dau gia , the gioi smartphone , download game mobile , smartphone , tang truong , khoa hoc cong nghe thong cong , mua ban sim , Smartphone gia re , cong nghe tuong lai , cong nghe 360 , giai tri guongmat.org , su kien trong ngay , thoi trang hi tech , thong tin 360 , may tinh bang , perfect body , kasuman.com , gia vang hom nay , tin tuc an toan , kinh te viet nam , xay dung viet nam , thoi trang , thoi trang , phu nu viet nam , tin tuc moi online , dich vu bao ve viet nam , bao ve viet nam , cong ty bao ve viet nam , tin tuc moi online , giai tri 24h , tin tuc 24h

An Update From Feike

Please accept my apologies for temporarily abandoning our blog postings. As readers, clients and followers of the Blog are no doubt aware, I have been appointed to advise South Africa's Fisheries Minister on the administrative appeals lodged against decisions taken during the 2013 Fishing Rights Allocation Process (FRAP).

I am part of a 3-person advisory team, which includes an attorney - Ms Mamakhe Mdluli - and Prof Julian Smith, who served as Vice Rector of Stellenbosch University.

Since having commenced our brief to advise on the appeals that have been submitted, it became apparent that appellants were entitled to access a number of records and documents to which they had not had prior sight of in order to lodge proper appeals. Access to these records is presently being provided and appellants have been given until 16h00 on 31 July 2015 to supplement the appeals they had lodged in early 2014.

In addition, the Minister is presently engaging with the SA Commercial Linefishers Asscociation (SACLA) on a proposed settlement to the current review application brought by SACLA on behalf of traditional line fishers, which is presently before the Western Cape High Court. The review application is set down for hearing on 25 August 2015.


An Update From Feike

Please accept my apologies for temporarily abandoning our blog postings. As readers, clients and followers of the Blog are no doubt aware, I have been appointed to advise South Africa's Fisheries Minister on the administrative appeals lodged against decisions taken during the 2013 Fishing Rights Allocation Process (FRAP).

I am part of a 3-person advisory team, which includes an attorney - Ms Mamakhe Mdluli - and Prof Julian Smith, who served as Vice Rector of Stellenbosch University.

Since having commenced our brief to advise on the appeals that have been submitted, it became apparent that appellants were entitled to access a number of records and documents to which they had not had prior sight of in order to lodge proper appeals. Access to these records is presently being provided and appellants have been given until 16h00 on 31 July 2015 to supplement the appeals they had lodged in early 2014.

In addition, the Minister is presently engaging with the SA Commercial Linefishers Asscociation (SACLA) on a proposed settlement to the current review application brought by SACLA on behalf of traditional line fishers, which is presently before the Western Cape High Court. The review application is set down for hearing on 25 August 2015.


2015 KZN Beach Seine Fishery Shows Promise

The prospects for the 2015 KwaZulu-Natal beach seine fishery are looking very promising. The KZN beach seine fishery is a tiny small-scale commercial fishery comprising 24 quota holders. Their 10-year fishing rights are set to expire on 29 February 2016.

The Fisheries Department is currently preparing for the re-allocation of fishing rights in this sector, as well as in 9 other commercial and small-scale commercial fisheries.

The fishery is completely dependent on the annual sardine run - also known as the "Greatest Shoal on Earth" - and sardine shoals coming sufficiently close to shore to be harvested by the crate load.

Quota holders were achieving good prices as at yesterday of R800 / crate. Each crate carries 40kg of sardines.

2015 KZN Beach Seine Fishery Shows Promise

The prospects for the 2015 KwaZulu-Natal beach seine fishery are looking very promising. The KZN beach seine fishery is a tiny small-scale commercial fishery comprising 24 quota holders. Their 10-year fishing rights are set to expire on 29 February 2016.

The Fisheries Department is currently preparing for the re-allocation of fishing rights in this sector, as well as in 9 other commercial and small-scale commercial fisheries.

The fishery is completely dependent on the annual sardine run - also known as the "Greatest Shoal on Earth" - and sardine shoals coming sufficiently close to shore to be harvested by the crate load.

Quota holders were achieving good prices as at yesterday of R800 / crate. Each crate carries 40kg of sardines.

DAFF Press Statement on FRAP 2013 Appeals

On 17 April 2015, the Fisheries Department (DAFF) issued a press statement confirming that the Fisheries Minister is set to process all appeals lodged against decisions taken in terms of the 2013 Fishing Rights Allocation Process, except for those appeals lodged in the traditional line fish sector. The line fish appeals cannot be considered in light of a current court order authorising all long term line fish right holders (as at 31 December 2013) to continue to operate until such time as the judicial review application is finally decided.

However, with respect to the appeals lodged in the remaining 7 sectors, including Hake Handline, Oysters, Mussels, KZN Prawn Trawl, Demersal Shark, Tuna Pole and Squid, appellants must note the following:

1. The Harris Nupen Molebatsi report confirmed that in so far as the appeals process is concerned, the Department’s refusal to make available all scoresheets and application forms pertaining to all other applicants in the fishery concerned is unlawful. Every appellant has a right to access these scoresheets.

2. Accordingly, appellants have a legal right to first obtain all the comparative scoresheets and any application forms and documents related to the decision-making process for that particular fishery BEFORE their respective appeals may be considered. As such, appellants must immediately lodge requests for the following documents from DAFF:

2.1 Scoresheets for all applicants in the fishery concerned;

2.2 Copies of application forms and annexures submitted by all applicants in the fishery concerned. Access can be provided by allowing appellants the right to view applications at DAFF’s offices;

2.3 Any other documents used during the decision-making process, such as databases, records of right holder catch returns, levy payments and so forth.

3. Once the appellant is provided with the requested documents, and even though the applicant may have lodged an appeal in 2014, the appellant has the right to supplement its appeal based on the additional documents provided.

4. Until all appellants are provided with the above requested documents and an appropriately determined revised appeal deadline date is provided by the Minister, no appeal can lawfully be considered and decided.

5. Key grounds of appeal that should be raised are the rational and lawful basis for setting aside the number of rights for appeals by the Acting DDG in December 2013, the legal basis upon which new entrants were permitted into the fishery, the failure to exclude applicants that failed to comply with exclusionary criteria such as the requirement to prove access to a suitable fishing vessel, the rationality for using certain criteria as “balancing” criteria and not scoring important criteria such as “investments in vessels and infrastructure", "reliance on the resource", "local economic development" and proximity of the applicant’s domicile to the applicable fishing grounds. These were all serious, if not fatal flaws, that were identified by the findings of the Harris Molebatsi Report.

6. Finally, there are numerous other findings in the Harris Molebatsi and Emang Basedi Reports concerning the 2013 FRAP process that cannot be cured by an administrative appeal process. These include an unlawful consultation process that preceded the allocation process, the fact that the application forms do not speak to the various fishing policies and criteria and the allegations of maladministration and possible corruption during the fishing rights allocation process.

DAFF's press statement can be viewed here.

DAFF Press Statement on FRAP 2013 Appeals

On 17 April 2015, the Fisheries Department (DAFF) issued a press statement confirming that the Fisheries Minister is set to process all appeals lodged against decisions taken in terms of the 2013 Fishing Rights Allocation Process, except for those appeals lodged in the traditional line fish sector. The line fish appeals cannot be considered in light of a current court order authorising all long term line fish right holders (as at 31 December 2013) to continue to operate until such time as the judicial review application is finally decided.

However, with respect to the appeals lodged in the remaining 7 sectors, including Hake Handline, Oysters, Mussels, KZN Prawn Trawl, Demersal Shark, Tuna Pole and Squid, appellants must note the following:

1. The Harris Nupen Molebatsi report confirmed that in so far as the appeals process is concerned, the Department’s refusal to make available all scoresheets and application forms pertaining to all other applicants in the fishery concerned is unlawful. Every appellant has a right to access these scoresheets.

2. Accordingly, appellants have a legal right to first obtain all the comparative scoresheets and any application forms and documents related to the decision-making process for that particular fishery BEFORE their respective appeals may be considered. As such, appellants must immediately lodge requests for the following documents from DAFF:

2.1 Scoresheets for all applicants in the fishery concerned;

2.2 Copies of application forms and annexures submitted by all applicants in the fishery concerned. Access can be provided by allowing appellants the right to view applications at DAFF’s offices;

2.3 Any other documents used during the decision-making process, such as databases, records of right holder catch returns, levy payments and so forth.

3. Once the appellant is provided with the requested documents, and even though the applicant may have lodged an appeal in 2014, the appellant has the right to supplement its appeal based on the additional documents provided.

4. Until all appellants are provided with the above requested documents and an appropriately determined revised appeal deadline date is provided by the Minister, no appeal can lawfully be considered and decided.

5. Key grounds of appeal that should be raised are the rational and lawful basis for setting aside the number of rights for appeals by the Acting DDG in December 2013, the legal basis upon which new entrants were permitted into the fishery, the failure to exclude applicants that failed to comply with exclusionary criteria such as the requirement to prove access to a suitable fishing vessel, the rationality for using certain criteria as “balancing” criteria and not scoring important criteria such as “investments in vessels and infrastructure", "reliance on the resource", "local economic development" and proximity of the applicant’s domicile to the applicable fishing grounds. These were all serious, if not fatal flaws, that were identified by the findings of the Harris Molebatsi Report.

6. Finally, there are numerous other findings in the Harris Molebatsi and Emang Basedi Reports concerning the 2013 FRAP process that cannot be cured by an administrative appeal process. These include an unlawful consultation process that preceded the allocation process, the fact that the application forms do not speak to the various fishing policies and criteria and the allegations of maladministration and possible corruption during the fishing rights allocation process.

DAFF's press statement can be viewed here.

DAFF’s Aquaculture "Concept" Bill

During March 2015, the Fisheries Department published an "Aquaculture Concept Bill" for public comment. The "concept" bill is really a very rough and incomplete draft set of ideas on fish farming regulation, which should eventually evolve into a white paper, then a draft Bill and perhaps thereafter an Act. 

However, the fact that DAFF published such a draft straw document is to be commended! This is how a government department is supposed to conceptualise and prepare complex policy ... by seeking  inputs from the public at the very conceptualisation of policy and ideas. This is what is required when preparing fishing policies and fishing rights allocation processes! 

The aquaculture concept bill is clearly a response to Government's latest big plan - Operation Phakisa - which has committed to increasing current farmed fish production levels (±3000 tons annually) to a whopping 90,000 tons within less than two decades. Coupled to this, Operation Phakisa also reckons that we will grow jobs concomitantly from the current 1900 jobs to 250,000! 

What is apparent from the concept bill is that DAFF wishes to have a stand-alone Act regulating both marine and freshwater fish farming and to "streamline" the application procedure. Currently, and in terms of the Constitution, marine resource management, including marine fish farming, is exclusively regulated by the National Government (DAFF) in terms of the Marine Living Resources Act, 18 of 1998. Fresh water fish farming is the regulatory prerogative of provincial governments. 

A copy of the concept bill is available from Feike - unfortunately a copy of the draft bill is not on the DAFF website. Our brief comments on the concept bill which were submitted to DAFF as provided below.

FEIKE'S COMMENTS ON THE "AQUACULTURE BILL CONCEPT DOCUMENT"

1.         Firstly, it is noted that the concept document is very much a draft document lacking many definitions and content under the various text headings. There are a number of definitions that require incorporation such as “antibiotics”, "fish veterinarians", “ fallowing", "anti-fouling measures", “pesticides", “pollution", “ponds", "sea cages”, "brackish water”, “fresh water”, "alien and invasive species”, "fish" etc.

2.          The concept document makes reference to section 27 of the Constitution but oddly makes no reference to the section 24 - the right to a healthy and safe environment. 

3.         The structure of the concept document does not adequately address the fact that marine based fish farming is the regulatory prerogative of the National Sphere of Government while the regulation of freshwater fish farming vests with the Provincial Sphere of Government. This distinction must be clearly defined and delineated in any Bill, failing which it would render the Bill confusing, if not unimplementable and unconstitutional. The Bill does not appear to also recognise the overarching application of the MLRA in terms of section 3 of the MLRA, which extends application of the Marine Living Resources Act to all fish which is found in waters that form part of the sea at any time. 

4.         With respect to the stated objectives of the Bill, no reference is made to the following important considerations: 
           
            4.1       Application of the precautionary principle and fish farming management in terms of the best available scientific evidence;

            4.2       The need to promote responsible trade in farmed fish and to identify key markets. This is crucial since issues of HACCP and other health certifications will apply to farmed fish destined for human consumption; 

            4.3       The farming of alien and invasive species;

            4.4       Maintaining genetic biodiversity of indigenous fish species and health of water bodies; 

5.         Perhaps one of the most glaring flaws of the draft bill is the contradiction between the stated intention of “streamlining aquaculture authorisations” and the extremely bureaucratic and administrative heavy institutional structures that are proposed in terms of chapter 2 of the Bill. For example, it is incomprehensible to understand how application processes will be streamlined when ONE of the decision-making bodies - the National Interdepartmental Authorisation Committee - comprises no less than 8 separate government departments! One need only consider the current paralysis with regard to decision-making concerning fishing harbours where DAFF and PWD are the two government departments that are supposed to facilitate harbour management. Requiring officials from 8 separate government departments to consider, understand and decide fish farming applications (which could number dozens or hundreds annually) will frankly destroy the industry.

6.         If indeed DAFF is serious about giving effect to the rather optimistic objectives set out in Operation Phakisa with respect to fish farming, our advice is to remove the various and unnecessary hurdles and regulatory licensing requirements for fish farming and to instead recognise that as with terrestrial animal farming, fish farming does not ordinarily pose any risk and harm to the environment and as such licensing should not be required if certain aspects of the fish farming venture exist. Our proposal would be to stipulate that fish farms that meet the following criteria SHOULD NOT REQUIRE ANY LICENSE OR PERMISSION FROM DAFF TO OPERATE:

            6.1       Farms that use brackish water, fresh water or sea water pumped into an on-land facility. Fish farming in the ocean (territorial waters and beyond) will require licensing and authorisation by DAFF);

            6.2       The farm produces less than 100,000 kg (for example) of fish annually; 

            6.3       The farm produces prescribed fish species only (for example, oysters, mussels, tilapia, abalone etc); 

            6.4       The farm commits to making available a percentage of its spat to facilitate and support small-scale fish farming start-ups in a bid to fast-track growth of small-scale and subsistence (Especially pond-based) fish farms. It is common cause that one of the largest barriers to fish farm start-ups is access to spat. 

            6.5       These farms must provide quarterly reports to DAFF on specified biological and ecological data and DAFF must maintain a publicly accessible register of these fish farms and what they are farming. 

7.         In addition, a revised Bill should make provision for industrial scale fish farmers (i.e. those producing more than 100 tons of fish annually) to claim reduced levy/regulatory fees if they provide technical, scientific and advisory support to small-scale and subsistence fish farmers, thus again facilitating and promoting small-scale fish farming, reducing the business risks associated with such ventures and reducing the administrative and cost burden on DAFF. 

8.         Finally, the Bill should consider addressing the increasingly important global concern of correct naming and labelling of farmed fish and farmed products, together with the certification of such products. In this regard, one should consider the work that has already been undertaken by SABS in this regard covering wild and farmed fish but which will be a voluntary mechanism once finalised. 


DAFF’s Aquaculture "Concept" Bill

During March 2015, the Fisheries Department published an "Aquaculture Concept Bill" for public comment. The "concept" bill is really a very rough and incomplete draft set of ideas on fish farming regulation, which should eventually evolve into a white paper, then a draft Bill and perhaps thereafter an Act. 

However, the fact that DAFF published such a draft straw document is to be commended! This is how a government department is supposed to conceptualise and prepare complex policy ... by seeking  inputs from the public at the very conceptualisation of policy and ideas. This is what is required when preparing fishing policies and fishing rights allocation processes! 

The aquaculture concept bill is clearly a response to Government's latest big plan - Operation Phakisa - which has committed to increasing current farmed fish production levels (±3000 tons annually) to a whopping 90,000 tons within less than two decades. Coupled to this, Operation Phakisa also reckons that we will grow jobs concomitantly from the current 1900 jobs to 250,000! 

What is apparent from the concept bill is that DAFF wishes to have a stand-alone Act regulating both marine and freshwater fish farming and to "streamline" the application procedure. Currently, and in terms of the Constitution, marine resource management, including marine fish farming, is exclusively regulated by the National Government (DAFF) in terms of the Marine Living Resources Act, 18 of 1998. Fresh water fish farming is the regulatory prerogative of provincial governments. 

A copy of the concept bill is available from Feike - unfortunately a copy of the draft bill is not on the DAFF website. Our brief comments on the concept bill which were submitted to DAFF as provided below.

FEIKE'S COMMENTS ON THE "AQUACULTURE BILL CONCEPT DOCUMENT"

1.         Firstly, it is noted that the concept document is very much a draft document lacking many definitions and content under the various text headings. There are a number of definitions that require incorporation such as “antibiotics”, "fish veterinarians", “ fallowing", "anti-fouling measures", “pesticides", “pollution", “ponds", "sea cages”, "brackish water”, “fresh water”, "alien and invasive species”, "fish" etc.

2.          The concept document makes reference to section 27 of the Constitution but oddly makes no reference to the section 24 - the right to a healthy and safe environment. 

3.         The structure of the concept document does not adequately address the fact that marine based fish farming is the regulatory prerogative of the National Sphere of Government while the regulation of freshwater fish farming vests with the Provincial Sphere of Government. This distinction must be clearly defined and delineated in any Bill, failing which it would render the Bill confusing, if not unimplementable and unconstitutional. The Bill does not appear to also recognise the overarching application of the MLRA in terms of section 3 of the MLRA, which extends application of the Marine Living Resources Act to all fish which is found in waters that form part of the sea at any time. 

4.         With respect to the stated objectives of the Bill, no reference is made to the following important considerations: 
           
            4.1       Application of the precautionary principle and fish farming management in terms of the best available scientific evidence;

            4.2       The need to promote responsible trade in farmed fish and to identify key markets. This is crucial since issues of HACCP and other health certifications will apply to farmed fish destined for human consumption; 

            4.3       The farming of alien and invasive species;

            4.4       Maintaining genetic biodiversity of indigenous fish species and health of water bodies; 

5.         Perhaps one of the most glaring flaws of the draft bill is the contradiction between the stated intention of “streamlining aquaculture authorisations” and the extremely bureaucratic and administrative heavy institutional structures that are proposed in terms of chapter 2 of the Bill. For example, it is incomprehensible to understand how application processes will be streamlined when ONE of the decision-making bodies - the National Interdepartmental Authorisation Committee - comprises no less than 8 separate government departments! One need only consider the current paralysis with regard to decision-making concerning fishing harbours where DAFF and PWD are the two government departments that are supposed to facilitate harbour management. Requiring officials from 8 separate government departments to consider, understand and decide fish farming applications (which could number dozens or hundreds annually) will frankly destroy the industry.

6.         If indeed DAFF is serious about giving effect to the rather optimistic objectives set out in Operation Phakisa with respect to fish farming, our advice is to remove the various and unnecessary hurdles and regulatory licensing requirements for fish farming and to instead recognise that as with terrestrial animal farming, fish farming does not ordinarily pose any risk and harm to the environment and as such licensing should not be required if certain aspects of the fish farming venture exist. Our proposal would be to stipulate that fish farms that meet the following criteria SHOULD NOT REQUIRE ANY LICENSE OR PERMISSION FROM DAFF TO OPERATE:

            6.1       Farms that use brackish water, fresh water or sea water pumped into an on-land facility. Fish farming in the ocean (territorial waters and beyond) will require licensing and authorisation by DAFF);

            6.2       The farm produces less than 100,000 kg (for example) of fish annually; 

            6.3       The farm produces prescribed fish species only (for example, oysters, mussels, tilapia, abalone etc); 

            6.4       The farm commits to making available a percentage of its spat to facilitate and support small-scale fish farming start-ups in a bid to fast-track growth of small-scale and subsistence (Especially pond-based) fish farms. It is common cause that one of the largest barriers to fish farm start-ups is access to spat. 

            6.5       These farms must provide quarterly reports to DAFF on specified biological and ecological data and DAFF must maintain a publicly accessible register of these fish farms and what they are farming. 

7.         In addition, a revised Bill should make provision for industrial scale fish farmers (i.e. those producing more than 100 tons of fish annually) to claim reduced levy/regulatory fees if they provide technical, scientific and advisory support to small-scale and subsistence fish farmers, thus again facilitating and promoting small-scale fish farming, reducing the business risks associated with such ventures and reducing the administrative and cost burden on DAFF. 

8.         Finally, the Bill should consider addressing the increasingly important global concern of correct naming and labelling of farmed fish and farmed products, together with the certification of such products. In this regard, one should consider the work that has already been undertaken by SABS in this regard covering wild and farmed fish but which will be a voluntary mechanism once finalised. 


Over the past few days, I have repeatedly been asked for my analysis of and what my understanding of the Draft Small Scale Fisheries Regulations, policy and roll-up plan are.

The implementation of the Policy and Regulations is popularly justified as being the panacea for small-scale fishers and fishing villages. In particular, there has been substantial rhetoric about allocating small-scale fishing rights exclusively to co-operatives comprising hundreds and thousands of "fishers". We are told that the intention is to accommodate a whopping 30,000 "fishers"! The reality of course is that what we will achieve is poverty and resource destruction on a coastal scale.  

Don't believe me? Well, its awfully simple to understand.

Fact. We currently have some 2200 small scale fishers fishing for abalone, line fish, lobster, hake handline, mussels and oysters. 

Fact. The hake handline fishery is an extremely seasonal 3-month long fishery that operates in a very specific geographic area on the Southern Cape coast and can accommodate a maximum of 80 right holders. 

Fact. The abalone fishery is in serious biological decline currently accommodating a maximum of 300 right holders. Of the 7 fishing zones, the department's scientists repeatedly state that 4 of these zones need to be closed to fishing. 

Fact. With respect to lobster, the fishery was determined to be able to accommodate some 850 right holders back in 2004/5 each holding economically viable small-scale quotas. The inclusion of an additional 2000 "interim relief" fishers since 2007 has decimated stocks to the point where lobster is 97% overfished now. Not that these 2000 interim relief fishers have access to biologically or economically viable quotas. Their allocations are in fact nothing more than poverty traps worth less than R15,000 annually. 

Fact. There is therefore no additional fish to be allocated. So, the fish that was shared amongst 2200 fishers is now expected to be shared amongst 30,000 fishers! One does not have to be a rocket scientist to immediately appreciate the ensuing poverty. Consider this statistic. We currently have 850 nearshore commercial lobster fishers who each have some 500kg of lobster each season (500kg of lobster is worth R100,000 before tax). DAFF's proposal is to add an additional 30,000 "fishers" to the small-scale pool via co-operatives. Lets assume that of these 30,000 fishers, 10,000 "fishers" are located on the west coast where our lobsters are located. Simple maths would mean that each fisher would effectively get 42 kilograms of quota per season! This would earn each fisher an effective R8,500 per year! And let us not forget that the TAC for lobster has declined by 29% over the past 2 seasons alone. Within 5 years, annual allocations will be less than 30kg per person per season!

Line fishers would essentially get 1 snoek each per season to harvest! 

Unless DAFF intends to magically increase our nearshore fishery biomass 13-fold, it is incomprehensible as to how 30,000 fishers can be accommodated in our nearshore sectors ... and that is assuming that there are 30,000 fishers.

So, pray tell, can anyone who supports the proposed small-scale fisheries regulatory framework explain to me how it will alleviate poverty, recover our overfished and collapsed nearshore fish stocks and help coastal communities?  
















Over the past few days, I have repeatedly been asked for my analysis of and what my understanding of the Draft Small Scale Fisheries Regulations, policy and roll-up plan are.

The implementation of the Policy and Regulations is popularly justified as being the panacea for small-scale fishers and fishing villages. In particular, there has been substantial rhetoric about allocating small-scale fishing rights exclusively to co-operatives comprising hundreds and thousands of "fishers". We are told that the intention is to accommodate a whopping 30,000 "fishers"! The reality of course is that what we will achieve is poverty and resource destruction on a coastal scale.  

Don't believe me? Well, its awfully simple to understand.

Fact. We currently have some 2200 small scale fishers fishing for abalone, line fish, lobster, hake handline, mussels and oysters. 

Fact. The hake handline fishery is an extremely seasonal 3-month long fishery that operates in a very specific geographic area on the Southern Cape coast and can accommodate a maximum of 80 right holders. 

Fact. The abalone fishery is in serious biological decline currently accommodating a maximum of 300 right holders. Of the 7 fishing zones, the department's scientists repeatedly state that 4 of these zones need to be closed to fishing. 

Fact. With respect to lobster, the fishery was determined to be able to accommodate some 850 right holders back in 2004/5 each holding economically viable small-scale quotas. The inclusion of an additional 2000 "interim relief" fishers since 2007 has decimated stocks to the point where lobster is 97% overfished now. Not that these 2000 interim relief fishers have access to biologically or economically viable quotas. Their allocations are in fact nothing more than poverty traps worth less than R15,000 annually. 

Fact. There is therefore no additional fish to be allocated. So, the fish that was shared amongst 2200 fishers is now expected to be shared amongst 30,000 fishers! One does not have to be a rocket scientist to immediately appreciate the ensuing poverty. Consider this statistic. We currently have 850 nearshore commercial lobster fishers who each have some 500kg of lobster each season (500kg of lobster is worth R100,000 before tax). DAFF's proposal is to add an additional 30,000 "fishers" to the small-scale pool via co-operatives. Lets assume that of these 30,000 fishers, 10,000 "fishers" are located on the west coast where our lobsters are located. Simple maths would mean that each fisher would effectively get 42 kilograms of quota per season! This would earn each fisher an effective R8,500 per year! And let us not forget that the TAC for lobster has declined by 29% over the past 2 seasons alone. Within 5 years, annual allocations will be less than 30kg per person per season!

Line fishers would essentially get 1 snoek each per season to harvest! 

Unless DAFF intends to magically increase our nearshore fishery biomass 13-fold, it is incomprehensible as to how 30,000 fishers can be accommodated in our nearshore sectors ... and that is assuming that there are 30,000 fishers.

So, pray tell, can anyone who supports the proposed small-scale fisheries regulatory framework explain to me how it will alleviate poverty, recover our overfished and collapsed nearshore fish stocks and help coastal communities?  
















 Page 5 of 64  « First  ... « 3  4  5  6  7 » ...  Last »