From: SealAlert-SA
Date: August 15, 2006
Dear All Seal Supporters,
Whilst South Africa sent a delegation to the recent CITES Animals Committee Meeting in July in Peru - to request CITES to list "Perlemoen" a shell-fish on Appendix III. Seal Alert-SA together with 12 million supporters were campaigning to have Namibia end its genocidal slaughter of protected Appendix II CITES species of nursing baby seals in birthing and breeding grounds. On the day the newspapers in South Africa highlight South Africa's Appendix III move for Perlemoen - Seal Alert-SA requests CITES to move Cape fur seals from Appendix II to Appendix I (without South Africa or Namibia government support) - and requests a full investigation of both South Africa and Namibian Management Officials involved in the illegal trade of millions of Cape fur seals since 1977 - and requesting a ban on all wildlife trade - for the Seals - Francois.

----- Original Message -----
From: SealAlert-SA
To: John.Sellar@cites.org
Cc: willem.wijnstekers@cites.org ; jim.armstrong@cites.org ; marceil.yeater@cites.org ; juan.vasquez@cites.org
Sent: Tuesday, August 15, 2006 11:40 AM
Subject: Special Request CITES - Distribution of Cape fur Seals
Southern Africa
Dear Mr Seller,
I refer to my emails dated 10th and 11th August 2006, to which I
have not received an acknowledgement to the email dated 11th.
As my request to the Namibian CITES Management Authority went
un-addressed - with no announcement that the 2006 sealing season
has been stopped.
I therefore request the CITES Secretariat to investigate all the
allegations and evidence contained in summary form below,
including;
* Legal opinion of the jurisdiction of the sealing permits with
regard to the mainland, regulated under the Seabirds and Seals
Protection Act No.46 of 1973 and from 2000, the Marine Living
Resources Act, including the regulations relating to the age group
of seals covered under the "pup" and "bull" quotas.
* The violations and detrimental alleged seal exports between 1977
and 2006 for Namibia and South Africa.
As these CITES violations have been so widespread since 1977, Seal
Alert-SA requests that Namibia and South Africa joined the other 14
African countries and the other 19 countries already in violation
of the CITES Convention, and a suspension of all wildlife trade be
recommended.
In addition Seal Alert-SA requests CITES Secretariat to consider
Amending the Cape fur seals from Appendix II to Appendix I status,
at either the next 54th Meeting of the Standing Committee in Geneva
2-6 October 2006, or the Meeting of the Conference of Parties in
the Hague 3-5 June 2007.
Could you please acknowledge receipt of this email, noting that the
contents have been read including examination of the colony by
colony pics and data.
For the Seals
Francois Hugo Seal Alert-SA

Special Request :
CITES Secretariat
Request to Amend Cape Fur Seals (Arctocephalus pusillus pusillus)
from Appendix II species to an Appendix I species.
If this request is to be considered. Seal Alert-SA requests an
opportunity to present a detailed summary for this request.
The below is a brief analysis.
International Trade Background:
In light of the substantial allegations and evidence Seal Alert-SA
has placed before the Secretariat since early July 2006 - it asks
if the Secretariat will view this in the urgency that is
required.
Seal Alert-SA has been on the forefront of Cape fur seal
conservation since 1999, involved in almost every sphere of its
protection.
One of the most serious flaws in the conservation of this species -
has been the classification that it is a "seal". 'True Seals' spend
almost their entire lives at sea and are so evolved, and as in the
case of "harp seals" - require dry-land for less than 14 days
before pups are fully weaned. Cape fur seals require dry-land for
at least 50% of their lives, to warm-up, moult, raise their young,
to mate and to breed - as they have not evolved into true seals.
Cape fur seals walk on all fours and still have external ears, and
as such are more akin to the sea-lion species. Dry safe off-shore
habitat is therefore of paramount importance to this species future
survival. A conservation reality over-looked as yet by
conservationists in southern Africa.
In 1972 the USA banned the import of all Cape fur seal skins or
products from South Africa and Namibia - to which all Cape Fur seal
skins were being exported at the time to one fur company called
Fouke. The US Marine Mammal Protection Act (MMPA) regulations,
which states that the "taking of a nursing pup in a birthing and
breeding colony" is illegal and cruel, (as it interferes in the
natural breeding behaviour of this species). Instead of accepting
this scientific conservation reality, South Africa under its
apartheid policy with its "world sanctions" tried to circumnavigate
this decision, trying first to obtain wavers in the US courts,
before finally failing, and then deciding to privatise sealing,
with an introduction of a Sealing Act in 1973.
To truly understand how far reaching these violations in regard to
CITES goes and how far back - a brief background is required.
Historical sealing on seals breeding in their natural habitats -
islands, had already driven the species close to extinction by
1900. Establishing with proven historical fact - that commercially
harvesting this particular species, either of its pups, cows, bulls
or juveniles - resulted in massive disturbance, fleeing from these
small breeding locations, and causes colony and eventually species
extinction.
As the seal population gradually recovered came renewed interest in
harvesting them or keeping their numbers down. Sealing at the time
was not very profitable, so methods were sort to keep sealing costs
to a minimum. Island Seal colonies were widely dispersed over 4000
km of mostly inaccessible coastline with few harbours. With the
average income per seal, even in its peak years, averaged less than
R10 or USD $2. Transporting sealers via boat to these islands,
processing difficulties and transport of these seal products back
to harbours and the mainland proved economically
unviable.

clear evidence of official island seal disturbance
policies
The forced re-location of seals to the mainland, via physical
banning, island disturbance, guano harvesting or seabird
conservation - presented an ideal situation, where large amounts of
seals could be forced to congregate and therefore be harvested in
large numbers, at minimal cost - the opposite side to this coin,
sealers had to change their sealing methods on the mainland.
Instead of driving seals into the 'islands' interior away from the
sea - sealers now drove seals inland away from the safety of the
sea.
The as yet unanswered question - is the sealing industry in
southern Africa - a sustainable harvest or a cull? Statements since
1973 appear to confirm the latter. This immediately creates a
dilemma, for as all sealing products are exported, these exports
cannot be exported if "the export is detrimental to the survival of
the species" - a violation of the CITES convention since 1977.
Confirmation to support this is contained in the evidence, where in
seeking a waiver in 1975 which would limit the harvest to 70 000
skins - South Africa exceeded the quota before it was granted and
therefore had to abandon plans to import skins into the US. In the
1990 Commission on Sealing - further evidence states, "if the
objective is the reduction of the total seal production, the most
effective way to achieve this is to cull the adult females;
however, it must be appreciated that the products from such a cull
have negligible economic value, so that such an operation will not
be self-financing".
Culling of a seal population with quotas involving 90% of it pups
in birthing and breeding grounds whilst still nursing, in an 'open'
eco-system can only be considered detrimental - a CITES
violation.
South Africa which administered Namibia until 1990, brought out the
Seabirds and Seals Protection Act No.46 of 1973 - which act was
incorporated into Namibia until 2000. In 1977 the US appeal court
upheld the banning of Cape fur seal imports. Since 1977 Cape fur
seals have been given the criteria of Appendix II and CITES has
been regulating the international trade.
Since the Seabirds and Seals Protection Act of 1973 transferred
sealing from government to private individuals/companies by way of
a permit system, and where most sealing activities centred on three
mainland colonies - Kleinsee (RSA) and Wolf/Atlas Bay and Cape
Cross in Namibia - there has been an unresolved legal issue regard
lawful jurisdiction - of these "Sealing Permits'. The Act states,
"To provide for the control over certain islands and rocks; for the
protection, and the control of the capture and killing, of sea
birds and seals and for matters incidental thereto" and "Island" -
means any island or rock or any group of islands or rocks specified
in Schedule 1 and "Minister" - Powers of the Minister in connection
with islands, seabirds and seals and the products of sea birds and
seals. "Prohibitions" - No person shall - set foot on or remain
upon any island; upon any island or within the territorial waters
or fishing zone of the republic or along the coast of the Republic
between the low-water mark and the high-water mark as so defined,
pursue or shoot at or wilfully disturb, kill or capture any sea
bird or seal, except under the authority of a permit.
Under "Offences and Penalties" - Any person who - contravenes or
fails to comply with the provisions of this Act; or with any
direction in a permit issued; shall be guilty of an offence and
liable on conviction to a fine not exceeding two hundred rand or to
imprisonment for a period not exceeding three months or to both.
Any person arrested, as soon as possible be brought to a police
station and the provisions of section 27 of the Criminal Procedure
Act shall apply in respect of his detention thereafter.
Although this act has been in place since 1973, Francois Hugo of
Seal Alert-SA has been the only person who has been arrested and
criminally charged under this Act. As no other convicts have taken
place its jurisdiction with regard to the sealers has therefore
never been tested. Under a newly introduced regulation in 2000,
designed to prevent him unconstitutionally rescuing injured, sick
or dying seals - by making it a criminal offence to feed such an
animal. He was arrested in 2003, for tube-feeding a baby seal pup
rescued several months earlier. The authorities withdrew the charge
on the date of trial stating, "It was not appropriate to proceed
with the prosecution until we have completed the new seal
policy".
From fossil remains of Cape fur seals found on the Cape west coast
dating back 5 million years, Professor Andy Smith and Dr Woodbourne
of the Archaeological department at UCT are of the scientific
opinion that no mainland breeding Cape fur seal colonies existed
prior to 1940. This view is supported by Dr Jeremy David.
Specialist Scientist at Marine and Coastal Management (MCM)
Department of DEAT - South Africa, Dr Jeremy David (formerly
in-charge of sealing and seal management) stated, "Seals select
offshore islands as their preferred breeding sites ....there are
also six mainland colonies, five of which have become established
only since 1940 ....the 6th only since 1850 .... as a result of
exploitation the seal population had been reduced to very low
levels by the start of 1900. In fact, at least 23 island colonies
had become extinct by then .... seals have only recolonised 3 of
them". According to the Seabirds and Seals Protection Act No.46 of
1973 (South Africa), this legislation was adopted and still in use
until 2000 by Namibia. A total of 46 offshore islands are listed,
with a total land surface area of 1000 ha (Schedule 1 of the Act).
The reality is that these former 23 seal island colonies represent
99% of the total protected island land. Since official population
surveys were undertaken in 1972 - 98% of these former breeding seal
colonies have remained extinct.
There are some excellent references to the abundance and size of
these former island seal colonies contained in the book "Before Jan
Van Riebeeck - by R Raven-Hart" and taken from historical accounts
between 1488 - 1652. For example -
o Algoa Bay on South African east coast - where the islands Bird,
Seal, Black Rocks, Stag and St Croix are situated, this bay was
actually named the "Bay of Seals" - today Black Rocks remains the
only seal colony, and in 2002, Dr Stewardson reported that it has
declined 94% since first surveyed, and is in danger of going
extinct (our eastern most seal colony).[see map below].
o In 1603, Sir James Lancaster described Robben (Seal) Island,
southern Africa's largest island, a UNESCO world heritage site and
protected for Seals and Seabirds, as "this island there is such
abundance of seals and penguins, in such number as incredible" - it
has remained extinct since 1700.
o In 1604, Sir Henry Middleton wrote, "such infinite number of
seals it was admirable to behold, the whole seashore lies
overspread with them".
o In 1607, David Middleton wrote, "in my opinion, there is no an
island in the world frequented with more birds and seals then this
island".
There are of course many, many more descriptions detailing the
'Seal Life" on all these 23 islands, still protected today, but
extinct now to every major former seal breeding colony.
Based on these historical accounts, and using population densities
of current island colonies, extrapolated over the known existing
islands surface area - we can determine a rough example of the size
of the former island populations of seals. An estimated 4 million
pups or a total population of 16 million. The seal population as
its surveyed peak in early 1990's is less than 10% of the pristine
population.
Based on current population numbers, the largest island, currently
extinct to seals, but still bears their name Robben (Seal) Island -
if the entire population of Cape fur seals in southern Africa, over
their full distribution range, South Africa and Namibia included -
would return, they would occupy less than 6% of this island or 21%
of its seashore.
Prior to 1940 sealing was undertaken exclusively on islands on a
slowly recovering species from near extinction nearly 40 years
prior. By the early 1970's as island populations of seals continued
to decline, sealing moved to the mainland. By the first population
survey in 1972, South Africa's only mainland colony had a pup
production of 46% of the South African seal population, by 1990
when South Africa stopped it had risen to 58%. Likewise the two
mainland sealing colonies in Namibia had a pup production of 53% of
the Namibian seal population, by 1990 rising to 64%, and later to
75%.
As all Cape fur seals originated from one population of island
seals prior to 1940 - it seems absurd that mainland seal colonies
would continue to represent larger and larger portions of the seal
population in (particularly as sealing activities intensified) -
whilst 98% of their former colonies remained extinct and island
populations grew smaller. Even more absurd, is the decline of fish
stocks in the northern west coast area in the late 1960s where
these mainland seal colonies have developed.

Since 1973 and the incorporation of
Cape fur seals in Appendix II in 1977, and the export criteria
required - "An export permit may be issued only if the specimen was
legally obtained", the whole question of "jurisdiction" comes into
question.
Mainland seal colonies on average stretch about 3 km along the
coast and about 200 m inland (confirm by MCM official Mike Meyer in
2006). Well beyond the high-tide mark. Mainland sealing involves
rounding the seals up and driving the herds inland again, away from
the high-water mark inland. Where the harvest occurs between 200m -
400m from the high-water mark.


clear evidence of sealers at Kleinsee operating well outside their
jurisdiction (criminally)
Between the period 1973 and 1990, all seals killed on the mainland
at Kleinsee - South Africa, involving over a million seals were
killed outside the jurisdiction of their permit and the act. A
criminal offence. The majority of the Kleinsee seal colony is in
fact situated on private land, on the farms known as Kleinsee 192
and Dryerspan 193. These farms fall within the diamond restricted
area belonging to De Beers, of which De Beers the largest gem
diamond producer in the world, is the owner of these farms. Sealing
sheds situated at least 400m inland away from the high-water mark
on these farms were used to slaughter and process seal
products.
In essence what occurred here - sealers ignoring the definitions of
the act and its jurisdiction - a criminal offence - "pursued, shot
at, wilfully disturbed, captured and killed seals" - by driving
them away from their permitted jurisdiction in order to harvest
these seals more effectively. Nobody until now has ever questioned
these methods - not even the Commission on Sealing in 1990, headed
by WWF-SA former chairman, Dr John Hanks or the 11 scientists
appointed to advise the then Minister.
Seal Alert-SA since its complaint to the Public Protectors Office
in 2000, which resulted in a five-year investigation by advocates
Pienaar and Fourie, and a report to Cabinet, known as the Report
No. 51 of the Public Protector - South Africa into "Allegations of
improper conduct by the Department of Environmental Affairs and
Tourism in connection with the Conservation and Protection of the
Cape Fur Seal" addressed some of the issues surrounding this but
mainly focused on the 'seal rescue and rehabilitation' aspect.
Regardless many of these issues were the same. Key Findings : were
are follows.
* 1. Mr Hugo's complaint was justified in so far as it related to
the absence of clear and adequate legislation regulating the
protection, conservation and rehabilitation of seals; and
* 2. The Department is currently drafting legislation that would
address the said deficiencies.
Note - Although a draft has been released, Seal Alert-SA has made
submissions, but has not been consulted and in its opinion, still
fails to address many issues.
As the Namibian Ministry has stated, "Sealing methods are currently
regulated through the Sea Birds and Seals Protection Act (Republic
of South Africa, Act No.46 of 1973) and the Sealing Regulations
(1976). Although this legislation is still in force in Namibia".
The Namibian sealers since 1973 to 1990, and from 1990 to 2000, are
as criminally guilty as their methods are the same as their South
African counter-parts during their sealing years 1973 - 1990. The
Wolf/Atlas Bay seal colonies are again in the diamond restricted
area. Controlled through a joint partnership with Namibian
government and De Beers, known as Namdeb since 1994. The Cape Cross
seal colony in situated in a protected Nature Reserve.
In 1983, a European Communities Directive binding on all members
states came into force. It prohibited the import of the skins, raw
or processed, of 'nursing' harp seal pups (whitecoats) and
'nursing' hooded pup seals (bluebacks) - CITES Appendix III species
(no mention is made why Cape fur seals Appendix II species was
omitted from this EU ban). In 1987 the Malouf Report findings in
the Royal Commission on Seals and Sealing states that "nursing baby
seals" should not be commercially harvested or traded in at any
stage anywhere. In 1987 the Canadian DFO introduced regulations
that banned the hunting of 'nursing' harp seal pups (whitecoats)
and 'nursing' hooded seal pups (bluebacks). Marine Mammal
Regulations now prohibit the trade, sale or barter of the fur of
these pups. Furthermore, seals cannot be harvested when they are in
breeding or birthing grounds. Although Cape fur seals have a
distribution range >from Mozambique, South Africa, Namibia to
Angola - after South Africa announced it was stopping commercial
sealing in 1990 - Namibia has remained the only country to
commercially harvest and export Cape fur seals and in particular
90% of their harvests in nursing Cape fur seal pups.
Namibia now remains the only country in the world to commercially
harvest "nursing baby seals in birthing and breeding grounds" and
the only sealing country, after Canada, Greenland, Norway and
Russia banned the practice in 1987 - to export and trade
internationally with CITES approval.
In a study done on stomach contents of the pups harvested on the
sealing colonies in Namibia (Best and Shaughnessy 1975) - only 8%
of the pups harvested contained solid food of any kind - all the
rest 92% were milking or empty.
There is a question whether this species should be commercially
traded. With 63% of the weight of pups, and 75% of the weight of
bulls, are wasted and discarded, after the skin and blubber (oil)
has been removed. Pup skins are more valuable than bull skins.
There is no economic value in adult females -hence their zero quota
for past 100 years. The carcass at 50%, has attempted to be
utilised, but not very successfully, although large amounts are
exported as meat-meal and bone-meal to the livestock and petfood
industries, mainly in South Africa. The value as mentioned, is as
low as USD$3 - USD$20 for the whole seal. Bulls genitals are
exported to the east, but it seems hardly justifiable to slaughter
a large bull for its genitals.
There are also many very real and precautionary health risks
involved. Research is lacking into exactly what accounts for the
mass die-off's from starvation in 1988, 1994, 1995,1996, 2000 and
2001. A by-symptom of distemper is starvation. Stress in these
conditions is a breeding-ground for diseases and viruses. The
increasing herds of jackals and hyenas that have been congregating
around these mainland colonies since 1940 have recently all tested
positive for distemper and jackals are known to cause at least 30%
of the rabies cases in Africa.
In a media release by the Minister in 2000, "I hope that many
Namibians will find ways to increase the contribution of seals to
food security and health in Namibia ..... to assist in this
direction I attach a recipe for several seal dishes".
In the book "For the Love of Nature" by Chris Mercer and Beverley
Pervan - describing the goings-on at the world famous Harnas Lion
Farm in Namibia. There are a number of quotes that are interesting.
Pg 87 - "We have plenty seal meat. It is only Savannah the Cheetah
who will not eat it". Pg89 - "The amount of meat that has to be
prepared .... and even seal meat from the culling exercise at Cape
Cross. The seal meat is very rich and oily and not all the animals
will eat it". Pg92 - "look at those bliksem jackals...., ignoring
the seal meat that she has put down for them. If you go to Cape
Cross, you will see plenty jackals feeding on the seal there. But
my jackals, oh no, they are too proud to eat it".
If you go back even further into the hardened lives of these first
explorers to this country, exploits which are contained in the
book, "Before Van Riebeeck" written by Major Raven-Hart - John
Jourdain in 1608 describes the following, "and having brought our
boats laden with these seals, we cut the fat from them for oil, and
the rest was thrown a good distance from the tents because of the
noysommness, which even after seven or eight days caused such a
stench that the tents had to be moved >from there, and which
neither the wolves nor other ravenous beasts would touch".
Minister's reply recently, when he stated, "If culling seals is a
problem, the solution is to eat them". Is a dangerous precedent to
set.
In 1997, one of only two concessionaires was caught attempting to
process seal meat to be sold as sausages for human consumption. The
subsequent impounding by Health Inspectors >from the Ministry of
Health or the statement made by Albert Brink of Sea Lion Products
at Cape Cross, "criticised the move by health ministry to impound
the meat, saying it was unwarranted as no health certification was
necessary".
Seals in general are known to be infected with a multitude of
viruses, diseases and parasites that seals can potentially carry,
such as Pox virus, Hepatitis, Influenza, Morbillivirus, Salmonella,
Mycobacteriosis, Staphylococcus, Clostridial, Mycotic, Candidiasis,
Sarcocystis, Toxoplasma, Lung, Stomach, Heart, and Hook worms, and
the resultant as yet, untested threats these could pose to human
health.
Is the Minister willing to risk an outbreak similar to "bird-flu"
or in this case, "Seal-Flu", for the sake of two concessionaires
who employ part-time a few unskilled workers, whose culling at best
benefits Namibian fishery by only 0.02%, or is CITES willing to be
a part of such an out-break.
Since Namibia's independence in 1990 it has maintained an annual
harvesting policy of Cape fur seals as claimed by the Minister of
Fisheries under the Constitution to be a "utilization of living
natural resources on a sustainable basis". Over 90% of the harvest
involves pups aged 7 - 9 months, in birthing and breeding colonies
who are still nursing at the age of 10 months (Ministry of
Fisheries in Namibia 2000 and 2006). In recent years the Ministry
have changed the definitions of this harvest, by at times stating
it is a cull or they are going to die anyway why not harvest them
or to reduce the population. The sustainability of which was
determined by a harvesting a maximum of 30% pups born in each
separate colony. Calculated from annual pup population surveys
conducted between 18-24 December. Sealing quotas have been awarded
for two mainland colonies Wolf/Atlas Bay and Cape Cross. Where
according to the Namibian Ministry 75% of the Namibian pup
production occurs. Sealing season until 2001, ran from August 1 to
November 15, thereafter it was lengthened to July 1. Sealing quotas
have risen steadily from 9 790 pups on a pup population of 126 000
in 1990 to 85 000 pups on a pup population of 119 000 in
2006.
Namibia between 1990 - 2001 had two sealing concession holders
sharing the TAC almost 50/50. They employed between 14 - 150
unskilled, part-time workers between August and November. In 1997,
both sealing concession holders together with an unnamed foreign
partner announced they were going into a N$2.5 million seal pup
processing factory to be built at Henties Bay in Namibia. They
announced they would be seeking higher quotas to ensure a return on
their investment, and would be seeking more stability by requesting
rolling TAC's. In 2001, the Namibian Minister of Fisheries
announced 3-year rolling TAC's. The 2006 sealing quota was divided
as follows - Namibia Venison & Marine Exports 38 050 for
Wolf/Atlas Bay and Sealion Products 32 950 and Cape Cross Seals 20
000, both for Cape Cross seal colony.
Export trade income (which involved 100% of the harvest) between
1998 and 2000, was N$3.9 million to N$600 000 respectively ( USD
$650 000 and USD $100 000). Although the quota was doubled in 2000
to 60 000 pups. Income per pup between 1999-2000, dropped 90% from
N$139 to N$14 - (USD $ 23 to USD $3), although the harvest
increased from 25 161 to 41 753 seals exported.
Namibia has a human population of 2.4 million and the fishing
industry is the third largest contributor to GDP. Between 1998 and
2000, Seal exports contributed to fishery exports of between 0.18%
to 0.02% respectively.
Analysis over a decade (1990 - 2000) revealed that sealers
harvested 267 450 pups on a TAC quota 403 800 - on average 66% of
the TAC quota. International trade or exports of seal pup skins was
291 488 - or 109% of that harvested.
Since the first reported mass die-off in Namibia in 1988 were 80%
of the pups died of starvation. A number of anomalies have crept
into Namibia's sealing quotas, harvests, exports and international
trade.
Major known mass die-offs of Cape fur seals occurred in Namibia in
1994, 1995, 1996, 2000 and 2001 - whilst little scientific evidence
exists of the causes or the effects or the actual numbers involved.
The scientific research findings of Dr Jean Paul-Roux, head of the
Marine Mammal Section at the Namibian Ministry of Fisheries into
the mass die-off's (1994-1996), which was by no means was the
largest such incident on record, and released publicly in 1998,
provides useful insight, into how these events could have effected
the seals in the other less researched incidents - and preceding
years growth.
Dr Jean-Paul Roux wrote, "The seal population was affected quite
drastically by those events. From January 1994, pup growth was very
low due to lack of prey available to the lactating females. The
pups were loosing weight in March and pup mortality increased. By
July 1994 researchers of the Marine Mammal Section estimated that
less than 5% of the 200 000 strong 1993/94 cohort would survive to
the weaning stage. In mid-June the average mass of the few
surviving pups was just over 8,6 kg nearly 5 kg less than the
average for the previous seven years. At the same time thousands of
emanciated adults were washed ashore in an unprecedented mass
starvation (this statement seems absurd as these mainlands are
these seals colonies why would they leave and then 'wash ashore' as
opposed to simply dying in the colonies). Adult mortality seemed to
peak during mid-winter but continued until the end of October
(sealing season). Both sexes and all age groups were affected. An
estimated 300 000 seals died during 1994, nearly a third of the
total population. From August to November 1994, the body conditions
of the remaining adult females had deteriorated badly and abortions
were wide-spread. Researchers estimated that around 40 000 females
aborted during this period at Cape Cross alone. There was no
improvement during the following breeding season. Sixty per cent
less pups were born in Namibian colonies than during the preceding
years. This low birth rate was attributed to adult mortality,
abortions and the undersized pups due to poor condition of mothers
during pregnancy. The early pup mortality was the highest recorded
since 1987. Many of the adults who survived in the breeding
colonies were in poor body condition. Pup growth was again very
poor during most of 1995. In the northern most colonies, adults did
not show signs of recovery before July 1995. At the end of winter
many adult females aborted again. The Namibian seal population is
estimated to have been reduced by between one third and one half.
This includes a 40% drop in the foraging population and the
breeding stock since 1993 and the near total eradication of two
chorts of pups".

In 1994 well aware that all the pups
(100%) were dying. Namibia increased its pup quota from 50 850 to
56 000. Sealers then harvest 32 545 pups or 58% of TAC. Exported
with CITES approval 43 547 skins - 33% more skins than harvested.
In 1995 well aware that again 100% of the cohorts had failed.
Namibia reduced the pup quota from 56 000 to 17 450. Sealers then
harvested 18 260 - 5% more. Exported with CITES approval 37 019
skins - 102% more skins than harvested or their TAC quota. In 1996
aware that conditions were similar. Namibia increased the pup quota
from 17 450 to 20 500. Sealers then harvested 15 378 pups or 75% of
TAC. Exported with CITES approval 42 611 skins - 177% more skins
than harvested.
In the period between 1993 and 1997. Pup TAC quotas were 174 800.
Sealers harvested 124 916 pups or 71% of TAC. Exported with CITES
approval 197 599 skins - 58% more skins than harvested.
The question to answer in all this, if two cohorts of pups died in
1994 and 1995 - where did the CITES approved exports of 197 599 pup
skins come from? Is it suggested that under the Namibian
Constitution of "sustainable utilization of living natural
resources" or under CITES " non detrimental exports of the survival
of the species" - that sealers killed over 197 000 pups that 'were
barely still alive at the time of harvest' - which resulted in
every pup being killed?
The sealing regulations for "pups" state - a pup, means a seal in
its first year of life. In 1998 Dr Jean-Paul Roux of the Namibian
Ministry of Fisheries reported that the average weight of a "pup"
over the last seven years was 13,6 kg (around the time of the
harvest). On the, 16th August 2005, Sapanet ANC newsbriefing
reveals - "Sea Lion products manager at the reserve, Philipp
Metzger, said pups culled so far this year had 20kg to 25kg less
blubber than normal. "It's not enough for them (weened pups) [this
statement is nonsense as pups only stop nursing after 10 months
(Sept/Oct/Nov)] to go swimming far.Fifty per cent of the seals are
in good condition. The rest are poor or very poor. They can't
survive this year as well." Last year about 500,000 seals died of
starvation on the Namibian coastline".
Clearly therefore "pups culled" weighing on average 13,6 kg - could
not possible have 20-25 kg less blubber than normal - unless these
sealers are slaughtering seals and not pups. A violation of their
sealing regulation. As apparently from their statement "normal"
this practice is widespread over the years. This would further mean
that sealing exports were in violation of CITES - "as an export
permit may be issued only if the specimen was legally obtained".
There is additional video-taped evidence between 1993 - 2000, that
this practice was widespread to fill quotas. In 2000, a television
program broadcast in 44 African countries, showed undercover
footage of sealers randomly clubbing all age groups of seals. (see
attached media article)


clubbing of seals who are clearly not "pups" between 1993 - 2000
(contravention of sealing regulations)
In 2000 Namibia doubles the sealing quota for pups from 35 000 to
60 000 - an increase of 71%. Whilst still regulating sealing under
the (South African) Sea Birds and Seals Protection Act of 1973 -
(as Namibia only incorporated seals into the Marine Resources Act
on the 27th December 2000 and into the regulations on 7th December
2001). Sealing season went ahead, and one month after it ended on
the 14th December 2000 - Namibian Ministry of Fisheries released
the following press release, "Dead Seals on Beaches - The
phenomenon reminds of the seal die-off seen in 1994 and the cause
is in fact the same as in 1994. The recurrence of a starvation
event only four years after the 1994 disaster however clearly
invites the question as to whether the seals have not reached
numbers that outstrip the carrying capacity of the present
environment".
Seal Alert-SA is aware of two Namibian Marine Scientists who
critised Namibia's pup and bull harvest quotas - and were given
24-hours to leave Namibia.
Between 1973 - 1990 in South Africa, sealing was conducted at
kleinsee, within the diamond restricted area. Where public access
is restricted, and no cellphones or camera's are allowed into the
area. Likewise at Wolf/Atlas Bay between 1973 - 2006 access is also
restricted, it being a diamond restricted area. At Cape Cross or
any of the sealing colonies, filming is not allowed during the
harvest. In addition as confirmed by a reporter from a Namibian
newspaper, a few days ago - guards patrol Cape Cross seal colony
with guns and rifles and access is strictly forbidden during
sealing operations. Executive Producer of the Namibian State run
Namibian Broadcasting Television program Current Affairs -
confirmed in an email that he has been the first reporter allowed
in to film, in many years.
Over the years and as recently as a few days ago - Namibian sealers
have stated, "we farm sheep and cattle, so why not harvest seals".
Thereby suggesting that their concept of sealing is not harvesting
'wildlife', but instead farming a 'species bred simply for
harvesting'.
Lets explore this concept a little. It costs a little over R4000 in
feed costs alone and over 2000 hours to bring a pup to harvesting
age. Even in a rescue sense, no ownership can be claimed or
exploitation rights, yet Namibian sealers incur none of these costs
but lay claim to being "seal farmers" - can come along wait for
nature to grow this pup and club it to death and sell its skin for
US $3 - and then claim he is a "Seal Farmer". If he had even half
the costs incurred in a seal rehabilitation sense, how much would
he have to sell each skin for ??? R2000, R4000 or R6000 instead of
just $3. Why should he profit on these terms ? If he had the market
for 85 000 skins (as he wanted the increased quota), would he be so
keen to feed 85 000 seals a R4000 each to bring them to "market"
and sell them for $3 - how long would he stay in the seal farming
business in this way.
There is another issue to consider. Not even livestock farmers
slaughter their new-born young - as they will clearly go out of
business. Yet, CITES on a Appendix II endangered species - permits
the international trade of this method and species?


diamond restricted areas in South Africa and Namibia
De Beers, the largest contributor to Namibia's GDP and the world's
largest gem diamond producer in July 2006, sent an official letter
to Seal Alert-SA saying "they were completely opposed to seal
culling" (CITES has a copy).
Two days later after Namibia announced it had experienced its
largest die-off of seals in 2000, on the 16th December 2000 (start
of next seasons pupping season), the Weekend Argus carries a report
which states, "90 000 pups have already in their first month of
birth washed up on Namibia's beaches" - a second major mass die-off
in two years, and the 5th such disaster in just the last 6
years.
In 2000 with a newly increased quota to 60 000 pups. Sealers
harvest 41 753 - or 69% of their TAC. Exported with CITES approval
48 686 - 16% more than that harvested. (If Namibia suffered its
largest mass die-off from starvation - where did the 48 686
exported skins come from pups or older seals?)
On the 10th February 2000, Minister Iyambo signs a document which
states - "information on the levels of seal harvest is freely
available, and is made public each year. The allowable harvests set
since 1993 have been as follows" - (Seal Alert-SA note : there is a
huge difference between a "sustainable TAC" set prior to the start
of a sealing season, and the actual number of seals harvested
thereafter three months later).
At the CITES 20th Animals Committee Meeting in 2004 to "Review the
Significant Trade" of Namibia with regard to seal exports - a
report prepared by TRAFFIC and the IUCN/SSC Wildlife Trade Program
quote and lists a "table of harvest quotas" supplied by the
Wildlife Society of Namibia (2001). When comparing this to the
figures stated by the Minister, Wildlife Society of Namibia and
TRAFFIC - the mismanagement here is only too apparent. (See
Below).
In 1994 - TAC was 43 000. Namibian Wildlife Society reports - 50
850. CITES states 43 547 skins were exported. In 1995 - TAC was 37
019. Namibian Wildlife Society reports 17 450. CITES states 37 019.
In 1996 - TAC was 17 000. Namibian Wildlife Society reports - 20
500. CITES states 42 611. In 1997 - TAC was 26 000. Namibian
Wildlife Society reports - 30 000. CITES states 29 950.
Acceding to Sealers demands on the 14th June 2001, the Minister of
Fisheries lengthens the sealing season by one month to now start
July 1 and issues a 3-year rolling TAC on this newly doubled
sealing quota of 60 000.
There is a very real scientific concern here, if the harvest of
these seals - has not been detrimental to its survival, and sealing
TAC's are set at sustainable levels - why have sealers consistently
only be able to harvest 68% of their TAC. Unlike the Canadian Seal
Hunt where ice floes and weather play a part in reducing or
delaying the harvest, none of these "weather" factors are present
on the dry desert coastline of Namibia. If with a lengthened
sealing season, sealers have not improved their harvested
percentages on their TAC's.
In 2002, on a 60 000 TAC quota Namibia exports 117 409 skins.
According to the report of the 20th Meeting of the CITES Animals
Committee in 2004, to report on the "Review of Significant Trade"
of Namibia. CITES ends its report with, "Exports of sealskins from
Namibia dipped to a few thousand skins per year in 1998 and 1999
(Seal Alert-SA evidence - 54 636, hardly a few thousand), increased
to over 40 000 skins in 2000, dropped to 20 000 in 2001, then
quadrupled to over 112 000 skins in 2002. Namibia has not notified
the CITES Secretariat of an export quota for this taxon. An
explanation from Namibia regarding the large increase in exports in
2002 would assist the Animals Committee in determining whether or
not this species should be selected for a Review of Significant
Trade.

As can be seen from the table above,
between 2001 and 1992 - the Cape fur seal population in Namibia
have declined by almost 50%. This was confirmed in Dr Jeremy
David's report on the "population status of the southern African
fur seals" during a IFAW hosted seal workshop in March 2003. Where
he stated, "the 2001 surveys had estimated that the Namibian pup
population was 110 000".
This is below the population level last seen in 1979, just 7 years
before the first known population survey.
By using a factor of 4.19 as used above extrapolation of the pups
on each colony can be determined. For the sealing colonies at
Wolf/Atlas Bay and Cape Cross we see that the total pup production
in 2001 - 70 939. Namibia issued a 60 000 sealing quota - or 84% of
the pup population (ignoring his own policy that harvests should
not exceed 30%). It is unknown how many seals sealers harvested,
but CITES records reflect 20 654 skins were exported - or 34% of
the TAC quota.
In 2002, Namibia on a 60 000 TAC quota exported without CITES
approval 117 409 skins. Hence the 20th Meeting of CITES Animals
Committee in 2004 and its Review of Namibia's Significant Trade in
Seals.
In 2002, US NOAA Fishery officials seized 5000 raw Cape fur seal
skins illegally imported from Namibia on the 24th June, (one month
prior to the start of sealing season)?
In 2003, South African arrested, charged and convicted a South
African who imported two separate batches of 135 and 30 Cape fur
seal skins, illegally from A Brink in Namibia, a sealer.
In 2003, Mark Radermacher of Duck Valley International in George -
South Africa, advertises Cape fur seal skins for USD $20 on his
website (see attached).
In 2003, Francois Hugo of Seal Alert-SA answered an ad to buy a PC.
The seller, Will Carter of Staghorn Scottish Outfitting & Hire
in Plumstead - South Africa, staghorn@iafrica.com , unaware of who I was -
proudly showed me his workshop where he was manufacturing Scottish
'sporran' purses from Cape fur seal skins. He informed me he was
importing tons cheaply and was making millions re-exporting them to
Scotland. I informed the SA authorities and have heard nothing
since, except to see that this concern closed up shop and
disappeared.
Although South Africa in 1990 stopped the commercial harvesting of
Cape Fur seals - According to the CITES Animals Committee Review -
South Africa exported 6000 skins in 1992, 5 500 skins in 1996, 50
skins in 2000 and 409 skins in 2001.
In 2004, a Dutch newspaper reported that whilst the EU banned the
import of CITES Appendix III "nursing baby seals in birthing and
breeding grounds". The EU imported 1.2 million Euros worth of
Appendix II "nursing baby Cape fur seals in birthing and breeding
grounds" - which would involve a minimum of 80 000 seal skin
imports into one country. Once again Namibia's total Sealing TAC
quota for 2004 was 60 000.
In December 2005, Mr W Burger of Namibian Venison & Marine
Exports admitted on video camera that he was regularly exporting
skins and tons of carcass meal to the South African livestock and
pet-food industries. (There are no CITES export permits for these
products between 1992 - 2002)
As far as Seal Alert-SA can determine the conservation status has
not been properly assessed since 1990 - some 16 years ago.
Considering that population surveys only go back to 1972. 40% of
this species conservation period has not been properly assessed, if
at all.
In the CITES January 2004 - Review of Significant Trade - Analysis
of Trade Trends:
It contains conservation comments primarily from a website of the
Seal Conservation Society (based in the UK) - 2001, (which is no
longer operational, and which this information is extremely poor)
(for a detailed CITES 'Trade Analysis'). The CITES enclosed chart
lists no real exports, otherthan skins - when every part of this
species requires an export permit in this 100% internationally
traded wildlife industry - such as genitals, carcases, oil, meal
etc. It ends with a Comment : "recommended for a review to
determine sustainability of trade" - based on the export in 2002 of
117 400 skins on a sealing quota of 60 000.
In the CITES 20th Meeting of the Animals Committee - Review of
Significant Trade - in April 2004:(three months later)
In its conservation status report prepared by TRAFFIC and IUCN/SSC
(world conservation union - headed by former Minister of South
Africa Valli Moosa) it contains information, as pointed out in my
email dated 10th August, Trade in Seals, that it is in fact
scientifically false and a complete misrepresentation of the facts.
As pointed out in the publicly available scientific findings of Dr
Jean-Paul Roux, head of Namibian Fisheries Ministry for Mammals in
1998 - that the allegation must be that this report is or has been
"fraudulently prepared" - what other excuse is there? Particularly
the release of Dr Burger Oelofsen's press release in 2000, and the
complete omission of the information contained therein. The review
ends - "Namibia has not notified the CITES Secretariat of an export
quota for this taxon. An explanation from Namibia regarding the
large increase in exports in 2002 would assist the Animals
Committee in determining whether or not this species should be
selected for a Review of Significant Trade".
The "Terms of Reference" of the Advisory Committee on the
Commission on Sealing in 1990 - South Africa - was, "To investigate
and report on the scientific basis for harvesting seals as a
renewable marine resource on a sustainable basis"; "To investigate
and report on the scientific basis for culling as a method to
reducing the seal population"; "To make recommendations for future
research" and "To review and report on the cruelty aspects of
culling".
Almost none of the issues raised above were ever addressed and Seal
Alert-SA was not established at the time of the Commission.
Although reference is made to the EU directive banning imports of
"nursing pups in birthing and breeding grounds" since 1983 and in
1985, and specifically to the Canadian Royal Commission on Seals
and Sealing in 1986 findings and report. South African scientists
although well aware that 90% of the harvests or culls involved
"nursing baby seals in birthing and breeding grounds - simple
ignored all the 'conservation realities' involved with these
sealing methods that were detrimental to the future survival of
this species.
One of the recommendations of the Commission was never adopted -
"As there is no evident biological basis to distinguish "Namibian"
and the "South African" seals and there is no evidence that there
is more than one seal population in southern Africa - it is
recommended that the Minister gives priority attention to liaison
with the relevant authorities in Namibia with a view to the
possible implementation of a unified policy for seal
management".
At this point the following needs to be considered. The CITES
Secretariat monitors the implementation of the Convention in its
169 Parties (reviewing legislation, levels of trade, illegal trade,
annual reports, etc) but Namibia has not been identify as a
priority country for attention under the different mechanisms
established by the Conference of the Parties. Accordingly, the
CITES bodies has not adopted any decision recommending a suspension
of commercial trade in specimens of CITES-listed species with that
country".
o In light of the substantial violations, allegations and evidence
contained above - it would seem appropriate that a "suspension of
commercial trade of all specimens of CITES-listed species with
Namibia" is adopted.
o In light of the substantial violations, allegations and evidence
contained above - it would seem appropriate that similar
suspensions are adopted for South Africa.
With the Namibian Minister's confirmation that the Namibian seal
population in 2006, was lower than the population in 1982 and 27%
lower than pre-1993. The quota of 85 000 pups and 5000 bulls,
Namibia's highest on record - a 68% increase over the sealing TAC
in 1994. After the population had experienced mass die-off's in
1988, 1994, 1995, 1996, 2000 and 2001. Needs urgent review.
Considering this quota does not subscribe to the scientifically set
harvest of a maximum of 30% - 35 000, and taking into account the
natural mortality experienced by this species of 25-32% from birth
- will see a total chort extermination of this years pups.
In the first sealing decade after Namibia's independence - the
Namibian seal population has declined by 50%.
As mentioned "detrimental trade" or "sustainable harvests" should
not only consider "pup populations between 18-24th December" as
their corner-stone of this species conservation status and trends.
Habitats, current and former are just as important - particularly
if there is already widespread extinction of these colonies
already. In the case of this species 98% has been lost and is now
extinct.
Based on the evolutionary cycle and known scientific fact of this
species distribution - Cape fur seals should be displaced as
follows. Based on the geographic size and location of islands along
the distribution range of Cape fur seals. The species if healthy
and in effective conservation management, should be located as
follows; 4% east coast, 85% Cape west coast and 11% in
Namibia.
Population surveys and trends have been extremely difficult to
access. Seal Alert-SA acquired an official set of colony by colony
pup surveys for the period 1972 to 1997. However more recent
surveys have been impossible to acquire. Except for some Namibian
population figures in 2000, 2001 and some data for 2004 and the
Minister confirmation in 2006 of the population.
Based on the peak of the population in 1993 of 300 000 pups - if
seals were allowed to naturally be distributed we would see;
o East Coast - 12 000 pups or 4% . Instead we find, 30 602 pups
breeding on 0,6%. Representing (42% of the islands populations of
seals).
o Cape West Coast - 255 000 pups or 85%. Instead we find, 6 170
pups breeding on 0,2%. Representing (8,5% of the islands
populations of seals).
o Namibia - 33 000 pups or 11%. Instead we find, 35 262 breeding on
0,7%. Representing (49,5% of the islands populations of
seals).
+ Overall - 23% of the seal population breeding on 18.3 ha (<2%)
of the 1 099 ha available on islands and on 17 out of 46 islands or
37%.
73% of the seal population is now breeding on 7 mainland
colonies.

From the chart above. As supplied by Dr
CJ Augustyn, Chief Director : Research, Antarctica and Islands
(MCM) Department of Environmental Affairs and Tourism - South
Africa, in May 2006. Presents a serious decline across the seal
population when comparing 2004 - 1997.
o
Total Population is down -14%.
o
Total Population in Namibia is down - 6%.
o
Total Population in South Africa is down - 24%.
o
All Mainland colonies are down - 33%.
o
Mainland Colonies in South Africa is down - 39%
o
Mainland Colonies in Namibia is down - 29%
o
Island Colonies in Namibia is 23% below the population first
surveyed in 1972.
Considering the significant harvest by foreign fishing fleets in
Namibian waters - where in 1968 the catch for pilchards was 1.387
million tons, before declining to 25 000 tons or 3% within a
decade, and in 2002 the quota was zero. With Namibian fleets facing
collapse requesting South Africa if it could fish in our
waters.
That the Cape fur seal population would naturally migrate towards
Namibia and onto the mainland, and grow from 0 pups in 1940 to 230
000 pups in 2006 or 83% of the total population. With intensive
sustained annual escalating sealing or culls - where over 2 million
seals were harvested.

On the 27th December 2000, Namibian incorporated the Cape fur seals
into its Marine Resources Act, and as such is seen as a
'harvestable marine resource' if one considers the TAC fishing
chart above for two of the most commercially valuable fish species
in Namibia, worth 2.639 billion Namibian dollars or 93% of
fisheries TAC. Namibia's management of this 'resource' over the
past decade, presents serious concerns for the "non detrimental or
survival" of the Cape fur seal species.
o
Hake - Even though the biomass was declining, its most important
valuable resource. Fishery Minister set increasing TAC's above what
the fishing industry could catch.
o
Pilchards - Even though the biomass dived sharply, its second most
valuable resource. Fishery Minister set increasing TAC's and
allowed the fishing industry to far exceed these set TAC's.
If this management approach is being applied the annual harvest of
seals it will be "detrimental to the survival of the species",
which with a 100% chort pup quota - clearly it is.

The chart above illustrates - SE Coast
SA colonies already extinct since 1972. SW Coast SA colonies with
no growth or decline since 1972. The Orange or Central/South
Namibia is where sealing currently occurs, and it indicates the
"disturbance and fleeing" factor caused by sealing activities -
causing seals to migrate south and north increasingly.

The above chart (supplied by Dr S
Kirkman Scientist for MCM/IFAW) shows the clear imbalances caused
by sealing on the mainland between 1972 - 2004. It is important to
note that - prior to 1940 - all seal populations originated from
one (island population of seals), whose remnants since 1972 have
declined.
Since the Sea Birds and Seals Protection Act of 1973, CITES
Management Authorities in South Africa and Namibia, whilst
exporting and trading in the "legally obtained and non detrimental
survival of seals" engaged in consist programs of banning seals
from all historical former island breeding habitats, through
physical shooing and shooting of any seals on any island larger
than 3 ha - therefore ensuring that the 20 of the 23 former island
colonies of seals remained extinct. The following major islands,
listed under the act, as protected island habitats have been
identified;
o
Robben (Seal) Island - the largest island in southern Africa, whose
land surface area accounts for over 57% of all the island's land
was involved in shooing, shooting and banning of seals. Since 1999
it has been a UNESCO World Heritage Site.
o
Dassen Island - the second largest, whose land surface area
accounts for over 27%, has been involved in shooing, shooting and
banning of seals.
o
Bird, Seal, Stag and the Islands of St Croix in Algoa Bay - on our
east coast, formerly known as the "Bay of Seals" has conducted
similar illegal practices. In the last few years the population of
seals has become extinct (See Dr Stewardson's 2002 report)
o
Dyer Island - has maintained similar practices.
o
The Saldanha Bay group of Islands, known as Jutten, Marcus, Malgas,
Meeuwen, Schaapen, Vondeling - have all banned seals from this
UNESCO World Biodiversity region. In 1998 and since, South African
management officials have resorted to shooting bull seals in the
surrounding island waters in order to keep seals illegally off
these islands.
o
Penguin Island in Lamberts Bay - has recently been in the news,
where South African management officials have asked the Minister of
the Department of Environmental Affairs and Tourism for annual
funding to hire full-time seal shooting marksman and professional
'seal shooing' individuals to keep seals off the island.

o
Ichaboe Island in Namibia - a major seal breeding colony, and later
a sealing station, which once held a pup production exceeding 50
000. Has been completely walled and has full-time staff banning
seals from this island, which remains extinct to seals.
o
Mercury Island - a major former seal breeding colony was extinct.
In the early 1980's seal began recolonising the island. In 1985,
the island recorded a pup production of 3 606 pups. During the
Commission on Sealing in 1990, it was recommended to the Minister,
"that the seal disturbance program on Mercury Island be continued".
In 1996 the last 158 pups were recorded on the island, since then
the island has become extinct to seals.
As South African and Namibian Management Authorities have
maintained the extinction on 20 of the 23 former major seal
breeding island colonies, by restricting seals to 2%, whilst
ensuring 98% of the island surface area remains banned - all
exported trade since 1977 has been detrimental to the survival of
the species - a CITES violation. Having caused the direct
extinction of the eastern most seal colony and the extinction of
the most northern island colony in 1996 - and as all island
populations of seals are the lowest on record - all trade involving
millions of exported seal skins and products has been detrimental
and a threat to the future survival of this species.
In the words of the Department of Agriculture, Conservation,
Environment and Land Affairs, Gauteng Provincial Government and
those of the Department of Environmental Affairs and Tourism -
South Africa, on the criminal conviction of a South African
importer who illegally imported two consignments of 135 and 30
illegal seal skins, respectively from Namibia in 2003 - "The
wildlife trade is a major source of revenue and the illegal trade
is regarded as a threat to the country's economy. If South Africa
can be identified by CITES as allowing such activities to happen,
there is a risk that the country will be banned by the Convention
from carrying on the trade. Consequently, other countries may even
be prevented from trading with South Africa" and in the words of
NOAA Fisheries Law Enforcement, "Illegal trade in endangered or
threatened wildlife continues to be a problem that NOAA fisheries
takes seriously. Seizures like this should be a warning sign to
others who traffic in marine mammal parts".
The South African and Namibian Management Authorities clearly have
a lot to answer for, considering all this illegal trade since 1972
in which millions of seal skins and seal products were illegally
traded and exported in violation of CITES Convention.

East Coast Seal
Colonies of Southern Africa
1 ha - Black Rocks. PP - 1702 - 142
(Declined) -[the circled rock in red is black rock see below
pic]

14 ha - Bird Island. PP - 0
(extinct)
2 ha - Seal Island. PP - 0 (extinct)
NO PICTURE
1 ha - Stag Island. PP - 0 (extinct)
NO PICTURE
0.8 ha - Seal Island
- Mossel Bay. PP - 3234 - 691
(declined)

1 ha - Quoin Rock. PP - 3744 - 1779
(declined)

20 ha - Dyer Island. PP - 0 (extinct)
*
3 ha - Geyser Island. PP - 2679 - 11 184
*

2 ha - Seal Island - False Bay. PP - 14 449 - 16 806
*
0.2 ha - Duiker Klip - Hout Bay. PP (never surveyed)
*
West Coast Seal
Colonies of Southern Africa

Block B : See above (including Robben
'Seal' Island) out of pic at the bottom is responsible for 85% of
the Island surface area
off Southern African Coastline - the distribution range of the Cape
fur seals
* 576 ha - Robben
(Seal) Island - PP - 0 (extinct)
*
0.1 ha - Robbesteen - PP - 2425 - 1155 (declined)
*
273 ha - Dassen
Island. PP - 0 (extinct)

21 ha - Vondeling
Island. PP - 0 (extinct)
*
46 ha - Jutten
Island. PP - 0 (extinct)
NO PICTURE
11 ha - Marcus
Island. PP - 0 (extinct)
*
8.3 ha - Malgas
Island. PP - 0 (extinct)

0.3 ha - Jacobs Rock. PP - 4804 - 1650 (declined)
*
*
2 ha - Paternoster Rocks. PP - 758 - 1200
*
2 ha - Penguin Island - Lamberts Bay. PP - (unknown) *
*
0.2 ha - Elephant Rock. PP - 2494 - 2165 (declined)
NO PICTURE
Northern Cape and
Namibian West Coast Seal Colonies
NO PICTURE
Mainland - Kleinsee. PP - 30 429 - 87 841
*
*
3.2 ha - Sinclair Island. PP - 15 771 - 10 771 (declined)
*
NO PICTURE
Mainland - Lions Head. PP - 2767 - 8 308
*
NO PICTURE
0.1 ha - Albatross Rock. PP - 3 719 - 2 785 (declined)
*
NO PICTURE
Mainland (sealing colony) - Atlas Bay. PP - 8 873 - 46
225
*

90 ha - Possession
Island. PP - 0 (extinct)
*

2 ha - Long Island. PP - 12 219 - 14 835
NO PICTURE
Mainland (Sealing
Colony) - Wolf Bay. PP - 7 436 - 36 700
*

0.1 ha - Dumfudgeon Rock. PP - 2 873 - 465 (declined)
*
0.1 ha - Boat Bay Rock. PP - 1 680 - 883 (declined)
*
*
0.1 ha - Staple Rock. PP - 2 908 - 1 899 (declined)
*
*
0.1 ha - Marshall Reef. PP - 755 - 146 (declined)
*
*
2 ha - Hollamsbird Island. PP - 5 039 - 3 478 (declined)
*
*
Mainland - Pelican Point. PP - (Not in Official Surveys)

1 ha - Penguin Island. PP - 0 (extinct)
*
*
7 ha - Seal Island. PP - 0 (extinct)
*
*
6.5 ha - Ichaboe
Island. PP - 0 (extinct)

3 ha - Mercury
Island. PP - 3 606 - 0 (extinct)
*
Mainland - Dolphin Head. PP - (Not in Official Surveys)

Mainland
(sealing colony) - Cape Cross. PP - 19 738 - 48 993
*
Mainland - Cape Frio. PP - 477 - 7 191
*
For the Seals
Francois Hugo Seal Alert-SA















































