Special Request CITES - Distribution of Cape fur Seals Southern Africa
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.

Total Population is down -14%.
Total Population in Namibia is down - 6%.
Total Population in South Africa is down - 24%.
All Mainland colonies are down - 33%.
Mainland Colonies in South Africa is down - 39%
Mainland Colonies in Namibia is down - 29%
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.

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.
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;

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.
Dassen Island - the second largest, whose land surface area accounts for over 27%, has been involved in shooing, shooting and banning of seals.
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)
Dyer Island - has maintained similar practices.
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.
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.

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.
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)

1 ha - Stag Island. PP - 0 (extinct)
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)
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)

Northern Cape and Namibian West Coast Seal Colonies

Mainland - Kleinsee. PP - 30 429 - 87 841

* *
3.2 ha - Sinclair Island. PP - 15 771 - 10 771 (declined)


Mainland - Lions Head. PP - 2767 - 8 308


0.1 ha - Albatross Rock. PP - 3 719 - 2 785 (declined)


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

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