We suggest that the words ‘of a specimen’ be inserted before ‘of listed species’ in sub sections (1)(a) to (h). We submit that § 23(1)(a) is in conflict with § 23(1)(b) given the specific definition of ‘listed large predator’ in the Bill. The considerations set out in 3.7.2. and 3.7.3. above also apply to § 23(1)(a). 23 (1)(c): ‘intensive wildlife management system’ is not defined in the Bill but there is a definition in the Regulations. We submit that the qualification ‘where supplementary food is provided for 9 – 12 months of the year’ be deleted in the Regulations since it is arbitrary and may cause confusion. 23(1)(e): ‘holding facility’ must be defined. What happens where, say, buffalo are released from a quarantine boma, situated within or ‘adjacent to’ an extensive wildlife system? 23(1)(g): The corresponding national stipulation is § 24(1)(f) in TOPS. That regulation deals with listed large predators and rhino only whereas § 23(1)(g) deals with all listed species. We submit that this cannot be the intention. If this section stands it would mean that no hunting of listed species may take place without such an affidavit. Would a landowner be required to give an affidavit for the hunting of, say, a gemsbok if he translocated different groups of gemsbok to his property, where gemsbok are also born, over multiple years? How is the ‘period’ to be determined? How does he determine whether that animal was born on that property? § 23(1)(h): The points raised i.r.o. § 21 and § 23(1)(a) and (g) are also relevant here. § 24(2) We suggest that ‘only’ be inserted at the end of this section. § 26 Is it appropriate to incorporate regulations into an Act purely by reference?
We suggest that the words ‘of a specimen’ be inserted before ‘of listed species’ in sub sections (1)(a) to (h). We submit that § 23(1)(a) is in conflict with § 23(1)(b) given the specific definition of ‘listed large predator’ in the Bill. The considerations set out in 3.7.2. and 3.7.3. above also apply to § 23(1)(a). 23 (1)(c): ‘intensive wildlife management system’ is not defined in the Bill but there is a definition in the Regulations. We submit that the qualification ‘where supplementary food is provided for 9 – 12 months of the year’ be deleted in the Regulations since it is arbitrary and may cause confusion. 23(1)(e): ‘holding facility’ must be defined. What happens where, say, buffalo are released from a quarantine boma, situated within or ‘adjacent to’ an extensive wildlife system? 23(1)(g): The corresponding national stipulation is § 24(1)(f) in TOPS. That regulation deals with listed large predators and rhino only whereas § 23(1)(g) deals with all listed species. We submit that this cannot be the intention. If this section stands it would mean that no hunting of listed species may take place without such an affidavit. Would a landowner be required to give an affidavit for the hunting of, say, a gemsbok if he translocated different groups of gemsbok to his property, where gemsbok are also born, over multiple years? How is the ‘period’ to be determined? How does he determine whether that animal was born on that property? § 23(1)(h): The points raised i.r.o. § 21 and § 23(1)(a) and (g) are also relevant here. § 24(2) We suggest that ‘only’ be inserted at the end of this section. § 26 Is it appropriate to incorporate regulations into an Act purely by reference?
Feb-23-WRSA-comments-2.docx