This is a guideline to submit Public Comments on the proposed development of a private owned multipurpose game farm / petting zoo, in the heart of a sensitive ecosystem outside Kleinmond, Western Cape, South Africa.

One of the most recent rapid fires in the Overberg, which killed one person and injured three, early in January 2019. Fires are recurrent in the area. The approval of this development for the use of  many large animals, which are impossible to evacuate in a short time,  is a carnage waiting to happen.
Image credit Greater Overberg FPA

The deadline to participate to the Public consultation is the 14TH of April, please submit following the GUIDELINE below in two essential steps:

  1. Register: send a mail to requesting to be register as an IAP (Interested Affected Party) for the proposed Development of a Game Farm with Tourist Facilities and Associated Infrastructure on the Remainder of the Farm Lamloch no. 892 Caledon District, Ref. no. 16/3/3/6/7/1/E2/18/1343/15
  2. Submit: send your comments to, using part of all the points of the following



Doug Jeffery Environmental Consultants


Western Cape SA

14th April 2018

Dear Adel, Sirs,

Re: Objection to the Proposed Development of a Game Farm with Tourist Facilities and Associated Infrastructure on the Remainder of the Farm Lamloch no. 892 Caledon District, Ref. no. 16/3/3/6/7/1/E2/18/1343/15

As a Conservationist/







Local house owner/

Private individual,

Wildlife passionate,

We have not received sufficient information on the consequences and implications linked to the approval of this project, in accordance to Section (2)(4)(f) and (o) of the NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998. In fact, the participation of all interested and affected parties (I&APs) in environmental governance, including the public, must be promoted and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation.

The NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998, requires to adequately inform the public and give opportunity to suggest ways for reducing or mitigating any negative impacts of proposed projects, through meetings and public workshops.

We have noted a very concerning lack of transparency in the management of conflicting interests since all potential and I&APs have a right to be informed early and in an informative and proactive way regarding proposals that may affect their lives or the environment.

We have not been reassured with any scientific evidence and proof against the negative effects of this project, on our community, our environment and the endangered species of the area. 

We therefore object to the approval of the project as follow:

1. Our concerns and legal considerations are:

  • Cape Nature has approved the Game Management Plan for Elephants, before any   assessment of the environmental impact of keeping them on the Lamloch property was done.
  •  Attempts to obtain copies of the application and the terms and conditions attached to the Plan have been rejected indicating a very concerning will to deny transparency along the process; Cape Nature refuses releasing copies of the application even after receiving a so called “PAIA” application for information, through the Promotion of Access to Information Act. This is arrogance of the highest level.
  • The abuse of our environmental law relating to the fencing of “coastal public property”, since the property has been enclosed by an electrified game fence on the cadastral boundary, is appalling. On the false assumption that the new fence simply replaces former fences, the developer was allowed to erect the fence across the watercourse that connects the Bot River Estuary with the Kleinmond estuary. Part of the public area of the Bot River Estuary has been enclosed by the boundary fence and will have a privately owned tourist accommodation camp built over a sensitive watercourse, the whole community benefits from. In the majority of places where the fence is now erected, there never was any fence.
  •  It has been reported by local hikers that the building of a massive facility (prior the approval of any permit) is already taking place in such delicate environment and in the face of any compliance with the law.
  • The Proposal gives an understatement of the extent of the development relative to the area of the total property. It proposes that the footprint of buildings and infrastructure be the extent of the development. In truth, the whole of the area over which animal encampments will be created and the area over which animals will be allowed to trample, should be included in the area deemed to be disturbed by the proposed Game Farm. That puts a very different perspective on the extent to which the proposed development will impact the property.
  •  This development has been proposed as a “Wildlife Sanctuary” which is misleading. A”Wildlife Sanctuary”, is a place created for the benefit of the animals where they are protected from harm. Keeping animals in captivity, asking people to pay an entrance fee to view the animals, is a zoo or a “Game Farm”, a place where animals are bred for commercial purposes. The purpose and mandate and application of this project should be clear and coherent.  From the Pre-Application Basic Assessment Report (PBAR), which gives the intention as “The Applicant wishes to introduce eight elephants and other wildlife for tourism purposes”, clearly, the purpose is for the commercial exploitation of the animals, so the Wildlife Sanctuary signs erected on the property are misleading and should be amended to read “Breeding Farm” “Petting Zoo”.
  • The animals to be housed for “conservation” and referred to as “wildlife” have been in captivity and have been acquired through commercial transactions. They are going to be enclosed in camps separated by electrified fences. Unable to forage for food, they will be fed by keepers, habituated to the point where they will be incapable of being returned to the wild. This is not a conservation project.

2. Contradictions:

Cape Nature officially declares that it does NOT encourage nor condone the interaction of wild animals with humans, yet supports this proposal by approving the elephant management plan, then refuses to divulge the particulars.

3. Our concerns on the lack of regulation and monitoring:

  •  In South Africa the wildlife industry has some of the worst labour practices.  Handlers do not require any formal training to be able to work with or handle elephants. The fact workers in this industry are not organised or monitored opens them up to exploitation and unfair labour practices.
  •  There is a notable lack of government approved and enforceable norms and standards governing the training methods for elephants in South Africa. This has implications for the insurance cover of operators utilising elephants in captivity in the tourism industry.
  • There is also no formal licensing procedure of elephant trainers or handlers.
  • These kind of businesses have a very poor record, are known to abuse animals and are “black holes” where the public, media and NSPCA are not able to monitor or observe the industry in action.
  •  Brian Courtenay, the Chairman and Founder of SATIB (Safari and Tourism Insurance Brokers), says that the lack of formalised norms and standards or protocols within the industry is of considerable concern and is a threat to South Africa’s tourism reputation. According to Courtenay, the current operating practices are “simply accidents waiting to happen…and there have been a number of incidents in the past and they will happen again.

4. Damage to Brand South Africa and financial impact on local activities and businesses:

  •  The captive lion, rhino and elephant industry smears South Africa’s image as a conservation leader and damages our tourism industry. There is no conservation benefit to captive breeding and wildlife/human interaction. Locally and globally there is a general abhorrence to the captive wildlife and interaction industry across multiple sectors of society. Allowing this zoo to go ahead would fly in the face of the global trend of responsible tourism which is rapidly moving away from exploitative wildlife interactions.
  •  The South African Institute of International Affairs (SAIIA) 2018 report cautioned that South Africa’s tourism brand value could potentially be negatively affected by as much as R54 billion loss in revenue over the next decade, if the Captive Lion Breeding Industry is allowed to continue. It is extremely important that governing bodies in South Africa help to establish solid ground rules to prevent unethical tourism taking root.
  •  The South African Tourism Services Association (SATSA) enphasized the need to toe the line with regards to ethical and responsible tourism during the 2018 annual SATSA Conference panel discussion on Animal Interactions.
  • Several Safari`s in the Eastern and Western Cape remain compliant to best practices and sanctuaries follow the best standards; they risk of being painted with the same brush of this project, when non-compliant animal interaction “sanctuaries” are allowed to open and operate, no matter what.
  • There is a REAL sanctuary in the area, Panthera Africa in Stanford. This is what should be supported. The approval of this Game Farm project under the vest of conservation will compromise the work, the reputation and efforts of Panthera Africa.
  • The growing condemnation towards facilities exploiting iconic animals will negatively impact all accredited Responsible Tourism and Fair Trade activities and businesses of the area.

5. Our concerns on the environment and conservation of the sensitive ecosystem of the area:

  • The introduction of a game farm, masqueraded as a wildlife sanctuary that will exhibit animals that are not endemic to the Overstrand and risk destroying sensitive and endangered ecosystems critical to endemic fauna and flora, is unjustifiable.
  • The lack of studies on the detrimental effects on the sensitive ecosystems on Lamloch Farm cannot be ignored and bypassed.
  • The National Environmental Management Act recommendation to implement the “precautionary principle” in the case of insufficient data, would be ignored.
  • If the elephants are found to cause damage to the critically endangered flora on the area, they would have to be removed, this proves the financial weakness of the development, from the start.
  • In the Betty’s Bay area you can see the effect of keeping horses in an encampment on the local fynbos. Within two to three years the fynbos was destroyed, and the encampment was transformed into a sand dune.
  • There is no independent research that shows that interacting with captive wild animals contributes to conservation. This is the antithesis of environmental conservation; a practice that internationally is being forced out of existence.

6. Our concerns on the Fire Risk

  • We are particularly concerned about the total absence of any fire prevention Plan, any risk mitigation Plan, any evacuation Plan, nor any mention is made to actions in the event of fire. It is well known that the area very recently burnt out of control over 12 000 ha destroying 40 houses and veld – one life was lost due to heart attack as a result of smoke inhalation.  Having to evacuate, in a short time and in security a considerable number of large herbivores and big cats / predators, is simply an impossible mission. In case of a rapid fire, which is a recurrent event in such a windy area, all animals will have to be left to die, which is not only morally unacceptable but will cause worldwide reaction, criticism, condemnation. This, once more will affect Brand South Africa.

7. Our Concerns on the validity of this project: Education, Recreation

  • Mr Saunders venture is a business that will exploit wild animals purely for commercial gain.
  • Children know more about dinosaurs than about elephants, this proves that interaction and watching animals in captivity or under human exploitation is not the right message and does not teach about preserving and respecting wildlife, rather the opposite.
  • From the recreational point of view, the significant risk to human safety, including fatalities, through physical interactions with elephants, lions and other carnivores. In the lion industry in South Africa this has resulted in at least 37 incidents affecting no less than 40 victims since 1996 and including 12 deaths. The captive elephant industry is not transparent and information about deaths and injuries in this industry are therefore difficult to monitor, nonetheless, a 2015 EMS Foundation report into the industry showed that between April 2001 and January 2014 there were at least 18 incidents of injuries and/or deaths (of handlers and tourists).

8. Social Benefits:

  • It is prospected that the development will create at least 50 permanent jobs.
    It is not specified, though, in any way, how these jobs will be created and what kind of jobs they will be.
    It has also been alleged that Saunders pays a cleaner at his “Plettenberg Venture” approximately R120/day. This is hardly economic emancipation but rather, slavery. There is also no evidence of any partners in any of Saunders’s ventures, also in this proposal – thus, the venture is solely for his own financial gain.

9. Concerns about the history of the owner Craig Saunders and his business:

  • Craig Saunders’ history speaks for itself: his recent changing of websites, his testimony in court, his run in with environmental officers, relating to a property bought in Vermont, are only a few, more recent stories which highlights his character.
  • Five of the elephants Mr Saunders owns are “Tuli elephants”. In July 1998, thirty wild elephant youngsters, 24 females and 6 males, ranging between 2 and 5 years old, were kidnapped from their families in the Tuli region of Botswana and taken to South Africa for sales to zoos, circuses or elephant back safari/elephant interaction facilities.
  • Video footage of the elephants ‘training’ and abuse and their obvious suffering was leaked to animal welfare organisations and the public, eliciting never-before-seen public outrage.
  • Craig Saunders was intimately involved in the abusive training of some of these little elephants.
  • Craig Saunders had previously attempted to fence inside his property the wild horses of the area and only a massive public outcry made him rethink. Clearly, he cannot be trusted!