Government Gazette, Vol. 620, 8 February 2017, No. 40601
Notice 75, Department of Environmental Affairs (DEA)
“Members of the public are invited to submit to the Minister, within 30 days after the publication of this notice in the Gazette, written representations or objections to the following addresses:
By post to: The Director -General Department of Environmental Affairs Attention: Ms Makganthe Maleka Private Bag X447 PRETORIA 0001
By hand at: Environmental House, 473 Steve Biko Street, Arcadia, Pretoria, 0083.
By email: firstname.lastname@example.org
Any enquiries in connection with the notice can be directed to Ms Makganthe Maleka at 012 399 8865.”
By post (PDF Leopard Hunting Proposals, 21 February 2017)
Dear Ms Makganthe Maleka,
Please find below “written representations or objections” to the proposed “Draft norms and standards for the management and monitoring of the hunting of leopard in South Africa for trophy hunting purposes” – (the “draft norms and standards”), as notified in Government Gazette, Vol. 620, No. 40601, Notice 75, Department of Environmental Affairs (DEA), dated 8 February 2017.
Due to the lack of fully published data within Notice 75 draft norms and standards, it is impossible for anyone to independently assess the SANBI’s proposed leopard hunting quota, because the basis for estimated leopard densities and populations in potentially outdated, with no publicly available data that gives confidence that a SANBI leopard population estimate (not published) is valid.
Concerns were raised in 2009 over the sustainability of leopard trophy hunting in South Africa by Balme et al (2009) , what has improved since? What evidence is there that leopard populations today within South Africa are able to sustain the hunting quotas proposed in Notice 75 draft norms and standards?:
- The IUCN Red List (Pathera pardus – “Vulnerable”) considers the leopard population within “South Africa appear to be decreasing from previous estimates with Leopards disappearing from areas with increased human development and areas of intensive conflict with humans.” Furthermore, Swanepeol et al (2014)  stated that “we found an unequivocal risk of population decline in South Africa as a whole as well as for several provinces.” How does the trophy hunting of leopards help offset that acknowledged decline in the leopard population within South Africa and where is the independent scientific evidence to prove it?
- The financial contribution of leopard trophy hunting (and trophy hunting in general) is minimal to South Africa’s GDP, so why take the risk? Again and again, trophy hunting has been proven as a broken theory (alluded to within Swanepeol et al (2014) ; Leopard (Panthera Pardus) Case Study (2008) and Balme et al (2009) ) unable to deliver the promised regulatory conformity and any notion of sustainability, or any overwhelming positive contribution to the species’ conservation.
- In January 2016 the DEA set a zero leopard hunting quota across all provinces. The DEA accepted the negative non-detrimental finding (meaning it found it detrimental) to hunt leopards from 2016. The DEA’s directive/statement concluded that “the number of leopards in the country is unknown and, for this reason, the sustainability of hunting cannot be accurately assessed” – Daily Maverick 
- The directive, issued by the DEA appeared as a “negative non-detrimental finding,” ie as leopard specialist Guy Balme of Panthera explained at the time “that this means hunting is likely to have a detrimental effect” – Daily Maverick 
- Guy Balme also reportedly said at the time in 2016 “We just don’t know how leopards are faring in South Africa. They’re secretive, mainly nocturnal, solitary and range over huge areas. Counting them requires intensive research using expensive technology such as camera traps, which can only be deployed over small areas, far smaller than the areas in which hunting quotas are determined” – Africa Geographic 
- What does the SANBI/DEA think the 2017 leopard population is within South Africa that can be quantitatively applied to any hunting quota, when in 2016 leading experts stated that leopard populations within South Africa were unknown and virtually unknowable?
- Where are the SANBI’s estimates for male leopards ≥ 7 years old in any given province with a proposed hunting quota? Where is the confidence that the hunting quotas proposed within the Notice 75 norms and standards (also given at Figure 4 – Appendix 1) are sustainable and not likely to be detrimental to the species’ survival?
- Why is there no published data for the “province-wide camera-trapping efforts – (SANBI unpub. Data) that is supposed to support the SANBI’s knowledge and understanding of South Africa’s leopard population?
If a leopard hunting quota is issued based upon weak and passive penalties as proposed at (7) of the Notice 75 draft norms and standards, then wrong-doing will most likely go unpunished.
Leopards face many threats (persecution as cited by Leopard (Panthera Pardus) Case Study (2008) ), none of these threats are considered or offset by the contents of the Notice 75 draft norms and standards.
In the absence of credible data to work from (the SANBI has not been explicit in the quantitative leopard population estimates is has used to derive the proposed hunting quotas), the concept of the cautionary principle is required, always erring on the pessimistic scenario, rather than a best case scenario, or ‘hope’ to try to justify a desire to perpetuate a delusion “there must be plenty of leopards left to kill.”
How do any of the deficiencies in Notice 75 draft norms and standards, or hunting’s minimal positive contributions, offset the proposed trophy hunting of baited leopards and the export of trophies that are likely to be “detrimental to the survival of the species?”
All of these points are expanded upon in the attached Appendix 1.