Concept Note: Key challenges relating to the management of elephants in South Africa

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CONCEPT NOTE
KEY CHALLENGES RELATING TO THE IMPLEMENTATION AND ENFORCEMENT OF THE
NORMS AND STANDARDS FOR THE MANAGEMENT OF ELEPHANTS IN SOUTH AFRICA

BACKGROUND AND DISCUSSION

The Norms and standards for the management of elephants in South Africa (Elephants N&S) were
published in the Gazette for implementation on 29 February 2008. Since the commencement thereof on
1 May 2008, a number of elephant management challenges have been identified, among others:
The requirement of a management plan, in particular:
The responsibility to develop a management plan for a roaming elephant (an elephant from a
known or unknown locality for which responsibility cannot readily be determined);
Refusal of permits for the translocation of elephants in emergency circumstances, in the
absence of a management plan;
Lack of monitoring compliance with the requirement to submit a management plan;
Restrictive provisions relating to the import or export of live elephants, which state that:
Wild elephants may only be imported/ exported mainly in terms of an international agreement,
or for scientific/ research purposes; and
Captive elephants may be temporarily imported/ exported, only as part of a bona fide circus.

The purpose of Elephant N&S is, among others, to manage elephant populations to ensure long term
survival in the wild, promote broader biodiversity and socio-economic goals, and to ensure sustainable
utilization of the resource. However, a number of the guiding principles relate to the prevention of abuse
and the neglect of elephants, which is problematic as the Department of Environmental Affairs (DEA)
does not have the mandate to regulate welfare issues.

The DEA solicited inputs through intergovernmental structures such as Working Group 1 (relating to
biodiversity matters), Working Group IV (compliance and enforcement matters), Working Group 11


Concept Note: Key challenges relating to the management of elephants in South Africa
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(legislative matters) and the Permit Enforcement and Planning Committee, relating to challenges to
implement and enforce the Elephants N&S. Other inputs were also received during the elephant
research workshop held on 11-12 February 2013 at Skukuza in Kruger National Park.

The following is a summary of key issues received through the intergovernmental structures as well
from the elephant research workshop:

1. Definition
Cow-calf group (definition problematic)
Preferred management density:
o the definition is too limiting. This definition must be extended to also clarify what "an
acceptable range" is;
o an ecological carrying capacity is too rigid and that a more flexible, preferred stocking
density, is required. Alternatively, the economic carrying capacity should be considered
rather than the ecological carrying capacity.

2. Welfare issues
It is not within DEAs mandate to regulate welfare issues
Little emphasis is placed on the management of captive elephants, which has become a very
contentious issue and needs to be addressed accordingly.

3. Keeping of elephants
The requirement of an approved management would make it difficult to keep elephants since it
could take a longer period for the elephant management plan (EMP) to be approved as there
are many aspects to consider.
Challenges relating to the capacity/ availability of resources to conduct on-going assessments
of the impact of elephant on the habitat and ecological function of the area.
It is unclear in what format the on-going assessment should be submitted as well as the
required time frame.

4. Management plans
No restricted activities allowed until the EMP has been approved.
Limitations for EMP. Details required, preferred management density.


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It is not clear who approves the management plan considering the implications of Section 87A
of the National Environmental Management Laws Amendment Act, 2013 (NEMLA).
Need to streamline and simplify the approval process.

5. Initial assessments
It is not clear if an initial assessment is applicable to captive elephants.

6. Adequate enclosures
It is not clear if communal land can be adequately enclosed to keep elephants.
Very specific minimum fencing requirements.

7. Administration of scheduled substances and sedation
It should provide for circumstances under which an elephant can be sedated more than once.

8. Capture of elephants
The provisions are very limiting since it provides for capture only for:
o wild elephant (kept in captivity)
o only temporary (translocation) capture
o rehabilitation facility for sick/injured
Exceptional circumstances on approval by the Minister:
o international agreements or scientific
o research purposes

9. Translocation of elephants
Previously translocated animals cannot be translocated again except under exceptional
circumstances, have not been defined.
Only cow-calf group.
Release camp required (specifications in Annexure at least 6 elephants and other added cost
implications for introducing elephants).
In mixed groups or where populations have increased over several years, how will an
owner/manager be able to distinguish between translocated and non-translocated individuals?
It is suggested that a time frame be included.



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10. Import and export of elephants
No wild / captive elephants imported or exported for the purpose of keeping it in captivity in a
controlled environment, however there are exceptions.

11. Release camps
The elephants could be kept in the release camp for a few minutes before releasing within the
property or merely offloaded within the release camp, since only a maximum period has been
provided but not a minimum period or guidelines that need to be adhered to.

12. Control of wild elephant population sizes and distribution
To manage size, or composition or rate of growth of a population, the options limited:
o only allowed to capture, relocate/translocate (not cull)
o flow diagram to rule out the need to cull
To management of spatial distribution within boundaries, options excludes:
o hunting and culling

13. Establishment of new population of wild elephants
Very prescriptive requirements:
o social structure (matriarch)
o initial populations not less than six individuals (cow-calf groups)

14. Contraception
A lot of uncertainty at the time the Elephant N&S were developed and published.

15. Range manipulation:
Vey prescriptive requirements:
o management of water supply / feed supply / fire
o enclosure / exclosure fences
o corridors / expansion through acquisition of additional land.

16. Hunting of elephants
Should only be considered for bulls, although the Elephant N&S provide that females can be
hunted on private or communal land as per management plan.


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No hunting in immediate proximity of female/calf groups.
Consideration should be given to stipulating a minimum approximate distance that a bull should
be away from a herd before hunting is allowed.
How long should an elephant be allowed to settle in an area that it has been moved into before
it is hunted (relates to the issue of put and take hunting)?

17. Hunting methods
No hunting within 500 of water point (problematic for small areas).

18. Provisions for captive elephants
Annexure VII has not been published. This hampers the effective implementation and
administration of the Elephant N&S by creating areas that are currently not addressed
specifically for captive elephants.

19. Keeping elephants in captivity
What happens to elephant that were acquired without the necessary permits before the
Elephant N&S came into effect.
The availability of elephants for zoos and other eco-tourism activities would be a challenge.

20. Escaped or roaming elephants
The Elephant N&S do not deal sufficiently with roaming elephant, especially where elephant
enters South Africa from neighbouring countries.

Due to the above challenges, the need to review the Elephant N&S has arisen. In order to initiate the
review process, the DEA is convening a stakeholder workshop on 12 August 2014. The purpose of the
workshop is to discuss the challenges relating to the management of elephants in South Africa; in
particular, the implementation and enforcement of the Elephant N&S.

The current Elephant N&S will be revised, based on the outcome of the stakeholder consultation
workshop.