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Objecting to the agreement between Cape Nature, Western Cape Government and the agricultural lobby group (the “Predator Management Forum”), aimed at destroying our biodiversity. 1 June 2012 The DA and Premier Helen Zille promote the use of gin traps such as these above, now renamed as“soft traps”. Purpose: Formal objection to the “cooperative agreement between the Predator Management Forum and the Western Cape Nature Conservation Board: guidelines for the management of bushpig, black-backed jackal and caracal that are responsible for agricultural losses within the boundaries of the Western Cape Province”. This “agreement” will further be calledWestern Cape Biodiversity Massacre 2012The Landmark Foundationformally objects to the content of the agreement, its proposed modus operandi and manner in which it was arrived at, and we call on all stakeholders in this matter to start the process from the start. In the interim we call on a moratorium on the issuing of any further permits or permit exemptions for hunting damage-causing animals. Context: In 2011 the Democratic Alliance administration of the Western Cape and CapeNature implemented the largest state sanctioned and permitted cull of indigenous wildlife in the history of Africa by permitting for destruction 894 250 caracal and jackal. It became known as the Bredell Cull. This occurred after political coercion from DA ministers (MEC Anton Bredell and MEC Gerrit van Rensberg, and supported by Premier Helen Zille) and subsequent capitulation of CapeNature officials and Board to abide by their political masters. This remains a disgrace of unparalleled proportions. On 12 January 2011 Dr Kas Hamman, now acting CEO of CapeNature, confessed in writing: “Yes, political pressure has certainly been brought to bear on us and in no uncertain way. Let's talk about how LF (sic, Landmark Foundation) could possibly assist us in the most effective way.” This was followed by a year of cloak and dagger “engagements” and behind the scenes political deals that have resulted in the agreement now out for public comment in the form of this “agreement”. CapeNaturestaff have been forced to toe the line and even the Board of CapeNature has approved the tools put forward in the agreement in October 2011 in a CapeNature Board resolution. This occurred while all stakeholders that may object to this agreement have been shunned and any engagement with them has been rejected, despite requests for such. Even as late as April 2012 only sweetheart organisations have been included in any discussions with DA run institutions. The Premier even appointed a sweetheart forum to advise her on welfare issues, actively excluding critical stakeholders. This agreement is thus a “blank cheque” to the agricultural lobby groups to assault indigenous occurring species and to self-regulate themselves to do so. It is a replica of the disastrous bounty fundedOranje Jag in the Orange Free State Province of the Apartheid regime of South Africa of the 1950s – 1990s that saw hundreds of thousands of animals exterminated over the agricultural landscapes, together with even greater numbers of by-catch kills of innocent animals. We believe the consultation whereby CapeNature and the DA administration of the Western Cape have handed over the management of our biodiversity to an industry lobby group with a demonstrable atrocious record in biodiversity management, especially top trophic level species, amounts to biological asset striping of our natural heritage. We strongly object to the “public participation” process by which this agreement has been struck, and the political coercion used to come to this agreement and the exclusion of interested and affected parties in this process. We believe this to amount to gross maladministration. (CapeNature have refused to release a report and literature review of Prof J du P Bothma that was to scientifically inform management and the way forward. This report was paid for by public funds but for some reason it is not being released.) Objection: The overall issues that we object to in the proposedWestern Cape Biodiversity Massacre 2012 are: 1. Outsourcing of biodiversity management and oversight CapeNature’s actions have effectively absolved themselves of their responsibility to managing biodiversity on farms, despite their better judgement and knowledge is objected to and alleged to be contrary to their legislative mandate. By CapeNature’s own version their mandate with regards to the management of DCAs includes the following: • The formulation, administration and application of legislation; • The prevention of unacceptable or unselective management methods; and • The promotion and support of research into DCA’s. This agreement sees the outsourcing of that responsibility and the selective engagement of one grouping in the manner in which these functions are to be implemented. Only parties that have promoted large-scale indiscriminate lethal controls of predators were consulted, and the mechanisms of implementation agreed to runs contrary to targeting only individual damage causing animals, related to specific events that have had mitigation measures fail. It is inappropriate to hand over the management of DCA to agricultural unions and even farming groups that have stated objectives to exterminate top trophic level species. In the 1950s – 1990s a province-wide cull of predators was managed across the Orange Free State Province through a bounty incentivised cull with organised hunt clubs called the ‘Oranje Jag’. This Oranje Jag saw the decimation of faunal diversity in that part of the country. This agreement is a fall back to and emulation of such draconian times and will see the same results in the decimation of biodiversity across the province. This political coerced action and outcome is objected to and the Western Cape Biodiversity Massacre must be stopped. The parties have disregarded the general public interest, and specific stakeholders in having a healthy environment and ecosystems conserved, which is the very reason for spending taxpayers money on the legislative mandate of CapeNature. 2. Blanket approval for species assault While the agreement document starts with appropriate principles, everything that follows in the mechanisms of execution of the agreement flies in the face of these principles. The principles that at promoted are that actions must be: Humane; Selective (target the individual responsible for the losses); Ecologically acceptable; Within the legal framework; and Efficient and cost-effective. The use of gin traps (now euphemised to “soft traps”), hunting dogs, 1080 poison collars, helicopter hunting, uncontrolled cage traps, daytime hunting (inclusive we assume of denning, conibear traps and other barbaric means) and call and shoot hunting are contrary to these principles. Further too, this document goes into extensive detail of how the killing must only target damage causing individual animals, but extensive latitude is given to approval of killings in advance of any damage actually having taken place, and large-scale hunting permissions being given in advance of damage having taken place. It is clear that the agreement is rather a smokescreen for entire species extermination efforts. For example, the “agreement” stipulates that the parties are: “To apply management methods in such a manner that the balance between commercial agriculture (food security) and biodiversity is enhanced. To ensure that landowners act in such a manner that: o non-target species are not negatively affected in the process; and o the natural environment (soil, water, vegetation and naturally occurring wildlife) are not prejudiced in the process. To promote the sustainable and economic utilisation of all resources. To take decisions jointly in order to determine which management methods achieve the best results.” While the above principles and stated objectives seem sensible, the modus operandi flies in the face of these: Firstly the oft quotes issue of food security is a rather desperate attempt for the parties to extract some political relevance. Animal fibres and wildlife production methods of the producers involved play NO part in food security, and what relevance lamb and mutton has in the food security debate when these products retail at upto R150/kg in stores is highly questionable. The notion of sustainability is void for vagueness, and is used by all when they want to defend any indefensible position. The methods approved will for certain, by virtue of their non-selective, indiscriminate, inhumane (=barbaric) and ecologically damaging nature kill off non-target species, kill off non-culprit individuals, target entire species for decimation and thus ruin the ecology of the entire province. The joint decision making of this political expedient and coerced partnership of this agreement excludes an entire constituency that have an interest and right in healthy ecosystem management. This agreement is nothing less than a global indigenous species extermination effort. It’s clear that the modus operandi of the permitting system approved is not targeted at individual animal removals that may cause damage, but a prospective, species wide (and anything that gets in the crossfire or caught as by-catch) extermination cull cloaked in nice principle statements. 3. Open season hunts The permitting system promoted is nothing less than a province wide extermination cull of several species. It mimics the “Oranje Jag”, encourages hunt clubs through the agricultural unions and clearly aims to promote the hot-pursuit tactics of the pre-1994 hunts that left biodiversity over much of South Africa decimated. The one year prospective permit, together with renewal options,is thus aimed at a sustained assault on the biodiversity of the province. The platitudes of reporting outcomes of hunts has been demonstrated over and over again to yield scant, if not negligible, reports of the actual decimation that takes place on a daily basis. The example of only some 200 – 300 kills reported in the almost 900 000 CapeNature’sBredell Cull approved kills in 2011 just proves the disregard this industry and lobby group has for the accountable governance associated with permitting. The allowed hunting of jackal and caracal during the day without permits demonstrates that the agreement has no intention of placing any controls whatsoever on landowners as it is nigh impossible for the institutional governance organisations to know what time of day animals are killed. It proves that the entire agreement is a sham. 4. Self-regulation The handing over of the management and governance of biodiversity management to farmers is an absolution of responsibility and clear neglect of statutory duties that the Western Cape Government and CapeNature have to all the citizens, not just the political connected elite of the DA administration. This will fail and will misrepresent the actual decimation of wildlife in the province. We call of the provincial authorities to exercise their control over the devastation of biodiversity taking place on farmlands that is done in the name of the management of damage causing animals. To simply hand over the management of this fraught problem to farmers through this atrocious agreement is shameful and clearly demonstrates that the Western Cape’s DA administration only panders to the agricultural lobby groups that make up their power base, and has scant respect for biodiversity conservation. 5. Approval of methods of mass species destruction The approval of gin traps, hunting dogs, helicopter hunting, 1080 poison use, and prospective hunting (uncontrolled in daytime) and night time call and shoot hunting is indiscriminate, unethical, ecologically damaging and flies in the face of the principles the agreement ambiguously espouses. It is clear that this agreement hands the right to the agricultural lobby groups to prospectively and systematically exterminate naturally occurring species across the Western Cape with methods known to damage biodiversity, that are unethical and demonstratively unselective. It is all together cynical to rebrand conventional gin traps as “soft traps” and killing dog packs as “sniffer” dogs. This is a deliberate deceit of the public and dishonest. 6. Hunt Clubs&Hot-pursuit actions It is patently clear that the Western Cape Government and CapeNature aims to re-establish hunt clubs and hot pursuit actions of old, through group issued permits “managed and controlled” by the agricultural unions/farmers associations. (Hot pursuit was practiced in the draconian Apartheid years whereby predators could be pursued on anyone’s land).The de facto coercion of neighbours to sign consents will be immense and thus will become the norm. 7. The draft NationalDamage Causing Animal management regulations being used as the basis of action The agreement is said to be based on thepublished draft Norms and Standards for the Management of Damage-Causing Animals (Government Gazette Vol545, Pretoria, 26 November 2010, No 33806) General Notice (1084 of 2010), herein after referred to as the Norms & Standards. It fails to note that this draft national regulation has not been finalised by the national department, as on publication is was subject to the largest objection ever in the environmental legislative process. These regulations inexplicably had massive alteration after drafting by specialist teams after intense lobbying by the same groups in the so-called “Predator Management Forum”, now subject to this agreement. The full objections of the Landmark Foundation to these regulations are contained here below – see annexure 3. The gin traps that this agreement now rebrands as soft traps are the conventional traps used in South Africa and made by Peter Schneekluth of Prince Albert. To claim that hunting dogs are only sniffer dogs is frankly deluded and a dishonest representation of the realities on farms, never mind contrary to the Animal Protection Act, as are the use of baited traps. 8. Bizarre consultative process that precededunprecedented coercion of conservation staff and stakeholders to allow this “Bredell’sOranje Jag” The long history of political coercion in the development of this agreement to artificially and wrongfully promote the interest of a certain lobby group in cahoots with political power brokers is wrong. It has actively excluded other stakeholders, and even at the conclusion of the agreement a shammed process of co-opting sweetheart organisations to give legitimacy to this agreement is an abuse of power and unconstitutional. Stakeholders in the field were even excluded through abuse of police officials on 4 April 2012 after a publicly announced meeting on the topic by the DA administration and hosted by Premier Zille refused them access to discussions. The calling on public comment on this agreement is a bizarre manner to try to give legitimacy to outsourcing of state functions. Annexure 1: Background information Three important articles from the US need to be interrogated speaking against the approach taken by this agreement that is being railroaded through by the DA administration in the Western Cape – there are parallels to what is happening in in the Western Cape Part 1: http://tinyurl.com/8625p3l Part 2: http://tinyurl.com/6unjlx3 Part 3: http://tinyurl.com/6vsd7hw Also please watch the following documentary as these methods are currently being promoted in the agreement between CapeNature, the DA administration of the Western Cape and the various farming and hunting lobbies to “control” so-called damage causing animals. The methods being promoted have indiscriminate impact across many species as by-catch! http://www.21paradigm.com/cullsynopsis.php Annexure 2: Some specific points 1. That a concerted effort should be made to focus the legislative and implementation control of activities and methods that may impact on the patterns and processes of biodiversity. (It is the humans that need control, not the species.) It is proposed that CapeNature control the methods used and not outsource their responsibility. 2. CapeNature should exercise direct control over all species that are exploited ordinarily and not allow methods, whether directed or potentially as by-catch, that can affect any commonly persecuted species. They should retain control over these methods of impact and not outsource it to ill-disciplined hunt clubs or operators. Thus a species listing should be developed and should involve all species experiencing human exploitation to the extent that populations are disrupted in their natural states. All mammal species that are exposed to human exploitation (either through direct action or inadvertent collateral damage in the exploitation of other species or processes) should be afforded protection under this legislation and any operational activities. As such we propose that at least the following mammal species be listed for such oversight control (other experts may have meaningful input to this list, especially other faunal and floral species), namely – this covers South Africa in general: Aardvark Orycteropusafer Aardwolf Protelescristatus* Baboon, ChacmaPapioursinus Badger, Honey Mellivoracapensis* BlesbuckDamaliscuspygargusphillipsi BontebokDamaliscuspygarguspygargus* Buffalo Syncerus spp. Buffalo, Cape Synceruscaffer BushbabyOtolemur spp. Bushbaby, Thick-tailed Otolemurcrassicaudatus Bushbuck Tragelaphusscriptus BushpigPotamochoerusporcus Caracal Caracalcaracal Cat, African Wild Felissilvestris Cheetah Acinonyxjubatus* Civet, African Civettictiscivetta Duiker, Blue Philantombamonticola* Duiker, Common Silvicapragrimmia Duiker, Red Cephalophusnatalensis Eland Taurotragusoryx Elephant, African Loxodontaafricana* Fox, Bat-eared Otocyonmegalotis Fox, Cape Vulpeschama* Gemsbok Oryx gazella Genet, Large-spotted Genettatigrina Genet, Small-spotted Genettagenetta Giraffe Giraffacamelopardalis* Grysbok, Cape Raphicerusmelanotis Grysbok, Sharpe’s Raphicerus sharpie* Hare, Scrub Lepussaxatilis Hartebeest, Red Alcelaphusbuselaphus Hippopotamus Hippopotamusamphibius Hyena, Brown Hyaenabrunnea* Hyena, Spotted Crocutacrocuta* Hyrax, Rock Procavia spp. and/or Heterohyrax spp. Impala Aepycerosmelampus Jackal, Black-backed Canismesomelas Jackal, Side-stripped Canisadustus Klipspringer Oreotragusoreotragus Kudu Tragelaphusstrepsicerous Lechwe, Red Kobus leche Leopard Pantherapardus* Lion Panther leo* Mongoose Mongoose, White-tailed Ichneumiaalbicauda Mongoose, Yellow Cynictispenicillata Monkey, Blue Cercopithecusmitis NyalaTragelaphusangasii OribiOurebiaourebi* Polecat, Stripped Ictonyxstriatus Porcupine Hystrixafricaeaustralis Reedbuck Redunca spp.* Reedbuck, Common Reduncaarundinum Reedbuck, Mountain Reduncafulvorufula Rhebuck, Grey Peleacapreolus Rhinoceros, Black Dicerosbicornis* Rhinoceros, White Ceratotheriumsimum* Roan Hippotragus equines* Sable Hippotragusnigerniger ServalLeptailurusserval* Springbuck Antidorcasmarsupialis Springhare Pedetescapensis Squirrel, Ground Xerus spp. SteenbuckRaphiceruscampestris SuniNeotragusmoschatuszuluensis SuricatSuricatasuricatta TsessebeDamaliscuslunatuslunatus* Warthog Phacochoerusafricanus Waterbuck Kobus ellipsiprymnusellipsiprymnus Wild Dog, African Lycaonpictus* Wildebeest, Black Connochaetesgnou* Wildebeest, Blue Connochaetestaurinus Wildebeest, Red Connochaetesgnou x taurinus* Zebra, Burchell’sEquusburchellii Zebra, Cape Mountain Equus zebra zebra* Zebra, Hartmann Equus zebra hartmannnae The definitions used in any agreement need some special attention – here are some important ones for consideration: 1. Activity – actions taken to impact on wild species or processes, such as hunting, darting, harvesting, trapping etc. 2. Body gripping/Instant Kill/Walk-through killer traps/Conibear/Killer traps - The animal touches the wire triggering mechanism which springs the trap. The trap is designed to close on the neck or torso of the animal which closes the trachea, and may fracture the spinal column. The trap is made from round bar steel which is spring loaded and comes in several sizes. 3. Cage Traps - Cage traps are designed to catch live animals in a cage. They may be baited, sometimes with food bait and sometimes with a live "lure" animal. Cage traps usually have a trigger located in the back of the cage that causes a door to shut; some traps with two doors have a trigger in the middle of the cage that causes both doors to shut. In either type of cage, the closure of the doors and the falling of a lock mechanism prevents the animal from escaping by locking the door(s) shut. 4. DCA - “damage-causing animal” means a wild vertebrate animal that, when interacting with humans or interfering with human activities, there is substantiated proof that it — In livestock farming: (a) causes repeated and regular and excessive losses to livestock; despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. In game Farming: (a) causes repeated and regular and excessive losses to other wild specimens, which is inconsistent with the animal’s natural behaviour and ecologically damaging to the specific enterprise; despite the existence of a certification of adequate enclosure to exclude predators from a game farming area, as approved and verified by the relevant environmental management agency. (b) causes repeated and regular and excessive damage to cultivated trees, crops, natural flora or other property; despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. (c) presents an imminent and realistic threat to human life; (d) is present in such numbers that agricultural grazing is materially depleted to a significant detrimental extent with respect to biodiversity and farming enterprises, despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. 5. Gin Traps (variably referred to as “gin traps”, “soft traps”, “soft catch traps”, “slaughter irons”, “steel jawed leg or foot hold traps”) - the gin trap/foothold trap is made up of two metal jaws, one or two springs that slam the jaws closed, and a trigger plate in the middle which is usually a round/square pan that trigger the trap. When the animal steps on the trigger the trap jaws closes around the foot, preventing the animal from escaping. Modified traps are also available with offset jaws, or lamination, or both. Traps are also available with a padded jaw, which has rubber inserts inside the jaws. 6. Hunting - in relation to any wild animal means by any means whatsoever to hunt or search for, to kill, capture or attempt to kill or capture, or to pursue, follow or drive with intent to kill or capture, or to shoot at, poison, be in wait for or wilfully disturb. 7. Hunting client means a person who pays or rewards a professional hunter for, or in connection with, the hunting of wildlife species. 8. Method – series of steps taken, with tool(s) used or otherwise to effect an outcome on a wild animal or species. The tools used could be a rifle, gin trap, cage trap etc. 9. Permitting process – is the process to be undertaken to get authority from the permitting authority to carry out a restricted activity or use a restricted method. 10. Prohibited – activity or method is not permitted to be carried out under any circumstances. 11. Restricted – any method or activity that is regulated by legislative processes. Restricted activity or method can only be undertaken through a permitted process that stipulates the terms and conditions of the activity being executed, and the methods permitted to do so. 12. Snares (wire/cable noose – neck, trunk or limb) – Snares are anchored cable or wire nooses used to catch and restrain animals. A snare traps an animal around the neck, limb or the body and tightens around the animal, restraining it. Several modifications may be made such as stops, ID tags, swivels and dragging (non-fixed) anchors. Further Notes: 1. The Norms and Standards for the Management of Damage Causing Animals was issued in terms of section 9 of NEMBA (act 10 of 2004) and covers both listed and non-listed TOPS species. 2. TOPS regulations refer to section 97 of NEBMA and is independent of N&S developed in terms of section 9 of this same act. 3. As such # 1 and # 2 above are independent legislative documents, hopefully acting in concert, but clearly in reality these statutes are not. 4. In the DCA definition it is absolutely essential that “excessive damage” clause be retained. Failing this, even just the act of eating a blade of grass by a wild animal would consign it to the fate of DCA extermination as it would then be argued that it has caused damage. The responsibility thus rest with the issuing authority to motivate that damage is excessive, which is reasonable considering their accountable adjudication role in this matter. 5. Hunting definition – see above. The intention to kill is not the only requirement to make it a hunt. Hunting could also include search for, to kill, capture or attempt to kill or capture, or to pursue, follow or drive with intent to kill or capture, or to shoot at, poison, be in wait for or wilfully disturb. (THIS IS IMPORTANT in the function of the restricted activities and methods, and its regulation.) It remains almost impossible in a court of law to prove “intension” . 6. Hunting client – it is immaterial whether a hunter is South African or not as the outcome for biodiversity is the same. Thus delete (a) in present definition. 7. Hunting clients are to be prohibited from hunting DCAs. This is to avoid the scenario where incentives created for the hunting of DCAs – thus creating a precedent to classify wild animals as DCA through this profit motive. 8. The following methods are to be prohibited in the hunting (as defined here) of all TOPS and DCA vertebrate animals, namely a. Snaring b. Gin traps (and all other similar devices as defined here) c. “Killer” walk-through snap traps (or other similar devices) d. Poison baits e. “Coyote” getters f. Hunting dogs g. Denning h. Helicopter hunting i. Holding captive of captured DCAs, especially to capture urine or excrement scent lures This prohibition is motivated on the basis that these methods are indiscriminate and have wideranging and damaging impact on biodiversity patterns and processes, and varying degrees of inhumanity attached to it. Furthermore these methods have been demonstrated not to resolve DCA problems. 9. Other methods of hunting should be restricted activities and its methods should be subject to the activity and methods being compliant to permitted conditions through the permitting authorities. 10. Permits must be issued within a limited time period. 11. Farmers, Game Owners, Agricultural Lobby Groupings, Traditional Healers or Cultural Traders should NOT be granted any special rights or privileges in these regulations as they are citizens like us all and should comply with the regulations as we all have to. This also goes for livestock farmers and game farmers – all citizens are equal before the law and should comply equally. Further too, DAFF, lobby groups such as the PMF should have no veto rights on legislation and species lists – again, all citizens are equal before the law. 12. There should be no distinction in these regulations between individual animals in game farms, outside game farms, or on reserves. The regulations should focus on biodiversity patterns and process conservation and legislative protection, and it applies to all citizens. Certificates of adequate enclosure merely provide access to ownership of wild animals and no special permission to dispose or trade in them without compliance with restricted activities. 13. It must be stressed that the exclusion of merely one commonly persecuted species from a species listing, and the concurrent allowance of indiscriminate persecuting methods and activities would effectively render any conservation action on any species un-implementable as these indiscriminate controls/hunting methods can effectively impact all species, even critically endangered species through by-catch or even undeclared agendas. The legislative control thus has to be concurrently from two perspectives: a. Comprehensive listing of all and every persecuted species, AND b. Prohibitions and restriction of both activities and methods that may be indiscriminate across species. Annexure 3: Landmark Foundation: Objections to the Published Draft National Norms and Standards for the Management of Damage Causing Animals The Director General: Environmental Affairs Attention: Mr Thomas Mbedzi Private Bag X447 Pretoria 0001 OR The Director General: Environmental Affairs Attention: Mr Thomas Mbedzi North Tower (Room 1320) 315 Pretorius Street Pretoria OR Tel: +27 (0)12 320 3225 Fax: +27 (0)12 320 7026 Email: [email protected] Dear MrMbedzi (for the Director General, Department of Environmental Affairs) Re: Objections and Comments on the Published Norms and Standards for the Management of Damage-Causing Animals (Government Gazette Vol 545, Pretoria, 26 November 2010, No 33806) General Notice (1084 of 2010), herein after referred to as the Norms & Standards In terms of the General Notice published in the above listed Government Gazette I wish to make the following representations and objections. I will make them in three categories, one general, another on key omissions, and another specific to points in the published document. General Comments and Objections 1. The specialist task team put together by the officials of the Department of Environmental Affairs to help draft these Norms & Standards, after several meetings and detailed discussions, had made certain recommendations that have been disregarded in the final document. Most importantly the definition of damage causing animals (dealt with here below), the restriction of the use of gin traps (and now called “soft” traps) for 3 years (after which they would be prohibited under all conditions), and the prohibition of methods like dog hunting, denning, helicopter hunting, poison baits, and snares, have not been dealt with or retained in this version of the Norms & Standards. 2. Chapter 2 section 24 of the Constitution of the Republic of South Africa deals with the Bill of Rights, and the provisions of this Norms & Standards undermine those rights. I refer you to section 24 in the Bill of Rights in this chapter of the constitution that deals with the environment. I quote specifically: 24. Environment Everyone has the right a. b. to an environment that is not harmful to their health or well-being; and to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that i. prevent pollution and ecological degradation; ii. promote conservation; and iii. secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development. 3. The published Norms & Standards specifically enable the use of methods that have been scientifically proven to cause ecological degradation, to undermine conservation and ecologically sustainable development. This specifically involves the issue of gin traps (renamed as “soft” traps in the Norms & Standards) and the use of hunting dogs. This will open this piece of statute to a constitutional challenge as currently published. The scientific data to support this is contained in the reference list attached as an annexure. Furthermore section 7 (2) of the constitution places an obligation on all, but specifically the “state must respect, protect, promote and fulfil the rights in the Bill of Rights”. As such I would expect the published Norms & Standards document to do so. The supremacy of the Constitution must be respected. The constitutional rights to dignity, psychological integrity, freedom from violence and the environmental rights guaranteed in the constitution are placed in jeopardy by some provisions in the Norms & Standards. 4. Furthermore, although animals are not accorded legal rights in our constitution, in a civilized and humane society of which I hope we are a part, we have a duty of care to treat our environment respectfully and humanely, neither of which are promoted by the contents of this Norms & Standards. 5. The principles promoted in the Norms & Standards document are accurate and appropriate, yet the conditions promoted in chapter 2 part 3 are contrary to the very principles laid down by this document, making its provisions fatally flawed. 6. Certain provisions in the Norms & Standards run contrary to other acts and legislation, for example the allowed method of dog hunting is prohibited in terms of the Animal Protection Act 71 of 1962 and thus may be unlawful, as are the use of traps. Other provisions are unlawful in terms of certain species such as listed Threatened Or Protected Species (TOPS) being hunted through luring in methods like call and shoot hunting, dog hunting and gin traps. Furthermore it is unclear how the provisions in TOPS relating to Damage Causing Animals and these Norms & Standards relate to one another, as the provisions relating to TOPS listed species are contradictory in terms of these Norms and Standards, e.g. the use of gin traps on TOPS listed species are prohibited. 7. The definition of a damage causing animal is so broad as to effectively make ALL wildlife by definition damage-causing animals, and with the subsequent vagueness of the control of restricted activities, and the absence of listing of prohibited activities, this will lead to ongoing and wide-scale abuse against the faunal diversity of South Africa. 8. There are several issues in the Norms & Standards that are unclear and makes this guideline document open to abuse and likely to be ineffectual, namely: a. The meaning and implication to management of restricted activities are void due to vagueness and thus opens the system to abuse. Specifically the document is unclear and vague on the implications of an activity being restricted, and leaves it open to abuse. We strongly recommend that all restricted activities be subject to a permit being issued each time such an activity is being applied for. The Norms & Standards are ambiguous on this matter. 9. 10. 11. 12. b. The Norms & Standards are silent of those activities that are to be prohibited. We strongly recommend that all prohibited activities be prohibited under all conditions and that those activities be defined and listed as being such. We also recommend that the Norms and Standards make a defined distinction between prohibited and restricted activities. c. The prohibited activities are to include: gin traps, walk through snap (“Killer”) traps and all forms of leg held devices, poison baits, denning, dog hunting and helicopter hunting. Additionally we recommend that all forms of holding captive of individuals of damage causing animals, such as to capture urine or excrement scent lures, be prohibited. d. The document is silent in terms of how permits for restricted activities are to be issued. We strongly recommend that permits are to only be issued after the relevant issuing authority or such registered professional known to and acceptable to the relevant issuing authority, has conducted a site inspection and reviewed the relevant information prior to issuing any permits for restrictive activities. This Norms & Standards compounds the existing confusion between the provisions of the TOPS regulations, NEMBA and the various provincial ordinances and hunting notices/permit /bag limit provisions pertaining to damage causing animals. The terms and definitions vary, and the net result will be that the confusion legalizes the continued indiscriminate extermination of many animals and indeed species. For example, certain activities against TOPS listed species are prohibited, yet if they are classified as a DCA they would be permitted in these standards, besides, if, as per definition of these Norms & Standards, all wildlife would be classified as DCA’s it would make the TOPS regulations obsolete. There can be no place for the continued use of gin traps (cynically called “soft” traps – they are the same thing). There is no scientific or any ethical justification for their use. They remain indiscriminate, lethal controls of little efficacy in targeting even culprit individual damage causing animals. Their continued use even as a restricted method, in the management of damage causing animals flies in the face of the very principles supported by these Norms and Standards. Furthermore it is in contravention to the Animal Protection Act 71 of 1962, and the TOPS regulations. It is not possible to define gin traps and soft traps to exclude gin traps from the ambit of soft traps, or visa versa. As such, the attempt to do so in this document is nonsensical, illogical and perhaps even cynical. There can be no place for the continued use of hunting dogs. There is no scientific or any ethical justification for this. They remain indiscriminate, lethal controls of little efficacy in targeting even culprit individual damage causing animals. Their continued use, even as restricted method, in the management of damage causing animals flies in the face of the very principles supported by these norms and standards. Furthermore it is in contravention to the Animal Protection Act 71 of 1962, and the TOPS regulations. Omissions from the Norms & Standards 13. A very important omission from the Norms and Standards is that under no circumstances should a DCA be hunted for any profiteering venture or be “sold” to a hunting client. This is a VERY important provision as certain key and high hunting value species will be indiscriminately motivated as being DCAs and will be selectively persecuted. 14. No restricted activity permits should be issued post the execution of an activity. 15. The absence of the definitions of prohibited and restricted activities is an omission that will lead to general abuse of damage causing animals. Prohibited activities should be defined as those activities that are prohibited under all and every circumstances. Restricted activities should be defined as activities that are restricted through the use of permit conditions laid down by the relevant issuing authority, and guided by the minimum requirements listed in the Norms and Standards. 16. It has been omitted to detail on how restricted activities can be permitted. The Norms and Standards should set such norms and standards which should entail: a. An application to conduct a restricted activity detailing the history of the loss, b. An inspection by the relevant issuing authority, or a registered environmental assessment professional with the authority, should be done and reported on, c. Proof of preventative measures or mitigation measures that have been implemented to prevent the loss should be detailed, d. Permit should be issued for the conduct of a restricted activity, which should detail the conditions, the time limits, and the location of such activities, and the subsequent report back provisions. 17. The absence of a detailed list of prohibited activities is a glaring omission, these should include: a. Snaring b. Gin traps and “soft traps” c. “Killer” walk-through snap traps d. Poison baits e. “Coyote” getters f. Hunting dogs g. Denning h. Helicopter hunting i. Holding captive of captured DCAs 18. Section 2 (6) is missing in the document as this must be a typographic error. Specific Objections and Comments 19. Refer 1 (1) b – it is noted that in terms of the Animal Protection Act 17 of 1962 it is an offence to: a. Ill-treat or maim any animal b. Cause unnecessary suffering c. Lays any trap or other device for the purpose of capturing or destroying any animal, wild animal or wild bird the destruction of which is not proved to be necessary for the protection of property or for the prevention of the spread of disease d. Use unregistered dog clubs e. Wantonly or unreasonably or negligently doing or omitting to do any act or causing or procuring the commission or omission of any act, causes any unnecessary suffering to any animal The use of gin traps (“soft” traps) or hunting dogs are not permitted in terms of this legislation and its inclusion on these Norms & Standards makes it inconsistent with the law. 20. Definition of damage causing animals as it stands is a MAJOR problem in these Norms & Standards as they effectively make all wildlife damage-causing animals per se. This creates the avenue for the persecution of wildlife on the whim of any applicant to conduct restricted activities. It is imperative that wildlife only be classified as damage causing animals with good reason and after repeated, regular and excessive damage been proven and verified, with all reasonable preventative measures having been tried. As such we recommend the following definition to be included, and please note that livestock farming and game farming requires different definitions: “damage-causing animal”means a wild vertebrate animal that, when interacting with humans or interfering with human activities, there is substantial proof that it— In livestock farming: (a) causes repeated and regular and excessive losses to livestock; despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. In game Farming: (a) causes “repeated and regular and excessive” losses to other wild specimens, which is inconsistent with the animal’s natural behavior and ecologically damaging to the specific enterprise; despite the existence of a certification of adequate enclosure to exclude predators from a game farming area, as approved and verified by the relevant environmental management agency. (b) causes “repeated and regular and excessive” damage to cultivated trees, crops, natural flora orother property; despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. (c) presents an imminent and realistic threat to human life; (d) is present in such numbers that agricultural grazing is materially depleted to a significant detrimental extent with respect to biodiversity and farming enterprises, despite the land user having applied and exhausted all reasonable methods and systems of exclusion and damage prevention. 21. Definition of “soft traps” and paragraph 14 is problematic to the extreme. These Norms and Standards are creating a new and false differentiation between gin traps and soft traps. There is no such differentiation in reality and making such a distinction has no merit in law. There is no way in law that a distinction between gin trap and soft traps exist in reality. This creates confusion and a sinister loophole in the statutes to prevent effective control of these devices. It also renders other legislation, like NEMBA and TOPS, impossible to implement in terms of gin trap prohibitions. These Norms & Standards thus effectively creates a mechanism to continue and entrench to use of gin traps, albeit under a new name, but within the same reality of its damage to biodiversity and with its continued ethical problems. 22. The continued use of gin traps (and here rebranded as soft traps) is contrary to the very principles of these Norms & Standards, contrary to the Animal Protection act 71 of 1962, the TOPS regulations of the NEMBA, and the consequences of its continued use is at variance to the constitutional rights provided in our constitution. 23. The specific minimum requirements of the so-called “soft traps” have many problems; mostly that it is a rebranding of currently used gin traps. The Norms & Standards is thus illogical in respect that it seemingly creates a nomenclature distinction between gin traps and soft traps which in law and practice is not possible, but in defining the minimum standards they are the same things. We believe this is intended to mislead and creates ongoing ineffectual and non- implementable legislation. It is notable that there is an absence of the definition of a gin trap in the document. The problems with the minimum requirements are: a. The name soft trap is an oxymoron as has nothing soft in its structure, mechanism of action, impact on faunal species or biodiversity in general. We are of the opinion that this distinction included in the Norms & Standards are sinister and intended to render the implementation of controls against gin traps ineffectual. SOFT TRAPS as defined in this document are GIN TRAPS. b. The definition suggested that these traps must be target specific and selective. This is not practically possible. These traps are by their nature non specific and indiscriminate and almost invariable lethal. In no way is it thus possible to assert they can have specificity or selectiveness. There is no research to support the stance that gin traps are target specific, effective or selective in trapping damage causing animals. There are however numerous scientific papers as well as comments by top academics and researchers to illustrate the lack of target specificity and poor efficacy of the use of gin traps to trap DCA in farming areas. c. The selection of a minimum weight of 1.75kg is utterly arbitrary and entirely irrelevant, as almost all traditional by-catch of gin traps of these species are above this weight category and thus susceptible to their impact. There has only been research by one researcher in South Africa in an area of questionable mammalian biodiversity to lend any support to this weight category. Although the trapping of certain species such as the Cape fox Vulpescharma and the Bat eared fox Otocyonmegalotis may be slightly reduced by setting the tread plate to release at pressures in excess off 1.75kg. This mechanism has been in operation in South Africa for over 10 years as seen in the “Terminator” gin trap tread plate mechanism. However in practice, this has not alleviated the by-catch of thousands of non target innocent species. Skinner &Chimimba (2005) indicate that the following species (for example) would fall prey to these devices as they fall above this weight category: Cape fox, African wild cat, bat eared fox, civets, genets, black footed cats, primates, antelope, dassies, rock rabbits, spring hare, scrub hares, cane rats, leopard cheetah, lion, hyena, caracal, jackal, domestic dogs, humans, etc (to arbitrarily select a few species). Haw (in prep, 2010) demonstrated that “terminator” traps (which are described in the Norms & Standards as soft traps) had a 8% specificity in capturing predators demonstrated to have sheep remains in their stomachs, demonstrating either scavenging or predation events. d. The actual description of soft traps is the actual parameters of the most commonly used gin traps in South Africa, namely those manufactured by Mr Peter Schneekluth of Prince Albert, being sold under the name of “terminator” traps and “leopard” traps. These traps fall exactly into the Norms & Standards definitions and description of minimum standards as it stands in the current document. e. In addition the power of the spring mechanism has not been coherently addressed. This is perhaps the most important aspect of the gin trap mechanism with respect to causing injury to trapped wildlife. A trap such as the “Terminator” is way too powerful even for an animal the size of a leopard. This has been vividly illustrated on numerous occasions where numerous species of wild animals trapped with the Terminator gin trap have had to be euthanized as a result of their limb injuries associated with this trapping specific mechanism. This trap is compliant with the minimum standards of soft traps in the Norms & Standards. This is a Terminator Trap. This leopard died. 24. Chapter 2, Part 1, 6(2) refers to “where an inspection is required”. This reference is void due to its vagueness and should read that all applications for a permit to execute a restricted activityshould be legally required to undergo an inspection by a member of the relevant issuing authority or alternately a registered environmental assessment professional. 25. The attempt to require the response of the authorities to complaints about Damage Causing Animals to be "proportionate to the damage caused" is problematic when para 6(1) is read with para 6(4). This seems to imply, although it is not clear, that the most severe harm (loss of human life) requires the most severe response – i.e. killing the animal? Rather the issuing authority should be required to respond reasonably or to use reasonable measures. It may not be reasonable to kill an animal even if it has killed a human. In deciding what are reasonable measures, the issuing authority should rather have regard to the principle that an animal has a basic intrinsic right to exist as a part of its particular habitat and ecosystem and that the legal right of humans to life and security of property should be carefully weighed against this. 26. Part 2 (7) (3) (a) (iii) makes all and any translocation doomed for failure. Firstly it is not practical to get written prior consents as many of these events unfold as desperate emergencies. Secondly this specific provision is impracticable as these animals may traverse the properties of many farm owners (hundreds in some instances). Thus the Norms and Standards are not practically and realistically implementable. We recommend that this provision should read that “the issuing authority may decide to release a translocated animal in an area it deems appropriate, or the receiving landowner or entity that seeks to received such an animal must sign a written undertaking accepting all legal responsibility and liabilities for the animal being received, and must abide by the provisions laid down by the relevant issuing authority.” 27. Part 2 (8) (1) (b) (i& ii) (Dead Stop Collars and King Collars) are brand names and should fall away as they are dealt with under (vi) 28. Part 2 (9) (1) is dealt with under points 12 & 13 above here. Specifically it is recommended that all restricted methods ONLY be permitted under permits issued by the relevant issuing authority. 29. Part 2 (9) (1): the use of (b, e & f) (poison collars, soft traps and dogs) are contrary to the very principles of these Norms and Standards, never mind to other legislation (APA 71 of 1962, TOPS, NEMBA) and in variance to the constitution. These should be termed prohibited methods. 30. Clause 13 should have three additional aspects added as separate clauses within the minimum standards for call and shoot hunting, namely: a. Only target specific individual known culprit damage-causing animals. b. Not be remunerated per number of animals shot , but per problem resolved, to prevent the current practice of large number of animals being shot on a single hunt c. Be issued with a joint TOPS and DCA permit should a TOPS listed species be involved in the damage a destruction permit be requested. 31. Clause 15 is in contravention of the Animal Protection Act 71 of 1962 and dogs may not be used to hunt other animals, especially in terms of the definition in this Norms and Standards of hunting. 32. It is also incongruous in terms of 9 (1) (f) and 15 (2) that different numbers of dogs may be used in these hunts (that are in any event unlawful). 33. Chapter 3 (18) states that it is lawful to use gin traps (here referred to as soft traps), which is factually incorrect in law (refer to TOPS and the APA 71 of 1962, and the Constitution). This is furthermore in variance to the recommendation made by the specialist task team that helped to draft these norms and standards who recommended that: Gin traps (with minimum standards) will be allowed for use as a restricted method in the management of damage-causing animals under individual permitted conditions issued by the relevant issuing authority , and in the use of trained and registered service providers. This provision would be in place for three years; thereafter the method would become a prohibited method. We formally object that this recommendation has been disregarded and altered, that gin traps have been illogically rebranded by an oxymoron to soft traps, and their continued use be entrenched in these Norms & Standards. This is contrary to the constitution, NEMBA, TOPS and the Animal Protection Act 71 of 1962. I trust that these detailed submissions will be considered and that the department will apply its mind to the illustrated flaws, omissions and recommendations made herein. Yours truly, Dr Bool Smuts Director Landmark Foundation Annexure 4: The following scientific papers and notes thereof in support of the notion that there is no data to support the inclusion of gin traps, coyote getters as a management tools of jackal, in particularly, as a damage causing animal. (Drafted by R Harrison White) Parks and Un-persecuted jackal populations 1. Rowe – Rowe & Green – “Steel jaw traps for live capture of black-backed jackals Afr.J.Wildl. Res 1981 : Aug – Sept (70%) 17 trap nights per jackal (11 adult and 4 immature <1yr but papers differ - other paper 1yr (1): 1-2yr(3): 3-4yr (4):4-5(2): >7(1 )(15 in 256 trap nights) - with decreasing success in 4 nights of rapping: 5 on the first night, 7 on second night, 1 on the third, and 2, on fourth nothing after that. 2. Rowe-Rowe & Green 1981 no success in 206 nights when no fresh signs of jackal 3. Mckenzie 1990: ”Cooperative hunting in the black-backed jackal”: 7 jackals in Moshatu Game reserve – total 20 jackals caught between methods – traps most successful – 7 trapped within 10min to 2yrs of setting trap – one jackal killed by lion in trap – no non targets – 6 of the trapped jackals showed lameness for 2-17 days after capture – as no visible injuries – lameness probably due to ligament, tendon and muscle injury including in the free lag from straining to get out of trap. 4. Kamler :June – August 333 nights 15 jackals: all territorial – no age analysis = 22 trap nights per jackal – classified 1-2 or adult perscomm 5. A.J.Loveridge and D.W.Madonald “Seasonality in spatial organization and dispersal of sypmpatric jackals”J.Zool.Lond.2001 = 6 trap nights per jackal 22 jackals caught (11 mesomelas) – ages not given – no weights etc– ear tags - 2785ha next to Hwange National park – trapping done in dry season (June to August– mating estimated from pups to be mid July) - to avoid capturing juveniles? Pups dependant on den site to December (would agree) - 6 jackal groups (2 mated pairs and others mated pairs with 1-4 extra individuals)– June 1995-April 1997 – dusk to midnight or midnight to dawn every 10mins – fixes for rapidly moving jackals not taken- animals not fitted with tags were identified by their age and markings – “no estimation on population size …because of the difficulty of recapturing individuals” Territories probably about same size as in KGP Ferguson +- 400Ha but no info given here Persecuted populations 1. Kaunda: “Black backed jackal predation at Mokolodi Nature Reserve” 1998 2. 3 captures in 204 trap nights = 68 trap nights per jackal - going on neck size two were pups(210 & 225) caught Nov 95, June 96 ,Oct 96 3. “Adult jackal consistently avoided being trapped” Kaunda - adjacent farms have PA control – makes it harder & reserve is only 3000ha. No non target info 4. A. Haw September 2009 – January 2010 unpublished - 25 gin-traps permanently – has caught 5 jackals in +- 120days =3000 trap nights although some animals sat in traps for over one week so one could probably take say 10% off this figure make it say +_ 2700 trap night for 5 jackals =.540 traps night per jackal 5. Bothma 1971 Control and ecology of the black- backed jackal in Transvaal. Zool. Afr.6:187-193 6. Bothma perscomms to Rowe –Rowe “steel jaw traps proved least successful and capture effort was enormous (methods used greyhounds, gin-traps, Getters and digging) 7. Ferguson J.W.F: The Ecology of the black backed jackal 1981 using Lensing, J.E. & Le Roux, T.F. 1975: “A capture snare for the small mammal predators and scavengers” method of snaring with a fishing rod apparatus. “Between 5 -25 snares were set each night (fishing rods) in each of the two study areas in the Transvaal. The capture success with snares was 550 snare nights per jackal in the Western Transvaal and 104 snare nights per jackals and in the Suikerbosrand Nature Reserve. This difference in capture rates is largely due to the fact that jackals are intensively hunted by land-owners and this makes the jackals more frightened of human smells and human apparatus”. Ferguson 1980 Jackal probably don’t bred before 3rd year Group sizes were smallest during July to October following he peak in pupping (July) and before pups leave the den and greatest from November to February when pups forage with the adults” – Black-backed jackal population structures in the natal Drakensberg Rowe – Rowe The Lammergeyer 32 January 1984 Kaunda catch rate was extremely poor but this was probably because of intense jackal persecution on farms bordering the 3000ha reserve. The effect of this is aptly described by Kaunda “ jackals encountered outside the reserve bolted for cover …. Jackals inside the reserve could be approached to within 50m”. This is the point – trapping in persecuted areas is not so easy and not effective. 8. Haw, A (2010, In prep) 5 months of intensive gin trapping on productive sheep farm monitored gin trap efficacy and specificity. 20 gin traps used, 36 animal captured, all died, 3 (8%) had sheep contents in stomach = predator or scavenger (not necessarily culprit damage causing animal), 70% were non target species. Avoidance and “learnt “ behaviours A characteristic of the black backed jackal is this animal’s remarkable ability to learn and avoid mechanisms which are seen as “new” (neophobia) or dangerous. Much research has been completed on this aspect of the black- backed jackal behavior represented by research such as: 1. Brand & Nel 1997.: “Avoidance of cyanide guns by black backed jackal 2. R. Harrison – White June 2001: (in press) “Black backed jackal resistance to CD calling techniques” 3. P.J.J. Van Rensburg&M.J.De Wet 1995 : Final Report “The Effectivity and Selectivity of poison baits in the control of black back jackals” “ the avoidance by black backed jackal to poison baits makes this method an ineffective population control method”. This statement can without doubt be extrapolated to other control techniques. 4. R. Harrison – White July 2002 (in press): “Black-backed jackal avoidance of “Dropper Baits”” 5. R. Harrison – White July 2002 (in press): “Black backed jackal learned resistance to cage trapping in captivity” 6. Brand et al :”Progressive Resistance to Coyote Getters” Specific gin-trap mechanism avoidance: Parks and Un-persecuted jackal populations Author & Publication Rowe – Rowe & Green – “Steel jaw traps for live capture of blackbacked jackals Afr.J.Wildl. Res 1981 : Rowe – Rowe & Green – “Steel jaw traps for live capture of blackbacked jackals Afr.J.Wildl. Res 1981 : Mckenzie 1990 ”Cooperative hunting in the black-backed jackal” : Kamler 2008: “Efficiency and safety of Soft Catch traps for capturing blackbacked jackals and excluding non target species” Place No Jackals time year Drakensberg NP Aug – Sept (15 in 256 trap nights) Drakensberg NP Aug – Sept Trap success Moshatu Game Reserve 7 jackals trapped BenfonteinFreestate June – August 333 nights in 2 years =15 jackals 7 trapped within 10min to 2rs of setting trap– traps most successful method 17 trap nights per jackal - with decreasing success in 4 nights of trapping :5 on the first night , 7 on second night ,1 on the third ,and 2, on fourth nothing after that no success in 206 nights when no fresh signs of jackal 22 trap nights per jackal A.J.Loveridge and D.W.Madonald2001 “Seasonality in spatial organization and dispersal of sypmpatric jackals” J.Zool.Lond.2001 Ferguson J.W.F1981: “Ecology of the black-backed jackal” Farm 2785ha next to Hwange NP dry season (June to August) 11 jackals 6 trap nights per jackal ages not given – no weights etc– ear tags “no estimation on population size …because of the difficulty of recapturing individuals Suikerbosrand Nature Reserve 104 snare nights per jackal Persecuted jackal populations: Author & Publication Kaunda: 1998 “Black backed jackal predation at Mokolodi Nature Reserve” Haw perscomms. Ferguson J.W.F1981: “Ecology of the black-backed jackal” Bothma 1971 “Control and ecology of the black backed jackal in Transvaal”. Zool. Afr.6:187-193 Place No Jackals time year Mokolodi Nature Reserve 3000ha 3 jackals Taaiboshfontein Victoria west September 2009 – January 2010 Western Transvaal Transvaal Trap success 68 trap nights per jackal (3 captures in 204 trap nights) “Adult jackal consistently avoided being trapped” - adjacent farms have PA control – makes it harder”. 450 traps night per jackal - 5 jackals 550 snare nights per jackal “This difference in capture rates is largely due to the fact that jackals are intensively hunted by land-owners and this makes the jackals more frightened of human smells and human apparatus”. Bothma perscomms to Rowe –Rowe “steel jaw traps proved least successful and capture effort was enormous (methods used greyhounds, gin-traps, Getters and digging) This type of reaction summed up by P.J.JVanRensburg&M.J.De Wet 1995 in poison baits tests “ the avoidance by black backed jackal to poison baits makes this method an ineffective population control method” This statement can without doubt be extrapolated to other control / capture techniques. The failure of the gin-trap as a control option for jackals and jackal predations is evidently linked to this animals’ ability to learn and avoid control strategies, a point aptly supported by the above research.