As many of you will be aware, South Africa has cobbled together a proposal to supposedly conserve their national lion population. Unfortunately this proposal includes a recommendation to downlist lions from their current national status of "vulnerable" to that of "least concern".
There are a large number of significant shortcomings in South Africa's proposal which we address here. We have put this document out for review by a number of experts before we submit it to the South African Department of Environmental Affairs (DEA).
We would like to give you a similar opportunity to view this draft response:
Re: NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004 (ACT NO. 10 OF 2004) BIODIVERSITY MANAGEMENT PLAN FOR AFRICAN LION (PANTHERA LEO)
Written Representation on the above Biodiversity Management Plan
Table of Contents:
Disease – General overview
Disease – Bovine Tuberculosis
Disease – Feline Immunodeficiency Virus
Disease – Canine Distemper
Population Status in South Africa
Captive Bred Lions
Downlisting of Lions
South Africa should, with significant urgency, engage in a comprehensive and independently verifiable population count of lions in the one remaining long-term viable South African population (Kruger National Park) that has continental significance in terms of lion conservation. Counts undertaken in 2005/2006 are no longer valid to guide any national conservation management plan of the species. A promised survey in 2015 is not sufficient to support any proposed downlisting of conservation status of lions in South Africa that is likely to happen in the meantime.
South Africa, as an African lion range state, has a continental and international responsibility to maintain and protect national populations of a species in freefall decline. Any consideration of downlisting lions in South Africa to a species of “least concern” would be irresponsible in terms of South Africa’s regional, continental and international obligations to conserve with best practices an iconic species.
South Africa should not propose Biodiversity Management Plans for a species that lack accuracy, current information, latest scientific data and relevance to lion management plans in the region and beyond. While South Africa’s wild lion populations might have unique conservation management needs as all populations are fenced, a management plan developed in isolation is not conducive to integrated conservation plans for a species under ever-increasing survival challenges in Africa.
South Africa should not have published a proposal that has clearly been written over a long period resulting in a cut-and paste document rather than a revision based on current information. A comprehensive overhaul of the document is badly needed.
The proposal is badly in need of a much more scientific and up to date treatment of disease threats. The current document is severely lacking in an adequate and robust treatment of disease threats and as a result treats diseases as a minor cause of concern rather than the serious potential problem disease actually poses. This naïve approach to disease is clearly evident in the proposal, and once again underscores the lack of a comprehensive management proposal for Kruger’s lion population – one of the most important remaining African lion population strongholds.
The proposal should abandon all attempts to include managed populations in small reserves in any wild lion population in South Africa. Managed populations have been mismanaged for many years, and while “meta-population” management plans have been in existence for a considerable time, these have not materialized. South Africa could take a leadership position in proposing comprehensive guidelines for the management of lion populations in small reserves. In the first instance this should be a national plan rather than a Provincial/regional plan, and should be fully costed as to funding needed to be supplied by the State versus Provinces and the small reserves themselves.
South Africa should be fully cognizant that lion populations on small reserves represent genotypes not representative of South Africa’s lions as many were introduced from Namibia. Extreme care should be exercised in preventing cross-breeding of such populations with native South African lions although this has already happened in Hluhluwe-iMfolozi National Park. As an aside, it should be noted that lions were introduced from Namibia as a result of concerns about disease problems characteristic of the Kruger population – a concern that this proposal now seems to conveniently ignore (see recommendation 5 above).
There should be an immediate and urgent review of all CITES export documents issued by South Africa. In the past, South Africa has been in significant contravention of CITES regulations in terms of providing accurate “source codes” for lion product exports, with a very high percentage of such products supposedly originating from “wild” lions. This resulted in a ban placed on imports to the EU in 2012. The ban was reversed in 2014 since the EU was satisfied that South Africa had retrospectively amended their records. However, South Africa did not amend records to other importing CITES members, and this needs to be urgently addressed. Accurate source codes are needed to independently evaluate impacts of trade on wild lion populations which is now impossible. Unless and until South Africa makes a comprehensive and truthful effort to accurately report source codes the country remains in violation of CITES regulations. South Africa should also urge Provinces to comply fully in timely and accurate reporting requirements.
- The proposal hardly addresses the issue of captive bred lions in South Africa, despite an estimated 6,000 to 8,000 lions involved in a completely unregulated breeding industry. South Africa should impose minimal regulations in terms of animal welfare of lions in captivity and a harmonization of lion utilization regulations in a national, rather than a provincial management plan. Despite South Africa’s unwillingness to regulate the captive breeding industry, the fact that this industry provides the bulk of all South African lion exports supplied with the necessary CITES permits indicates a strong requirement that South Africa should provide oversight and control. The hunting of such captive bred animals has led to widespread international condemnation, and unless South Africa takes this matter in hand, it could well face an international backlash involving specific import bans. Such a call for bans is already well underway in the EU.
- Insummary, the proposal falls well short of a scientific, comprehensive and responsible lion conservation plan. South Africa should take a leadership position in lion conservation mindful of the needs of a species in continental decline, and accept that while this is a national plan South Africa cannot work in isolation. The report should be sent back to the authors with a strong recommendation to do better than this rather embarrassing proposal.
There are two levels of comment to be made on this proposal, one which is specific to the content, and the other is to prevent this proposal to be used as any justification to downlist lions as a species of “least concern” in South Africa.
As far as the management of wild lion populations is concerned, the proposal lacks understanding and clarity in terms of disease threats to animals in a number of locations, and most specifically Kruger National Park. Also, the proposal indicates a profound lack of understanding of current population numbers in Kruger - one of the most important populations to ensure the long-term survival of lions in southern Africa. It would appear that the last survey was undertaken in 2005/2006 and these results (without mentioning shortcomings of the methodology used) are significantly out of date.
As far as the proposed merger of wild lions and managed lions to satisfy the requirements of a downlisting from the current status of “vulnerable” to one of “least concern”, this is naïve, unscientific and based on no supporting information. Managed lions are often a mixture of South African and Etosha genotypes that have been acknowledged to serve no other purpose but to boost tourism income to the small reserves. While some of these populations were established a considerable time ago, an overall joint management plan has been sorely lacking. As a result, severe levels of inbreeding have been noted in many of these reserves (as mentioned in the proposal). Also, the reserves have largely failed to deal adequately with excess lions derived from natural reproduction among the introduced lions – perhaps due to the desire to offer the availability of cubs to visitors. The proposed management plan discussed in the proposal is merely a reiteration of past failed management plans and is unlikely to succeed unless there are specific targets and goals monitored for compliance by the DEA.
While the proposal mentions significant lack of CITES compliance by South Africa to properly list lion product exports under the appropriate source codes, this “mistake” has not been adequately corrected. To some extent, export records to the EU have been retrospectively amended after the EU Wildlife Trade Regulation Scientific Review Group passed a “negative opinion” on further lion product imports in 2012, but this has been far from comprehensive. In addition, export records to other CITES member states that did not raise objections have not been amended, indicating that South Africa did not take their responsibility to CITES seriously. Given this lack of attention to source codes, it is impossible to make any realistic and independent assessment of the impact of trade on South Africa’s wild lion populations despite locally derived Non-Detriment reports. South Africa made a minimal effort to participate in a CITES Animals Committee request for a Periodic Review of lions, indicating South Africa’s overall lack of concern for the conservation of the continental population. The proposal mentions no details of future better compliance with CITES regulations.
The proposal does not address the significant need of government oversight of the captive lion breeding industry. Captive bred lions, while nationally and internationally acknowledged to not in any way contribute to the overall conservation of the species, have been utilized in international trade for a number of products including hunting trophies, skins, bones, etc. South Africa facilitates such trade by issuing necessary CITES permits. There should at least be government regulations governing hunting regulations that currently vary from Province to Province, a minimum standard of animal welfare regulations, a minimum standard of live animal transport regulations, government oversight of export of live animals derived from captive breeding facilities to highly dubious destinations in Vietnam, Thailand, China, Myanmar and the United Arab Emirates provided with CITES permits. South Africa should be cognizant that the export of lion bones to Asian destinations (Laos and Vietnam) stimulates demand and can negatively affect wild lion populations in other African range states by providing a stimulus for lion poaching. South Africa should realize that while a lion skeleton can be sold for $1,000 to $2,000 at source, that the eventual rendered product in Asia is worth in excess of $70,000. South Africa should realize that by engaging and abetting the lion bone trade it has stimulated wildlife traffickers across Africa. South Africa’s response, as articulated by Minister Molewa, has been that the captive breeding industry protects wild lions by providing a source for lion products other than wild lion populations – an opinion that has been justifiably criticized by the international conservation community.
In short, the proposal falls well short of expectations given the long preparation time and various stakeholder inputs. The proposal should not be accepted in its current format, and significant revisions are needed to address a diversity of important shortcomings.
C. Specific comments
Disease: General overview:
The role of disease in determining a variety of factors such as longevity and reproductive potential is almost completely unknown among lion populations. Many diseases could act to debilitate rather than cause mortality, or cause mortality among cubs that are still in natal dens, or cause stillbirths that are not recorded. From antibody surveys among adult lions, diseases like feline herpesvirus, feline panleucopenia, feline calcivirus and feline enteritis are present among lion populations at variable levels of seroprevalence but do not seem to cause morbidity or mortality (e.g. Packer et al 1999; Hofmann-Lehman et al 1996). These viruses, however, largely cause mortalities among kittens in domestic cats – the causes of lion cub mortality are almost never determined in the wild as fresh carcasses are not found.
As a general comment, the actual role of diseases among wildlife populations is very poorly understood as diseased animals are not usually individually monitored to determine the eventual outcome of infections, especially among young animals. In addition, wild animals are not individually and continuously monitored to determine when they contract viruses and other pathogens to determine effect on health. We mentioned above that the information about wildlife diseases is almost always retrospective via seroprevalence surveys of specific antibodies, and that such surveys, while providing information about occurrences of specific pathogens in the environment, deliver little information about the significance of infection when it occurred.
Disease: Bovine tuberculosis.
The proposal comes to this rather surprising conclusion about the threat of bTB to future lion population stability and viability in Kruger National Park: “Initial estimates suggest that bTB may not be as severe for Kruger’s lions (Ferreira & Funston 2010a) as has been suggested (Keet et al. 2009).”
This is a highly naïve approach, and ignores ongoing research. For example, two recent peer-reviewed papers have this to say:
Viljoen IM, van Helden PD, Millar RP, 2015. Mycobacterium bovis infection in the lion (Panthera leo): Current knowledge, conundrums and research challenges.Vet Microbiol. 2015 Apr 8. pii: S0378-1135(15)00143-1. doi: 10.1016/j.vetmic.2015.03.028.
“However, no attempt has been made to collate and critically evaluate the available knowledge of M. bovis infections in lions and potential effects on population. In this review we set out to redress this. Arguments suggesting that ingestion of infected prey animals are the main route of infection for lions have not been scientifically proven and research is needed into other possible sources and routes of infection. The paucity of knowledge on host susceptibility, transmission directions and therefore host status, manifestation of pathology, and epidemiology of the disease in lions also needs to be addressed. Advances have been made in diagnosing the presence of M. bovis in lions. However, these diagnostic tests are unable to differentiate between exposure, presence of infection, or stage of disease. Furthermore, there are contradictory reports on the effects of M. bovis on lion populations with more data needed on disease dynamics versus the lion population's reproductive dynamics. Knowledge on disease effects on the lion reproduction and how additional stressors such as drought or co-morbidities may interact with tuberculosis is also lacking. Filling these knowledge gaps will contribute to the understanding of mycobacterial infections and disease in captive and wild lions and assist in lion conservation endeavours.”
Miller M, Buss P, Hofmeyr J, Olea-Popelka F, Parsons S, van Helden P. 2015. Antemortem Diagnosis of Mycobacterium bovis Infection in Free-ranging African Lions (Panthera leo) and Implications for Transmission. J Wildl Dis.Apr; 51(2):493-7. doi: 10.7589/2014-07-170. Epub 2015 Feb 3.
“Diagnosis of tuberculosis in wildlife often relies on postmortem samples because of logistical challenges and lack of field-friendly techniques for live animal testing. Confirmation of infection through detection of infectious organisms is essential for studying the pathogenesis and epidemiology of disease. We describe the application of a technique to obtain respiratory samples from free-ranging living lions to facilitate detection of viable Mycobacterium bovis under field conditions. We identified M. bovis by mycobacterial culture and PCR in tracheobronchial lavage samples from 8/134 (6.0%) lions tested in Kruger National Park, South Africa. This confirms the respiratory shedding of viable M. bovis in living lions. The implications of these results are that infected lions have the potential to transmit this disease and serve as maintenance hosts.”
Therefore, the treatment of bTB in the proposal is highly unsatisfactory. Wishful thinking on the part of the proposal authors is no substitute for actual science that urges great caution in terms of any such blasé acceptance of old data. In fact, the more recent scientific reports indicate that lions can well be maintenance hosts, that the route of infection is as yet unknown, and that stress via environmental factors or co-morbidities need to be much further explored before any statement can be made dismissing the potential highly negative impact of M. bovis on lion populations in Kruger.
Disease: Feline Immunodeficiency Virus
The proposal is equally dismissive of the effects of infection of Kruger lions infected by FIVple, despite considerable recent evidence that FIVple can have considerable consequences on cub mortality, longevity, and maintained function of the lion immune system.
FIVple has been classified as an endemic disease among lions, as many populations show antibody prevalence rates of over 95%. Not understanding the slow course of the disease within an infected host (FIV is after all classified as a lentivirus), early reports (e.g. Packer et al 1999) mentioned that infection was inconsequential. This mistaken opinion persists in the proposal under review.
These statements are also at odds with results reported by Roelke et al 2006 and Roelke at al 2009. Those authors reported the following:
i) “We conclude that over time FIVple infections in free-ranging lions can lead to adverse clinical, immunological, and pathological outcomes in some individuals that parallel sequelae caused by lentivirus infection in humans (HIV), Asian macaques (SIV) and domestic cats (FIVfca)”.
ii) ”Results from FIV-infected lions and pumas parallel human and Asian monkey CD4+ diminution in HIV and SIV infection, respectively, and suggest that there may be unrecognized immunological consequences of FIV infection in these two species of large cats.”
It is clear from those studies and others that FIV infection among lions has significant consequences on immune competence. Such infections can significantly impact the ability of affected lions to mount an appropriate and effective immune response to the various pathogens with which lions are constantly challenged. It is therefore a disease needing considerable further investigation, especially as it has been shown that some of the six identified FIVple strains circulating among lions are more pathogenic than others, especially FIVple strain E, examined by myself and co-authors (McEwan et al 2008) and discovered to be significantly genetically divergent from other strains.
We would strongly urge the DEA to adjust their stance on the consequences of infection with this immune deficiency virus based on a more careful and appropriate evaluation of the current scientific literature.
Disease: Canine distemper:
Based on serosurveys, canine distemper virus is encountered by many lion populations across Africa. The origin of this virus is largely assumed to be populations of unvaccinated domestic dogs living in close contact with wild carnivores, although there is a possibility of sylvatic cycles being maintained among wild carnivores. Canine distemper occurs as an epidemic disease among lions, with considerable recorded mortality among some monitored populations (Roelke-Parker et al 1996). There is a diversity of opinion as to whether CDV infections alone or in combination with other diseases cause mortality among lions, but the epidemic that caused over 1000 lion deaths in the Serengeti cannot be ignored. Further research on existing strains of CDV in wildlife and domestic dog populations and their levels of pathogenicity is required.
More recently it was shown that canine distemper virus no longer requires the presence of a route of transmission from domestic dogs to remain in circulation among lion populations, implying that other wild carnivore hosts, or even the lions themselves, could be implicated in the maintenance of sylvatic cycles.
Viana M. et al., 2015. Dynamics of a morbillivirus at the domestic-wildlife interface: Canine distemper virus in domestic dogs and lions.,Proc Natl Acad Sci U S A. Feb 3;112(5):1464-9. doi: 10.1073/pnas.1411623112. Epub 2015 Jan 20.
Population status in South Africa:
The proposal mentions these numbers of lions considered “wild” in South Africa:
The Kruger National Park had about 1700 lions (range of 1617 – 1751) in 2005/2006 (Ferreira & Funston 2010) with about 300 lions in the private nature reserves bordering the park.
About 130 (range of 90 – 160) lions are present in the Kgalagadi Transfrontier Park, with a further approximately 350 lions on the Botswana side of the park (Funston 2011).
At time of writing there were 14 lions in the Addo Elephant National Park (2011) (Eastern Cape), eight in the Karoo National Park (2011) (Western Cape) and 13 in the Marakele National Park (2011) (Limpopo).
Lions were reintroduced in Hluhluwe-iMfolozi Park in the 1958 with more recent introductions from 1999-2001 to improve the genetic variation (Trinkel et al. 2008). The Hluhluwe-iMfolozi Park currently has about 100 to 140 lions (Maddock et al. 1996) although previous estimates have been as high as 200 (Grange et al. 2012).
Lions also re-colonized the Mapungubwe National Park around 2000, coming in from the Tuli Block in Botswana, but fewer than 10 lions exist there.
There are several problems with these estimates, not least of which is the population of the single long-term viable population of lions in South Africa – Kruger National Park. It would appear that population estimates date back to counts done in 2005/2006 which are long out of date. While the proposal mentions that a new population survey will take place in 2015, this is likely to occur after the delisting of lions takes place.
One of the biggest problems with an understanding of current wild lion population numbers is that virtually all estimates have been based on extrapolations from indirect data. For example, the IUCN lion meetings in 2006 relied largely on delegate reports of lion numbers in their countries, most of which have been later shown to be extremely optimistic. One clear example comes from Niokolo-Kobo in Senegal/Guinea, where delegates estimated 1,600 lions whereas more recent ground surveys estimated that not more than a dozen are now present. The most recent pan-African lion estimates come from Riggio et al (2013) who used remote sensing data (satellite imagery) to estimate the size of “suitable” habitats for lions and then extrapolated lion numbers. This is far from acceptable to judge the conservation needs of a species whose population numbers have declined by an estimated 80-90% in the past 50 years. Overall, very few lion range states have any knowledge of their lion populations in any sort of scientifically credible detail.
For South Africa to contemplate using numbers from lion populations that are considerably out of date to justify delisting is not in any way scientifically supportable and verges on reckless practice.
Moreover, combining wild lions with lions held in private reserves to derive an overall number of “wild” lions in South Africa is far from justified. These lions held in 45 small reserves have uncertain genetic origins/or were established by importing lions from Etosha National Park in Namibia – after all, the reason why these lion were introduced was purely for tourism and NOT conservation reasons. The small reserves did not adequately manage their populations resulting in noted high levels of inbreeding (Trinkel et at., 2008, 2010), and despite plans to integrate such small populations in a “metapopulation” management plan, such resolutions were not implemented in the past and are likely not ready to be implemented in the near future if at all. The proposal mentions that the LiMF “ … recognizes that many of the natural processes characteristic of large naturally functioning lion populations have been disrupted on these small reserves” and it is unlikely that lion population on such small reserves can be considered in any way valuable to a comprehensive wild lion population management plan in South Africa.
E. Current use:
The proposal lists a number of exports according to CITES and ministry records, but again these are well out of date. The proposal acknowledges that there are significant problems in terms of CITES “source codes” for lion products exported from South Africa – a cause of significant concern for both CITES and the international community. South African lion exports to the European Union were halted in 2012 over concerns about the lack of correct source codes and adequate reporting of export numbers by individual Provinces. While the EU reversed the ban in 2014 based on South Africa’s retrospective amendment of the source codes, significant problems remain and the EU Directorate General has been alerted to these continued shortcomings. It should be noted that no such amendment of records have been made for exports to the United States and other importing countries, indicating that South Africa remains less than compliant with CITES regulations. This lack of attention to source codes makes it impossible to adequately assess the extent to which wild lions in South Africa are involved in trade, and unless a comprehensive review is undertaken, could result in further bans to imports. This is especially relevant now that the EU has recently amended regulations to require the issuance of import permits for all lion products in addition to the usual CITES export permits provided by South Africa. Unless and until South Africa can show proof that it is fully compliant with CITES regulations as a minimum requirement to evaluate the impact of international trade on South Africa’s lions, there is no justification to downlist South Africa’s lions to a species of “least concern”.
F. Captive bred lions:
The proposal mentions captive bred lions, and we fully agree that these lions have very limited, if any, conservation value. No mention is made in the proposal to implement much needed regulation to govern current captive breeding practices. This is a major omission and needs to be addressed in significant detail. South Africa needs to impose a diversity of restrictions, guidelines and controls over the captive lion breeding industry as mentioned in the introduction. The current approach of “laissez faire” has already had a significant local and international backlash to South Africa’s commitment to actively participate in urgently needed robust conservation plans for an iconic species.
Captive bred lions, while nationally and internationally acknowledged to not in any way contribute to the overall conservation of the species, have been utilized in international trade for a number of products including hunting trophies, skins, bones, etc. South Africa facilitates such trade by issuing necessary CITES permits. There should at least be government regulations governing hunting regulations that currently vary from Province to Province, a minimum standard of animal welfare regulations, a minimum standard of live animal transport regulations, government oversight of export of live animals derived from captive breeding facilities to highly dubious destinations in Vietnam, Thailand, China, Myanmar and the United Arab Emirates provided with CITES permits. South Africa should be cognizant that the export of lion bones to Asian destinations (Laos and Vietnam) stimulates demand and can negatively affect wild lion populations in other African range states by providing a stimulus for lion poaching. South Africa should realize that while a lion skeleton can be sold for $1,000 to $2,000 at source, that the eventual rendered product in Asia is worth in excess of $70,000. South Africa should realize that by engaging and abetting the lion bone trade it has stimulated wildlife traffickers across Africa. South Africa’s response, as articulated by Minister Molewa, has been that the captive breeding industry protects wild lions by providing a source for lion products other than wild lion populations – an opinion that has been justifiably criticized by the international conservation community.
G. Downlisting of lions:
The proposal states the following:
“… the status of the lion in South Africa should be changed from Vulnerable to Near Threatened or Least Concern. To qualify for Near Threatened the wild population has to have less than 1500 mature individuals. If the populations exceed this number, the species should be listed as being of Least Concern. The combined wild and managed wild populations in South Africa comprise about 1600 mature individuals. In terms of numbers of adults, the South African lion population should therefore be listed as Least Concern.”
For all the reasons listed above this would amount to a scientifically unsupported and careless move by South Africa. The only possible reason to downlist lions would be to further promote trade in lion products and to allow the use of wild lions specifically in Kruger to justify financial income at the expense of a conservation responsibility. Contemplation of this measure should immediately be abandoned if South Africa wants to be perceived by the international community as cognizant and concerned about the precipitous decline of lions across the continent. South Africa should accept the role of a lion range state that can make a difference to long-term wild lion conservation rather than seeking commercial profit from a species in freefall decline.