EIA Comments on the Draft National Biodiversity Economy Strategy

The Environmental Investigation Agency welcomes the opportunity to submit comments and recommendations to the South African National Department of Forestry, Fisheries and the Environment (DFFE) on the Draft National Biodiversity Economy Strategy in terms of Government Notice 4492 of 8 March 2024 (Government Gazette 50279).

As an overarching comment, EIA strongly opposes proposed Action 10.4. Considering the ongoing rhino poaching crisis in South Africa and the continued poaching risk to elephant populations in the Southern African region, the utilisation of rhino horn and ivory as envisaged in the Draft NBES would be immensely dangerous to implement and counterproductive to the stated purpose of the Draft NBES. EIA also provided comments on Actions 2.1 and 4.4.