The Endangered Wildlife Trust (EWT) has called for a revision and the republication for public comment, for a period of 30 days, of the government’s National Biodiversity Economy Strategy (NBES).
The Strategy was published for a 14-day public comment period on 8 March 2024. The comment period was later extended to 16 April 2024.
The EWT submitted extensive comments in two parts to the Department of Forestry, Fisheries and the Environment (DFFE) on 16 April 2024 outlining its general arguments regarding the NBES and detailed comment on specific issues contained in the document.
An initial NBES was published for implementation by the Department in 2016 outlining the steps necessary to ensure the success of the commercial wildlife and bioprospecting industries, as well as the transformation of both sectors of the South African economy. The 14-year plan’s aim was to provide a basis for addressing constraints to growth, ensuring sustainability, identifying clear stakeholder’s responsibilities and monitoring progress of the Enabling Actions. In terms of the first NBES, the goal has been to achieve an average annualised GDP growth rate of 10% per annum by 2030 in the biodiversity economy.
The Draft National Biodiversity Economy Strategy gazetted in March 2024 (link to the gazette) is a revision of the existing NBES and aims to “optimise biodiversity-based business potentials” across most economic sectors “for thriving people and nature”.
“In reviewing the NBES, the Strategy has been broadened to respond to the White Paper on Conservation and Sustainable Use of South Africa ‘s Biodiversity (the White Paper) as well as the Kunming-Montreal Global Biodiversity Framework (GBF), whilst incorporating the outcomes of the National Operation Phakisa Oceans and Biodiversity Labs, and addressing opportunities associated with all ecosystems,” the NBES Executive Summary states.
By broadening the terms of the Strategy, it has been “completely reconceptualised as a broad strategy to guide the whole of the biodiversity economy”.
The EWT, in its comments on the latest iteration of the NBES (link to the laws document), recognises the value that ecological sustainable use of wildlife brings to South Africa, and supports conservation practices that, within the scope of the law in the country, promote the ecologically sustainable use of wild animals in natural free-living conditions to the benefit of all.
While the EWT upholds the provisions of the environmental right contained in the Constitution, it does not support the industrial-scale production and management of South Africa’s wildlife when these activities are not in line with the principles of ecologically sustainable use, animal well-being and do not benefit the conservation of the species in the wild.
“These practices may also result in environmental harm and wildlife well-being concerns,” the EWT submission states.
In welcoming the opportunity to play a constructive role in developing an appropriate and equitable biodiversity economy strategy as part of the broader development of a sustainable green economy, while ensuring the enhanced protection of the country’s biodiversity, the EWT submits that the NBES itself is lacking in both content and clarity. Unless revised, it risks impeding ecologically sustainable use.
More information is required on the business cases underpinning the actions listed, and the economic information that has been considered in motivation for these activities.
“Critically, the NBES as it stands lacks SMART objectives, objectives that are specific, measurable, achievable, realistic and time bound.”
Detailed comments by the EWT deal with the goals outlined in the NBES highlighting various shortcomings requiring attentions. In almost all instances, the EWT points out a lack of clarity on the goals proposed, whether these can be justified, or considered realistic.
The EWT’s response to the first goal related to leverage biodiversity-based features to scale inclusive ecotourism industry growth in seascapes and in sustainable conservation land-use, points out the lack of explanation to justify targets provided, as well as the lack of clarity on what type of ecotourism infrastructure is to be developed in the buffer zones.
Similarly, with the goal to prioritise infrastructure development and viable enterprises in community reserves and areas adjacent to fauna/ Biq 5 areas. Here the EWT states the prioritising infrastructure development on the edge of protected areas undermines the principles of establishing ecological buffers around protected areas, a core principle for retaining the integrity of these areas as illustrated by the spatial structure of biosphere reserves, as well as Ecological Support Areas surrounding Critical Biodiversity Areas. These projects in must comply with environmental regulations to mitigate potential negative impacts on ecosystems, habitats, or protected areas, ensuring compliance with relevant laws and regulations and avoiding residual impacts where possible.