Unravelling FRAP 2022 further (2022)

It certainly is taking some doing, and still leaves one with a lot of inexplicable facts and unanswerable questions.

A simple one to start with is the question why quotas have been granted in such a fragmented way. The Department claims to endeavour to make sure that everyone is aware that they will not grant paper quotas. However, when you start off granting an applicant quota for a particular fishery that does not ensure that its vessel will need the whole year, or, where relevant, a normal season to catch the allocated grant, are you not then inviting Paper Quota holders? Of course you are, and I find it difficult to see how they can then avoid them. After all, an owner is surely entitled to expect to be able to keep its vessel fishing for the season, or full year, if there are no seasonal restrictions. Failure of that scenario means that it must then seek sufficient partners to ensure the financial validity of the operations. The only other alternative, which I think is counter-productive in all aspects, is to apply for a Right in another sector to ensure full usage of your vessel. This seldom works out, and the Holder then combines his Right in some manner with others in that second sector.

There are, of course throughout nearly all sectors, long-standing associations, some with the bigger operators, who then enter into an agreement with those short-changed quota holders to land their fish. In the case of the smaller operators, who normally do not have their own processing facilities, they need that association anyhow. However, if their quota was large enough to go it alone with their vessel, and then simply make an agreement to deliver their catch to those larger operators, it would result in far more stable situation, and reduce the need for non-operating entities. This would then simplify such matters like Departmental management and compliance, whilst in all likelihood improve profitability, tax generation, and, inevitably, job opportunities.

The next problem arises from the requirement that you must prove you have an interest or ownership in or of a suitable fishing vessel. Without that proof, the department says your application will not be considered. It would surely be more practical to simply state that one of the conditions, when you are awarded a Right, must be that you have say fourteen days to provide proof of your direct interest in a vessel, failing which your Right is voided. Instead we have the situation where various applicants are seen to nominate the same vessel several times, whilst others are allowed to hold back their nominations. (Why are they so favoured?) What a dog’s breakfast it then becomes for the Department to see to its being sorted out correctly, between the nominal award date and the time to commence fishing!

My next concern has to do with the awarding of rights to new entrants, particularly “C” entrants. Why is this necessary, particularly in view of the continual fragmentation that I refer to above? When I have asked this of the politically connected, I am told it is for Transformation reasons and to broaden the number of participants. “Broadening the number of participants” as an explanation, only raises suspicions of irregular intentions, whilst full proportional transformation of the Industry is a proven fact as shown by the Departments own disclosed calculations in respect of points awarded to the applicant in respect thereof.

Why would you otherwise bring in extra unqualified and inexperienced entities, who will inevitably catch less fish than your present successful well experienced owners? The preferential alternative is surely, through additional Quota, to allow the present owners to maximise their profits to the benefit of taxation,

whilst then being able to afford extra employees (Create jobs). The converse is to confirm those irregular intentions, whilst ignoring the intentions of the Constitution.

Anyhow, I will be analysing each sector briefly in explaining the fishing method, noting how many and type of Quotas granted with their suggested minimum landings per vessel for a full season’s fishing. Then I will note the number of below minimum quotas granted. The problem that does arise is when a Total Allowable Catch needs to be reduced, resulting in all Quotas being reduced proportionately. This only emphasises further the scam of broadening access to both “B” and “C” grantees! To avoid any so-called confusion, the Department has determined three differing Rights categories as follows:

Category A: Applicants who held a Right in the sector for the whole period since the granting of those rights in 2006, or subsequent granting, to the date your FRAP 20/21 application. Applicants who received fishing Rights due to transfers under Section 21 of the Marine Living Resources Act No 18 of 1998 at any stage during the period 2006 – 2020 were also considered under this category, providing they continued using them satisfactorily through until the end of 2021.

Category B: Applicants who did not hold Rights in the Hake Deep Sea Trawl sector between 2006 and 2020 but who did hold Rights in other fishing sector/s during that period.

Obviously, all such applicants have to have used such rights to the Department’s satisfaction.

Category C: Applicants who have never held a Right in any Commercial fishing sector.

(For the purposes of these allocations and categorization of applications, Fish Processing Establishment and Aquaculture Rights were not considered as commercial fishing Rights.)

In addition they have graded failed applications as either EXCLUDED or UNSUCCESSFUL. The former meant that your application was incomplete, or that the holder had been guilty of some misdemeanour in respect of their former grant’s conditions. The latter meant simply that your point’s score was not high enough to qualify as against other applicants’ scores.

Despite having done separate articles already on some the FRAP resources of 2022, namely threesome Bottom Trawling sectors, I will again include precised versions thereof so as to present as full a picture of the current state of the industry as possible. In addition, I will also add in those sectors, who are not yet up for FRAP renewal, for the same reasons.

There is inevitable criticism of the overall fisheries management structure and behaviour, which is not my primary intention. The situation with Rights grants, and for that matter, the whole Industry, is what it is, both from the current and historical situation, political or otherwise. Rather, it is to hope that some of the improvements we have seen will continue, firstly in the new transparency, then secondly in the greater logic that has been applied by the Department to this FRAP. Certainly, the latter has not been sufficiently adequate yet, nor in every sector. However, there can be no doubt that this is, at least in part, due to Ministers influence, and one hopes that she can also see to the establishment of a proper and effective Compliance division, before illegal fishing destroys, as it threatens to, all our inshore resources.

DEMERSAL SHARK LONGLINE

Similar fishing method to Hake Longline, except for often fishing in much shallower waters. Strict regulations in regard to bycatch. There were only six applicants, as, practically speaking, the fishery is still partly in an exploratory mode, with only one A Right granted. The TAE was set at four vessels, 2 A, 1 B, and 1 C, with the others held in reserve. However, the Right was granted for 15 years.

HAKE DEEP-SEA TRAWL

Rights have been granted for 15 years.

Benthic trawl nets are towed by refrigerated vessels of a minimum length of 30 metres in waters from 200 to 500 metres depth, though much larger sophisticated factory trawlers are utilised by the bigger operating entities. To operate profitably, the smaller vessels need to land around 1000 tons of hake a year, whilst the larger vessels need to land 1500 tons upwards. TAC for the sector is 110,000 tons for 2022, with it being recalculated annually according to two resource evaluation surveys a year. The sector, or more correctly Hake, is subject to international sustainability certification (MSC) every two or three years.

FRAP 22 saw 175 applications with Rights being granted to 25 A applicants of which 11 grants were insufficient for year round operations, 2 to B applicants, so small as to be ridiculous, and 2 absurdly generous grants to C applicants. Appeals have still to come.

HAKE LONGLINE

As with shark longline, refrigerated vessels of between 25 and 40 metres set one or two single longlines on the bottom in depths of 100 t0 300 metres, which can be from 7 to 20 klm long carrying 20,000 to 40,000 baited hooks on one metre leaders, every halve to one metre apart, coming off the line. Each end is attached to an anchored surface buoy. They are normally set after midnight to avoid seabird fatalities, and recovered starting two hours after sunrise during daylight. The catch is removed, and hooks rebaited with sardine or maasbanker to be set again the next night. All fish are then packed into bins of slurry ice after heading and/or gutting. Bycatch, with the exception of Kingklip, which must be limited to not more than 5% of landings, is low and not really problematical.

Trips are normally for 7 days. There are no seasonal restrictions other than to the closing off of the Kingklip aggregation spawning areas. The quotas granted to Rights Holders in this sector are ridiculously low with a financially viable catch needed for year round operations of some 500 tons or more. Many grants should be caught in a month or less.

FRAP 22 saw 446 applications with Rights being granted to 64 A applicants, with all grants insufficient for year round operations, and 4 were reserved, 7 to B applicants, of which all were hopelessly insufficient, whilst the 15 C grants are likewise all too small. Appeals have still to come.

KZN CRUSTACEAN BOTTOM TRAWL

Rights have been granted for 15 years.

This fishery consists of two parts, a deep water section between Cape Vidal and Amanzimtoti from 150 to 400 m depth, and inshore section for white prawn only from 20 to 80 m. However, because the inshore resource is dependent on mainly the nursery area of the St Lucia Lake system, which has been closed since the start of the century, it will not be productive again until reopened. Suitable refrigerated vessels are 25 to 35 m in length, TAE (Total Allowable Effort) controlled, and fish the year round.

FRAP 22 received 16 applications, and granted 2 A’s, 1 B, and 1 C, for 10 years. The B and C grantees have not yet nominated Vessels.

SMALL PELAGICS SECTOR

Small Pelagics are caught with a Purse-seine net by fishing vessels from 18m up to 35m in length. The net can be up to 1200 m long and 60 m breadth (depth), and is recovered through a power block. The net is set to encircle the shoal of fish, and is then closed like an inverted string bag by a steel cable attached to a lead-line along its bottom, whilst a string of corks holds the top of the net on the surface. When the fish are dried, i.e.: confined to a heavier piece of netting in the front section thereof, the fish are pumped into the vessel’s hold(s) by means of a suction pump.

FRAP 2022 has granted successful applicants the Rights for 15 years.

Present TAC: SARDINE- 30,000 tons plus bycatch allowance of +- 3000tons. Just over half of the sardine must be caught north of Cape Agulhas with rest from the Southwest and West coasts. There were 244 applications of which 46 A, 2 B, and 4 C were granted. Appeals are still to come. With the very low TAC no grant could be fished by a single vessel for a full season. The minimum grant was +- 200 tons.

Plus: ANCHOVY- 247,500 tons plus bycatch allowance of +- 5000 tons. The Anchovy TAC has no area restrictions. There were 346 applications, of which 59 A, 5 B, and 4 C were granted with appeals still to come. The minimum grant was +- 1320 tons, and approximately 18 applied only for Anchovy.

Plus: bycatch REDEYE SARDINE 50,000 tons is allowed together with an insignificant tonnage of other species.

It is generally accepted by the Industry that an annual/seasonal catch or 4000 to 5000 tons of small pelagics will ensure the vessel owner financially viable operations. However, a total of 44 grants are not large enough to do this, resulting in theoretical non-operating Owners. These then have to either seek other vessel owners in the same position to catch its Quota, or own a vessel in partnership with others. Many resort to applying for a quota in another sector. This problem is unfortunately present in all TAC controlled sectors, but does not apply to those sectors that are controlled by TAE (total allowed effort) restrictions.

SOUTH COAST ROCK LOBSTER

This sectors vessels are normally between 30 and 50m with a crew of +- 20 to 30. They can carry up to 2000 traps, of which 100, duly baited up, are attached to longlines up to 2 klm in length. These lines and traps are weighted to lay on the seabed, and paid out over the stern normally in a straight line with each end attached to an anchored floating buoy. Depending on the fishing circumstances, they are then left in the water before recovery from 20 to 70 hours, with ten to fifteen lines and around 2000 traps laid and recovered per day. Freezer vessels remain at sea for up to 40 days, packing the lobster tails on board. Vessels placing their catch on ice return to port every 7 to 10 days. Subject to a limiting of fishing days per annum, there is no seasonal limitation.

FRAP 2022 has granted successful applicants the Rights for 15 years.

Present TAC is +- 350 tons tail-weight for the current year 2021/22. The season is year round from the 1st of October, or until the individual vessel’s Quota has been landed.

There were 68 applications, with 7 A, 1 B, and 1 C granted for 2022/23. Appeals are still to come. There are certain regulations regarding bycatch which are of insignificance relevance to the fishery.

Many of the Quotas are insufficient to keep a vessel fishing the whole year.

SQUID

Squid are caught by medium size vessels, 15 t0 25 m in length with accommodation for 12 to 24 crew, by means of hand-lines attached to a single Jig. They are caught at night, being attracted by lights mounted on the vessel, fishing mainly in Jeffrey’s and Sardinia Bays in and around the Port Elizabeth area. Occasionally, the fish are found as far south asPlettenberg Bay and north around Port Alfred, but are always targeted when in spawning concentrations. The vessels are normally refrigerated, but a few still operate with only ice. The Sector is TAE controlled and Rights are granted for 15 years

FRAP 22: The fishing season is from 8.5 to eleven months, variable according to catch level. There were 162 applications with 73 A granted, but no B or C categories, though it is believed that small scale fishers are to be licenced to accommodate 366 crew fishing for a total of 2077 boat days from Ski type boats.

The holders granted as As are limited to 29500 boat fishing days with a maximum crew complement of +- 2000. No line fishing may be carried out on these vessels whilst having Squid gear on board.

The method of TAE is by limiting number of vessels and total crew.

POLE CAUGHT TUNA SECTOR

In my opinion, this is a badly managed sector by the Department, which in turn has affected the Rights grants of FRAP 22. There appears to be the mistaken belief that because Tuna, particularly Longfin and Yellowfin, are found in nearly all the temperate and tropical oceans on this planet, that resources found inshore, i.e. say out to 100 nautical miles off the coast, are continually reinforced from offshore resources. However I believe, in common with some scientists, that there is far more territoriality displayed by these two species locality, particularly the Longfin.

As a result, there is the strong possibility of overfishing, and the more remote possibility, as occurred with the False Bay Bluefin resource, that lower numbers may choose to arrive inshore.

However, the Department seems to have decided that there is scope for heavily increasing the number of Rights Holders, despite the obvious fact that many applicants apply just in case they cannot make a plan for their vessel to operate viably in some other resource sector. If they manage to, they then never, or only occasionally fish by pole.

Bycatch of Snoek and Yellowtail are also a potential problem with these two species probably already overfished by the Commercial Line-fish and Recreational sectors. However regulations require Pole vessels to move away should these species become prevalent in their landings.

Rights on a TAE basis were granted for 15 years.

FRAP 22: There were 204 applications and 98 were granted: 37 category A for 43 vessels, 32 B with32 vessels, and 29 C with 29 vessels still to be nominated.

TRADITIONAL LINE-FISH SECTOR

In my opinion, Traditional Line-fish, West Coast Rock Lobster (Crayfish), Abalone (Perlemoen), KZN Beach Seine caught Sardine, other inshore shallow water Net-fish, and Intertidal Resources, should all fall under a division of the Department known as Small and Medium Scale Fisheries. Nearly all their resources are dangerously over-exploited, with illegal exploitation very probably exceeding scientifically calculated TACs, and estimated TAE landings. On top of all of this, most of these resources are legitimate Recreational Fishery targeted species as well!

I believe the calculations used, so as to be allowed to dramatically increase participation through SSF regulations on line-fish, are nothing short of diabolical. Everyone has been aware, the scientists, all fishers, the conservationists, and the general public of the dire non-sustainability circumstances of our resources.

Much the same can be said about West Coast Crayfish, which has resulted in the TAC being reduced to a quarter of what it was only a few years ago. The net result is that Rights Holders’ quotas have been reduced to laughable and unsupportable levels, yet again the SSF legislation wishes to introduce hundreds more Rights Holders!

Rights have been granted for 15 years to applicants individually in one of three Line-fish designated areas, on a TAE basis, whilst appeals are still to come. In the 2005/6, grants reduced operating vessels from just under 800 to 450 limited to 3400 crew, and in those days illegal fishing (IUU) was far less than now. Appeals are still to come.

As far as FRAP 22 is concerned, out of 806 applicants Rights have been granted as follows in one of the three areas to 157 A, 30 B, and 101 C applicants. 122 Rights have been reserved for SSF use.

Now I will start with still valid earlier FRAP grants in other sectors, starting with the most troublesome one, West Coast Crayfish (Mid- and Inshore Rock Lobster).

WEST COAST ROCK LOBSTER

Midshore Crayfish are caught with mainly net-covered largish metal framed baited traps, each tied to a line long enough to reach the ocean bottom in reef areas. They are laid normally by 15 to 18 metre vessels from early morning, and then recovered during the same or next day. The catch may be kept on ice, but preferably landed live the same or next day, and always in a whole state at their nominated harbours. They fish regulated distances from the shore in a pre-determined designated area. The season may run for four to six months, depending on the Departmental authorities and area, or until their Quota is filled.

Frap 15/16 granted 15 year Rights to 2031 to a Quota denominated TAC for 2022 of 351 tons, less than a third of the 2016 grant. There are 255 Rights granted, 1 for 52 tons, 1 for 21 tons, 1 for 12.5 tons, 6 for 5 to 10 tons, 71 for 1 to 5 tons and 175 for .45 t0 1 ton. 88 tons are reserved for SSF Midshore. About 225 grantees will not be able to fish for the whole of their allotted season.

Inshore Crayfish are caught only with Hoop (Ring) nets, and are mainly by 4 to 5 metre dinghies, propelled mostly with oars. They may be as large 8 metres and be driven by single outboard motors up to 30 Horsepower with VMS equipment if over 5 metres. Dinghies may be towed by a vessel to a fishing site in their designated area, but can only launch at daybreak returning by 3pm, and not over weekends. The low Quotas between 130 and 738 kilos granted to 800 applicants are only sufficient to augment a Rights Holders annual Income needs.

LARGE PELAGIC LONG-LINE (TUNA)

Surface Long-line fishing for primarily Tuna species and swordfish, with a bycatch of certain surface sharks (white tip, mako and blue sharks) as well as occasional Marlin and other gamefish, is carried out by setting a normally straight line always at night. This can be from 10 to 50 kilometres and more long held up by floats. Droppers relevantly spaced and normally 15 to 18m long, hang down into the surface waters with a hook on each, numbering anything from 1000 to 3000. These are baited with either squid or mackerel. Anchored radio buoys mark the ends of each line with additional buoys in the centre dependant on the line’s length. Normally these lines are recovered from their starting point almost immediately after been laid. The fish are removed and the droppers rebaited to relay it again. Lines are only set in the dark to avoid seabird mortality. Fishing may only occur outside the 12 nautical mile territorial water line, but usually takes place 100 to 350 nautical miles from the coast, and all year round. It would appear that joint ventures with mostly Japanese vessels is still allowed by special permit. Originally, I believe eight were granted for eight vessels, all of which withdrew when the pandemic hit, with only one having returned so far. The Sector is TAE controlled

Frap 15/16 granted 59 Rights for 15 years for this fishery.

HORSE MACKEREL (MAASBANKER) MIDWATER TRAWL

This sector’s vessels are normally between 30 and 50m with a crew of +- 20, except more for the largest, the Desert Diamond. They operate a modified bottom trawl net which is then set to pass through the middle water column between the bottom and the surface at a predetermined depth. These large freezer vessels remain at sea for up to 40 days, packing their catch on board. There is no seasonal limitation.

Frap 2016 granted successful applicants the Rights for 15 years.

Present TAC is +- 30,000 tons, which I have as yet being unable to confirm exactly for the current year 2022. Neither have I been able to get a list of nominated operating Vessels, with the exception of the largest, Desert Diamond. The season is year round, or until the individual vessel’s Quota has been landed.

There were an unknown number of applications, with 10 A, 12 B, and 7 C granted back in 2016. There are certain regulations regarding bycatch which are of insignificance relevance to the fishery, apart from a maximum bycatch of 500 tons of Hake.

Many of the Quotas are insufficient to keep a vessel fishing the whole year.

INSHORE HAKE, SOLE, AND BYCATCH

Rather like the small pelagics’ Sardine, originally this shallow water benthic trawl sector was managed by way of quotas to catch Sole with Hake the prominent bycatch. Today, with somewhat larger vessels, which may not exceed 30 metres, it is possible that the sole has moved to shallower very small areas where it is not practical for these larger vessels to work. There is no credible scientific evidence that their diminution has been or is caused by over fishing. The hake quota for 2022 is 7725 tons with the Sole only +- 340 tons, with a further valuable 15% bycatch of total landings. Most fishing take place inside 40 kilometres from the southwest and southeast coasts and Rights are valid until 2031. This is another example of many fragmented quotas that will not support a year round season that applies to this fishery.

Frap 16 granted 15 remaining A Rights of which at least 8 are insufficient, 11 B rights all insufficient and 4 C Rights likewise.

PATAGONIAN TOOTHFISH

Toothfish are found fairly extensively in the Antarctic and Southern Atlantic Oceans, are the largest of the Seabream species frequently weighing over 200 kgs, very slow growing, and, as a result, were soon determined as easily over-exploited. Their fishing is tightly controlled by International agreement both in territorial and oceanic waters. However, because of the mainly distant waters in which they are found, their illegal exploitation abounds.

SA has licensed three Rights in its territorial Prince Edward Island waters, though, by agreement only one vessel operates for all three. The Rights were awarded for fifteen years in 2016. I have not been able to access accurate details for this fishery.

INSHORE OCTOPUS

Various species of Octopus are found in our inshore, Midshore and offshore trap, bottom trawl, ringnet, and Intertidal fisheries, and were originally all considered as insignificant bycatch. Since 2003 various experimental licences were granted at locations extending from our West Coast to KwaZulu Natal. Recently Octopus was added to the basket of intertidal Small Scale Co-ops species that could be harvested there. (These Co-ops have reportedly never really developed into anything permanent as has been the experience elsewhere along our coastline. Where they have managed to stay in existence, control thereof, combined with infighting, corruption, and illegal fishing, have contributed to the questioning of their practical validity.)

These experimental activities extend to the present, though I am unable to determine their current development or status. I am only aware of one operator, wrongly accused by the inevitable “greenies” of been a serious threat to our coastal fast growing whale population, who continues to operate here in the Western Cape. Once again I am unable to glean any further information.

KZN SARDINE BEACH-SEINE NETTING

When the KZN spawner Sardine migration hits the Province’s beeches, all hell breaks out as the Rights Holders descend on the relevant beaches with Truck, Trailer, Boat, and seine-net. A party is had by all, including tourists, both local and from overseas, joining in the festivity of hauling in the net that has been set around the shoal or part of it. However only around ten of the 30 grantees seem to regularly pitch up, and it is common knowledge that some of the grantees own neither net, nor boat with which to lay it. Despite this fact the last Frap 16 set aside a further 45 licences for anticipated Community Co-ops in the Province. Neither I, nor anyone else that I can discover, seems to know whether even one such Co-op has been identified. What must one say?

INSHORE AND SHORE-BASED NETTING

This fishery has long been a potentially serious problem in my mind. However, I must immediately admit that my knowledge of its extent and results is minimal. In addition I am, despite my interests in that direction, no scientist.

However, I have spent much of my life fishing in False Bay, and all along its coastline from the shore. As a result I will lay my head on the block with utter conviction over two matters. Firstly that the Harder (Mullet) resources, both in our Bay and along the immediate West Coastline, are but a fraction of what they were in my youth, and this applies to several other species as well, such as White Steenbras, White Stumpnose, Sand Steenbras, Yellowtail, Elf (Shad), and Kob. Not for a single moment, would I blame solely Trek-netting (Beach-seine) for the problem, but do believe it has been one of the major contributors to the serious over-fishing and diminution of these resources. Also, this particularly applies in respect of the substantial bycatch of their juveniles. Since my youth promises, firstly to curtail, and then progress towards the final removal of this practice, have achieved little in 60 years, other than to see corruption and the illegal fishing of them increase dramatically.

Frap 2006 granted Rights to 4 holders in Port Nolloth, 12 in the Cape Peninsula area, all trek-net licences for predominantly False Bay, and 112 for mainly drift and set net licences for St Helena Bay including a few for Saldanha. Their catches would be 90% Harders, and I have not being able to ascertain how this might have changed for Frap 2016.

ABALONE (PERLEMOEN)

The overriding problem with the Abalone resource is the enormous amount of illegal (IUU) exploitation that occurs, believed to be ten times or more than the permitted Commercial fishing TAC of just under 100 tons per annum. The TAC is fished from small craft, frequently outboard driven Rubber Ducks, manned by two to four scuba divers with the related equipment. There is a minimum size imposed on these extremely slow growing organisms, which only reach spawning maturity after 7 years and can live 25 or more years. About 260 individuals and 40 entities enjoy relatively small collection rights. No harvesting by any other party, recreational or otherwise is permitted. Right grants are valid to 2025, and they are mainly harvested from Saldanha Bay on the West Coast, around to Cape Infanta on the South Coast.

Today, a large and increasing amount of abalone is mariculturally grown in artificial marine pools constructed adjacent to the seashore. This infrastructure represents a very large investment of capital with no return thereon for 8 to 10 years. These farms are now being encouraged to undertake wild resource seeding, though it is too early to yet assess the effectiveness thereof.

SUMMATION

As already noted, the structure, many of its personnel, and the infrastructure of Branch Fisheries needs either a complete upg.rade and/or restructuring. This is the suggestion I make in a book I am busy authoring. It will take time, just as destruction has, but is essential to see pragmatic logic returning to its management and financial control. Clearly our Minister’s background shows she certainly has the ability to lead the way in these endeavours. Then once again, we should achieve the financial gain for our country together with Job creation and resource sustainability from these most important natural Marine Resources for the benefit all South Africans.

There must be many people at the Department, who must have worked long hours to have produced a much better organised Frap this time around, particularly when I remember the time restraints that earlier problems had influenced circumstances. One also gets the feeling that those delays did not emanate from the scientific fraternity, other than to remember that good scientific advice is often accompanied by a certain lack of good common and fishing sense to go with it. (This comment is admittedly made with a bit of tongue in cheek, but not wholly so!).

Yes, the concept of affording better access and usage of these resources to our coastal communities, whose very history is steeped in them through their past exploitation thereof, is absolutely relevant and right! However, one cannot undo the harm that has politically been foisted upon their management over the past nearly thirty years for the benefit of their political elite, instead of those people. Nor can you in any way determine, just for political expediency, that their sustainability, already severely compromised over the past two decades, and even partially before 1994, should now be further damaged!

Does nobody in Branch Fisheries understand that you cannot just change the current circumstances other than at too great a cost, because you are told to? During the past few years, it has politically, I presume, been engineered to both grant and further promise thousands of people and entities exploitation rights for either corrupt or expedient reasons. These include all the promises to SSF fishers for access to hopelessly over exploited resources which threatens to probably damage them irreparably, like Crayfish Interim Relief. Yet there are no less than 165 Category C grants which can only be for the wrong reasons, and 102 Category B grants, I suppose to try to make up for all the inadequate grants made in the past. Can anyone really believe that such haphazard and illogical thinking can ever be justified or lived with?

Of course there are cases where it is not entirely illogical to see the combination of differing sector Quotas on one vessel, such as Deep-sea and Inshore trawl, or larger Deep-sea vessels with Horse-Mackerel Midwater trawl. Mixing up grants from any of the other sectors onto one vessel really shouldn’t be considered anything but a costly inconvenience. It also has the effect of seriously complicating the Departments management procedures, let alone much needed, and presently ineffectual Compliance.