ANIMAL DAMAGE CONTROL INSTITUTE

One of the most important problems associated with the new laws is that some of the most important stakeholders was not consulted in the process of drawing up these laws(in particular the list of threatened or protected species). A process of consultation led the inception of the former National Problem Animal Policy committee in the mid 1980s. Involved were MECs, Conservation authorities, NGOs, Farmers, and some production organizations of agricultutral sector. Strategies, actionplans and operating procedures were hammered out and policy was established. This poinering example of cooperation happened a decade before the politcal changes in the country where this kind of cooperation were established as the standard. This committee still exist and has through the lapse of time adapted and shaped itself through this process of cooperation in the solving all the issue that arose. How then, may one ask, is it possible that such a smooth running and effective organization is swept off the table in one foul swoop and replaced by a bureaucratic law forced on the stake holders without any consultation???

"Government agencies for wildlife management must develop policies based on philosophy which is coherent and consistent and encompasses the gamut of wildlife/human conflicts. Without policy guidelines the alternative is often a piecemeal approach in response to immediate problems, which may lead to programs unduly influenced by the most vociferous, politically orientated, special interest group." Dorrance M.J.

2. NATIONAL NORMS AND STANDARDS FOR THE REGULATION OF THE HUNTING INDUSTRY IN SOUTH AFRICA

ABSTRACT

My comments are aimed at the Animal Damage Control (ADC) situation (formerly Problem Animal Control). The worldwide trend to address the problem from a holistic management perspective, rather than the killing of damage causing species is followed. However the effectiveness of non-lethal control methods are generally overrated and does not show the potential for solving most of the damage situations that commonly occur. Due to these imperfect methods, practicality, cost, and ecological (biodiversity) considerations, killing damage causing animals is often still the best option. This is also recognized by the recent European Union legislation on humane trapping for certain species – lethal methods are still allowed.

As far as damage causing animals are concerned, very clear distinction has to be drawn between large species for which a huge demand exist in the hunting industry and relatively few individual animals are involved, as compared to smaller animals where thousands are involved and the demand from the hunting industry will never be able to absorb these animals. Attempts to commercialize the hunting of damage causing animals in the recent past has led to abuse and such hunting can only be done where the manpower and will exist to properly control such actions. A clear case will also be made that the damage management of smaller predators does not conform to the definition of hunting but rather to culling.

The wisdom of adding abundant, resilient, widely distributed and adaptable species to the protected animal list, while species with clearly weaker conservation status are not, is questioned. Animals that were, till recently, listed in provincial ordinances as problem animals were animals proven to have severe impact on the agricultural sector regardless of ongoing lethal control on those species. All of these species are adaptable and learn to avoid control methods, thereby indicating the need for as wide a range of control methods as possible. Eliminating most of these options will have serious consequences for the affected sector. From a conservation point of view ALL species is important, but may also be reasonably utilized. The question is not whether the animals are managed, but does the natural population show a downward trend. This clearly is not the case.

Damage control equipment cannot be classed as selective or un-selective. It is the application (human factor) that determines the selectivity. A person abusing one piece of equipment is likely to abuse all others as well. Therefore the ADC legislation should regulate human actions and not so much the equipment. Equipment should be regulated only in as far as obvious negative and inhumane aspects.

For 300 years the South African government has helped trying to eradicate the jackal and failed miserably. Legislation was drafted to aid eradication, bounties were paid, fences subsidized, poison distributed at cost, hunt clubs encouraged and subsidized and governmental employees involved in killing predators on private ground. Only during the last 50 years or so was research directed at finding other solutions. Then the task of ADC was totally transferred to the landowner – all help, even the research has been stopped. The present step stops all effective control in one swoop. An implication of a government removal of the basic human right of protecting your property against damage is that the government then has to take the responsibility of protecting that property.

DISCUSSION

As much as animals will not be downgraded in conservation status without sound scientific data, their status should not be upgraded without data. We do have a duty to protect and apply the Precautionary Principle when necessary, but still there has to be sound grounds for using it.

During the evaluation of The Red Data book that was released in 2004 (Friedman & Daly 2004), a process was followed that is accepted by the IUCN and prominent SA conservationists, a number of international scientist and DEAT representative participated. This probably was the most serious attempt at getting accurate estimates for mammal numbers as has ever been attempted. During the process note was taken of the animals killed as problem animals. Yet at least four of the species that was listed as least concern, with ample reason to do so and with breeding pairs of over the 10 000 is has been placed on the protected animal list – why? At the same time animals that was listed as of lesser status are not listed. This includes the civet (Civettictis civetta) and the side-striped jackal (Canis adustus) with breeding pairs less than 2 500 and the jackal classed as Near Threatened. Both has quite limited distribution and need fairly pristine habitat to thrive.

The problem species on the other hand are problems because of their resilience, wide distribution and high tolerance for human induced changes in their habitat. They have been persecuted for over three hundred years but have never been in trouble as far as numbers are concerned. The fact that the animals are persecuted is not reason to list them as protected. Legal checks over the methods used to control their numbers can easily be proclaimed without the protected status. Quite al lot actually exists, but is not enforced.

It should be realized that these animals have been under bounty for most of the time that European peoples have been in the country. Bounty was paid in the Cape Province since 1656 (instituted by Jan van Riebeeck) till 1956 – 300years. This was in clear recognition from the government for the problems caused by these animals to farmers. Between the 1920s up till the bounty was stopped the average number of black-backed jackal killed annually, in the Cape Province alone, was about 20 000. This did not have any significant influence on the distribution of the animals in that Province. I doubt that presently this number is killed annually in the whole country.

The mechanism by which these animals maintain high numbers has been well worked out. For the coyote the figure of 70% killed per annum has been indicated as not enough to eradicate a population (Connolly 1978). When 50% is killed annually it is still the state of the habitat that determines the number present. This is part of the reason why these animals were declared problem animals in the first instance. When the numbers of the medium sized canids are depressed the breeding age of the animals comes down, the litter size increase and the natural mortality decrease. In some situations the control effort has succeeded in activating some of these symptoms, but nowhere has the effort to eradicate the animals succeeded. I therefore fail to see the need for the protected status.

Extent of damage to livestock

Because of the total lack of research on the issue of damage to livestock very little in hard scientific data on losses is available. Surveys among farmers have indicates the extent of the problem form their perspective. Lawson (1989) indicated a three million Rand per year loss for Natal Wool Board members and a survey by BKB for the National Woolgrowers Association (BKB 2002) indicated an average of 6.76% loss of annual lamb crop, with variation of 4,13% to 11,25% for the regions. When this is applied to the 11 million lambs that are born annually and a value of R250:00 per lamb, the total amount lost by members of the Woolgrowers amounts to about R200million. This is a serious amount and valid for roughly half the small stock in SA. Many of the remaining half of the sheep owners are not as strong farmers as the Woolgrowers and the losses can be expected to be higher. To this we have to add the losses suffered by the game industry. Under extensive game farming the effect of predators is perceptional and tourism operations actually welcome predators. However scarcer game prices exceed that of livestock and monetary value of losses sometimes is significant. These figures have not been challenged anywhere and is therefore seem to be accepted.

Oranjejag, in the Free Sate, and the Federal Problem Animal Control Association (FPACA), in the Transvaal, have been large damage control organizations managed by livestock producers and subsidized by Government. Both have been disbanded, not because of lack of damage, but because of not being able to provide an effective service to curb damage with their limited personnel. The staff of these organizations kept whizzing around their respective provinces to try and keep damage under control, but simply could not keep up. Individual members of the organizations felt that they did not get value for their money and despite paying for getting their problem solved, they were still suffering unacceptable losses.

Learning ability of common problem animals and its consequences

One of the problems that we have to contend with when dealing with problem animals is that they are capable of learning. Non-lethal control methods leads to the animal repeatedly getting in contact with the obstacle and learning how to avoid or circumvent it. Very few non-lethal control methods keep their effectivity over extended time periods. Here are two examples even of lethal methods:

THREE SUCCESSIVE POISONING PROGRAMS (PELLETS) IN THE AREA NORTH OF THE SOUTPANSBERG WITH PROGRESSIVE AVOIDANCE:

YEAR	JACKAL/AREA	SOURCE
1974	37 jackal on 2 farms	Danie Willemse - pers comm
1984	5 jackal on the same farms	De Wet - Unpubl data
1987	1 jackal for every 6 farms	Steyn – int.rep.Veterenary Services, Louis Trichardt

In this case the control on animal numbers was done because of rabies outbreaks. The State Veterinary Services called for the campaigns. The operations were done because of high jackal numbers, to try and break the chain of transmission of the rabies. It is clear that the number of jackal killed in the 1987 operation could in no way have made a significant difference in the jackal density.

PROGRESSIVE AVOIDANCE OF GETTERS BY JACKAL IN THE WESTERN CAPE (BRAND et al 1995)

YEAR	JACKAL CONTACTS	KILLED	AVOIDED	% AVOIDANCE
1985	34	18	16	47
1986	27	13	14	51
1988	66	5	61	92

The study area was chosen where coyote getters have not been used before. Within three operations it was totally ineffective.

Control methods

· When non-lethal control is discussed, fencing usually features high on the list. During the 1920s the State subsidized “jackal proof” fencing stretching for over 15 000 km. Mainly in the Karroo. Because of the low rainfall and nature of the soil, some of the original fencing still exist today – obviously it did not solve the problem. There are four major aspects that has to be considered in using fencing against problem animals:

Cost: Fencing material is quite expensive – predator proofing means mesh, or electrification, or both – driving up the cost tremendously. Labor cost is a huge chunk of the total cost. When the fence has to be medium-sized predator proof the labor cost usually more than doubles. This is due to the process of having to tend to and blocking all possible entry spots for the animals. Any irregularity, drainage line, rocks etc, etc, that affect the fence. Therefore ending up with a fence that is about three time or more the cost of and ordinary stock fence.

Maintenance: Keeping the fence predator proof is the next challenge. Porcupine and warthog can easily dig under a fence in one night. The predators follow. Jackal can dig its own crawl-through quickly in soft soil. This means employees (that has to be supervised) that are appointed and dedicated to the fence. We end up with such prohibitive costs that predator proof fences mostly are unsustainable.

Killing predators: Once the fence is up we have a regular fortress – with a full compliment of predators INSIDE. These animals have to killed before livestock can be grazed. Any predator that succeed to breach the fence and enter, similarly need to be killed. But killing the animals is prohibited thus rendering the predator-proof fence totally useless or even a menace.

Ecology (biodiversity): Getting to the major reason why we should not make extensive use of predator-proof fencing. A fence that is jackal proof is also rabbit proof, duiker proof and all manner of other small and medium animals that manage to exist under extensive farming conditions. Cutting these animals off from breeding partners, water and other resources. Thus catastrophe as far as biodiversity is concerned.

Predator proof fences therefore is practical only for small lambing camps and should not be used for large camps for grazing flocks of small stock. As this leaves the bulk of the sheep unprotected once again, or cause severe ecological interference.

Guard animals are all herd orientated and although they bond very well to their small stock herd, they prefer company of their own kind. Having two herds with guards in neighboring camps thus often lead to the guard animals lying on either side of the separating fence in each other’s company instead of protecting their herds. Guard animals get sick or injured and then leaves the herd unprotected.

This all boils down to a large scale farmer having to divide up his flock into groups of 200s and he has to build numerous camps to facilitate the guard animal. The camps are to small for grazing over long periods and the animals have to be rotated regularly.

Guard animals again can work wonders for small operations, but does not constitute a practical solution to a commercial farmer with more than thousand sheep.

The foregoing are examples of non-lethal damage control methods that show potential and is used, but cannot be considered as complete solution. Most of the non-lethal methods are much more expensive to employ than the lethal methods. This might still be practical in some commercial farming operations, but is impossible for small farmers and upcoming farmers. There are the very costly efforts by the South African government to establish upcoming farmers. When a small operation has a lamb crop of 20 animals and two are caught it is a 20% loss. This is unsustainable. To a commercial farmer with a crop of 1 000 lambs loosing 10 is a 1% loss and could be absorbed. When other losses, like disease and severe weather, is added, the small farmer has no chance of survival, and the commercial farmer has to really work hard at keeping his operation profitable. Accepting that losses have to be managed is essential, but accepting losses per se make no sense. This would be similar to a salary earning persons or businessman excepting that portions of their earnings is taken for no reason and not being allowed to do anything about it. Any reasonable person expects a responsible farmer to do his utmost to protect his income, even more so when it is live animals being mauled and killed. The law HAS to allow for this.

Stopping the use of lethal methods also stop the use of the poison collar. The only control method that has been devised to this stage that is 100% selective – killing only damage causing individuals out of the predator populations. The coyote getter, used by a properly trained person and with a pheromonal lure is an invaluable tool. These two methods make use of poison in a very sensible way and should not be discounted. Poisons vary tremendously in their characteristics, and I would like to see the acceptable poisons specified and the others banned. A poison like cyanide is as humane as any other acceptable lethal method.

Some leghold traps are undoubtedly unacceptable and have to be banned while others are indispensable tools in the variety needed to successfully keep ahead in ADC. (see figs.)

Shooting (with spotlight at night) can again be very selective and sort out problems within a short timeframe and little ecological effects.

It should be borne in mind that extensive farming practices are MUCH more biodiversity friendly than intensive farming, but that it is practiced at a price and farmers has to be granted the leeway to manage their operations properly. The management of the smaller, common problem animals does in no sensible way conform to the definition of hunting. It rather falls under the culling definition – very necessary management activity for the proper running of the operation. The nature reserves and similar institutions have been given this leeway. Natural production systems in which hunting and/or tourism is the main source of income can absorb much more losses form predators than the direct utilization of individual animals with livestock production. On livestock farms hunting of problem animals has NEVER been used as a source of income to the landowner. The landowner rather has to pay an operator to take out the problem animals.

Per definition a problem animal situation is a pressing, immediate problem and demands a quick solution. The hunting of leopard by South African hunters has been an open option for a long time but was seldom used. The farmer losing prized livestock kills the predator as quickly as possible, even though he could potentially have made money by having it hunted. I therefore have difficulty in understanding the concept of a “problem animal” for which there is time to arrange a hunt and have it taken out in this way. This only creates a loophole and opportunity for exploitation of our natural resources. The problem-causing animal (whether large or small) seldom is trophy quality but the option to have it hunted opens the door for substituting a trophy individual for the problem causing one. The problem then is not solved and thereby more suspicious hunting opportunities can be created. The only example that I know of where this situation has been well managed has been through the Mopani Damage Causing Animal Forum in the Gravelotte area.

Important principle is that inanimate equipment cannot be classed as unselective and/or inhumane. The problems stem from improper application and abuse of the equipment – therefore the human factor. When a person causes suffering and unselectiveness by applying any method of control, the chances are very good that he will apply all equipment in such a way. I therefore see little advantage and lots of disadvantages in banning equipment. A case in point is the discussion on leghold trap in this document. Only the types with obvious harmful attributes should be banned. The human actions should be regulated while allowing for the proper use of equipment. Motor vehicles cause an untold number of deaths and suffering on our roads. We do not ban all vehicles – we get and education program running and educated vehicle users. The knowledge exists to use the damage control equipment properly. When the equipment then is still abused we need law enforcement (as in the vehicle industry). It is no excuse for governments to ban equipment because they do not have the people to enforce existing laws. Creating new laws that will also not be enforced brings no solution to the problem. It only criminalizes citizens for exerting rights that have been established over hundreds of years.

The two countries that has sheep/ predator situation that is to an extent comparable to the SA situation are Australia with hybrid dingo/dog and fox problems and USA with coyote and bobcat. In Australia aerial poisoning campaigns by the government is still prevalent and bounty is still paid. USA has hundreds of government-employed trappers and a large private sector industry that kill coyote by any means possible, including poison, snares, leghold traps. Europe & North America has also has centers for testing & standards on humaneness of trapping. New Zealand produces lots of publications on humaneness – nothing done here in SA. Both countries also boast strong governmental research programs to solve damage by wild animals. There is a constant flow of publications on all aspects of Damage Control. This kind of commitment from the South African Government is totally lacking. This despite the fact that Southern Africa has a much richer biodiversity in need of protection. If National laws are passed on this issue, it is recognized as of national importance and then money and resources should be allocated for research and management.

Definitions as in section 12: the terms are too broad. Like “SNARE” there are neck snare, body snare, leg snare – some are quite humane live traps. Similarly “TRAP”: Pit trap, cage trap, gin trap, leg hold trap. This can be interpreted very broadly and cover almost any capture method.

Laws that simply ban activities previously accepted and even promoted practices are negative laws (maybe because the officials drafting the laws has not been able to come up with positive solutions?). This precipitates negative reaction from the citizens of the country. Coming up with positive solutions, of cause, will have the opposite reaction and cooperation from the public.

A case in point comes from the USA. Research on the coyote has enabled management system whereby killing only a third of the animals that were previously killed give the same or even better and longer relief from damage. This is state of the art control work – but no longer allowed in SA. This management system can be applied to the jackal in SA after a relatively small research project to convert the principles to our conditions. But research on problem animals is dead and will only come to its right if the SA government starts positive conservation practices and fund research.

No example anywhere in the world where livestock that are bred under extensive farming conditions, like in SA, has damage by medium sized predators been curbed to within sustainable proportions by non-lethal control methods only.

Under common law this is a basic principal: to be able to protect your livelihood and property against destruction. This legislation complicates this issue to such an extent that it removes this basic human right and criminalizes a person for doing what all other citizens of this country are allowed to do.

If an animal is considered the property of the owner of a protected area, that owner (state or private) is then responsible for keeping that animal under control and has to prevent damage by that animal to his neighbors property, failing which he will have to compensate the neighbor for any damage caused by that animal(s).

All reasonable people would like to see non-lethal control but there has to be a sensible, practical, affordable solution.

Nature Conservation (Government) has previously (up to about the 1960s) actively tried to promote and aid the extermination of the jackal. Subsidies to aid the farming community was paid and then stopped. Since then the government has slowly withdrawn from involvement and the only commitment to ADC was a few posts in Conservation bodies to aid research, but the responsibility for ADC was laid on the landowner. Finally all support and help was withdrawn. The conservation bodies promoted and encouraged landowners to do what was necessary to protect themselves. This legal intervention will only criminalize landowners for doing what they have been forced and encouraged by the Government to do.

If the SA government is really so worried about our biodiversity it should take positive steps to remedy perceived problems like funding research, become expert or contract experts and affected parties on the subject under discussion to guide the decisions. This kind of absurd direction taken by DEAT does serious harm to the credibility of the department. It places a question mark behind the motives of the department and one can only wonder about the scientific integrity behind these suggested law changes.

Bigalke R. 1951 The common jackal: Threat to the wool industry. Vacuum Boer 11 January

Botha T. 2000 Probleemdiere – waar lê die knoop? Landbouweekblad 13 Oktober

Cattrick A. The cunning jackal costs South Africa ₤500 000 a year. Sunday Times 28/08/1950

Commission of the European Communities 2004 Introducing humane trapping standards for certain species. COM (2004) 532, 2004/183 (COD)

Connolly G.E. 1978 Predator control and coyote populations: A review of simulaion models. In Bekoff M. (ed) 1978 Coyotes: biology, behavior, and management. Academic Press. New York

Friedman Y. & Daly B. 2004 Red data book of the mammals of South Africa: A conservation assessment. CBSG Southern Africa, CBSG (SSG/IUCN), EWT. South Africa

Hey D. 1967 Recent developments in the control of vertebrate problem animals in the province of Cape of Good Hope, Republic of South Africa. Proc.Vert.Pest Conf. 3 158-164

Lawson D. 1988 A survey of the effects of predators on sheep farming in Natal. Unpubl. Report. Wool Board, Natal Provincial Administration.

Roberts A. 1951 The mammals of South Africa. Trustees of the mammals of SA book fund. CNA

Shortridge G.C. 1934 The mammals of South West Africa. Vol.1. William Heinemann. London

Variations in leg hold traps

Thin jaws and strong spring combinations are equally non-usable.	Broader jaws with a reasonable opening between the jaws and springs matched.	Wavy jaws are unacceptable