biodiversity Area and it considered of worthy of inclusion into the core area of the Kogelberg Biosphere. Surely it is inappropriate to adopt an adaptive, wait and see what happens approach to such conservation-worthy land?
The Botanical Specialist notes the following: “The presence of elephants on the property would have a large influence on the future condition of the indigenous vegetation. It is uncertain whether the effects of their eating and trampling will have a significantly negative impact on the flora of the property (especially within the elephant camps, but also in the remainder of the property). It is therefore recommended that an assessment should be carried out before the elephants are introduced to the property to ascertain a baseline condition, and then at least once a year in the first three years of their presence on the property.
“After this, a follow-up assessment should be conducted every two years. This must be written into the EMPr (Environmental Management Programme) and carried out by a suitably qualified botanist/ecologist. If it is determined that the indigenous vegetation is being negatively impacted, the elephant numbers must either be reduced until a balance is achieved and the carrying capacity of the land is matched with the correct number of elephants or they must be accompanied at all time by a handler if they leave the camps to ensure that they do not cause excessive damage to the indigenous vegetation.”
Since the business model relies upon the elephants as a tourist drawcard, if the elephants are found to cause damage to the critically endangered flora on the property, they would have to be removed, thereby killing the financial viability of the development.
In the Betty’s Bay area there is an example of the effect of keeping horses in an encampment on the local fynbos. Within two to three years the fynbos was destroyed, and the encampment was transformed into a sand dune. Is that not likely to be the consequence of introducing elephants and other animals into encampments on the Lamloch property?
Alarmingly, Cape Nature has issued permits to the developer for keeping eight elephants before it has assessed the environmental impact of keeping them on the Lamloch property. Attempts to obtain copies of the application and the terms and conditions attached to the permit have been unsuccessful; Cape Nature refuses, even after receiving an application for information as provided by the Promotion of Access to Information Act, to provide information or copies of the application or permit. This is arrogance of the highest order and needs to be challenged in the public interest. The PBAR also does not include the elephant management plan; this too needs to be challenged in the public interest.
Details of the proposal can be found at https://www.dougjeff.co.za/index.php/projects/131-lamloch-game-farm-and-tourist-facilities. The deadline for comment is 2019-04-14. You are encouraged to take a personal interest in your environmental heritage and to submit comments. WCC will be doing so.