Inshore Resources Exploitation Controls (2020)

A proposal to resuscitate our marine fishery inshore resources

During last decade and a half, I have repeatedly written about the ever-increasing problems at Branch Fisheries, and their failure to reduce exploitation on Line fish and Rock Lobster, as well as their inability to organise and run an effective Compliance Department. All that has happened is that matters have gone from bad to worse. Then came the proposal of increasing artisanal type Rights, which in a country with such a high unemployment rate is entirely logical. The only negative is that it is somewhat unfair to those who have enjoyed Rights on such Resources for years, if not generations. Unfortunately, when you wish to change matters so dramatically from the previous norm, you need two essential qualities. Firstly, those responsible for the change need to know as well as anybody if not better than most, what they are talking about. Secondly, they need to plan everything correctly to the nth degree, and then have it introduced by people, such as the Minister or his/her representatives with a high degree of sensitivity. Instead, none of that happened, only wild promises that can never be kept!

Nobody listens to me, or for that matter to anyone else who has similar experience to what I have had. As a result, this will be my last article on these subjects, as I am ready to give up unless visible and practical changes begin to be introduced. If not, the net result will not be the total destruction of the relevant resources, just their slow demise to a level at which it will not be viable to catch what remains. Talk of extinction is unlikely, in that it would probably take a violent change in the resource habitat and environment for all of a species to die out. The sea will look after its own, but recovery could take decades. It is, for instance, over six decades since the collapse of the KZN Seventy-four resource saw the fish lose its status as the most important target species for their Commercial Fishing Industry. This finally resulted in it been placed on the No-catch list, but only now, three decades on, has their recovery possibly reached a level justifying their capture again. Then, it would also appear that certain behavioural changes might have occurred to that resource, resulting in its migration to a somewhat deeper environment.

All stakeholders know that Branch Fisheries is now a division of the Department of Environmental Affairs, together with the Marine Environmental Section that already resides there, and both need to merge again as one division of that Department. Then, accepting that neither of these two entities for years demonstrated much management ability, they need, as one entity, to be reorganised. This must include the procurement of the required skills to manage the abundance of our natural Marine resources by adequately qualified and experienced personnel in these fields.

This restructuring should include an adequate administrative sector run by experienced personnel to handle such matters as finance, the management of the many assets under this division’s control, scientific evaluation in respect of the resources, compliance, etc. A detailed proposal, as to the required sectors and their work responsibilities, will follow later in this article.

At this point, it must surely be acknowledged that our inshore resources of Line-fish, Abalone (Perlemoen) and Spiny Rock Lobster (Crayfish), must be one of the Department’s first priorities in the light of the dramatic collapse of so many of these species. This has been due to uncontrolled Exploitation, poor Rights Allocations, and ineffective Resource general management, all adding up to the simple result of their being over-fished. In accepting that these are resources caught by both Recreational and Commercial interests, one must acknowledge that all of them also suffer a high degree of Illegal exploitation. Now, most of them, quite logically, are been considered as species relevant to so-called Artisanal or Community future Inshore exploitation. For the purposes of this article and its proposals, we will include Intertidal Resources, but not octopus, all species of rock lobster caught in traps, and the dedicated Commercial Squid Fishery.

Of course, the immediate response to this is that, if most species are already overfished, how on earth can the authorities believe that as many as 30,000 (an already mooted estimate) be allowed exploitation rights to further decimate what little is left. These new exploiters are to be the subject of a new sector known as Small-scale Fishing Rights. This is the first obvious mistake! Just as it is logical that coastal dwellers should have access to Resources that exist on their very doorstep, it is equally logical that the exploitation of all similar Resources should be managed by one entity. So let one start by merging all the separate’s divisions responsible for these Inshore Resources into a new sector being Small Scale Fishing Rights on Inshore Resources. (SSFRIR)

In this situation, within the divisions of Recreational and Commercial fishing activities, you will now have three differing types of exploiters. They are those who do it mainly for Recreational pleasure combined with a degree of food acquisition. Then there are the Commercials that do it for reward. Lastly, you now have the Artisanal Fishermen, who were to do it for food acquisition, and a degree of Commercial reward. Already, this last principle of Artisanal type Exploitation has been largely deserted for Political convenience, as so many of our somewhat uneducated representatives (at least in Fishery matters) have to cope with the fallout of their delusional promises once again!

Of course, man has the right to predate on any resource that fulfils his need for nourishment and therefore life. Again, logically, despite what many of the greenies and naturalists claim, there should be no exceptions to this, and, in the case of the Marine environment, this should include seals and whales, to name but another two relevant species. However, no matter what anyone says or claims, there can be absolutely no excuse to allow man to plunder any resources beyond their propagatory Sustainability. After all, that is the equivalent of simply shooting oneself in the foot. In our sorry country, it is quite clear that our leaders consider their own political sustainability far more important than the sustainability of our food chain, whose species should be there for the benefit of all our peoples, which they are presently not!

The Department of Fisheries, now in the Ministry covering Environmental Affairs, surely deserves to be headed up by a full Director General stationed in Cape Town, the accepted centre of our Fishing Industry. Then, its various Divisions should be the following:

Major—

o Administration (DDG)-= General Office, Finance, Legal, Procurement, Human Resources, External Office Control.

o Compliance (DDG)-= Terrestrial, Small Craft, Deep-sea Patrols, Launch Site and Harbour Offices, Security.

o Offshore Resource Management (DDG)-= Mid-shore/Off-shore Demersal Trawl/Longline/Midwater Horse Mackerel;— Off-shore Large Pelagics by Longline & Pole; — Shark Longline;—Crustacean Demersal Trawling (KZN);—Squid;—Small Pelagics by Purse-seine;— Midshore Spiny Lobster by Traps (East, South, West Coasts);—-Octopus by Traps(West Coast).

o SSFRIR, Small Scale Fisheries (DDG)-= Abalone(Perlemoen) by Commercials Diving; by Recreationals by hand or free diving—Spiny Lobster Commercials with Ring-nets; by Recreationals and Artisanals by Hand, Dipping, Free Diving, Ring Nets (Crayfish, East, South, and West Coasts)—Line-fish by Commercials with hand-line; by Recreationals and Artisanals by rod and reel, hand-line and free diving—Oysters by Commercials by hand or free diving; Recreationals by hand; Artisinals (needs to be discussed).—Other Inshore Organisms by Recreationals and, as appropriate, Artisinals to include Giant Periwinkle (Alikreukel); Venus Ear (siffie) White and Black Mussels; Pencil bait, Worms, Burrowing and Swimming Prawns, Redbait, by hand, suction-pump, pusher, gaff.

Smaller—

· Right’s Allocation.

· Statistics.

· Fleet Management and Maintenance.

· Scientifics.

· Equipment Management, Maintenance, and Distribution.

· Mariculture.

· Communications, Internet, and Education.

You may well ask what has proposals for a revamped Department of Fisheries have to do with protecting and rebuilding our In/Near-shore Marine Resources. The answer to that question is that Natural Resources require very carefully management, if one is to achieve the aim of only Sustainable Exploitation. Then, none of the above will work without the guidance and application of persons with the required ability and qualifications, and the passion and understanding, to apply their skills in an Environment almost as foreign to humankind as Outer space! Finally, the next prerequisite is that such a Department has to have the capacity to ensure Compliance with management regulations developed towards these ends, to avoid as comprehensively as possible illegal exploitation on these Resources. Otherwise, such unrestrained activities simply negate all intended effect of all other actions, regulations etc., as is clearly the case presently.

To plagiarise Andrew Donaldson, with appropriate apologies of course, one now comes to your author’s never-ending “Grouse” of the badly failing ANC Government, and our ‘oblivious’ and Constitutional unaware President. (Even if he had more than 50% input therein‼). In 1994, the ANC were handed an operational Government and Bureaucratic structure. They immediately won the first democratic election with a “modest?” majority of something over 60% with the nearest competitor recording a “dangerous” 11%, in the eyes of the “fragile” ruling party! So fragile, that to cement their hold on power, it was apparently necessary to warn their supporters of the imminent danger of a reversal to the Apartheid past, a narrative that endures to today , purportedly in order to maintain unity and see off this imminent threat! (But really as the prime excuse for their failures and mistakes!) Their answer was, and still is, to out from all Government controlled entities all skilled Bureaucrats, teachers, lecturers, upper management, middle management, any management, if their skin was white. Thereafter, once they had destroyed their own areas of responsibility, they set about trying to enforce it legislatively on private enterprise as well, through all manner of legislation in the spirit of proportionate democratic representation. Today, it is required that this principle, in the name of Radical Economic Transformation, be applied in all social, departmental, and private business situations. WHY is this any longer necessary???? Nearly all of Non-ANC society, irrespective of their skin colour, would like to know that answer!

Think about it! How could the Black Majority, deprived, since Union shortly after the turn into the 20^th Century, of quality education coupled with cultural development, have ever hoped to find enough substitutes, qualified and experienced, to replace the incumbent Whites? To make matters worse, one supposes inevitably, the employment genocide of proportional racial quotas is now been forced on all non-African minorities. Perhaps, Zuma’s only claim to fame is the fact that, after all his Government’s manipulation, blatant corruption, and cooperation with the policy of State Capture, we have a fully “transformed” society. However, the cost of achieving that is almost incalculable and may never be more than a guesstimate. In fact, it is hard to find a worse example of killing all the geese that laid the golden eggs that the ANC received on the proverbial ‘Plate’ back in 1994. There can be few examples elsewhere, if any, of so many utterly ridiculous policies developed for our new Democracy, when the ANC politicians only seem keen to deny the very existence of our Democratic Constitution‼

After all, surely everybody must realise that the larger part of our population requires the circumstances of maximum economic growth and job creation to enable improved quality of life, supply of services, and education. Following the outdated and many times failed doctrines of extreme socialism and Communism will not achieve this, and such can never be the bedfellows of Democracy! Well, as they say, that is all water under the bridge now, and the only answer is to look to how we can improve the current situation, and, in this particular instance, to concentrate on Inshore Fisheries, one of my particular areas of expertise.

The first requirement, entirely ignored lately in the wish to empower coastal dwellers/communities on a political basis, is the need to award Artisanal type fishing rights with small quotas, or limited effort rights. This is the correct approach, but then automatically dictates that the fishing equipment should itself be low in cost to ensure that the return on a small catch generates an adequate level of income. The greater the investment needed to operate, the larger is the quota needed to generate adequate profit. With this in mind, reserving a percentage of allowable catch of four species, squid, offshore west coast lobster, all hand line hake, and line fish, for SSF is difficult to understand.

There is no independent Resource of ‘hand line hake’, as previous allocations and licences have proved. Today, it only makes up an insignificant contribution to line fish landings, whilst the licence holders catch any type of linefish.

How do you split line fish 50/50? The catching thereof can only occur with the same equipment, which is anyhow quite costly, and the return thereon is hardly a fortune.

The cost of vessels and equipment to catch squid immediately removes it from SSF class, and the same goes for trap caught West Coast and other Rock Lobster.

Now, maybe one can better understand the Departmental reorganisation suggested above.

ROCK LOBSTER

Let us start with biggest Resource in Value, our four main species of Spiny Rock Lobster.

1. West Coast Crayfish, Jasus lalandi. Split say 50/50 initially, the trap component has nothing to do with SSF, whereas the inshore catch represents the ideal Resource for SSF and Recreationals. Recreationals undoubtedly deserve open access limited only by size, number allowed, and maybe a shorter season than SSF. The need for careful research and accurate landing records are paramount in order to make certain that these landings with those of the trap boats do not exceed a quota that ensures Sustainability with an adequate degree of stock rebuilding. Therefore, can we not project 400 tons for inshore (ARTISINALS), which will include “Interim Relief” existing Right’s Holders, Port Nolloth, and Hondeklipbaai, and 37 tons for RECREATIONALS.

This will leave 400 tons for Offshore Trap Boats.

2. Deep-water south coast Rock Lobster, Palinurus gilchristi, and trap caught offshore Jasus lalandi do not belong under SSF Resources.

3. Neither does Palinurus delegoae, trawled with other Crustacea off KZN, together with a very small catch of Scyllarides elizabethae (Shovelnose Lobster).

4. Panilirus homarus, caught together with a small percentage of Panilirus versicor and ornatus, are inshore species from Port Elizabeth to Mozambique, which should all be caught by Artisanals and Recreationals, subject to Sustainability.

PROPOSED REGULATIONS (to be considered by the Authorities).

For the sake of standardisation of all locations and avoid confusion, it is recommended that all species of lobster harvested by Recreationals should be bound by the same regulations apart from seasonal limitations.

1) The new season for recreational fishing of West Coast Rock Lobster West of Cape Agulhas will open on the of …………………. and will close on the of …………….. , and for East Coast Rock Lobster East of Cape Agulhas ……………………..

2) Any person who wants to catch Rock Lobster for own consumption must be in possession of a recreational rock lobster permit, obtainable at Post Offices only.

3) The Bag limit shall be Four (4) per permit holder per day for own use.

4) The Minimum size shall be 80 mm – measured in a straight line along the middle dorsal line of the carapace, from the centre of the posterior edge of the carapace to the tip of the middle anterior spine.

5) Age restriction: Permits will only be issued to persons older than 12 years and under 70 years.

6) Recreational permit-holders collecting and landing Rock Lobster may do so only between 08h00 – 16h00, and they must be landed before the end of that time.

7) Any Rock Lobster caught, collected, or transported shall be kept in a whole state.

8) Rock Lobster in berry may not be caught and landed, and must be returned to the sea immediately.

9) No person shall buy, barter, sell, or offer for sale any Rock Lobster, which is caught with a Recreational permit or illegally.

10) A maximum of 20 rock lobsters may be transported per day, on condition that all the persons who caught such rock lobster are present in the vehicle, vessel or aircraft during transportation, and that such persons are in possession of recreational rock lobster permits.

11) No person or unlicensed entity shall keep, control or be in possession of more than 20 west coast rock lobster at any time at any location, (eg. home/residence).

12) Rock Lobster for own use may be caught by:

• using a baited ring- or line and scoop-net from a boat not licensed to catch Rock Lobster commercially, which must be launched and landed at a recognised registered launch site.

• using a baited ring- or line and scoop-net from the sea-shore;

• diving from the sea-shore without the use of artificial breathing apparatus, other than a snorkel;

13) No rock lobster traps, similar, or any other gear may be used.

14) Closed areas and MPAs: No person shall, in any manner or for any purpose, engage in fishing, collecting or disturbing west coast rock lobster in any location demarcated as closed to such activity. Document xxx, detailing such areas should be obtained from the Authority that issues your permit to fish Rock Lobster.

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LINE-FISH AND INTERTIDAL RESOURCES

The next major discussion resource is Line Fish, whose parlous state has been ignored for 40 years and more. When changes to the Regulations were made in 2000 towards improving Sustainability, they was based on science and warnings that were already more than ten years old. Unsurprisingly, they did little to improve matters. The various species stock levels continued their downward spiral as the level of the platform from which the changes in Regulations were based, were already out of date!

I fished False Bay and St Sebastian Bay (Breede River Mouth) on a regular year round basis semi-commercially from 1955 to 1990 with a commercial Skiboat licence until relinquishing it voluntarily around 1992. In addition, I have always fished, and continued to do so, as a Recreational, having captained the WP light tackle game fishing team for several years. It is, in the company of many others, my personal opinion that fish availability, particularly Bank Fish, had decreased by up to 90% by 1995. Although there has been a degree of recovery in San Sebastian Bay, particularly in the size spectrum across the board, there is virtually no improvement discernible in False Bay. This has inexplicably occurred despite an effort decrease from 2000 to today of at least 90 % as well. It may well be a combination of human disturbance from the shore side because of the Peninsula’s large population increase, possibly combined with Pollution.

As SSFRIR is about creating viable and sustainable jobs, I will not deal with permits for Aquarium fish collection or Scuba diving permits, neither of which impact available Resources, so should be dealt with outside this document. However to correct the present situation, unfortunately extreme measures are going to be necessary, and, apart from shore-based activity, one finds it difficult to imagine how present Inshore Fishing and Rights parameters can be differently handled, as is clearly required. After all, current boat based operations with Skiboats, or similar sized craft, is the norm, with only the odd exception at places like Kalk Bay, Struis’, and Arniston, where one sees older larger traditional craft still operating. It is noticeable that at these venues the main target catch is either or both Yellowtail and Snoek for part of the year. These two species the scientists luckily perceive as only fully exploited.

Pragmatically speaking, it would be impractical not to commercially catch any Reef-fish, Kob, and Geelbek, as the market demands and needs at least a limited supply thereof. I share the belief that any Resource can be sustainably exploited, as long as you take out less than its annual perceived propagation. Admittedly, this may be a difficult safe calculation in a stock depreciated to as little as 10% of its guesstimated pristine level! If it can be shown that further exploitation of such species has still diminished it year on year, then it must be transferred to the Recreational list, and all commercial exploitation and sale banned. A committee consisting of the re-established Advisory Forum members, two involved scientists, and three SFFRRI representatives from differing Provinces must take these decisions.

Let us now list all regular line fish and other organisms in six categories now rendered necessary by the present circumstances:

1. Recreational. 2. Commercial. 3. Non-landable. 4. Baitfish. 5. Shellfish, Bait, and Other Commercial Intertidal Organisms. 6. Special Small Scale.

Please accept that the following are my proposals that are sourced from my personal experience, research reading of scientific reports by others, and anecdotal information gleaned from hundreds of fishing friends and acquaintances, over sixty plus years. The intention is not to suggest that all are right, but to start a reconsideration of existing regulations and practices, which have patently failed in the past as an effective blueprint for Sustainable Exploitation. One has to remember that our scientists feel that our inshore resources of Line-fish have reduced enormously over the past fifty years, which, from the experience of hundreds of thousands anglers, is an undoubted fact. What has happened to them? Well, as ridiculous as it seems, we have eaten them, and in the process have caught more than the Resource’s propagative powers have been able to replace year on year, season on season

1. RECREATIONAL (Annex A)

a) It has been, once I had looked as the historic lists and regulations, difficult to attune myself to the thought processes that went into their original compilation. Yes, one realises that their authors were not necessarily fishers, but there have always been plenty around to have considered and reviewed their content. However, that water has passed under the bridge and criticising the past, instead of just learning from it, has never been a very productive practice. Sufficient to say that there are species on it that are seldom caught by rod and/or line, and others that are simply used as bait, etc. The changes to the lists that I envisage will be detailed fully at the end of this overall section.

b) The scientists state that of the common fish, mainly targeted by Recreational Shore and Boat anglers, and Commercial Boat fishers, out of 35 species, only 2 could possibly take a greater level of Exploitation (panga and streepie). Of the rest, 8 are maximally exploited, 6 are over exploited, and no less than nineteen are so heavily over exploited that their numbers are reducing every year/season from a level that already denotes them as collapsed stocks. This could mean that they are beyond recovery to a stable consistently yielding exploitation level again!

c) As I have said before, I do not believe this puts them in danger of extinction, as warned by so many. The sea will look after its own. But economically viable and needed natural food resources will be lost to all South Africans with the jobs they created! In addition, an increasing number of us will lose the pleasure and relaxation of fishing, as will the tourists, who we so desperately need.

d) When Recreationals realise that one of the major changes is the reduction of the total daily catch limit, as well as a reduction in specie limits, there will be many moans from frustrated anglers about the cost of their sport. However, they will have to be realistic, as nobody pays you, an amateur, to play golf, so, if you cannot afford that very expensive game, you don’t play!

e) After all, no family needs more than five fair sized fish at a time. Then how often, if at all, would one catch more? Even if you could have, it is illegal to sell them.

f) They will also have to accept less choice of launch sites, to enable the needed improvement in both Compliance Control and Catch recordal. All Launch sites will have to have a degree of permanent representative presence, like harbours, clubs, hotels, municipal sites, etc. It may even be rational to consider the number of launches allowed per day according to the circumstances of the site.

g) A Recreational will obviously be allowed to catch all species on the Commercial list that do not appear on the Recreational list with a maximum of five of any species. However, please note that the total allowable catch per day does not alter.

The question will arise as to why a Commercial may catch an unlimited amount of a species, whereas the Recreational is limited to 2. The reason is very simple in that the Commercial is to be allowed to catch certain over exploited species to satisfy market demand, whilst the present overall catch level has to be reduced. One must also remember that the new restrictions, hopefully to be imposed on Commercial licences, are expected to considerably reduce Commercial effort on fragile species.

h) However, a Recreational will be allowed to catch 20 combined or of any species on the Bait List, in addition to his species bag limit.

i) Recreationals fish for fun, so surely few will really be interested fishing at night for fun. Irrespective, it is imperative to reduce effort, so it is logical to reduce potential fishing hours. With this in mind, the recommendation is that no Recreational fishing be allowed between one hour after sunset and one hour before sunrise.

j) In order not to interfere with the traditional spawning and fishing grounds for Squid in the Eastern Cape, no Recreational or Commercial fishing shall be permitted from a boat in an area between Cape Recife and Cape St Francis Lighthouses for distance of 10 nautical miles from the inner coastline.

k) A long held belief of mine, going back to the eighties, relates to the validity of minimum size limits. This arose from my reading the ongoing research and experience of American Fisheries scientists on the breeding of Black bass for both maricultural purposes, and the seeding of heavily fished inland waters. At that time, they had reached the belief that the spawn of an older fully mature fish’s chances of survival are many times stronger than the spawn of younger fish.

It just seemed so logical, but I was laughed at, when I suggested to our scientific fraternity that it might well apply to oceanic species as well. They remained fully convinced that the theory of allowing a fish to reach spawning maturity by size limitation restrictions, had to be the way to go. My argument was that even in the case of slow growing species, growth initially was fast, and their mortality rate by predators was largely guesswork, which remains the case.

Today, the theory of stronger spawn is fully accepted and conventional wisdom. Apart from the strength of the spawn, it is also fact that the size of a fish’s gonads is at least directly proportional to its size.

As a result, I would far rather see a fisher landing a few juveniles, depending on the bag limit, than a much larger specimen. This would equally apply to the case of an Artisanal fisher, and would make the job of Compliance inspectors that much easier. It also emphasises how important it is to ensure the strict adherence to bag limits.

2. COMMERCIAL (Annex B)

a) Commercials will complain even more, when they see certain species removed from their permitted catch list, but again, they will just have to bite the bullet.

b) Then, it is my absolute opinion that Commercial Line-fish Rights Holders will have to accept that their licence entitles them to fish from, and return to, only one location. After all, this is the only sector where this ruling is not a condition. No more trailering their craft to wherever the shoal of fish stick their heads out, with boat after boat then arriving, until the shoal is decimated.

c) It will mean a dramatic reduction in effort overall, which is anyhow required, and far better catches much of the time for the fewer local boats.

d) The skill that will be required by management, the Department, will be the right allocation of the right number of licences for each venue.

e) Of course, this is required again to improve Compliance and Catch Recordal.

f) With Commercials retaining the right to catch certain over exploited stocks in order to try to satisfy market demand, although with much decreased effort, the question remains as to whether catch limits should apply for such species.

Explanations for the changes to the Recreational AND Commercial Line-fish Species lists are as follows:

i. The following species, identified by their common name, are seldom targeted, and not under threat, Banded Galjoen, Bank Steenbras, Blue Hottentot, and Dane. Therefore, they have been removed from any list.

ii. The following species have been combined together: Sharks etc., Rockcod, Kingfish, Knifejaw, Billfish, Hake, Kob, Tuna.

iii. Kob size limits, bag limits, and location limits, were too complicated, illogical, and sometimes simply wrong. I have sought to correct this, but it is open for discussion.

iv. Red Stumpnose is a no-brainer, though I must admit to being worried about leaving certain other bottom fish, kob, and geelbek, open to commercial Exploitation, which must be very carefully monitored!

v. I have put Wreckfish back, as I can find no explanation anywhere as to why they were banned. This might well be wrong. However it is wrong to have Wrasses and Seventy-Four banned.

vi. Putting Coelacanth, Great White Shark, Basking and Whale Shark, Sawfishes, Hammerheads on a banned list makes no sense. Where relevant, I have dealt with the species involved in other ways!

vii. Common sense determines that in Commercial landings you will require minimum size limits for many species.

3. NON-LANDABLE (Annex C)

a) Firstly, let us consider sharks, rays, skates, and chimaeras. Recreational fishers do not target these species, as a general rule, as very few of our diverse population look upon any of them as edible.

b) Today there is great concern that they too are been over exploited, simply by the chance of their still being there, whilst so many sought after fish are no longer available. Frequently, they are simply discarded on the beach or rocks, instead of been returned to the water.

c) Two notable exceptions to no direct targeting are Competitions and ‘Trophy Hunting.’ In the former instance, it is pleasing to note the almost total principle of ‘catch and release’ after photographing and measuring the catch, and the same should apply (as it often does) to all landings of the latter.

d) Then, in the spirit of your not knowing what you have caught until you at least see it or land it, these lists will include all prohibited species.

They are present as part of the lists attached as ANNEXURES A and B.

4. BAITFISH

a) I have removed all baitfish from the old lists and placed them all together on a separate list.

b) Actions allowed by the various exploiters are noted on the respective lists.

5. SHELLFISH, BAIT, AND OTHER INTERTIDAL ORGANISMS

a) I have only tried to simplify this list. Certain items could be extremely relevant to Artisanal SSF, but will be dealt with next.

b) Regulations need to be more precise about harvesting methods.

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6. SPECIAL SMALL SCALE (ARTISANAL)

a) I am not in favour of Co-ops, unless requested by 75% of the individually held Permit/Quota Holders, providing they are more than seven, and can produce a qualified and experienced bookkeeper who can prove his/her credentials. Then all Permit/Quota Holders in a particular location must belong to it, without exception, other than in d) below, should that proposal be adopted. Existing compulsory Co-ops in Port Nolloth and Hondeklipbaai have, and continue to have, never ending problems.

b) It is probable that these permits can only apply in reasonably isolated communities, but that also have the existing facilities of a licensed processing plant, such as refrigeration.

c) Issuing such Rights in areas of high-density populations, or without a clearly definable community, will be impossible to control, and only give rise to better opportunities for illegal practice. Similarly, the same will apply to areas with too low a population density, where such Rights Holders are too thinly concentrated.

d) I like the concept of tying in Individual Basket of Rights to a contractor bound to deliver his allowable catch to isolated coastal hotels, such as Hole-in-the-Wall in the Transkei. An example of this could be, say Mr Nkosi owning a vehicle and possibly a small boat, granted a permit entitling him to catch:

12 East Coast Crayfish over any three day period, whether he catches them in three days or less

15 fish off the Commercial list on the same basis.

25 Oysters, 90 Mussels, etc.

e) Such a permit would for the rest, be subject to all other conditions of the Recreational Permit. The Hotel Owner would be liable to act as a Compliance Officer, both in respect of his Contractor(s) and other local and visiting fishers in the immediate defined area. In other words, for example, should Recreational fish be landed, these must be subject to such applicable limits and only for own use, not for sale!

f) Species from the Bait list that, as and where appropriate, could be considered for Artisanal collection and subsequent sale, are Mud and Sand Prawn, Swimming Prawn, White Mussel, Black Mussel, Oysters, Red Bait, as per Recreational Limits. Care would have to be taken that such permits were not issued in conflict with existing Commercial Rights Holders!

g) Suggestions to reserve a proportion of a Commercial sector’s overall allowable Total Quota for SSF utilization, which would require the same equipment Investment to harvest, are simply stupid. This would seem to be a devious way that politicians think that they could remove historical Quota from existing holders without any thought as to how this could impact the sectors business viability, or overall Sustainability measures. If such a change was both logical and legitimate, it must fall within the normal parameters of FRAP applications‼

h) Once again, I must emphasise that this new concept of Rights Holdings must not in any manner lead to the risk of over-fishing of any Resource thus imperilling both its Sustainability and rebuilding potential!

SUMMING UP!

The concept of Coastal Dwellers’ Rights of Exploitation on Resources on their doorstep that they have grown up with, whist their family has long enjoyed the benefit thereof sometimes for generations, is logical. However, it is not appropriate to colour this concept on both sides of the coin by suggesting that rights should apply for any political reasons in any manner, let alone to satisfy the concept of proportional democratic representation. As a result of this continuing mishandling of Rights Allocations since the 1990s, whether for political or corrupt personal gain, correcting what has occurred in a reasonable manner towards the Artisanal type concept is going to be a slow process and take a long time. The reason is simple in that, for the most part, already far too much of these

resources have been allocated, which conflicts with the requirement of Sustainable Exploitation practice, leaving little or nothing over for further allocation. Adjusting the current allocations, must not be done by a stroke of a pen, as has occurred in the past!

Then there are certain fishing practices that have to be ended, namely Trek netting of any sort, other than a realistic number of Sardine trek net permits in Natal only to qualifying applicants. It is rumoured that almost half of the holders there have not fished for years, nor even own an operational Trek net. It is also noted that bycatch concerns are almost non-existent, unlike all other forms of Trek netting!

It is also debatable whether stake or any type of gill netting should be allowed around St Helena Bay or elsewhere. Here, many nets are illegally set in the Berg River Estuary and surrounding flats, where they do even more harm. If the netting of Mullet (Harders) is to continue, it should only be with throw nets in the shallows or limited size Purse-seine nets from a boat. Despite what seems to be scientifically believed, the incidence of Mullet along our Coastline and in our Estuaries is anecdotally seen as a fraction of what it was 50 years ago, and appears to still be continually reducing. Also, all their current forms of exploitation often regularly evidence a high degree of juvenile and other fragile species bycatch.

Then, I make no apologies for continually harping on this subject. If the Department does not restructure and develop a far more comprehensive Compliance facility, up and down the coast and at heavily utilized harbours, Sea Fisheries might as well close down! The whole structure, and in particular its outside offices’ staff are not sea-wise, inexperienced, poorly trained, under supervised, ill-disciplined, and easily subject to embracing self-gain corruption. The Department too easily blames lack of funds, which might be true, except that the concept gets overwhelmed by unnecessary and irrelevant expenditure been continually wasted. Certainly, unusually in a Government prone to excessive numbers of employees, this is an exception where many more employees may well be needed. For instance, at Hondeklipbaai, the Department’s first “so-called’ much vaunted Community Cooperative SSF experiment, there is not even a Compliance officer, let alone a record keeping office?! Perhaps, most importantly, the quality of staff is abysmal, and there is absolutely no sign of the sector making any inroads into kerbing illegal exploitation in renowned centres thereof, such as Hawston, Betty’s Bay and Paternoster, to name just a very few.

In this regard, the practice of low levels of prosecution has to end, and should be replaced with very strictly enforced standard practice, with appropriate penalty levels.

1. All transgressors of permit conditions of any description should get one RECORDED warning.

2. The second transgression, again of any description, should result in an appropriate predetermined fine.

3. Failure to pay such fine or a further transgression of any description should result in forfeiture of all equipment relevant to the permit.

4. Further transgression of any description must result in forfeiture of licence for life!

For the record, such arrangements should apply to all and every fishing Right!

In the midst of all of this, one cannot help remembering the success and the positive experience over the years in KZN. Here the old Natal Parks Board (Ezemvelo Wild Life) managed Compliance, both on land and in the Marine environment, as effectively as ever achieved in South Africa. On a smaller scale, the Breede River Estuary Conservancy was also for many years very successful. However, the Department summarily cancelled these former arrangements for no logical reason, with the result that Compliance in KZN has deteriorated to almost zilch.

In the latter case, the Conservancy also suffered through Inter-departmental, Provincial Government, and Municipal confusion, together with a lack of planning, cooperation, and illogical mandate changes, drastically reducing their effectiveness as well. Meanwhile, I also believe that Compliance should be pragmatically delegated downwards through to Provincial Government, and then to the Municipalities, as well as, where appropriate, to NGOs like Conservancies. However, to achieve this will require proper planning by the Department with the necessary financial arrangements. Until that occurs much of the intentions of the SSF Act will remain a Utopian Dream.

Quite honestly, without the implementation of most of the above, the aim of recovering inshore stocks, and, for that matter, maximising the benefits from all our other incredible Marine Resources, will also just be an unattainable Utopian Dream.

Click here to download a list of which fish may be caught.