THE PRECAUTIONARY PRINCIPLE PROJECT
ONLINE CONSULTATION
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From: Wayne Lotter
Affiliation: Game Rangers Association of Africa
Remote Name: faunaand-14.dsl1.easynet.co.uk
Time: 11:03:18 +0100
I have read the “DRAFT GUIDANCE FOR BEST PRACTICE IN APPLYING THE PRECAUTIONARY PRINCIPLE IN CONSERVATION AND MANAGEMENT OF BIODIVERSITY AND BIOLOGICAL RESOURCES” document and would like to offer the following brief comments:
Numbered paragraphs 1, 2 and 3 – I agree as is. I would like to emphasize the importance of the following sentence under 3 as being of key importance and a major shortcoming at present: “While it is important for the precautionary principle to be incorporated into law and policy, to have conservation impact it will typically require translation into concrete policy and management measures that address the conservation problem and specify actions to be taken in specific contexts.” This is a challenge that I believe really has to be met. There are numerous cases in South Africa (and I am sure elsewhere) of ‘lip service’ being paid the Precautionary Principle (PP) but it not being consistently applied. One example is with the Kruger National Park, where the PP is quoted as a reason for wanting to resume elephant culling (to prevent possible damage to other species), but it has not been applied to the commercialization programme of the Park - in that it was stated in official documentation that the effects of off-road driving may be irreversible but it was decided to allow it for financial reasons because tourists are willing to pay a lot of money to be allowed to drive off-road. (This theme/example also applies to some other of my comments in the paragraphs following)
Paragraphs 4 and 5 – Agree as is.
Paragraph 6 – Agree in full. It should also be added to this section that ‘where a decision is made to proceed with an activity/development in spite of potential negative consequences (irreversible impacts as in the case of the Kruger National Park off-road driving example), there must be a burden of proof placed on the proponent of such development or activity.’
Paragraph 7 - Agree as is.
Paragraph 8 – agree in full. And to expand on the issue of “who decides” the question should also relate to who stands to benefit by the decision cf. who stands to lose? Precaution should be the overriding factor in cases where the benefits of proceeding would accrue to a small group of stakeholders, and/or even a large group but over a shorter time scale, compared to that of the potential negative consequences. This point also relates to paragraph 9, which I also support but believe therefore should be expanded to include temporal as well as distributional impacts and socio-economic feasibility.
Paragraph 10 – Agree, yes, but also suggest that time scales should be considered here (‘big’ short term gains cf. small losses for future generations).
Paragraph 11 – Agree in full. Would like to stress the necessity of management measures taken in the face of uncertainty needing to form “part of a rigorously planned and controlled trial, with careful monitoring and periodic review to provide feedback, and amendment of decisions in the light of new information.”!
Paragraph 12 – Agree, absolutely.
Paragraph 13 – Agree in full and would like you to add the following to the list of rights: ‘the responsibility of current to future generations’!
Thanks for the opportunity to participate with this project. Best regards, Wayne Lotter Game Rangers Association of Africa
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