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Written evidence submitted by Mabalengwe Safaris (AAB0023)

MABALENGWE SAFARIS

Prepared for UK Environment, Food and Rural Affairs Committee – ANIMALS ABROAD BILL

CALL FOR EVIDENCE

Matetsi Unit One, Matetsi Safari Area, Zimbabwe

September 2021

1. OPERATOR INFORMATION

1.1. Name of Area                                                        MATETSI UNIT ONE, MATETSI SAFARI AREA

1.2. Operator                                                                      MABALENGWE SAFARIS (PVT) LTD

1.3. Years in business?                                                        14 YEARS

1.4. Country                                                                      REPUBLIC OF ZIMBABWE

2. CONCESSION

2.1. Name of Concession                                          MATETSI UNIT ONE

2.2. Area                                                                      403.7 km²

2.3. Land Tenure                                                        10 YEAR CONTRACT  WITH                                                                                                                 ZIMBABWE PARKS & WILDLIFE AUTHORITY

2.4. Renewable?                                                        YES, 5 YEARS

2.5. Trophy fees received 2019                                          US$ 418,237

2.6. Concession location

2.6.1.                    Map showing Matetsi Safari Area in relation to Victoria Falls, Zimbabwe

2.6.2.                    Matetsi Safari Area, Unit One boundaries in relation to Hwange               National Park, Kazuma Pan National Park and Matetsi ECA

2.6.3.                    MATETSI UNIT ONE

MATETSI SAFARI AREA IS DEFINED AS A “SAFARI AREA” IN TERMS OF SEC 35 OF THE ZIMBABWE PARKS AND WILDLIFE ACT  (Chapter 20.14 (1996) as amended in 2001.

Matetsi Unit One is a SAFARI AREA and located in the center of all the Units. The vegetation is dominated by mopane (Colophospermum mopane) woodland in association with vast stands of Lebombo ironwood (Androstachys johnsonii) and Combretum woodlands.

The geology is made up of mainly kalahari sands and basalt which form the base structure for the perennial rivers namely MATETSI, KACHACHETE, MANYATI and TSHABALISA RIVERS.  Unit One also contains a number of fresh water springs that provide good groundwater all year round which makes it unique in the region.

The topography is varied from wide open savannah, dense riverine and teak forests and heavily grassed vleis.

Matetsi Safari Area is made up of seven Hunting Units measuring in excess of 380,000ha in extent and bordering Hwange National park in the South, Kazuma Pan National Park in the West and Zambezi National  Park in the North. It is also bordered by three Protected Forest Areas. The Matetsi “Environmental Conservation Area” makes up the most of the North Eastern boundary.

3. COMMUNITIES

As previously stated Matetsi Safari Area is classified as a Safari Area in terms of Sec 35 of the Parks and Wildlife Act, and human habitation and movement has been restricted since the promulgation of the Safari Area in the early 1970’s. There are no communities living in the concession.

3.1. Community Areas - Environmental Conservation Areas (“ECA”)

In early 2000 a number of privately owned game farms were sequestered by the State to form the Matetsi ECA. This area was resettled by small groups of villagers who took on the responsibility of  managing the wildlife in these areas through the CAMPFIRE program (www.campfirezimbabwe.org). The ECA is administered through the District Council who have engaged a hunting operator who provides hunting services to the ECA. 55% of all proceeds from the hunting go to the communities living in the ECA as well as the meat from the animals hunted. Mabalengwe Safaris also provide these villagers with excess meat from time to time. At present there are 263 households. ALL hunting in the neighboring Community Areas is regulated by ZPWMA Matetsi Headquarters which is wholly funded by Safari Area Hunting Operators.

4. RELEVANT GAME POPULATIONS – MATETSI UNIT ONE

5. LOCAL COMMUNITY PARTICIPATION

As mentioned previously Matetsi Unit One is a designated Safari Area and falls within the definitions of the Parks and Wildlife Act.

5.1. Employment

A total of fifteen seasonal contract workers are employed from the local surrounding areas with two admin staff employed year round. The hunting season normally extends from April through to November.

5.2. In May every year a further eight casual workers are employed from the surrounding areas to assist in the burning of protective fire-breaks within the area.

5.3. A total of six professional hunters are employed throughout the season on a contract hunt by hunt basis.

5.4.   During the off-season six full-time staff are employed except in April/May when a crew of nine casual workers are employed to implement our fire management plan with early burning of firebreaks

6. ANTI POACHING

6.1. As mentioned above Mabalengwe Safaris contributes US$ 220,000.00 per annum to Zimbabwe National Parks and Wildlife Authority who employ all of the anti-poaching staff as well as provide the ecology and biology services to each Matetsi Safari Area Unit and the surrounding Community Areas. A total of 32 wildlife rangers are employed on a full-time basis

6.2. Anti-poaching is conducted year round

6.3. At any point in time at least two anti-poaching details comprising two armed Parks rangers and one armed policeman are in the field on deployment. This relates to 270 Extended Patrols and 30 local patrols with ad hoc strategic patrols per month

6.4. Mabalengwe have one dedicated anti-poaching vehicle which is utilised for anti-poaching patrols over and above the one vehicle employed by Parks for the same purpose.

6.5. The coordination of the anti-poaching patrols and any reactions are coordinated between the Senior Ranger at Parks HQ and the Mabalengwe General Manager.

6.6. Upon any arrests being made the Police personnel within each anti-poaching unit prepare all the necessary statements, complaint forms, crime reports, etc and the accused is then handed over to the Police in Victoria Falls for prosecution. We then engage an independent organisation namely SPEAK OUT FOR ANIMALS (“SOFA”) www.speakoutforanimals.org  to monitor any court proceedings and are engaged in the training and awareness of public prosecutors and the judiciary in wildlife crime prosecution.

6.7. Informal Anti-poaching units

Mabalengwe partly fund the employment of three youth volunteer anti-poaching units on our eastern boundary in the ECA. These units operate under the local District Council and are trained by Parks and Forestry Commission personnel. A total of 18 community scouts are employed under this program. We reward any of the community scouts for poaching related information and upon obtaining any arrests. In 2019 they were responsible for a total of six poacher arrests in the surrounding areas.

6.8. Anti-poaching results

7. COMMUNITY INVESTMENT

As previously stated, a number of unproductive farming and ranching areas were designated as “Safari Areas” as per the Parks and Wildlife Act more than 50 years ago creating wildlife areas used exclusively for hunting. The areas were also unsuitable for photographic safaris due to their rugged terrain and poor infrastructure. The purpose of these Safari Areas was to generate income for ZPWMA to make up the lack of funding from the non-hunting National Parks and to contribute to the administration and management costs of these vast areas. The areas are uninhabited and access is tightly controlled and the wildlife management is done as a joint effort between Parks and the Operator.

In our case the burden of social responsibility rests with ZPWMA who created the Environmental Conservation Areas which were developed so that Communities receive direct benefits from hunting.

Over and above this, Mabalengwe Safaris do however invest in other community based self-help projects through which we assist in the establishment of Income Generating projects. Examples of these are;

              Hwange Baobab Processing Center

              Matetsi Rural Tannery

              Mabalengwe Game Meat Processing Project

This model is used successfully around most of Zimbabwe’s main National Parks ie Hwange, Gonarezhou, Matusadona, etc.

Mabalengwe Safaris has contributed a total of US$654,892 to ZPWMA over the last three years in Right to Hunt Fees, Concession Fees and Trophy Fees.

8. HUNTING POLICIES

8.1. All Professional Hunters employed by the company must be licensed with Zimbabwe Parks and Wildlife Management Authority (ZPWMA) having undergone a four-year apprenticeship under a licenced PH and then having passed written, oral and practical examinations. All of the PHs   employed by the company have at least 10 years post apprenticeship experience.

8.2. Hunting may only take place in the presence of a licenced PH

8.3. Each hunt is issued a specific quota and must be pre-registered with ZPWMA and a ZPWMA ranger accompanies each hunt and records all trophies taken and their location

8.4. Hunting only takes place within daylight hours

8.5. No animals may be shot from a vehicle and must be hunted on foot

8.6. Sex and trophy requirements for hunted animals

• Old non-breeding male individuals are taken off as trophy animals

                            • No female lions are hunted or taken as trophy animals

9. HUNT RETURNS AND REGULATION

9.1. Each Outfitter is issued a QUOTA by ZPWMA at the beginning of each year which has been determined by ZPWMA Ecologists and then presented at a public Quota Setting meeting held before the commencement of each season.

9.2. The Central Bank and ZPWMA operate an online platform namely Tourism Receipts Accounting System (“TRAS”) which links all outfitters and ZPWMA to a central accounting system in which each hunt is captured prior to the commencement. The information is captured on a form (Annexure XX) which is then processed by the ZPWMA authority Area Office who authorises each hunt by way of a stamp once it has confirmed that there is available quota, etc.

9.3. A ZPWMA Ranger accompanies each hunt.

9.4. Upon completion of each hunt the “Details of Species Hunted” portion of the TRAS form is completed by the Ranger and submitted back to the ZPWMA Area Office for deduction from the quota.

9.5. Every TRAS form is signed by the Operator, the PH conducting the hunt and the hunting client on the completion of each hunt.

9.6. There are heavy fines and penalties for any operator who exceeds his quota

10. OTHER INFORMATION

Hunting in Zimbabwe Matetsi Safari Area is strictly regulated and monitored in line with national hunting laws, regulations and ethics. All hunting activity are monitored to verify that quotas and sex/age restrictions of harvested animals are being met.

The legal and regulation framework applicable to the hunting, conservation and protection of all species includes:

Parks and Wildlife Act; Chapter 20:14 (1996) as amended in 2001.

Environmental Management Act; Chapter 20:27.

Statutory Instrument 362 of 1990: Parks and Wildlife (General) Regulations, 1990.

Statutory Instrument 76 of 1998: Import and Export of Wildlife Products.

Statutory Instrument 40 of 1994: Parks and Wildlife Act (General) Amendments.

Statutory Instrument 26 of 1998: Parks & Wildlife Act (General) Amendment.

Statutory Instrument 92 of 2009: Compensation Values for Wildlife.

Statutory Instrument 93 of 2009: Compensation Values for Trapping of Animals.

Trapping of Animals Control Act 20.16.

Forest Act; Chapter 19:05.

Further conservation strategies for individual and groups of similar species are available to guide conservation of species of conservation concern. These include the Lion Conservation strategy of 2006 and the National Elephant management Plan (2015-2020) which is reviewed every five years.

10.1.          Maintenance of the concession

10.1.1.                 Law enforcement

Local, mobile (vehicle), extended and strategic patrols are conducted by ZPWMA rangers. The rangers use of Spatial Monitoring Reporting Tool (SMART) technology to collect and capture and produce reports on law enforcement activities which enhances effectiveness and coverage of all concession area. Ranger support in the form of vehicle for deployment enhances timeous response to incursions across the concession which significantly reduce illegal offtake by poachers.

10.1.2.                 The concession undertakes fire management activities to: manage fuel load, improve habitat heterogeneity, control parasites and stimulate forage production and suppress unplanned veld fires during the dry season. Fire breaks along concession boundaries are carried out by ZPWMA in conjunction with the concession. The concession has an annual target of 50km2 of early block burning, minimum of 50km target of road grading and fire breaks.

10.1.3.                 Game water management is also a critical are of management given the high elephant numbers. Supplementary artificial game water is provided by means of solar and wind power during the dry season (applies to other units except unit 1). Matetsi is endowed with natural annual rivers and springs that provide water for wildlife. Care is taken to prevent the unplanned game water provisioning through guidance from Area Ecologist in order to maintain area integrity through limiting impact of high elephant densities during the drought months from surrounding protected area network (parks and forest estates). Veterinary matters such as diseases outbreak are managed and monitored by the ZPWMA Area Veterinary Doctor in conjunction with private wildlife veterinary institutions.

10.2.          Research

Research in fire and habitat management, animal’s survey is done by Area Ecologist and external researchers. The ZPWMA office at Matetsi Safari Area is involved in measuring, monitoring and analyzing trophy quality and offtakes of all hunted animals. This is done to ensure that Safari hunting does not substantially alter natural selection or ecosystem processes. The limited quota, as further limited by age restrictions, ensures that hunting offtakes do not negatively affect natural processes. This age-based policy for lions (Panthera leo) and Panthera pardus (leopard) was adopted in part to mitigate any social or population impacts from limited safari hunting.

11. ANIMALS ABROAD BILL

11.1.          “Will the Government’s proposals on the export and import of hunting trophies effectively support the conservation of endangered species?”

On the contrary, external interference in the well-regulated sport-hunting industries in Africa amounts to nothing more than eco-colonialism. The proposed BAN on hunting trophies mainly stem from  Animal Rights Activist organisations that have no scientific basis to support their demands, except for emotional appeals to naive donors who provide them with lucrative incomes.

11.2.          “Should there be different rules for the trade in animal trophies depending on the setting in which the animal was hunted?”

In the majority of cases there are different rules for the trade in animal trophies within the countries of origin. Surely, it is for these individual countries to regulate their own trade in wildlife trophies and not to be dictated to by uninformed governments who have little or no knowledge of the complexities of conservation in Africa. On the whole, our wildlife is thriving and in particular with Lion and Elephant (where we now have a problem of over-population!) which have been properly managed by implementing Sustainable Use practices that are working right now.

11.3.          “What are the possible unintended consequences of the proposals, for example in relation to animal trophies that pre-date the legislation?”

The consequences of implementing any ban on the import of hunting trophies will have a catastrophic effect on wildlife conservation by limiting the income which is derived from sport-hunting, which in turn, will dry up the monies used to fund conservation. For example, in the Hwange/Matetsi Ecosystem, 80% of the cost of conservation is funded by hunters!  As can be seen from the evidence presented above hunting organisations provide large sums of money to conservation.

11.4.          “How effective are current measures on the trade in trophies of hunting, including how they support conservation?”

There is a simple adage in African Conservation which states “If it pays, it stays!”. In countries that have banned trophy hunting they have lost large proportions of their wildlife populations. In the case of Kenya for example they have lost 70% of their wildlife populations since the 70’s when they stopped hunting. On the other hand, countries that apply sustainable use practices have seen their wildlife populations prosper. This is certainly true for Zimbabwe, Botswana, Namibia, Zambia, Mozambique and South Africa.

11.5.          “What will be the impact of the proposed domestic ban on advertising and offering for sale overseas attractions, activities or experiences that involve the unacceptable treatment of animals?”

Any action taken by importing countries that hinder the sale of hunting activities will have a detrimental effect on the flow of funds from the hunters into conservation. The sustainable use model is working and provides an effective means of funding conservation and until any alternate method might become available, it should not be tampered with.

11.6.          “Who should be responsible for ensuring attractions, activities or experiences overseas do not cause the unacceptable treatment of animals?”

These should be (and normally are) regulated in the countries to which these animals belong. It is not for Africans to interfere in British animal treatment (for example horse and dog racing!) and conversely Britain should stay out of conservation in Africa. We are doing a fine job anyway!

There is no “one size fits all” conservation model when determining an country’s  commitment to conservation and communities.  Some African Operators (especially within the South African high-fence models) are specifically involved with community upliftment as are our CAMPFIRE Operators. It is our position that our commitment is even greater in that we fund the Regulator who in turn administers Hunting and Conservation on the National level.

In our view the right scenario for Zimbabwe is where there is a mix of different models to attain true Sustainable Use Conservation which is the current National Conservation Policy and is being applied throughout the industry in Zimbabwe.

12. It is our humble submission that the ANIMALS ABROAD BILL is ill-conceived and unfounded on any of the scientific principals that have proven to be a success in self-regulated, sustainable-use conservation models in the world and should be struck down.

              prepared by

              CORNELIUS ABRAM SMIT

              General Manager, Matetsi Safaris and Tours (Pvt) Ltd