Wednesday, February 24, 2010

Performance Reviewing the Fishing Industry

When the long term commercial fishing rights were allocated back in 2005 and 2006, the vast majority of fishing rights allocated were issued subject to the periodic performance measuring processes. The intention was to ensure that while valuable fishing rights - collectively valued at approximately R70 billion in 2005 - were being issued to commercial enterprises for periods of between 8 and 15 years, right holders would have to remain accountable to the government who remains responsible for the sustainable management of fish stocks. Generally speaking, each fishery policy states that right holders' respective "performance" will be measured periodically against criteria to be confirmed in consultation with the sector concerned.

What was never envisaged was the present process which is akin to full-blown rights allocation process involving some 2500 right holders! It was never envisaged that MCM would have to spend some R9 million on a consulting firm to design complex application forms requiring an expanse of data that MCM ought to already have. What did MCM do with all that data they collected from the long term fishing rights process? Nothing is the short answer. They failed to produce any form of sector analysis after the allocation of fishing rights - in fact the only fishery sector analysis ever undertaken was by Feike in 2008.

By 2006, MCM had detailed data sets on every facet of each right holder's business from broad based black economic empowerment, the number, age and type of vessels used, the number of jobs sustained, financial performance, to annual catching performance. All that was required thereafter was to build on each right holder's respective data profile in each of the subsequent years. Every right holder is obliged in terms of its permit conditions to submit certain data including the following:

  • any information that the department may require, such as financial turnover, first sale reports, changes in black empowerment profiles, investments made in for example green technologies or EAF etc;
  • catch statistics; and
  • levies paid.
While catch statistics are routinely submitted and levies paid for fish landed by all right holders, it is clear from the so-called "pre-populated" forms MCM simply either does not have any of this data or it recognises that its data is so unreliable, it could not be used. The same applies to compliance records. MCM simply does not have a reliable record of who has broken
its laws and who has not; who has paid administrative fines for minor misdemeanours and who has had been convicted of more serious offences. This despite it having a sophisticated multi-million IT system designed for this very purpose of fisheries administration and management.

Back in 2005 when the performance review process was conceptualised, it was envisaged that periodically right holders in each sector would be evaluated by MCM based on a cumulative analysis of the data held by MCM for the each evaluation period. Broadly speaking, the intention was that those right holders that displayed a sub-average performance on any particular criteria would then be requested to explain their poor performance(s). Subsequent to each review process, MCM would then publish a detailed sector analysis indicating how the sector was progressing (or regressing and why) in the key environmental, ecological, social and economic sectors. In this way, both MCM and right holders (and industry bodies) would be able to make crucial decisions such as the need to invest in new fishing vessels, factories or staff or whether any target species required greater protection and thus a shift to other more sustainable species which might require both industry and government to identify new markets for the intended new target species and so forth. Of course this process assumed that MCM managers would be sufficiently skilled to not only maintain right holder databases but also interpret the data collected and act proactively to advance the fisheries.

However, what is apparent is that the performance measuring process is a consultancy-led exercise where MCM is simply looking to say they did it. It is clear from the generic forms and generic data required, that this expensive R9 million exercise will not achieve any of the original intentions. It is therefore certain that after the data has been submitted in April 2010, the industry will wait with bated breath only to receive an analysis free, data poor general set of reasons as to what was involved in evaluating each application submitted. We will wait in vain for any analytical statements about jobs, the future of the resources, the projected economy of the fishery or the health of black empowerment, particularly as many black right holders fell by the way-side during the 2008/2009 global and local economic downturn.

Sadly, the fishing industry is again being made to spend thousands of rands filling in these pointless applications only for them to find a home on MCM storage shelves.

No comments:

Post a Comment