started this petition to
Hon. Minister of Fisheries and Marine Resources Bernhard Esau,
Ombudsman John R. Walters,
Hon. Minister of Environment and Tourism Pohamba Shifeta,
Environmental Commissioner Theofilus Nghitila
Thank you for affording us the forum to voice our concerns
about the marine environment.
We would like to bring your attention to an urgent concern
regarding a proposal to the Namibian Government for the yearly live
capture and export of marine animals including Orca (Killer Whales), Cape Fur
Seals, African Penguins, and Bottlenose Dolphins, as well as sharks and other
species which have not been disclosed.
We are alarmed by this proposal. All species intended for
this live capture are listed on either Appendix I or Appendix II of the
Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES). These marine wildlife are shared
migratory species and do not belong to Namibia alone. These wildlife are specially protected under
international law and any trade is subject to strict CITES regulation. This
law requires Namibia to prove that any trade will not be detrimental to the
survival of the species. In addition CITES Articles III(2)(b) and IV(2)(b) require that these wildlife are not obtained
in contravention of the laws of Namibia.
We appreciate that, in accordance with Namibian law, the
Ministry of Fisheries and Marine Resources must follow the Constitution and apply
section 3 of the Environmental Management Act (2007) upon its decision making
under the Marine Resources Act (2000).
There is insufficient data available to the
public on the status of the proposed marine species, however scientific estimates
suggest that several of these species are either declining, rare or endangered
in Namibian waters. Removing any of
these species from the ecosystem would be in conflict with the supreme law of
the land, the Namibian Constitution, which states that all wildlife must be
maintained on a sustainable basis for present and future generations as an inheritance to our children. Sustainability requires a species to be available in the long term for
future generations and to never be depleted.
In accordance with section 3 of the Environmental Management
Act (2007), we, as interested and affected parties, would like our interest, needs and values taken into account in the decision regarding the harvest of live
We assert that the
functional integrity of the marine ecosystem can be badly damaged by removing critical marine wildlife. Each species has an important role to play in the correct functioning of the ecosystem. Removing any of them can cause irreversible damage to the entire food chain. We contend that removing numerous critical
species from the ecosystem is unsustainable and can cause a collapse.
The biological diversity of the marine ecosystem must be protected and
respected for the benefit of present and future generations.
Namibia‘s Environmental Management Act (2007) enshrines the Precautionary Principle in law to ensure that cautious decisions are made with regard to the wildlife. In order to ensure sustainability of the entire marine ecosystem, we urgently request the Ministry of Fisheries and Marine Resources to err on the side of caution and be careful of an unintended collapse caused by removing marine wildlife from the ecosystem.
Damage to the marine wildlife and ecosystem
must be prevented.
We thank you in advance for taking into account our serious
concerns for our marine wildlife and the functional integrity of the marine ecosystem.
We urge you to deny any permit application to capture and
export live marine animals. As part of
the public consultation process, we trust
that our concerns will be heard.