Comment on the Draft Regulations for the Domestic Trade in Rhino Horn.

Comment to the Department of Environmental Affairs by J.C. Rance.

Director: The True Green Alliance (TGA).

The Director General,

Dept of Environmental Affairs.

Att:  Ms Magdel Boshoff.

By e-mail:

Dear Madam,

Comment on the draft regulations for the domestic trade in rhino horn, or a part, products or derivative of rhino horn – notice 74 of 2017, Government Gazette number 40601, 8th February 2017.

Our company operates a game ranching, hunting, crop growing and agro-processing enterprise in close proximity to communal land in Transkei and former Ciskei in Eastern Cape province.  The operations encompass some 9500ha of land area dedicated to wildlife protection and utilization and the maintenance and increase of biodiversity on an economically and environmentally sustainable basis.

The operations are under-pinned by the sustainable utilization of natural resources, including wildlife.  Much of the area has been converted from unsustainable and uneconomic conventional agriculture which was characterized by poor environmental practices and the loss of natural habitat and resultant reduction in biodiversity.

In addition, the shareholders and directors are also involved in the operation of some 25’000 ha of forestry land leased on a 70-year lease from government, all FSC certified environmentally.

Plans are afoot and already well advanced to extend these operations to BEE shareholdings which have been fully supported by government.

The businesses have been operating sustainably in this region for some 75 years.

We have had sight of the submission made by the Private Rhino Owners Association (PROA) and wish to advise that we fully support this submission and take the opportunity of thanking the Minister for the proposal to allow the domestic trade of rhino products.

Our businesses do not own rhinoceros (rhino) species simply because there is no financial incentive to do so as the products cannot be economically utilized.  However we have the space and habitat for both black and white rhino.  If the trade in rhino species and products emanating from them were de-regulated so that the products could be utilized on a sustainable basis, thereby inter alia affording the considerable costs of protecting the species from poaching, there is little doubt our company would invest in the purchase and breeding of both white and black rhino species which could result in the further proliferation of many hundreds of those species.

As an aside and example of unintended consequences of unnecessary regulation, our companies also own TOPS registered species, all of which are now in decline and will likely be sold off because of regulatory restrictions.

It is noted that the constitutional and National Environmental Management Act (NEMBA) obligations of sustainable use of natural resources is highlighted the PROA submission.

Further to this, however, are the objectives and obligations of the United Nations International Union for the Conservation of Nature and Natural Resources (IUCN), often called the World Conservation Union (WCS) which are supported by WWF and should be supported by CITES.

One of the three guiding principles for modern wildlife management policies of the IUCN/WCS is to ensure the sustainable utilization of species and ecosystems (notably fish and other wildlife, forests and grazing lands) which support millions of rural communities and as well as major industries.

 Added to the above are the objectives to maintain essential ecological processes and life support systems and to preserve genetic diversity.

 With respect, it is incumbent upon your department to support these objectives.  A ban on trade of rhino species and products and over-regulation of trade in them will militate not only against our own constitutional and NEMBA obligations, but also the objectives of the UN’s IUCN/WCS.

Finally, in considering comments to the draft regulations (and for that matter, any sustainable use of wildlife products) the Department should beware of and discard submissions by the likes of Animal Rightist organizations (whether overtly or in disguise) which do not support sustainable use of wildlife or natural products as mandated by the obligations and objectives of our constitution, NEMBA and IUCN/WCS.

Any organization or person commenting on regulations should declare their unequivocal support for the obligations and objectives quoted above before their submissions are considered; otherwise they will be sure to make proposals and objections which render any regulations impractical and unworkable in achieving such objectives.

Yours faithfully,

J.C. Rance.

Director The True Green Alliance (TGA)

Director Rance Rural Development (Pty) Ltd


South Africa.

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