The opportunity to submit comments by members of the South African commercial fishing industry on the proposed criteria and processes for the commercial fisheries performance measuring process ended on 31 August 2009. Feike had submitted comments as an interested party. In brief, it is our view that the -
- the notice and comment process is inappropriate and prejudicial to a number of right holders;
- the proposed key performance indicators (KPI's) are too generic in nature and contrary to the sector specific fishery objectives and policy frameworks; and
- the proposed KPI’s are extremely vague, bordering on being irrelevant.
The full version of Feike's comments are available. Simply email (firstname.lastname@example.org) me with the subject-heading "Feike's performance measuring comments" for a copy of the comments.
The next step in the process will be for Marine and Coastal Management to consider the various comments and submissions made and thereafter to publish the final version of the KPI's for each commercial fishery (if they maintain the "one-size fits all" strategy). If they decide to abandon the "one-size fits all" strategy, then they would be obliged to re-advertise the new sector specific key performance indicators in terms of the Promotion of Administrative Justice Act, 3 of 2000.
Feike wishes to remind commercial right holders that participation in this process is not voluntary. Every right holder is obliged in terms of the conditions under which their commercial fishing right was allocated in 2005 and 2006 to participate in the performance measuring process. For more information, contact Feike.