Dear President Ramaphosa and Honourable Ministers,

On behalf of the “Coalition to Stop the Captive Breeding and Keeping of Lions and Other Big Cats for Commercial Purposes (The Coalition)”, we would like to state our formal support echoing that of The National Department of Tourism (NDT) for the Southern African Tourism Services Association (SATSA) guidelines and tool on captive wildlife interactions, as well as rebut an open letter submitted by a group only referred to as “Captive Wildlife”, unsigned by any group representative. 

The above mentioned letter was submitted in opposition to the non-binding and voluntary guidelines released by SATSA on 31 October 2019. The group claims that the SATSA “Guide & Tool for Captive Wildlife Attractions & Activities” is “misleading, biased, unethical and unconstitutional”. On the contrary, in conjunction with SA Tourism, SATSA undertook 12 months of rigorous, country-wide stakeholder engagement workshops (10 workshops in 9 provinces), surveys and feedback sessions. These were open to all SATSA members (approximately 1200 entities in 11 member categories), as well as the wider tourism industry, including internationally, and other interested and affected parties that intersect with the tourism industry. The need for homegrown animal interaction guidelines was voiced at SATSA’s 2017 AGM, and the production of the Guide and Tool has been a 2-year journey. 

These guidelines are based on an ethical framework that is the determining factor against which activities/attractions/facilities should be measured. The ethical framework includes an “Integrative Approach”, developed by Professor David Bilchitz, (Professor at the University of Johannesburg and Director of the South African Institute for Advanced Constitutional, Public, Human Rights and International Law (SAIFAC), and current Secretary-General of the International Association of Constitutional Law). This approach focuses on “the survival of both the individual and the species, rejects the sacrifice of the individual to advance the goal of species conservation and recognises a relationship between respect for an individual animal and the survival of the species, the former being essential for preserving the species as a whole.”

The South African Constitutional Court recently endorsed this view of conservation, holding that, “This integrative approach correctly links the suffering of individual animals to conservation, and illustrates the extent to which showing respect and concern for individual animals reinforces broader environmental protection efforts. Animal welfare and animal conservation together reflect two intertwined values.”

Whilst we appreciate that the guidelines are not regulative or legislative, we believe the South African tourism industry will in time regulate itself according to the rapid global movement away from all types of exploitative wildlife tourism activities. SATSA’s “line in the sand” clearly indicates what they believe to be ethically acceptable and what is not, and this follows many of the international standards for wildlife tourism as well as the ANVR guidelines, which were published nearly four years ago.

There is a growing global social movement towards ethical and responsible travel witnessed on platforms such as Trip Advisor, Instagram, Air BnB and Expedia. In October, the New York Times reported on Airbnb’s new featured offering of “animal experiences”, which will have an ethical focus and will ban any direct contact with wild animals. This announcement came after Trip Advisor’s decision to stop ticket sales to all attractions that feature whales and dolphins.

In March, the New York Post reported on a survey done by OnePoll on behalf of Exodus Travels that revealed that 57% of respondents said they want tour companies to have responsible wildlife policies. The respondents included riding on elephants, swimming with dolphins and posing with wildlife for photos on their list of unethical activities that they would not repeat. It is clear that most people love animals, and, when given the correct information, they would prefer to interact with them in ways that do not harm the animals, creating a better experience for everyone involved. 

In reviewing the global tourism platforms above, it is very clear that there is a global shift in how the tourism industry and tourists view ethical and responsible travel. Any responsible business that wants to protect its financial future and its employees has a responsibility to adapt its business model to or accept the consequences of their inaction.

This Captive Wildlife letter states that it has been signed and supported by more than 300 “concerned citizens, academics, conservationists, veterinarians, zoologists, wildlife owners, wildlife facility owners and tourism industry representatives.”  With such strong claims as outlined in the letter, we find it very surprising that none of the signatories’ full names, designations or affiliations are listed and that no formal committee is listed on their behalf. We have been able to identify some of the signatories and their affiliations, with many being connected to two lion petting facilities.  We believe that the lack of transparency in the signatory names is a cause for concern and a risk to Brand SA.   

In the address to delegates at the 2019 Africa’s Travel Indaba, President Cyril Ramaphosa referred to tourism as the “new gold” to highlight tourism’s importance in growing economies across Africa. With a growth rate of 7% in tourism in Africa in 2018, and with the President acknowledging that “Modern tourists are very discerning because they are spoilt for choice when it comes to choosing destinations. We live in the age of AirBnB and TripAdvisor. All these new technologies are opening up new opportunities and competition.” Groups such as the anonymous “Captive Wildlife” should not be allowed to risk South Africa’s reputation as a responsible and ethical travel destination.

Whilst the guidelines do not consider welfare and are based on an ethical framework, we feel it vital that the Constitutional Court ruling that animal welfare and conservation are intertwined concepts be respected, i.e. the protection of animal welfare is recognised as a part of the environmental right set out in section 24 of the Constitution. 

In closing, we wish to bring to your attention the responses by the Minister, Departments and Industry specifically regarding the Captive Lion Breeding (CLB) Resolutions:  

a) Parliament was instructed to put an end to the commercial exploitation of lions through the implementation of the National Assembly Resolutions. 

b) The CLB issue has generated “huge international outcry” and “it is tainting South Africa’s brand image from abroad”.

Contrary to the request made by the Captive Wildlife Group’s letter, we humbly ask that you endorse and support the SATSA Guide and Tool in line with global transformation and standards, and to ensure that tourism growth continues unabated in South Africa and remains untarnished by the minority captive industry. 

Signed by the Steering Committee.

Sent to:
The Honourable President Matamela Cyril Ramaphosa 
Honorable Mmamoloko Kubayi-Ngubane: Minister of Tourism 
Honorable Barbara Creecy: Minister of Environment, Forestry and Fisheries 
Honorable Angela Thoko Didiza: Minister of Agriculture, Land Reform and Rural Development 
Honorable Matsie Angelina Motshekga: Minister of Basic Education 
Honorable Bonginkosi Emmanuel “Blade” Nzimande: Minister of Higher Education, Science and Technology 
Sthembiso Dlamini (acting): CEO South African Tourism 
Tshifhiwa Tshivhengwa:  CEO Tourism Business Council of South Africa 

CC
Magdel Boshoff: Department of Environmental Affairs and Tourism 
David Frost: CEO SATSA