SOUTH AFRICAN GAME RANCHERS' ORGANISATION
SUBMISSION ON THE FIREARMS CONTROL BILL (B34-2000)

Introduction
We thank you for the opportunity granted to us, on behalf of the South African game ranchers, to comment on the new firearm control bill. We would like to emphasise the rather unique situation of the South African game rancher and why the bill should be adapted to this situation.

According to information supplied to the President's Council, 80% of the total conservation action in South Africa was already at that stage conducted on land privately owned. The game ranchers' stake in this conservation action cannot be under estimated.

This conservation action is presently conducted on 9 000 specialist game ranches, plus a further 6 000 ranches on which game ranching forms a secondary farming activity. South Africa is seen to be the undisputed world leader as far as extensive game ranching and private sector conservation are concerned.

The game ranching industry forms the bases of a fast growing eco-tourism industry. Satour found that approximately 65 % of all visiting tourists were inspired by our nature and nature-orientated assets to visit South Africa. This huge potential of the game ranching industry is even recognised by government as the instrument to ensure future growth and development.

It should also be kept in mind that most game ranches are situated in the arid and semi-arid areas of our country where other forms of farming proved to be not sustainable, even with government subsidies; that job creation on game ranches is estimated at 6X that of other extensive farming industries; that game ranching is regarded as a environmental friendly form of land use in these arid areas, and that the game ranching industry created a lifeline in the remote country communities.

The unique situation of game ranchers
It is our submission that the proposed bill does not mike provision for the unique situation of the game rancher.
- We farm with game. A game herd, as is the case with cattle or sheep, must be manipulated to optimise the ratio between sexes, age groups, trophy qualities and productive animals. Whereas cattle can be managed in a kraal environment, manipulation, in the game industry, can only be done by utilising firearms. We use our firearms, and mainly rifles, as the tools of our trade, the same as a mechanic would use a spanner or hammer. It is our tools which are being regulated by this proposed bill; it is our conservation action that are being influenced! If we cannot have hunting rifles, we cannot farm with game. Is it fair to terminate our livelihood by refusing a re-application of an existing licence? Mr Chairman, therefore we would rather suggest a system of auditing of licences legally granted, rather than a system of re-application.

- Nature is our workshop - an environment full of dangerous animals. We are obliged to protect our staff and clients. Our guides don't carry rifles for the image, they do so to protect their clients. The proposed bill must address this situation.

- Our game ranches are situated in remote areas - in those areas where you actually try to limit crime. We also use firearms to ensure the safety of our clients. We cannot afford our eco-tourism industry to be destroyed by an incident involving one of our foreign clients - that would be disastrous, not only for our industry, but for South Africa as a whole is R680-million of foreign currency is earned annually by the game ranching industry.

- Because of our effective game ranching practises, our game tends to increase. This increase can only be controlled by a hunting rifle - be it hunters, foreign trophy hunters or the rancher and his staff. Consumptive utilisation practises, with a rifle in hand, generates approximately 78% of the revenue of the game ranching industry. Please Sir, do not restrict this utilisation practise - of every R 100 generated by this form of utilisation, only R 2, 13 ends up in the pocket of the game rancher. The balance is indirectly invested in the community, either as salaries for staff local purchases, maintenance, and interest on overdrafts - all to the advantage of the remote communities.

Many more examples of the unique situation of game ranchers can be mentioned, but those mentioned should be sufficient for purposes of this hearing.

Proposed amendments to the draft bill
We would like to suggest the following amendments to provide for the unique situation of game ranchers.

These suggestions have been discussed with the departmental committee of the SAPS (Adv Kok, Mr Rick DeCaris and others) who have shown great understanding for these amendments.

The unique situation of game ranchers should be acknowledged in the new bill.

We have requested the creation of a separate category for game ranchers under Chapter 6 of the bill. We have been advised that game ranchers shall qualify for a licence to possess a firearm under Section 23 of the bill. We are however of the opinion that this section is vague and ambiguous and that legal certainty can better be attained by the creation of a separate category as suggested. We believe that, because of our unique character, one cannot be accommodated in the same category as for instance, a security company.

The creation of a separate category will better address the specific needs of our industry - for example, game ranchers will not be forced to own a hunters' association in order to enjoy certain privileges as a dedicated hunter. In order to facilitate the creation of such a category, a game rancher should also be defined in Chapter 1 and we suggest the following definition: "A game rancher means a person who owns/manage a specially fenced game ranch which is either exempted or registered as such with the provincial nature conservation authorities and who is also a member of an accredited game ranchers' association."

Even if game ranchers and professional hunters are specifically mentioned under section 23, as was suggested the departmental committee of the SAPS, we are still of the opinion that the problems caused by the unique character of game ranchers are not addressed.

- The game ranching industry has developed over many years and existing gun-ownership patterns should be acknowledged by the new bill.

A game rancher should automatically qualify for licences to possess those firearms currently legally in his possession. Consideration should also be given to an auditing process rather than a system of re-licensing, as proposed by the new bill.

- The period of validity of licences in this new category for game ranchers should be included in section 30 of the bill.

It is proposed that the validity period for licences held in the suggested new category for game ranchers should be at least a period of 10 years, the same as for dedicated hunters.

- The status of accredited game ranchers' associations if the creation of a separate category for game ranchers is not approved.

- Accredited game ranchers' organisations should enjoy the same status as hunters' associations for qualification as dedicated hunters.

Summary
- We have emphasised the unique situation of gam' ranchers
- We have proposed a new category for game ranchers
- We have in broad terms endeavoured to suggest only those amendments that would restrict the use of firearms, the game ranchers tools of trade, to the minimum, and thereby not limiting the potential of the game ranching industry to contribute to South Africa's future growth and development
- We have tried not to waste your time on smaller issues - issues that we are aware will be raised by other interest groups. Although we regard those issues as important and support it, we tried to concentrate only on issues, which have a direct influence on our industry. We however call on you to seriously consider all issues raised by our utilisation groups, the professional hunters and local hunters.

We trust that we could assist you in the drafting of an effective bill.