- The Director General: Environmental Affairs Attention: Mr Thomas Mbedzi
Gin traps – these are horrible, mechanical devices, designed to grasp an animal by the leg using spring-operated metal jaws. In their desperation to escape the pain and terror of being trapped, the captured animal will sometimes bite off the limb that has been caught. The use of gin traps has been illegal in the UK since 1958 and is banned in 90 other countries around the world.
The Government of South Africa is now proposing new legislation which will permit the use of the mis-named “Soft Traps” to capture animals suspected of attacking livestock. In action and effect, Soft Traps are the same as gin traps. It is a totally misleading name for such a nasty, cruel device.
1. Definition: The definition of a damage causing animal (DCA) 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, the nature of the minimum standards, and the absence of listing of prohibited activities, this will lead to ongoing and wide-scale abuse against the faunal diversity of South Africa. There should be provision in the definition for excessive, repeated and regular damage of property to qualify as a damage causing animal.
2. There is no definition of what a restricted activity is. It should involve an individual permit to be issued for each damage causing event and its permitted restricted activity.
3. No definition of what a prohibited activity is given. All prohibited activities should be prohibited under all conditions and that those activities be defined and listed as being such.
4. No listing of prohibited activities is provided. The prohibited activities should include: gin traps (inclusive of your termed “soft traps”), walk through “Killer” snap traps and all other forms of leg held devices, snares, poison baits, denning, dog hunting and helicopter hunting. Additionally we recommend that all forms of holding captive of individuals of damage causing animals be prohibited.
5. No clarification of permitting procedures involving restricted activities is given. 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.
6. 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 an VERY important provision as certain key and high value hunted species will all find themselves being motivated as being DCAs and will be selectively persecuted.
7. No restricted activity permits should be issued after the execution of such an activity.
8. I object to the continued inclusion of gin traps/soft traps as an allowable management tool in damage causing animal management.
9. I object to the rebranding of gin traps as soft traps. There in no legal or practical distinction to be made, and attempts to do so is cynical and intended to confound.
10. I object to the continued use of dog hunting as a management option for damage causing animals. Dog hunting is unlawful and should also be prohibited on the basis of its damaging ecological consequences and ethical care considerations.
I trust that you will apply your mind to my concerns and that rectification of a thoroughly flawed norms and standards will be effected,