Open Letter to President Cyril Ramaphosa and the Minister of Forestry, Fisheries and the Environment

From the People of South Africa – Defend Our Wildlife, Uphold the Law and Halt the Trophy Hunting Quotas
To the Minister and the Department of Forestry, Fisheries and the Environment,

We submit this representation in the strongest possible opposition to the proposed CITES export quotas for elephant, black rhinoceros, and leopard hunting trophies for 2026 and 2027. We do so not only on ethical grounds, but on the basis that these quotas contradict the spirit, intent and in several respects the legal obligations of South Africa under national law, constitutional environmental rights and binding international conservation agreements.

This proposal represents a profound failure of stewardship over species that are not merely national heritage, but part of the shared ecological patrimony of the world.

1. Constitutional and Environmental Law Concerns

Section 24 of the Constitution guarantees everyone the right to an environment that is not harmful to their health or well-being and obliges the state to protect the environment for present and future generations through reasonable legislative and other measures that:

• Prevent ecological degradation.
• Promote conservation.
• Secure ecologically sustainable development while promoting justifiable economic and social development.

Authorising trophy exports of threatened and protected species fundamentally undermines these obligations. The deliberate killing of ecologically critical, long-lived, socially complex animals for recreational purposes cannot reasonably be framed as a conservation necessity where less harmful alternatives exist.

Furthermore, the National Environmental Management Act (NEMA) and its environmental principles require:

• A precautionary approach where scientific uncertainty exists.
• Protection of biodiversity and ecosystems as a priority.
• Consideration of cumulative impacts on ecosystems.

Approving quotas for species that are already under severe pressure from habitat loss, poaching and genetic fragmentation violates the precautionary principle and risks irreversible ecological harm.

2. Violations and Conflicts with Biodiversity Protection Frameworks

The proposal is inconsistent with the purpose and intent of:

• National Environmental Management: Biodiversity Act (NEMBA)
• Threatened or Protected Species (TOPS) Regulations
• National Biodiversity Framework obligations
• South Africa’s commitments under the Convention on Biological Diversity (CBD)

These frameworks exist to ensure the survival, recovery and long-term viability of species, (not to facilitate their commodification).

Black rhinoceros are globally endangered. Leopards face population fragmentation and increasing human-wildlife conflict. African elephants are keystone ecosystem engineers whose loss destabilises entire landscapes.

To authorise their killing for trophies while claiming so called “conservation objectives”, undermines the legal purpose of these protections.

3. Contradictions with International Obligations

The proposed quotas raise serious concerns regarding compliance with:

• CITES (Convention on International Trade in Endangered Species) principles.
• The precautionary principle embedded in international environmental law.
• The Kunming-Montreal Global Biodiversity Framework commitments to halt biodiversity loss.
• The IUCN Red List conservation guidance on vulnerable and endangered megafauna.

CITES allows trade only where it is demonstrably non-detrimental to the survival of the species. In the context of:

• climate-driven ecological stress,
• escalating wildlife crime,
• shrinking habitats,
• and uncertain population dynamics,

the burden of proof must be extremely high. It has not been met publicly or transparently.

4. Ethical and Scientific Reality – Sentient Beings, Not Commodities

Elephants, rhinos and leopards are highly sentient, socially complex beings.

Elephants:

• Maintain lifelong family bonds.
• Exhibit grief, empathy, and advanced cognition.
• Possess matriarchal knowledge systems vital for herd survival.

Killing individuals, particularly large tuskers and dominant animals, destroys social structures and knowledge networks that have evolved over generations.

Black rhinoceros:

• Represent one of the most heavily persecuted species on Earth.
• Require every possible protection measure to recover populations.

Leopards:

• Are essential apex predators that regulate ecosystems.
• Experience population declines due to fragmentation and persecution.

If these beings were human communities with voices, societies would never justify killing them for recreational display. The moral test of a nation is how it treats the voiceless, not how profitably it can exploit them.

This policy fails that test.

5. Economic Claims Do Not Justify the Harm

The argument that trophy hunting “funds conservation” is increasingly challenged by evidence showing:

• Limited trickle-down benefits to local communities.
• Disproportionate profits captured by private operators.
• Damage to the country’s eco-tourism reputation.
• Loss of long-term sustainable revenue streams.

Photographic tourism and biodiversity-based economies generate significantly broader and more sustainable benefits without destroying the very wildlife that draws visitors.

A living elephant generates far greater ecological and economic value than a dead one exported as a trophy.

Policy Alternatives: The Opposite Approach Required

Instead of expanding trophy export quotas, the government must urgently pivot to a rights-based, biodiversity-centred conservation model grounded in the strongest available legal frameworks.

1. Immediate Moratorium on Trophy Hunting of Threatened Species

Implement:

• A full moratorium on trophy hunting of elephants, black rhinoceros and leopards.
• A scientific reassessment conducted by independent ecologists and international conservation bodies.
• Transparent population audits using best-practice ecological monitoring.

This is consistent with the precautionary principle in NEMA and international conservation law.

2. Elevate Wildlife Protection to a Rights-Based Framework

South Africa should lead globally by recognising:

• Sentient wildlife as holders of intrinsic value and ecological rights.
• Legal recognition of wildlife interests within environmental governance.
• Stronger protections under biodiversity legislation.

Policy reform should include:

• Strengthening TOPS protections.
• Closing loopholes allowing commercialised hunting under “conservation” narratives.
• Establishing wildlife guardianship frameworks.

3. Align Conservation with the Global Biodiversity Framework

The government should instead commit to:

• Expanding protected areas.
• Restoring wildlife corridors.
• Increasing funding for anti-poaching enforcement.
• Investing in community-led conservation economies.

These measures align with:

• CBD targets
• Global biodiversity restoration commitments
• International conservation best practice.

4. Replace Trophy Hunting Revenue with Ethical Conservation Funding

A strategic transition should include:

• National biodiversity conservation funds.
• Eco-tourism expansion and marketing.
• Payment for ecosystem services.
• Carbon and biodiversity credit markets.
• International conservation financing partnerships.

Communities must benefit directly from wildlife protection, not its destruction.

5. Transparent Governance and Independent Oversight

To restore public trust, the Department must:

• Publish full scientific data used to justify quotas.
• Allow independent review by conservation scientists.
• Ensure meaningful public consultation.
• Establish oversight bodies free from hunting industry influence.

Conclusion

The proposed quotas are not merely a policy decision; they are a moral and ecological crossroads.

South Africa can either:

• Continue down a path that commodifies threatened wildlife, or
• Lead the world in a modern, ethical, science-based conservation paradigm.

The killing of elephants, black rhinoceros and leopards for trophies must come to a complete halt.

The government has both the constitutional obligation and the global responsibility to protect these species, not auction them.

We therefore formally object to the proposed quotas and call for their withdrawal, replacement with stronger protection measures and a national shift toward non-consumptive wildlife conservation.

This decision will define how history remembers our stewardship of the natural world.

All South Africans are urged to participate in our future and how we conduct ourselves within our environment – have your say here: https://dearsouthafrica.co.za/hunting-export-quotas/, NOW – 7th March 2026 is closing date.

Copyright © Cheri Simonne Rubens. All Rights Reserved.