THE PREN SUBMISSION OF COMMENTS ON THE DRAFT POLICY POSITION FOR SUSTAINABLE USE OF ELEPHANT, LION, LEOPARD AND RHINOCEROS TO THE SOUTH AFRICAN GOVERNMENT DEPARTMENT OF FORESTRY, FISHERIES AND THE ENVIRONMENT

Elephants are sentient and display complex cognitive capabilities. They are self-aware and require access to large, complex, stimulating ecological and social environments, and they must therefore be given the freedom to exercise choice over their foraging options and companions.

PREN has previously submitted an overwhelming body of evidence that elephants suffer significantly in captive situations. Elephants express well-documented symptoms of Post-Traumatic Stress Disorder (PTSD)1 which is testimony to the damage caused by capture, separation and agency deprivation. Stereotypies such as head bobbing and rocking have never been observed in elephants the wild. The lack of sufficient movement and stimulation may cause elephants chronic loss of muscle tone and physical damage to bones and joints, as well as psychological damage due to the lack of continuous and diverse foraging challenges, social deprivation, and the frustration of being unable to make their own decisions2. Elephants possess distinct histories, personalities and interests, exhibit compassion for others and are capable of communicating complex emotions and of suffering intensely, both physically and mentally. Elephants have strong family bonds and operate within highly socialised groups and unnecessary disruption of these groups by human intervention should be avoided.

In 2022, Dr Rob Atkinson and Dr Keith Lindsay described the minimum required standards for the welfare and well-being of elephants held captive, in their Report for the Conservative Animal Welfare Foundation, titled, Expansive, diverse habitats are vital for the welfare of elephants in captivity. The Report, endorsed by twenty-five elephant experts and scientists, was then submitted to the Department for Environment, Food and Rural Affairs, Government of the United Kingdom, in July 2022.

The report highlighted that:

A. The practice of elephant-keeping is under increasing critical scrutiny;
B. Elephants held captive spend their lives confined in spaces thousands of times smaller than wild ranges. Directly or indirectly, this likely results in poor welfare;
C. A large quantity of quality space is critical for good welfare;

“Space should be viewed from an elephant’s perspective. Nothing less than areas equivalent to wild ranges of 100km2 (10,000ha) and upwards truly enable elephants to breed and flourish, and to carry out the complex social interactions of their species. […] Elephants in such facilities will be a dynamic part of their environment, able to exercise more of their natural behavioural repertoire”.

Elephants are particularly ill-suited to captivity and extremely vulnerable to suffering in a captive setting. As a result, captive elephants are vulnerable to sudden outbursts of aggression, normally towards the handlers, which has led to injuries and fatalities to humans in South Africa and leads to the risk of euthanasia of the elephant.

Recent tragic incidents involving elephant trainers at a single captive elephant tourist facility include:

  1. In 2005, Tobias Ndlovu, an elephant handler was killed at Knysna Elephant Park, by the dominant bull. The owner said the elephant was trying to pick Tobias Ndlovu up after he had fallen and killed him by accident. Reports instead indicated that Ndlovu was trampled to death.
  2. In 2011, Melikhaya Ndzwanana, a guide and elephant handler was seriously injured and maimed by an elephant at the Knysna Elephant Park. The park manager attempted to lessen the seriousness of the incident. The elephant had attacked the handler, flinging him in the air and trampling him in front of visitors. The attack lasted about 10 minutes and resulted in Ndzwanana suffering numerous fractures, blood loss and the amputation of his shattered left leg.
  3. In 2021, an experienced elephant handler named Shepherd Chuma was trampled and killed; family members also testified that this was not the first incident where an elephant at the Knysna Elephant Park charged Shepherd.

Elephants can live with the impact of trauma for decades. More incidents might occur. The training methods of elephants continue to be unregulated and elephant handlers do not require any formal training. Owners of these businesses insure themselves by making sure that tourists sign indemnity forms absolving them of any responsibility or possibility of legal action.