THE NEW CANNED HUNTING REGULATIONS

 by

CHRIS MERCER.

Co author of the Books

 “For the Love of Wildlife” and “Canned Lion Hunting  - A National Disgrace”

These are my submissions as requested by the ANC Study Group which saw my presentation at Parliament on Monday 26^th February, 2007.   Some relevant questions for the Minister, as well as some extracts from the regulations, are included at the end.

Because of the high levels of ethical illiteracy in conservation services, some effort must be put into uplifting those levels.  Ideally, a proper course by an organisation like the Humane Education Trust should be implemented.  Failing that, I would be prepared to attend upon conservation structures and give my audio-visual presentation, in order to stimulate debate on the issue of ethics in animal welfare.                                                           

I believe that the new hunting regulations are nothing but an elaborate public relations exercise. 

The two new government publications, norms and standards on hunting, and the Regulations on Listed Species, are fundamentally flawed in critical respects:

  First, there was never any intention to stop the cruelty, so what we have is a formula of pious, unenforceable aspirations, all designed to stifle public criticism.  But it is the cruelty which offends the public, and until that is addressed by a complete ban on the hunting of any captive-bred animal, international pressure will continue to mount against South Africa. 

Second, the attempt to infiltrate hunting industry notions of fair chase into biodiversity protection is transparently flawed.  All trophy hunting is genetically and environmentally devastating, whether the hunter shoots like a colonial fop from a vehicle, or like Rambo on foot after a long stalk.  The result is the same, pain and death for the animal, and a loss of biodiversity.  And nowhere do the new regulations/standards recognise that trophy hunting causes stunting in species.  Compare the slight Karoo springbok and Cape Leopard (who have been hunted hard for 350 years) with their much larger Kalahari cousins (who have only been hunted hard for 50 years).   

The new regulations are drafted to look very impressive on paper, but just look who is going to enforce them - the very same conservation officials whose ethical illiteracy has caused the problem in the first place.  As Einstein reminds us “problems can never be solved at the level at which they were created”.  I for one would have no problem getting around them, especially if I had cronies in the conservation services, and I am sure that many lion breeders are much smarter than me. 

Nothing less than sweeping out of our conservation services all the hunting thugs who wear conservation uniforms will stop the cruelty.  Expecting such officials to enforce the new restrictions is as absurd as asking Al Capone’s henchmen to monitor his activities.  Employing hunters in Conservation is like appointing serial rapists to look after a Girl’s Hostel. This is simply industry self- regulation in a new disguise. 

So far from stopping the cruelty, the new regulations seek to extend the grisly business of killing wildlife for profit to black empowerment groups.  Our nation and this world need fewer killers, not more. 

There is a major moral issue here, which is being studiously ignored - whether the infliction of suffering and death upon unoffending animals for pleasure is acceptable.  If it is criminal to beat a dog or a donkey, why should  trophy hunters be allowed to do much worse to other animals?  Is it Government’s position that lions and elephants do not feel pain like dogs and donkeys?  See the Animals Protection Act.

As for the Minister’s fine rhetoric about the new regulations being ‘the end of canned hunting,’ I predict that his extravagant boast is going to suffer the same fate as George W Bush’s boast three years ago that ‘the war in Iraq is over.’   Forget fair chase, Minister.  Just stop the cruelty.

1. The New Regulations make no attempt to define Canned Hunting.  All Trophy Hunting in South Africa falls within the standard definition of Canned Hunting.

It is important that the new Regulations define Canned hunting, and do so honestly and accurately in order to meet public concerns.  Here is the standard definition:  

Canned hunting is the hunting of an animal where the target animal is unfairly prevented from escaping the hunter, either because of physical constraints (fenced in) or because of mental constraints (habituation to humans.)

If this standard definition is adopted, it can be seen that no captive bred animal should ever be targeted, and most trophy hunting is canned because there is no true wilderness left in South Africa and all hunting takes place in fenced off areas from which the animal cannot escape.

The notion that a captive bred lion can be hunted once ‘rehabilitated’ to a bigger camp (extensive wildlife system) violates the definition above on both grounds.  Such an animal is not wild; it is merely alternative livestock, and no one would allow farmers to charge around their farms shooting their sheep and cattle with bow and arrow or guns for fun.

Section 24 of the Bill of Rights of the South African Constitution entitles South Africans to reasonable and appropriate methods of nature conservation for their well-being.  This includes the “aesthetic interest of all South Africans in the preservation of their environment”.   (See definition of “environment” in the National Environmental Management Act, 107 of 1998.)  In a landmark American judgment approved by the Federal Supreme Court of the United States, one’s ‘aesthetic interest’ was held to extend to the right not to be offended by cruelty to animals.

In the case of Nair v Union Government of India, decided in Kerala, a case involving circus elephants, the Indian Supreme Court came to the same conclusion.

So there is solid authority in Constitutional Law to say that cruelty to animals such as canned hunting violates the Constitutional rights of SA citizens.

But the case against canned hunting goes further than this.  The Animals Protection Act of 1962 extends protection to all wild animals who are captive.  The word ‘captive’ is subject to interpretation, but surely applies to canned hunting where  habituated, hand-reared lions are hunted in fenced enclosures from which they cannot escape. 

Why do the new regulations violate the Animals Protection Act?  Because of the vague definition of an ‘extensive wildlife system’(see below).  What does ‘minimal’ mean?  How big or small may the camp be?  Notice there is no minimum area requirement eg 5000 hectares, which is a fatal flaw, because chucking a few springbok into a large camp where young lions were being raised would comply with such a loose definition, but would violate the Animals Protection Act on several grounds, including ill-treatment of the springbok prey animals:-

“extensive wildlife system” means a system that is large enough, and suitable for the management of self-sustaining wildlife populations in a natural environment which requires minimal human intervention in the form of –

(a)        the provision of water;

(b)        the supplementation of food, except in times of drought;

(c)        the control of parasites; or

(d)        the provision of health care.

In short, canned hunting as defined above, which is facilitated and promoted by the new regulations, is arguably illegal as well as unconstitutional.

2.  Trophy hunting is Colonialism, making SA a hunting colony.

No doubt hunters persuade African governments that killing animals is poverty alleviation.   Actually, it is Colonialism.

Look at trophy hunting. Chucking a few dollars at local landowners in order to plunder our wildlife heritage is not conservation, it is Colonialism. When organisations such as Safari Club International in U.S.A. patronise this industry, they export blood dollars and colonialism to Africa, and they import misery and bloodshed in the form of trophies. Their dollars are a corrupting influence in the third world, perverting conservation policies away from preservation towards the cruel exploitation of wildlife.

Somalia banned all trophy hunting in 1973 on the ground that it was a barbaric relic of colonialism, and Kenya followed suit three years later.  There is nothing radical about banning all trophy hunting in SA, and prohibiting the export of trophies.

3.  In pure financial terms, Trophy hunting is a huge potential liability, not an asset to SA.

Trophy hunting accounts for a tiny fraction of the income from eco-tourism.  Kenya which banned trophy hunting thirty years ago has a tourism industry that all African countries envy.  We do not need hunting.  In the age of the Internet where millions can be mobilised at the touch of a button, it would be foolish to risk tourism and trade boycotts, disruption of events such as the 2010 World Cup soccer tournament, etc. etc by prolonging support for a hunting club which is despised by hundreds of millions of people in Europe alone.  (Polls consistently show that 4 out of 5 people in UK are opposed to any form of sport hunting.) 

Hunting Reserve Directory. 

There is one way to deflect the taint of hunting away from legitimate eco-tourism, and that is by publishing a Directory of Reserves and Resorts where hunting takes place.  All this information is in the Department’s hands already. 

Publishing the Directory to the tourism industry at large would allow overseas travel and tourism agencies to offer holidays to SA on a “hunting or non-hunting” basis.  There would be no reason to boycott SA altogether if the tourist were able to choose resorts where he knew his tourist dollars were being ethically spent.

Unlike eco-tourism which gives real careers to previously disadvantaged people, trophy hunting benefits only a few cruel soldiers of fortune, leaving only menial work like skinning for employees.  In truth, hunting is a wasteful use of land.  See the article “To Snap or Snipe” which was shown to the ANC Study Group, which explains why. 

Unlike eco-tourism where a large number of tourists bring vast sums of foreign currency into SA, trophy hunting offers ideal opportunities for tax fraud and foreign currency swindling.  If a wealthy businessman has siphoned off funds from his business and needs to hide this hot money, he can ‘invest’ in a hunting farm or operation, and then leave the foreign income outside the country in some tax haven.  Before allowing this industry to continue, the SA government should at least ask the SA Revenue Services to do a comprehensive forensic audit upon it.

4.  The new Standards and Regulations impose expensive bureaucratic burdens upon legitimate wildlife rehab centres and sanctuaries, but will not deter hunters.

No one in government knows anything about wildlife rehab or sanctuary work.  Of course, wildlife sanctuaries have been and are still banned in SA, (to get around this, one registers as a Zoo)  Because of this (studied) ignorance, the new legislation is impractical and onerous on legitimate sanctuarians (who presently have to operate under Zoo or Rehab permits to do Sanctuary work.)

Hunters have the money to employ lawyers and consultants who will quickly build up an expertise in filing all the necessary forms, risk assessments etc which soon become standard form and meaningless.  But real sanctuarians are far too busy looking after animals to find time to familiarise themselves with complicated forms, nor do they have the money to employ consultants to do the work for them.  They will struggle with the annual bureaucratic burden, which is completely unnecessary for bona fide sanctuaries.  I have prepared a Sanctuary Policy, copy on our website, and there is a case for making Rehab Centres and Sanctuaries Self-governing within the limits of this Sanctuary Policy.  It would remove an onerous burden for both the Rehabbers and the Conservation Services.

Take the microchipping requirement.  This is an expensive and life threatening exercise when applied to dangerous animals like lions, who have to be darted.  Darting damages the kidneys and cannot be done too often, or inexpertly.  Allow R500 for darting costs per lion and you see how prohibitive it becomes for honest sanctuary charities. (The hunters can afford it easily)  Aged and infirm animals should be exempted from being microchipped (and darted) anyway.

They provide exceptions which will become the rule. 

The new Regulations are full of bold-sounding bans, but for every ban there is an exception, which will allow the hunter to circumvent the ban. 

Dogs.

Take the use of dogs for hunting.  Several trophy hunting operators use a pack of dogs for all their hunting purposes.  Conservation officials allow them to set a pack of dogs onto a tame, released predator to keep it from running away from the hunters, who can approach at their leisure.  See eg Mr Strydom’s operation www.africancats-hounds.co.za which features a photo on the home page of a leopard being savaged by a dog pack.  Of course, a total ban is called for to end this barbaric form of hunting, but instead, here is how the new policy reads:

“(3)            Subregulation (1)(a)(iv) does not prevent the use of dogs for the purpose of –

(a)        tracking a wounded animal;”

So the new policy permits dogs to be used to follow up a wounded animal.  (This is not necessary; wounded animals leave spoor and a blood trail).  Now, Mr Strydom will be able to drive a coach and horse through this loophole.  First, who can possibly tell from the carcase whether the wounds were inflicted before or after the dogs were set upon the victim?  Second, even in the unlikely event of an un-corrupt conservation official actually attending a hunt, there is nothing to stop the hunter from starting the hunt by deliberately wounding the animal slightly, in order to permit the dog pack to be released.  Because it is a rule which is impossible to enforce, the prohibition on hunting with dogs becomes meaningless - just like all the other bans in these new policies. (which is why they have the approval of the hunting industry.) 

Bow hunting

And what about the bow-hunters, who shoot arrows (contrary to the Animals Protection Act in many cases) into the alternative livestock for fun?  Minister Van Schalkwyk says that bow-hunting has been banned.  This is not true - the section in the new Norms and Standards allows exceptions where the province allows it.  Permitting individual provinces to opt out of the new Regulations and Policy makes the Minister’s statement that the new policy will bring uniformity another overstatement.  However, the Regulations have finally outlawed bow hunting for large animals:

(8)        An issuing authority may not issue a permit to hunt a listed large predator, Ceratotherium simum (white rhinoceros), Crocodylus niloticus (Nile crocodile), Diceros bicornis (black rhinoceros) or Loxodonta africana (African elephant) by means of or by the use of a bow and arrow.

But unless all bow hunting is banned for cruelty, how can anyone supervise or prevent hunting parties from being in big game areas in possession of bows and arrows.  They could say they are looking for eland.  And bow hunting an eland would in most cases not be humane.

Captive breeding for Hunting.

Contrary to the Minister’s public statements, this form of factory farming has not been banned.   Section 24 of the Regs purports to ban:

(g)        the breeding in captivity of a listed large predator, unless the prospective breeder provides a written undertaking that no predator of that species will be bred, sold, supplied or exported for hunting activities that are considered prohibited activities in terms of paragraphs (a) to (e) of this subregulation;

Notice the glaring loophole: there is no ban on breeding for ALL hunting, only a ban on breeding for certain listed hunting activities, such as the unlikely method of using a gin trap on a rhino (see below)  The breeders and hunters will easily evade these paper restrictions.

Under the new regulations then, any canned hunting breeder can circumvent the prohibition on captive breeding for hunting by registering himself on the basis that he intends to release the progeny animals ‘back to the wild.’ (not real wilderness, of course.)  He then ‘releases’ his young lions into a big camp which includes some prey animals (referred to in the new regulations by the grand title of an ‘extensive wildlife system’) keeps them there for two years as required, and then he can get a permit to hunt them.

He can continue to feed and habituate them during the two years subject to the vague and utterly unenforceable requirement that it should be ‘minimal’ (whatever that means)

The two year period has obviously been chosen to suit the hunting industry, since it takes at least three years for a lion(ess) to reach huntable size.  It has nothing to do with rehabilitation to wild status, which is a risible concept for anyone who knows anything about lions and other predators.

Notice that the term ‘extensive wildlife system’ has deliberately been so vaguely defined as to be meaningless, to assist the hunting industry.

These regulations can be seen by anyone with experience in legal drafting to have been carefully framed so that they can be circumvented. 

6.    They seek to draw a line between ethical trophy hunting and ‘environmental thugs’ whereas no relevant difference exists.

There is only a difference between ‘ethical’ hunting and ‘environmental thugs’ in hunting circles (this includes conservationists in SA).  No one else cares about stupid hunting rituals.  No one in DEAT or other conservation structures seems to understand that the concern of the public is firstly for the welfare of the animal.   Unless government learns to look at conservation from the same perspective, it will always be engaged in bitter, protracted battles in which the government is always the loser.  Win or lose, every issue fought tarnishes the image of conservation, and the integrity of officials.  Eventually this conservation regime will be so prostituted that it will be overlooked and unrespected by the public, and South Africa will become a targeted rogue state for the powerful animal rights and welfare organisations in the developed world.  No one in government seems to understand the dangers to SA tourism and trade of continually offending hundreds of millions of people overseas.

Animal welfare must be placed on  the agenda on every issue, because, inter alia, our tourism industry will suffer if it is not.   

The new Norms and Standards will deliver our remaining wildlife heritage into the hands of the very people who have damaged it - the hunters.

By treating hunting farms as if they were part of the nation’s nature reserves, government errs badly.  Hunting farms are not complete eco-systems.  Going down to the ‘Game’ sales to buy fifty animals, and then putting them into a 200 hectare camp and shooting them out over the next six months is not conservation.  It is using wildlife as alternative livestock.  When the animals are originally removed from their natural wilderness environments, they are lost to conservation.  They now become livestock in a farming business.  And the Animals Protection Act of 1962 now protects them from ill-treatment.  Wilderness and wildlife are no longer wild. The Department of Agriculture is better suited to supervise such an industry.  The hunters have chopped up the real wilderness into little fenced camps to commit sadistic acts of cruelty upon semi-domesticated animals.  It is the destruction of our wildlife heritage, and the numbers of these prisoner animals are irrelevant for conservation purposes.  The wild species are being destroyed regardless of the numbers of prisoners in concentration camps (called game farms).

Instead of rectifying this national catastrophe by forcing landowners to consolidate property, the new policies seek to make hunting self-regulated.   Instead of throwing the hunters off the land, taking out the fences, appropriating the land for public nature reserves and joining all the little inadequate fragments of parks to form extensive national parks, here is government saying to the destroyers: “Go ahead, regulate the destruction yourselves.”  I believe this is a dereliction of duty.

South Africa has always been a paradise for hunters. The flip side of this dubious claim is that for the wildlife, SA is Hell on earth.   Captive breeding is the inevitable consequence of over-hunting.  After wiping out the trophy animals in the wild, the industry has to turn to captive breeding to keep a constant supply of targets.  It has nothing to do with conservation. 

So let us sum up: TROPHY HUNTING (CANNED HUNTING) IS THE ASSET STRIPPING OF OUR ENVIRONMENT.

 ‘Hunting is conservation!’ hunters claim righteously.

This is absurd.  It is like saying that only whaling can save the whales.

Canned lion breeders are wealthy landowners.  Millions of honest South Africans have to survive without the privilege of land ownership, and it ill suits wealthy landowners to complain that they cannot find any use for their land which is both harmless and constructive.

The culture of hunting contaminates our whole conservation regime. Many so-called Nature Conservation officials are actually themselves professional hunters.  They have financial, family, social and cultural links with the hunting industry. They justify their support for hunting in financial terms. 

The evils of sport hunting are apparent to most decent people.  Yet hunters have formidable accomplices in the United Nations Environment Program and pro-hunting groups within the IUCN.  It was these groups who conceived the Dogma of Sustainable Use.  What this establishes is that natural resources may legitimately be used, provided the use is ‘wise’ in the narrow sense of not being excessive. This doctrine makes sense when it is restricted to inanimate resources such as tin or copper.  But including sentient beings within the scope of mere ‘resources’, which may be harvested, was far from wise, and probably closer to collective insanity.  Anyone who can lump gorillas, elephants and lions in with bacteria and then treat them all alike as mere organisms, has lost touch with reality.  The reality of public opinion.

                                    ****************************
                                                END

Chris Mercer

Campaign Against Canned Hunting, Inc.

PARLIAMENTARY QUESTIONS

Eleven Questions which the Minister should answer:

With reference to the draft National Environmental Management : Biodiversity Act, 2004: Threatened and Protected Species Regulations, and the associated draft Norms and Standards for the Regulation of the Hunting Industry, will the Minister explain the following apparent contradictions:

1. Why has the Minister failed to include a definition of Canned Hunting in either the new Regulations or the new Norms and Standards?  The Minister himself has announced the banning of ‘canned hunting’.  What does he mean exactly by that phrase?
2.  The Minister has represented to the public that the new regulations will “close the loopholes that have allowed environmental thugs to get away with immoral activities like canned hunting.”  Yet the new regulations are full of deliberate loopholes.  Will these loopholes not allow the inhumane treatment of animals to continue unchecked?

3.   Since the use - and abuse - of "extensive wildlife systems' will constitute the major loophole in the regulations, why has such 'system' been so poorly and vaguely defined?

4.   The draft regulations often revert to province-level legislation instead of establishing “… uniform national systems that will apply the same standards throughout the country,” as stated by Minister van Schalkwyk. For example, Bow-hunting, which the Minister claims to have banned, is specifically allowed where the particular province desires it.  Bearing in mind that cruelty in one province can cause substantial loss to other provinces through trade and tourism boycotts by ethical tourists/investors, does the Minister not feel that he should honour his claim that "Control needs to come from national level to enable uniformity of regulation and enforcement', especially in regard to intrinsically cruel practices such as bow-hunting?

6.  What is the relevance of hunting club notions of fair chase to biodiversity preservation?  How is the loss of biodiversity remotely affected by the method of causing such loss?

7.                The infliction of suffering on dogs and donkeys - and any captive wild animal -would be criminal under the Animals Protection Act of 1962.  Since the hunting of captive-bred or fenced-in 'wild' animals is in reality the hunting of alternative livestock, is the Minister not guilty of promoting and facilitating criminal behaviour?

8.                No one can deny that incompetence and ethical illiteracy in SA conservation services has seen it degenerate into institutionalized cruelty.  Would it not be better for SA if game farming were removed into the portfolio of the Department of Agriculture?

9.                Has the Minister asked the Commissioner of SA Revenue Services to do a forensic audit on the trophy hunting industry, because of the obvious opportunities for tax fraud and foreign currency manipulation?

10.            Is there any reason why the Department cannot publish a comprehensive Directory of Hunting Reserves in SA, listing all reserves, protected areas, resorts and farms where hunting takes place.  See para 3 above for reasons.

11.            Section 28 of the draft Regulations (quoted below) appears to continue the current ban on the establishment of wildlife sanctuaries.  What is the reason for this and why is there not a single clause in either the draft Policy or the draft Regulations making 'animal welfare' a legitimate 'use' of animals?

(Section 28 of the draft Regulations reads as follows:)

28.       (1)            An issuing authority must refuse an application for a permit for the captive breeding or keeping of specimens of a listed large predator species except if the purpose of such breeding is for –

(a)        the conservation of the species; or

(b)            rehabilitation of that species in an extensive wildlife system in the natural distribution range of the species.

EXTRACTS FROM THE NEW REGULATIONS:

 “extensive wildlife system” means a system that is large enough, and suitable for the management of self-sustaining wildlife populations in a natural environment which requires minimal human intervention in the form of –

(a)        the provision of water;

(b)        the supplementation of food, except in times of drought;

(c)        the control of parasites; or

(d)        the provision of health care.

“gin trap” means a leg hold or foothold trap made up of two tightly closing jaws, a spring of sorts, and a trigger in the middle, without an off-set jaw or padded jaw that reduces chances of injury to the animal;

Prohibited activities involving listed large predators, Ceratotherium simum (White rhinoceros) and Diceros bicornis (Black rhinoceros)

24.       (1)            The following are prohibited activities involving a listed large predator, Ceratotherium simum (White rhinoceros) or Diceros bicornis (Black rhinoceros):

(a)        The hunting of a listed large predator, Ceratotherium simum (White rhinoceros) or Diceros bicornis (Black rhinoceros) that is a put and take animal; 

(b)        the hunting of a listed large predator, Ceratotherium simum (White rhinoceros) or Diceros bicornis (Black rhinoceros) in a controlled environment;

 (d)       the hunting of a listed large predator released in an area adjacent to a holding facility for listed large predators; and

(e)        the hunting of a listed large predator, Ceratotherium simum (White rhinoceros) or Diceros bicornis (Black rhinoceros) by making use of a gin trap;

(g)        the breeding in captivity of a listed large predator, unless the prospective breeder provides a written undertaking that no predator of that species will be bred, sold, supplied or exported for hunting activities that are considered prohibited activities in terms of paragraphs (a) to (e) of this subregulation;

 (2)            Subregulation (1) does not apply to a listed large predator, Ceratotherium simum (White rhinoceros) or Diceros bicornis (Black rhinoceros) bred or kept in captivity which –

(a)        has been rehabilitated in an extensive wildlife system; and

(b)   has been  fending for itself in an extensive wildlife system for at least twenty four months.

Prohibited methods of hunting

26.       (1)            An issuing authority considering an application for the hunting of a listed threatened or protected species may not authorise the following methods of hunting, unless it is for the management of damage causing animals in accordance with regulation 14:

(a)        Listed threatened or protected species, may not be hunted by means of –

 (iv)      dogs, except as provided for in subregulation (3);

(v)            darting, except as provided for in subregulation (4);

 (vi)      a weapon which, after it has been discharged, automatically reloads and fires when the trigger thereof is pulled or held in a discharged position;

(vii)            a weapon discharging a rim firing cartridge of .22 of an inch or smaller calibre;

(viii)           shotguns, except for the hunting of birds; and

(ix)              airguns;

(b)        listed threatened or protected species may not be hunted by luring it, by means of –

            (i)            bait, except in the case of -

(aa) lions, leopards and hyena, where dead bait may be used;

(bb) listed threatened or protected marine and other aquatic species; and

(aa)            invertebrates to be collected for scientific purposes;

            (ii)            sounds;

            (iii)            smell; or

            (iv)            any other induced luring method;

(c)        except as provided for in subregulation (4), (5), (6) or (7) the animal may not be hunted by using –

            (i)            flood or spotlights;

            (ii)            motorised vehicles; or

            (iii)            aircraft; and

(d)        the animal may not be hunted if it is –

            (i)            under the influence of any tranquillising, narcotic, immobilising or             similar agent; or

(ii)        trapped against a fence or in  a small enclosure where the animal does not have a fair chance of evading the hunter.

            (3)            Subregulation (1)(a)(iv) does not prevent the use of dogs for the purpose of –

(a)        tracking a wounded animal; or

(b)        flushing, pointing and retrieving listed threatened or protected species.

                        (5)            Notwithstanding subregulation (1)(c) –

(a)        an aircraft may be used for -

(i)            tracking an animal in an area where the hunt takes place over long ranges;

(ii)            culling; and

(b)        a motorised vehicle may be used for –

            (i)            tracking an animal in an area where the hunt takes place over long ranges;

            (ii)            culling;

            (iii)            allowing a physically disabled or elderly person to hunt.

(6)            Subregulation (1)(a) and (b) does not prevent the use of the hunting methods or luring methods described in these subregulations for the purpose of controlling damage causing animals in accordance with regulation 14.

(7)            Subregulation (1)(c) does not prevent the use of flood or spotlights for the purpose of –

(a)            controlling damage causing individuals;

(b)        culling of listed threatened or protected species; or

(c)        hunting of leopards and hyenas.

            (8)            An issuing authority may not issue a permit to hunt a listed large predator, Ceratotherium simum (white rhinoceros), Crocodylus niloticus (Nile crocodile), Diceros bicornis (black rhinoceros) or Loxodonta africana (African elephant) by means of or by the use of a bow and arrow.