TO: Mr TM Mbeki
President of South Africa

CC: Mr M Van Schalkwyk
Minister of Environmental Affairs and Tourism
Mr OC Chabane
Limpopo MEC for Economic Development, Environment and Tourism

Dear Sir


During the last month I have raised my concerns regarding the above matter in letters to the Minister of Environmental Affairs as well the Limpopo MEC for Economic Development, Environment and Tourism.

Briefly the situation is as follows. Three private nature reserves adjoining the Kruger National Park (KNP) entered into an agreement with SANParks to remove the fence separating them from the KNP. The intention being to expand the conservation area. However it has been brought to my attention that one of these private nature reserves, the Timbavati (TPNR), has practiced lethal commercial hunting. In other words animals protected and conserved at great cost within the KNP can roam into the TPNR where they can be hunted for the financial gain of a small group. It must be noted that I have been informed that reports exist which claim very little game was present within the TPNR prior to removal of the fence. However records reflect that the TPNR has made huge amounts of money from the commercial hunting of game such as buffalo, lion and leopard.

Since raising this matter, I am relieved to state that the Limpopo Government has announced a moratorium on hunting in the TPNR until the matter is resolved. However, the independent investigation that I have called for, has not been instituted by the Minister at the time of writing this letter. He did meet with some of the stakeholders in the TPNR and has called for a report from SANParks. I have indicated to the Minister that SANParks is clearly part and parcel of the current situation, and if there were any wrongdoing it would be ridiculous to expect them to investigate themselves. An independent investigation is necessary.

Quite disturbingly some of the landowners and stakeholders within the TPNR who were brave enough to publicly raise their own concerns regarding the current situation have been summarily suspended from the TPNR Association. It is a cause for concern that people who have exercised their right to freedom of expression regarding the protection of national assets should be treated in this fashion.

I have now received further information, this time relating another private nature reserve adjoining the KNP, the Umbabat (UPNR), which also has no fence separating them from the KNP. It transpires that here too, lethal commercial hunting is taking place. The pattern seems to mimic what has happened in the TPNR. I’m aggrieved to state that my information is that lethal commercial hunting in the UPNR has included elephants. One of the troubling aspects of this matter is that this commercial hunting of national assets seems to have been allowed by the Limpopo Provincial Government supposedly on the understanding that it would be purely for conservation purposes and funding thus raised would go towards conservation. There are serious questions about whether this revenue is actually ploughed back into conservation. The TPNR budget for instance has a section specifically named “Conservation”, but it is a mere fraction of the millions generated through hunting. In the UPNR, I have been informed, that such hunting revenues have been directly distributed to members of the UPNR. There are therefore serious questions about whether this entire situation is nothing but a quasi-legalised version of poaching that a select elite is benefiting from. I have been informed (and this definitely requires investigation!) that the UPNR has refunded hunting revenues to members in order to avoid the tax implications; it is unclear whether the individual members in turn properly declared these revenues for taxation.

I enclose a copy of the 2003 Financial Statements for the UPNR . This shows total reserves of R595117 for 2002, and R801804 for 2003. But the UPNR claimed in a scoping report for SANParks and the Limpopo Government that they needed to hunt to raise money to pay their bills? On top of this, at that time the UPNR by its own admission was doing practically no conservation. So during 2003, the UPNR gets provincial approval to possibly kill a national asset to raise funds, as a result the UPNR hunts elephant and buffalo to the value of R394340, and then only spends R181515 on conservation. Simultaneously the UPNR still has reserve funds of R595117 from 2002. The result is clear, even after giving R332703 back to members as a refund (a questionable practice referred to above), the UPNR now suddenly has cash reserves of R801804.

It is apparent to me that huge amounts of money and powerful people are involved in this matter, and that SANParks willingly or unwittingly is involved. I have serious doubts that the process the Minister is currently following, i.e. depending on SANParks to investigate, will result in a proper investigation and resolution of this matter.

Given the information I have received to date I am extremely concerned about the ability of SANParks to fulfil its mandate and protect game under its responsibilities. The odds are that if commercial hunting of national assets has occurred in two places that it might be a widespread occurrence.

As far as the KNP and surrounding areas are concerned it is vital that the entire affected geographical area must be investigated. In other words, not only the APNR area (including the TPNR, UPNR, Klaserie and Balule), but also provincial parks that border the KNP and where fences have been removed, such as Letaba, Manyeleti, and Andover.

The South African taxpayers deserve to know whether they are sponsoring conservation or providing stock for a select, and already rich, few to profit from. I therefore urge you to immediately institute an independent investigation into lethal commercial hunting in and around all reserves under the control of SANParks. I believe that this investigation should involve the Auditor General and the South African Revenue Services. I would urge you to ensure that the terms of reference for this investigation will allow all interested stakeholders to deliver evidence.

Please indicate at your earliest convenience whether such an independent investigation will be instituted, since I wish to contribute to drafting terms of reference based on the documentation that I have received on this matter.

I need to warn you in advance that other, even more disturbing, allegations have been made to me, and which I may be in a position to verify in the coming days. When I have received sufficient verification of this information I will forward this also to your office.

Your urgent attention to this matter will be appreciated.

Kind regards

Bantu Holomisa, MP
President: United Democratic Movement

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