Who should (be allowed to) catch what?

As many friends and associates know by now, I am very passionate about the Marine Environment and all that lives in it. However I do not, like so many so called Conservationists, Climate Change Activists, and, unfortunately, Scientists, (all those voices of doom!?), fail to remember that Mankind is meant to be, and is, the dominant species. Though a predator of undoubted note against most other natural species and circumstances of this planet, his needs must be catered for as a first charge as pragmatically as possible not only for his required food, but in many other respects as well. This calls for a balancing act, the recipe for which still clearly eludes us.

What can we do about our frightening population increase year by year, decade by decade, and century by century? Are you aware that as recently as 100 years ago, the world population had probably not yet reached a (1) billion? Now we know it to be between 7 AND 8 BILLION. Should it not be our most important task to see how we can arrest this problem, when we already do not have the ability, or apparent will, to feed all that are here already?

Abalone

Then take Climate Change, a cyclical event repeated many times in the history of this Earth, where we believe that we mere mortals could now change the inevitable. Yes, we should try to minimise the discernible harm we add to our environmental circumstances, but surely much more emphasis should be placed on how to prepare for these changes, instead of just considering whether we can live differently in the vain hope that this might break the cycle. It is an obvious case of man proposing, but only GOD or Nature disposes.

Well my interest is in trying to get the Authorities, or, perhaps more realistically, to motivate every body’s support and action to get them to appreciate the absolute need to protect and nurture our valuable Marine resources.

Some 70 years ago at the age of twelve, the writer, having already learnt its potential for great excitement, fun, and success satisfaction, first realised that fishing also had an even greater potential as a source of hard-to-come-by Pocket money! And the die was cast! In fact, after I left school, it was six years before my monthly salary for the first time exceeded my average fishing income from line fishing in False Bay.

Sardine Shoal

There were fish in those days, once you learnt the necessary about the weather, water temperature, and other skills, to the extent that now I sometimes wonder if the passage of time and my advancing age do not exaggerate those memories. But of course they do not! Many days we caught very little, but that was the result of youthful impatience and optimism, despite knowing that the conditions were not right! Many other days we loaded up until we could carry no more, and such catches were often greater than many of my younger friends today would be delighted to land in total all summer.

In my early twenties, I decided that, to be a ‘compleat’ fisherman, I needed to understand the science of fish and the behaviour of the different species, and, under the influence of one of my closest friends, a University lecturer in Natural Sciences, began their study accordingly. As a result, I can claim to have been one of the first to warn of the demise of the then “South West African” Pilchard (Sardine) resource, and definitely the first to blame human disturbance in part for the inevitable event. This hobby has then developed into a moderate understanding of Fisheries Resource Management as well.

The need for conservation of Marine Resources was an unknown concept in those early days, and fears of over-fishing in South African waters were only first considered by the then Director of Sea Fisheries in the late fifties and early sixties. This only arose in relation to the enormous landings of sardine (Pilchard) and maasbanker (Horse Mackerel) by the Pelagic fleets of Walvis Bay and the Cape West Coast. Worldwide, fish resources were then considered impervious to over-fishing, in some cases due to their resource’s perceived size and in others their wide distribution.

The International Game Fishing Association (IGFA) first recognised that recreational fishers’ landings, combined with those of the commercial fleets, might be a danger to the strength of various pelagic and demersal resources, due to diminishing Bluefin Tuna and Swordfish stocks. At more or less the same time, International Marine Scientists became aware that Cod landings in North Atlantic waters and Menhaden in Southern USA waters had started declining alarmingly. Here in South Africa, our scientific and sport-fishing communities (the latter led by Hymie Steyn) only really began acknowledging the risks of over-fishing and the need to act accordingly in the seventies, whereafter scientific evaluation began in earnest.

In the late seventies and early eighties of the last century, those South African scientists who concentrated their research on our Inshore Marine resources, began to warn of the risks of over exploitation, and, firstly in the case of West Coast Rock Lobster, began considering the need for more attention to the need to reduce catch levels. They also recommended reducing exploitation effort on traditional Line-fish multi-species landings, and an increase to the minimal regulations that existed for those species at that time. By the nineties, their cries were becoming desperate, supported by such organisations as SAMLMA, whilst the authorities prevaricated and applied very few new restrictions. At the time of the millennium, with matters reaching a critical stage, the then responsible Minister finally declared an emergency for line-fish exploitation, gazetting regulations, which had been already recommended by the scientists ten years earlier. Hardly surprisingly, these have not proved particularly effective, thus inevitably failed to achieve the emergency’s intentions.

I recently penned a book in the form of certain memoirs of my fishing life. (https://www.jackwalsh.co.za) As one of my main motivations was to emphasise our need for Conservation and Management both to rebuild and to ensure future Sustainable exploitation of this country’s wonderful Marine Resources, the last third of the book dealt with just that. They were my personal views on how this may be achieved as, though not necessarily always right, I do have a full lifetime of experience in those fields. However the decision was that I should not mix oranges with apples, so I left that section out. However, I must be true to my beliefs, right or wrong, so here goes with that omitted section!

Unfortunately, there is no doubt that, with very few exceptions, nearly all our inshore resources have been overfished for years, and have already declined to crisis levels. The new set of Regulations that was promulgated in 2000 did result in Commercial Line-fishing Rights been considerably reduced. However, it very soon became apparent that, despite these moves, the new quantitive regulations totally failed to halt their decline, as was .pointed out by both the authorities themselves and many other parties including the writer. With many Line-fish species already on the “Endangered list” and many other Line-fish and other species from the intertidal zone to the nearshore waters deserving to be placed there, whilst others were acknowledged as being seriously over exploited, what exactly has our department achieved to try and arrest this situation? Perhaps it would be best not to even answer that somewhat rhetorical question?

Those resources have been further threatened again for several years by a now irrationally split department, with one half (that of management) tacked on to Agriculture and Forestry, and the other (not too sure what they do) to Environmental Affairs. Coupled to this, Branch Fisheries stated intention for the last few years is to hugely expand Exploitation by granting additional Small Scale Fishery rights to an estimated 30,000 coastal community individuals on already over-exploited resources.

There used to be one Department under the Ministry of Tourism and Fisheries, but it was certainly logical to create a dedicated Ministry for Tourism, a potentially very important area of growth both for our Foreign Exchange earnings and Job creation. Surely it would be just as logical to have a separate Ministry for Fisheries, including the Maritime Environmental side, for exactly the same reasons, and due to the fact that our Fisheries’ resources are one of our country’s most valuable natural assets. Apart from increasingly poor management control, the inevitable elephant in the room is the fact that the responsible Authorities have never developed an effective Compliance structure, and still show no signs of overcoming the problem. Surely, with the right will and experienced personnel, a Department of Sea Fisheries in its own Ministry could be built with the main structures of Deep-sea resources, Small and Medium Scale Inshore resources, and Compliance and Control, with secondary structures dealing firstly with Science and Environment, and secondly Rights allocations and Permits.

I have been complaining about this idiocy of this split for years, but no one listened even as the sector slid further and further into chaos and ineffectiveness, corruption and incompetence. This scenario was not helped by the successive appointment of some of the most useless ministers and overall management with nil experience of the Marine environment. Finally, thanks to CR’s efforts to reduce bloated, and in many cases unnecessary government structures, the Department has moved from the Agricultural Ministry to Environmental Affairs. Why Forestry accompanies Fisheries is difficult to understand, but, irrespective, Fisheries can now be reconstructed incorporating that sector that was so strangely removed from that Department. Furthermore, they can once again become responsible for their own Marine Environmental decisions, for which they alone have the overall expertise and associations. Finally, I am told that this Ministry has been gifted with an honest, highly competent, and hard-working Minister, who will make her decisions based on relevant input, not political expediency alone.

A further typical existing irony is the present order for three Multipurpose Patrol vessels for our Navy to, amongst other duties??, assist with Fishery Resource Protection! One must remind readers of the fact that it was only a few years ago that, after a year of so-called preparation, the Navy admitted that they did not have the ability to man, run, and maintain, such vessels originally built for Fisheries. These, for the most part, still remain un/underutilised, and, anyhow, what about the availability of so many other vessels in their possession? Are we able to afford such stupidity and one wonders what part or who of the ANC hegemony is benefitting illegally?

There actually is no problem with the principle of spreading fishing rights thinly amongst Coastal Fishing community members in undeveloped countries as proposed by the FAO. I have always been in favour of it myself. The problem is that we are only partially an undeveloped country with a mature and, for the most part, a well regulated, mainly by the stakeholders, Deep-sea Fishing Industry. This used to apply to our largest Inshore Resource of Spiny Lobster, (Crayfish) as well. Unfortunately it is presently, like the second biggest Inshore Resource Line-fish, heavily over exploited, and anyhow subject to long term rights granted to many holders who have held them for many years.

Following on the above and my recent articles about the status of our Marine resources, and the present ineffectiveness of Branch Fisheries and our Environmental Ministry to both manage and control them allowing only their sustainable exploitation, where should we be going towards these ends, whilst at the same time trying to consider the practicality of Small Scale Fisheries.

Where now is this intended development of The Small Scale Fisheries Initiative, clearly motivated by National Government in line with their recently stated new? policy of forced Economic Transformation. One thing that is definitely lacking in its progression is meaningful Communication from the department with all stakeholders, including the 30,000 or so ‘would be’ small scale fishers. It may be, of course, that the Department is appreciating the cost and improbability of their ability to keep another of government’s delusional promises once again!

They then wish to do this by empowering groups of individuals in the form of community cooperatives. Do the powers to be really believe this will achieve anything but further opportunity to cheat on the outcomes both monetarily and exploitation wise. Equally, where will the responsible Fisheries Department, already mired in like conflict, find either the money or the human capacity to develop and administer such structures? Unfortunately, our history of the past two decades is one of unbridled excesses in the form of increasing general corruptive and criminal action. This applies to the ANC elite hierarchy, right down to the lower echelons of government employees. Therefore, one must conclude the integrity of nearly all South Africans of all races has plummeted to dismal lows.

Social and economic transformation was inevitable in a society that had to change as much as ours has, but equally would have occurred by natural evolution helped by enabling Legislation, as opposed to ‘forced’ Legislation. Would that we can now hope only for such enabling legislation, rather than to see the threatened Economic Transformation applied to an industry that probably evidences the highest level of Transformation in the country! It is an industry I have always loved and proud to have been part of, although its administration has left much to be desired for as long as I can remember, certainly from well before 1994.

The destruction and ‘forced’ transformation of so much of this country’s infrastructures, particularly by black economic empowerment in respect of jobs, has dramatically reduced our economy, delivery ability, and productivity. This has reached a level never contemplated at the time of the birth of our then intended, but now failed, “Rainbow Nation” by the realistic and capitalistic members of our society, be they black, brown, or white. They, and we all, appreciated that the socialistic nature of the stated policy of the ANC in the form of their NATIONAL DEMOCRATIC REVOLUTION would considerably alter our future, but few under Madiba’s reign, including the writer, could ever have imagined the extent of our downwards slide that might even still have a long way to go. Let us Pray that this is not so.

Let us be aware of both the inevitable and necessary advance of continuing transformation, but in a realistic light of pragmatic poverty alleviation of fishers and their communities without depriving legitimate historic rights holders of their livelihoods as is occurring with FRAP proposals right now! By all means consider and then look at the population make up by race groups, as the Government is wont to do, of the existing communities only, to establish as fair a distribution of rights as possible amongst all future participants according to the numbers. Let us then look to Government’s sought after Economic Transformation only when and where it is genuinely possible. This could then be applicable to the Small Scale fishing industry in the Western Cape, Northern Cape, and Eastern Cape, all of which encompass about 95% of South Africa’s inshore landings.

However, again let us not forget that all along it has been stated, yet frequently not acted upon, that historical and existing participants in a fishery with the necessary experience and/or qualifications will be a mandatory requirement in assessing their right to apply for a licence. Let us do away with the present descriptions of SSF and SME bundling them together as SMALL SCALE FISHING RIGHTS ON INSHORE RESOURCES. These shall only be granted to qualifying participants who may, after the granting thereof, be entitled to join together cooperatively, as generally understood in the SA business environment. They should be entitled to market their catch directly themselves or contract it to a licenced distributor. Let’s drop the concept of formal community co-ops or community committees managing and controlling successful applicants from a specific community. It will just not work unless it is formed voluntarily by the participants in due course again by natural evolution of the circumstances. Anyhow, as asked before, where would the money have come from to fund such setups and the education of the needed workforce on the original scale envisaged by the Department?

In the interests of spreading the opportunity to make an acceptable living for as many individuals as possible, the question of the magnitude of a right, or basket of rights, to ensure virtually an annual income will become cardinal to the issue. The next question is WHAT these existing and new rights holders will be ALLOWED TO CATCH/HARVEST and HOW? The ‘how’ can be debated later, but here goes with the ‘what’:

Certain baits, white mussels, oysters, abalone, seaweed collection, inshore crayfish with dinghies and ring nets, line-fish from the shore or from a boat.

However, BEFORE THIS CAN BE CONTEMPLATED, a proper Compliance Structure must be planned, setup, and the necessary personnel identified, acquired, and adequately trained to do the job. Its HUGE importance renders it unnecessary for me to apologise for harping on this matter so often in this article!!

IF YOU LIVE BY AND FROM THE SHORE, YOU SHOULD NEVER GO HUNGRY! Please forgive the partial plagiarism and let’s seek to make this true for as many as possible. (But not 30,000 I’m afraid to have to say.)

In accepting the current status of our Marine Resources, and the present ineffectiveness of Branch Fisheries and our Environmental Ministry to both manage and control them in regard to their sustainable exploitation, where should we be going towards these ends? This is predicated on the basis of that failure, which is particularly applicable to the INSHORE RESOURCES, my speciality and greatest concern. So let us first look at the various sectors, both the existing as well as that perceived for the future in the form of Small Scale Fisheries. With Sustainability having to be the keyword, maybe this may help to guide us towards a pragmatic and acceptable solution in all South Africans’ best interests, whilst allowing as far as possible for the Government’s stated desire of Economic Transformation of a “cake” that is in no way big enough to satisfy all presently participating and “would be” parties.

There are three major sectors, and eight smaller Commercial sectors which we will deal with last. This section will cover Recreational, then Spiny Lobster, and the next Line-fish which is so wide reaching.

1. THE RECREATIONALS: There are approximately 250,000 recreational permits issued of which some 30,000 fish from boats, and it would probably be conservative to estimate that there could be at least twice that number of unlicensed participants. Obviously only sea water anglers are considered here.

A 2007 Economic Impact Study produced figures for participants and boats far in excess of the above, which must be considered somewhat suspect, though the subsequent value calculations, particularly when the last ten years inflation is adjusted for, are probably pretty close to the truth.

Operating from the shore, in estuaries, and from boats, they are partially controlled at best by regulations specific to them primarily by way of Catch, Bag, and Size Limits. Certainly in the past they have been one of the main culprits in overfishing Line-fish resources, until they started waking up to what the real application of Sustainable Exploitation actually meant. Finally, really only since just before the turn of the century, the penny dropped and many a recreational angler now considers the protection of all our inshore species a priority, especially if we all, let alone our successors, want to continue the very enjoyable and rehabilitating sport of fishing.

Today, more and more anglers practice the principle of catch and release, keeping only what their family would eat. Furthermore, they increasingly also release mature large fish whose fecundity far exceeds that of the more average or smaller sizes.

This sector, much as commercial fisheries would disbelieve it, may well be the most valuable in terms of GDP generation when one remembers its importance as a tourism magnet, and the huge number of local participants from all sectors of our population, all of whom spend continually on tackle, boats, and bait. This creates thousands of businesses and hundreds of thousands of jobs in the manufacturing, retail distribution, and operational activities, right down to artisanal type SME bait collectors and guides (gillies).

Can anyone, as they have both in the recent and not so recent past, legitimately and logically ask if Recreationals should have access to inshore resources? Surely that is a rhetorical question? They should have priority including on all intertidal, nearshore, Spiny Lobster, and Abalone, resources. A la Trump, despite his being hardly a favourite world leader, “Please put South Africans FIRST.”

However, as important as they are, they have to accept that their landings have to reduce. As with developed countries, peer pressure can, and must be brought to bear, coupled with education. On that latter front, our written publications can hardly be faulted, our Angling Clubs could do much more, and, in respect of the former, our social electronic media participants, in the form of so many fishers, are starting to have a wonderful effect by shaming transgressors.

As far as regulations are concerned, it is difficult to understand why any Recreational Angler should be allowed to land more than five fish per day, (or maximum twenty per boat). We know the Boat owners will cry foul and point out what their sport costs them in investment and running costs. What has that got to do with it? If Golf costs you more than you can afford, you don’t take it up! Why should boat angling be any different? Then, as in KwaZulu Natal, boats should only be allowed to depart and return to a Registered Landing Site, private or public, to enable improved compliance. Furthermore Clubs, NGOs, Resorts, Municipalities should assist with Compliance. Lastly, with certain exceptions such as Crayfish, Abalone, etc., why have a size limit for Recreationals? On the basis of the juvenile mortality rate expectations of nearly every species, it will do far less harm to the resource to remove five undersize Kob or one undersize Steenbras rather than a fully mature adult of either species. Also then compliance as to only numbers will be far simpler!

Clubs should not accept members with Commercial licences and all Recreational boat fishing should be banned at night, not just in the Breede River. With further thought out innovation, there could many other practical conservation methods to reduce catches, but the best of all will always boil down to the willingness of the participants themselves to conserve for the future generations.

2. SPINY LOBSTER West Coast: Including Trap boats, the quota allocated to Commercial licence holders is 736 metric tons; in addition approximately 2000 individual Small Scale ‘Relief’ permits are theoretically allocated 163 tons, SSF Cape coastal region 144 tons, and Recreationals are estimated to land 39 tons. Unfortunately, as with nearly all our inshore resources, illegal fishing (poaching) is rife with the common belief that such landings probably even exceed the total allocated quotas of 1084 tons.

For the purposes of this article, although I mention Trap Boats, I actually believe they belong to the deep sea operations. The traditional Cape Kreef (Crayfish) has faced annually reducing landings for as long as I can remember, after the scientists realised measuring landings was a necessity. At the same time realisation that catches seemed to be reducing steadily from the North, southwards, was recognised. The real reasons for the decline in the resource are, I fear, far from certain. OVERFISHING, catching more of the resource than its ability to replace those caught by normal reproduction, is certainly one of the main reasons, but not the only one. To the best of my knowledge, a diminution in their food supply chain is not evident. Then that apparent southerly migration, or, alternatively, the resource’s failure to replace seasonal landings through reproduction in the northern areas of our relatively lightly populated West Coast, begs further questioning with few answers. After all the environmental conditions there have not changed, despite the very real global warming for whatever the reason for it.

What then? I have always believed that our scientists consider far too little the fairly logical conclusion of man’s harassment of Marine swimming resources, (Yes Crayfish do swim!) and their susceptibility to move away from it. The False Bay family of Bluefin Tuna is a good example, as they certainly were never all caught!!

Presently the issuing of quotas/licences is in complete disarray which again underlines the fact that the department actually has little pragmatic understanding of its own intentions brought about by the confusion surrounding commercial and SSF exploitation both internally and with many of the existing participants. Then again co-ops are expected to satisfy most of their problems which unquestionably will not happen. With current scientific advice ignored by Branch Fisheries, and their total inability to apply any form of effective compliance control irrespective of the validity of questionable regulations, to what are we condemning this Resource? Once it was one of the mainstays of our commercial fishery now becoming a fading memory instead of guaranteeing so many coastal communities a stable living. Instead there is this initiative of Small Scale Fisheries’ somewhat, to put it mildly, impossible dream of supporting many more thousands of participants. Will the Authorities not accept that the cake is too small, whilst still eroding further year by year?

In the name of ‘forced’ Economic Transformation, as opposed to natural inevitable Transformation, you may be able, as they appear to be doing, to do two things: take away current inshore commercial quotas and limit true commercial exploitation to its off-shore component by allowing only trap fishing restricted, as applicable, as to distance, depth, and location. Then you could allow the inshore resources, with great caution, to be exploited by very limited SSF individual Daily/Weekly/or Monthly numerical Quotas saleable only personally, or to Nominated Distributors with controlled pricing. At the same time allow Recreationals a daily numerical Quota only for personal consumption. Of course none of this is possible without highly effective compliance control together with social co-operation, or is that just wishful thinking?

Then what reaction can you expect from the existing Quota holders to the news that theirs will be cancelled. I hate to think, and am not Solomon, so unable to propose a solution. But, once again the cake is just much too small, Mrs Minister!

3. INSHORE LINE-FISH, Demersal, Semi-Pelagic, and Pelagic: There seem to be between 10,000 and 15,000 Recreational Boats with Licences, mostly ski-boats including some 200 to 300 larger sport fishing craft, estimated to land 4000 tons annually, with a low degree of accuracy. To this must then be added shore based landings of again 4000 tons, probably an even more uncertain estimation. Then there are 455 Commercial Boat Licences with another 87 “so called” hake line boats who today have forgotten about hake, which was never going to viable and now only target line-fish. The commercial line-fish boats are believed to land around 8000 tons annually, which, because of the licence conditions, is likely a more, but not fully, accurate figure. Out of interest about 75% of boat line-fish landings are Snoek, to which you must add approximately 4000 tons of deep sea trawl bycatch landings of this specie. Now add in the 10% bycatch landings by the inshore trawl fleet of many species of line-fish which could total 2200 tons, and mainly harder targeting trek and gill-net fishers, including illegals, accounting for maybe another 1750 tons of inshore species other than harders.

How accurate are these suggested figures of mine? Well I have no idea but neither does anyone else because the Department is now only trying to put together combined line-fish landings by all sectors in order to try and establish viable and sustainable access for SSF fishers!! What I do know is that these possible total of Landings of 24000 tons must be completely unsupportable from a resource that has been shrinking year by year probably from the 1950’s onwards, with minimal improvement to one or two species only, following the declaration of an emergency in the fishery at the beginning of this century. This led to the promulgation of more stringent regulations coupled to a reasonably successful reduction in fishing effort. However these combined actions have had no effect, probably partly because of the departments hopeless record of compliance control, but mainly simply due to unsustainable over-fishing.

Here we are perhaps at the crux of the matter when one considers BRANCH FISHERIES stated objective on behalf of National Governments to create a Small Scale Fishery. This will surely only be practical in the scenario of placing all Inshore Resources relevant to it under one body. This must then collate all information about them, such as establishing quantitive availability thereof, and control of their exploitation on the basis of both full-on Commercial exploitation and maybe Small Scale individual permits somewhat in the form spelt out in the Crayfish Section above. Pragmatically speaking there is a need for both. Then the criterion of who should be allowed participation will have to be very carefully and precisely determined, to avoid the mistakes of recent years.

Since the turn of the century the dual problems have been encountered of quota or rights awards to people who have had no association, let alone experience, of the fishing industry, naturally followed by the exclusion of many with a history of generations, let alone years, of participation, who suddenly found themselves dispossessed. Of course there will never be sufficient resources to award all deserving applicants which is why so much care and transparency must be exercised!

It is a simple and widely appreciated fact that nearly all, with only a few exceptions, inshore resources are hopelessly over-fished, resulting in most of them having reached critical biomass levels. Even the Department recognizes this fact, which is, one assumes, why they continually delay “would” be participants with the excuse that the required Legislation to empower the 30,000 or more coastal community members is still a long way from reaching fruition. The principle of this empowerment is based virtually wholly on open availability of both line-fish and equally overfished crayfish, which is nothing but a myth unfortunately, like so many of our current Government’s promises since the millennium.

However this is not a political article, but rather as near a factual discourse as possible in order to evaluate what we are doing, both right and wrong, what we should be doing, and what we might be able to do to try to reasonably give effect to Government policy, whilst keeping the fisheries sustainable at the same time. After all we still need a degree of normal Commercial Line Fish landings to at least satisfy Tourism demands through our restaurants, as expected of a country with such a wealth of coastal Marine resources. We also need, as I think was adequately motivated in Para One above, their availability to the so important Recreational Sector for the same reasons. As far as an acceptable level of landings is concerned, we first have to admit, all of us, both the authorities, stakeholders, and the scientists, that current regulations and practices have failed miserably, so that regulations need to be re-thought if we are to bring landings down by all the main exploiter parties.

For instance I have always believed that the protection of size limitations in order to allow a fish to reach spawning maturity is simply a waste of time, other than in the full Commercial scenario where mostly number limits cannot apply. However by all means prohibit the landing of fully mature individuals by maximum size regulation, but again it is difficult to see how this can be applied commercially.

Then drastically improve regulations logically and sensibly. I, for instance, never fail to be annoyed by the sheer stupidity of seeing no restriction placed on the Commercial landings of certain species noted as over exploited on the SASSI red, yellow, and green list which Branch Fisheries, that is the GOVERNMENT, claims it whole heartedly supports!!?? However the Recreationals are correctly limited to catching one or two of such species. Can we not be logical and agree that if most parties reasonably agree that a resource/species is over fished that we firstly apply the same catch limitation to Recreationals and Commercials alike, and secondly ban their sale as with all species placed on the Recreational List.

Then we come to the circumstances of trailer launched fishing craft, both Commercial and Recreational in the light of the precarious state of our resources. As stated under Section one, no vessel should be allowed to be launched other than from a registered launch site, whilst commercial vessels should be restricted to more specific of the registered sites where controls are always present, with each vessel being restricted to launch and land at one site only. Again with the need to restrict effort and therefore total landings to a sustainable level, the practice of trailerable craft being able to follow any shoal or concentration of fish, until it is virtually annihilated, has to cease forthwith. Such a limitation will at least ensure that the local registered vessels will do far better from its presence until it moves on. In addition it will discourage applications for licenses for venues whose fish presence in the area is not strong enough to support commercial activity, thus allow hopefully the area to recover.

Then again there is far too much circumstance of allocated rights holders either not using them or allowing some other person to use them enjoying a rake off. This should never be permitted in the case of inshore rights, and present legislation deems it so but it is seldom enforced. (Compliance again). Secondly, if a right, permit, or licence holder breaks the law by ignoring a regulation, instant cancellation thereof should be, and is in many instances obligatory, but again is not applied.

All in all, the imperative for line-fish must be to reduce catches much further from their present levels. Recreational boat fishing has been for many years now on the decline for both economic reasons and the fact of the declining availability of fish. It probably peaked in the late nineties of the last century. Then again the number of commercial licences needs to be further curtailed, which will automatically happen through specified specific landing sites which will require to be evaluated to determine the maximum practical number of operators that could viably be expected to fish there in terms of resource availability and market.

I am not incidentally in favour of banning entirely the catching of a species, no matter how threatened it may be, for then you lose sight and the ability to evaluate its further decline or recovery. The Seventy Four is a good example of this. Once again this only emphasises the absolute need for effective management control through an efficient compliance structure. Mankind is too greedy and dishonest for this to be ceded to the participants themselves, which is simply a pipe dream so that Branch Fisheries can avoid the responsibility. However good social education, towards the need for the necessary support from the Community would go a long way to help the situation of Compliance, but never ever replace it.

I am equally sure that if a lot of experienced people, fishermen, scientists, and management authorities, put their collective minds to it, a lot more innovative and practical ideas would be forthcoming in order to preserve our disappearing resources, Our failure to do this will simply result in natures own ability to prevent extinction, which probably only it, not puny mankind, can cause in the very protective and unfriendly (to us) environment of the sea and oceans. As with several species already, there will be simply not be enough left for it to be worthwhile to try to catch them. What a sorry day that would be!

Let us now consider those secondary, but just as important, smaller Inshore Resources and sectors, some of which are probably not practical for small scale exploitation such as Squid and Octopus. There are also other sectors which should probably not be allowed in the interests of protecting the overall eco system of the marine environment, such as most trek-netting and all gill-netting activities. So here we go again.

4. TREK-NETTING (Beach-seine). 4 licences are for False Bay and 15 for the West Coast, with 20 for KwaZulu Natal.

The sentimental attachment to one of the oldest forms of fishing, particularly in the Cape, is understandable. However even more critically important is the extreme harm that this fishery does to all resources by inevitably landing juveniles as bycatch, as well as highly vulnerable and protected species. For sentimental and possibly tourism reasons, perhaps the oldest family participants at Fish Hoek beach should be permitted to continue for a limited time of the present generation, as the last generation to be so licensed.

The position in KwaZulu Natal during the annual sardine run, is very different bycatch wise except for three specific multi-species permits, which do great harm. Subject to continuing scientific evaluation, this form of exploitation, which is the sole effort on this frequent migration of that species, should be allowed. This activity contributes considerably to local work opportunity, the economy, and as a tourist attraction. There however remains the apparent strange situation in that it appears that only 50% or less of 30 allocated rights holders own nets, and have therefor ever fished?

5. SET/GILL-NET FISHERIES. The incredible situation exist that no less than 112 individuals are granted Set-net or gill-net rights, with a further 45 said to be reserved for SSF.

It is extremely difficult to understand the motivation that results in the issue of so many set or staked net licenses. They do similar and more damage compared with trek nets, as they are left for hours in a particular location. The disturbance caused by entangled fish literally drives all other fish away from the area.

Another good example of this, further exacerbated by the presence of fish traps, is the Kosi Lake System in KwaZulu Natal, where all types of landings, recreational and artisanal, have been declining for years. Such low levels of artisanal landings can have little effect anymore on the fortunes or food supplies of the local populace, and should surely be able to be phased out with a bit of innovation and imagination by substituting some other more meaningful type of employment for the present remaining participants. In the case of Kosi, the increasing eco- and other tourism attractions of the area mitigates against removing recreational fishing, though there is little doubt that the whole system could do with a period of rehabilitation in respect of its finfish and other marine species.

In general, along the whole South African coastline, the above comments are equally relevant in respect of local licence grants in every area. The control of their activities, which are anyhow extremely difficult to police, is well nigh impossible, whereas nearly if not all of the other inshore species caught are already heavily over-exploited and most of them are not allowed to be sold. The one exception are harders (mullet), the normal claimed target catch of most trek nets and gill-nets, which unfortunately often only make up a small proportion of the catch. With all due respect to the scientists, this is one of the most poorly researched species, so that no one really knows the true condition of the resource. Any coastal, estuarine, or beach fisherman, will attest to the fact that this very important part of the coastal food chain is severely depleted in terms of its visible presence compared to say thirty years ago, let alone before that time.

6. OCTOPUS. After a period of experimental fishing 3 rights have been granted.

Deepwater Octopus has always been part of the allowable bycatch of certain bottom trawl activities. However, the different specie inshore partly intertidal resource has only in recent years seen certain experimental trap exploitation allowed. Apparently this has indicated its viability. Certainly this is another resource that has always been exploited by Recreationals both as bait and to eat. The intertidal component has most certainly been decreasing year on year, particularly in the vicinity of popular angling destinations. The scientists have very little idea as to its overall size, nor its spread between intertidal and deeper inshore environments. Added to this is the possibility of a partial migration occurring due to man’s disturbance factor in the inshore gullies and reefs. Because we know so little about it, should we not in this instance use the cautionary approach, which I personally hate doing in terms of management scenarios, and leave it to the Recreationals inshore, continuing with only limited full commercial exploitation offshore, as an offshore resource.

A further recent complication has suddenly arisen, whereby a public outcry developed when a beached dead whale carcase washed up with some Octopus trap ropes wrapped around it. As mentioned before, I am no Solomon, so please do not make it my problem to solve, but I would simply like to note the following:

· Greenies are not amongst my favourite people for the simple fact that their attitudes in respect of humankind’s relationship towards fauna, flora, etc., of a lower natural order than man, is always so biased without pragmatic judgement as to mankind’s reasonable needs in our overpopulated world. On the other hand, because of humankind’s frequently overdone greed and self-interest, their exaggerated opinions can offer a degree of balance towards the truth of such situations.

· By no stretch of imagination can the likelihood of the death in this manner of one of this world’s largest mammals, which are most certainly not an endangered species, compare with the likelihood of such being fatally injured by a passing ship. Then what about the similar risk of entanglement with much more prolific crayfish traps. No fishing because of whales, which are no mean fish and other marine specie consumers themselves?

· Remember the worldwide increased infestation of the oceans by seals. Thanks to the Greenies and their like, they are now an acknowledged pest that used to be harvested for many benefits to humankind, but are now somehow classified as untouchables.

· There needs to be a reasonable balance in all situations, particularly when it comes to nature and humankind!

7. SQUID.

For many years, the knowledge of a central major area where Squid propagated, St Francis Bay, was not appreciated. There were several areas from False Bay to the Port Alfred coastline, including St Francis Bay, where it was known that they aggregated, and, it was soon assumed, spawned. Finally, with demand growing for our local species together with its price, it became worthwhile to target them at those various locations, until the much greater availability at St Francis Bay became obvious, creating a whole new branch of the fishing industry.

It soon became apparent that there were annual fluctuations in the size of its biomass, whilst it also seemed that its availability at other known locations, and as trawl bycatch, seemed to vary and possibly diminish, as it was increasingly harvested. I am not aware if any scientific research done confirmed this, but through my own limited experience, it did seem to be the case. Being a new Industry, it’s participants were well aware of the risks of over Exploitation, and have cooperated with the authorities and scientists to try to make sure of the resource’s sustainability.

Although at the times of peak availability the resource could deemed to be inshore based like line-fish, the capital required for its exploitation is considerable. Therefor it should probably be best left as an offshore resource for directed commercial operations, and simply be available as “bycatch” in Recreational and Commercial line-fish activities, without, with all due respect, catch limitations for Commercials, except in the main area of St Francis Bay.

8. INSHORE HAKE. There are 87 licences issued for line caught hake.

This is only a very small component of Line-fish catches, both Recreational and Commercial. Certain regulations can probably ensure the minimal effect it may have on the Commercial trawl and longline resource, instead of the apparent growing fear that line-fishermen could in anyway affect it, anymore than line-fish bycatch by the shallow water bottom trawlers impact meaningfully on line-fish resources.

Granting 87 Line Caught Hake licences to 2020 seems like a nonsense exercise. Originally only 59 applicants claimed to have boats, and, as far as I can gather there are zero fulltime operators. Simply allow it to become a species component of a line-fish licence again. It is unlikely to contribute effort wise to SSF. As to my previous comments as to effective management, I suspect that these 87 licences merely swell the number of Line-fish licences today!

9. OYSTERS. There are 54 issued collector licences in issue, expiring 2020.

This resource epitomizes the conundrum facing the proponents of SSF exploitation. Many of the current rights holders and their families have held them for decades, and, as genuine SMEs, morally it would be wrong to deprive them of such. However, in SSF parlance, this is an ideal resource that, being in most instances not over exploited because the harvesters are well aware of the necessity to exploit them sustainably, could form part of a basket of inshore resources to make up a viable package to afford them the chance of meaningful operations. However, once again it is, because of its nature and environment, very susceptible to illegal harvesting, which risk would be hugely increased by the activities of SSF exploitation. Anyhow, I find the concept of a Basket of Rights totally unacceptable unless in the form of Coops, which I still maintain are totally impractical.

10.BAIT COLLECTORS.

Here is an area that has not enjoyed the attention it deserves. There are six or seven WHITE MUSSEL teams of pickers licenced for specific beaches. There are apparently a small number of RED BAIT pickers licenced and there are several other species of bait, such as Estuarine MUD PRAWNS, that should be and apparently are now considered. However all such activities require excellent regulations and COMPLIANCE, both of which are still missing, to prevent collateral damage to the environment in which they are found, and to their sustainability.

11.SEAWEED COLLECTION.

I have very little knowledge regarding licence holders, the two main species that are collected, the demand, and the use thereof, or its relevant market value, and, therefor, the economic viability of such operations. I believe I am correct in saying that it may not be cut, but only collected when washed up by the tide. I do know that recently it has been established that the Cape Kelp’s rate of recovery, after cutting for whatever reason, far exceeds original estimates. Whether then allowing such activity for that species in a carefully controlled manner would improve the economies of the operation, needs to be properly researched.

Hearsay tells me that recent moves or intentions of the Department in this regard promise to be very unfair and are somewhat chaotic presently. This may well be a potential area both for increased effort and empowerment of SSF, but needs to be handled both skilfully and fairly towards existing rights holders.

12. ABALONE (Perlemoen): There are 30 licenced Rights holders, some of whom work in Partnerships or groups harvesting 100 tons and are committed to supply nominated processors.

Proper Compliance Control somehow has to be re-establishedover this extremely valuable and vulnerable resource. Also it really should be available to Recreationals, even if it is only two per day. Tight regulations are needed for Commercial exploitation on a very conservative basis with quota holders, as with line-fish, strictly tied to location, not free to roam the coastline, or even a region thereof. Illegal poaching unquestionably harvests far more than the sustainably estimated overall allowable catch, so that proper compliance controls are an absolute must.

The validity of seeding projects now underway continually needs to be scientifically evaluated for the highest priced inshore marine product of all. I fully support the recent decision by the last Minister to double the quota, even if for completely the wrong reasons. The resource shows every indication of having stabilised in recent years, be it in somewhat deeper water, despite the known huge illegal take off for as much as the last 20 to 30 years. Somehow, Compliance has to be developed to stop the illegal harvesting.

DEEPSEA COMERCIAL RESOURCES

I think it would be appropriate at this point to list those Commercial Activities that would make up the Offshore Component of the fishing Industry, just to ensure there is no room for misunderstanding or mistaken overlapping in the whole situation. In almost all these sectors there are strong Stakeholder Associations who are entirely appreciative of the unequivocal need for good research and management control to ensure Sustainable Exploitation practices, and the level of cooperation between them and the Scientific Community is excellent. What a pity that similar co-operation between Management (the Department) and the Industry is virtually non-existent now. Would that a new Independent Fisheries Department and Ministry may again become a fully active part of that scenario for the good of all the participants, further job creation, the economy, and the future sustainability of some of our most wonderful Marine Resources. They are:

· Deep-sea Demersal Hake Trawling.

· Inshore Demersal Hake Trawling.

· Hake Longline.

· Crustacean Demersal Trawling.

· Midwater Horse Mackerel Trawling.

· Offshore Crayfish Traps (East Coast and West Coast)

· Small Pelagic Purse-seine.

· Squid.

· Large Pelagic Longline.

· Large Pelagic Pole Fishing.

· Shark Longline.

· Octopus Trapping.

THE NEXT STEP FOR SMALL SCALE INSHORE FISHERIES – COULD BE?

Create a commission made up of Inshore Experts and appropriate Scientists to consider Resource availability and sustainable Quantum, general selection criteria for Applicants, Economic Viability parameters, Department structure, and Compliance needs, all coupled to proposed Regulatory Conditions AND IN LINE WITH EXISTING LEGISLATION.

Their deliberations need to be completed in three to six months though final decisions can be implemented incrementally.

Thereafter the return of CAF, disbanded illegally by a Minister some time back, with a smaller number of highly and broadly qualified members, with none from the present Industry, nor politicians, nor Government employees. (Past participants/members from any of those sectors would be fine)

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