Friday, March 30, 2012

SA set to Join Somalia as a Failed Fisheries State

It is now certain that due to our bungling and incompetent Minister and her fisheries department, South Africa will lose all fisheries patrol and research vessel capabilities this weekend. Another tragic and historic milestone achieved by our government.

Come Sunday morning, April 1 2012, South Africa will awake to the first time in history since the regulation of fisheries began in the last century, where we will not have any fisheries patrol and research vessel deployment capabilities. And this despite us having some of the most advanced research and patrol vessels in the world.

It is almost incomprehensible that a Minister can effectively collapse a country's entire fisheries management regime and not be held to account for such incompetence and blundering. Will she not be fired?

It is now certain that with the termination of the hull and indemnity insurances over the vessels and the handing back of the SAMSA safety certificates, South Africa's oceans are now officially open to poaching just as is the case with Somali waters. We therefore could be considered a failed state as we are now the only state on the planet to share Somalia's "open water" regime.

Further, the critically important demersal research cruise which is scheduled for next week may not be able to occur. This research cruise assesses the state of our hake, horse mackerel and other demersal stocks, allowing scientists to advise the minister to set viable catch limits for the 2013 season in sectors that land fish worth some R3.5 billion and employ some 12,000 people.

It is unlikely that our 8 fishery patrol and research vessels will be capable of setting to sea within the next 1 month. The world's fishing pirates will surely be rubbing their hands in glee at the prospects of raping our oceans thanks to our Minister and her dysfunctional department.

And even if we manage to remove the vessels from the merchant shipping registry and onto the naval registry, there has not been any formal handover of skills and knowledge from the SMIT Marine crew to anyone else. And as we now know, a ship is not a tractor where one driver can simply hand over the keys to another.

SCA Upholds Transfer of Rights Fishing Policy

In two separate judgements issued on 28 March and 29 March 2012, the Supreme Court of Appeal ruled that the Transfer of Commercial Fishing Rights Policy of 2009 was valid and rational policy and accordingly rejected the appeals by fishing companies, Foodcorp and Oceana.

The judgements effectively confirm the validity of the Transfer Policy and provide important light on the prevailing relevance of transformation and black economic empowerment in the fisheries sector. The judgements also rely extensively on the General Fisheries Policy of 2005 and the Constitutional Court's 2004 pronouncements on transformation in the Bato Star matter.

The judgements are extremely important for fishing companies as they continue to invest and purchase fishing quotas through commercial transactions involving the purchase and sale of members' interest and shares in corporations. These transactions will impact on future applications for quotas in 2013, 2015 and eventually in 2020.

Fishing companies engaged in such transactions will be well advised to properly structure their transactions and seek the applicable authorisations from the fisheries department as stipulated by the General Fisheries Policy and the Transfer Policy.

However, what the judgements do not address is the fact that although the policies are valid and binding, we continue to be faced by a department and minister incapable of taking timeous decisions. The continued failure to dispose of transfer applications (with some applications remaining undecided for more than 2 and 3 years) continues to force fishing companies to ignore the regulated procedures as they seek to survive and avoid liquidation or collapse.

In this regard, Feike's advice is to force the department and its minister to do the job they are paid to do and flood them with positive interdict (or mandamus) applications, which are relatively inexpensive and can achieve a rapid result. It is our view that the failure to decide a transfer of fishing right application that has been with the department for more than 6 months amounts to an unreasonable delay in terms of our law and is therefore reviewable.

Thursday, March 29, 2012

Press Statement by SMIT AMANDLA

This is a press statement issued today by SMIT Amandla regarding the hand-over of the fisheries patrol and research vessels. It is important to note that the department gave SMIT less than 2 weeks notice to handover the vessels, whereas an orderly and effective handover would have taken some 90 days. Suffice-it-to-say, our vessels face mothballing as we have no trained crew or personnel to take over from SMIT and the vessels will not have any insurance cover from Sunday morning. And we have a Minister who refuses to speak to the public about this catastrophe that she and her incompetent department has created. She clearly does not have any solution other than to bury her head deep in the sand and pretend there is no crisis.


SMIT Amandla Marine (Pty) Ltd’s ship management contract with the Department of Agriculture, Forestry & Fisheries (DAFF) expires on 31 March 2012. The contract entails the manning, maintenance and management of the State’s fleet of fisheries research vessels (‘Africana’, ‘Algoa’, ‘Ellen Khuzwayo’) and patrol vessels (‘Sarah Baartman’, ‘Lilian Ngoyi’, ‘Victoria Mxenge’, ‘Ruth First’).
Since receiving the written instruction from the Director General of DAFF on Friday 16 March 2012 confirming that the vessels are to be handed over to the Department on 31 March 2012, we have executed a complex schedule of activities and have offered our full support and co-operation to DAFF personnel assigned to the handover.
We have contracted independent third party marine surveyors to verify onboard inventories and conduct condition and bunker surveys. Last week, we also provided the Department with a full risk assessment on the handover process – which was originally allocated 3 months in the ship management tender. Key concerns, amongst others raised by our company, have included:
· Time allocated by DAFF for the vessel handover.
· Familiarisation of vessels and operations for the new crew and technical support staff.
· The expiry of Hull & Machinery and Protection & Indemnity insurance for the vessels at midnight on 31 March 2012.
· The imminent return of all vessel certificates to the South African Maritime Safety Authority at their instruction and the implication of this on continued vessel operations post 31-March.
Since 16 March, we have increased security on all vessels as a precautionary measure. The protection of the fleet and a professional handover is our primary concern.
The vessels are due to arrive in Simonstown during the course of the day today, where they will be handed over to the Department’s delegated representatives by 31 March 2012. All SMIT Amandla Marine crew remaining onboard are scheduled to sign-off their respective vessels on Saturday.
For our team at sea and ashore involved in this contract, this has been a challenging period, not least because of the employment uncertainty post-31 March as well as the multiple tasks to be completed within 15 days so as to ensure a professional vessel handover to the DAFF by midnight on 31 March 2012. Mariners will know that every ship they work on becomes a home-away-from-home and many of our seafarers have served on these vessels for more than a decade; leaving them will not be easy. We pay tribute to our employees and thank them for their professionalism, dignity and commitment.
As a black empowered company in a highly specialised sector, supporting the State’s maritime interests is a priority. We would like to thank the team at DAFF for the opportunity we have had to manage these vessels which have sustained 170 jobs for South Africans and have been a platform for the development of scarce seafaring skills for the South African Maritime Industry, also supporting a successful Cadet Training Programme.
We look forward to an opportunity to provide continued support to DAFF and to tender for this service in the future, and we thank all of our Clients in South Africa and Mozambique for their support.

Wednesday, March 28, 2012

Sekunjalo Rejects Insider Trading Allegation

Black economic empowerment company, Sekunjalo Consortium, has strongly rejected accusations by the DA that it may have manipulated the share price during the time it was awarded a lucrative government tender. See for the full story.

The Views of an Insider

A reader of the Feike blog submitted this interesting little gem.

"Come 00h01 on April 1st, what poor sole will be left trying to save face for Tannie Tina?
With less than a week to go (Ed: Actually 3 days now) until the return of research and patrol boats to the Department of Agriculture, Forestry & Fisheries, there is still no word on just how the SA Navy will ensure a “seamless” fisheries research and patrol service, as promised by our Minister (ed: The Department refuses to comment as their heads are too deep in the sand).

Fisheries operational staff tip-toeing the Foreshore corridors themselves have no clarity on what “the plan” is. All we know for sure is that come midnight on Saturday, we will have our hands full trying to come to terms with the effective management of assets worth more than R1 billion, with mounting public pressure to deliver on Tannie Tina’s promises to the taxpayer.

Oh, if only a boat were like a tractor, this would all be very straightforward. We would pick up 8 sets of keys and hang them up in the Acting DDG’s office. But we learn that a ship is a far more complex beast, which is why they are fondly called ‘she’. According to the maritime agency SAMSA, an ocean of international legislation and flag state requirements have to be met before the boats can even go to sea under DAFF and the Navy’s control. We are now aware that even the insurance expires at midnight on Saturday but no matter how wildly the red flags are waving, Tannie Tina just sees red herrings.
Perhaps the Minister – in her infinite wisdom - will spare her poor school of snoek at Fisheries a thought as she relaxes at the Cape Town Jazz Festival this weekend. Many of us wonder if, like last year (Ed: And in 2010), she will be a guest of Sekunjalo Investments? Clearly nothing fishy there as she declared the “gift”
(Ed: See, pg 81 &, pg 73).

(Ed: In 2010 the Minister received 10 tickets and 6 tickets in 2011 with "unknown" values - hard to believe the Minister could not calculate the value of these 16 tickets).

JSE to probe Sekunjalo Share Price

It has been reported today by Die Burger ( that the storm over the Department of Agriculture, Forestry and Fisheries’ suspect R800m tender – subsequently withdrawn due to irregularities – has reached the JSE, which has been asked to investigate possible insider trading.

The share price of Sekunjalo Investments shot up from 40c to 79c per share shortly before the tender announcement. The price dropped significantly after Smit Amandla Marine started litigation in December 2011 to stop the awarding of the contract to Sekunjalo. The DA's Pieter van Dalen said the fact that Minister Tina Joemat-Pettersson officially declared that Sekunjalo was 'an innocent party' during a media briefing on 21 March 2012 was suspect in itself. The party referred the matter to the JSE, which in turn indicated that the investigation would be referred to the relevant directorate if any abuse was found. Sekunjalo chief executive, Khalid Abdulla, denied any irregularities and asked for proof. The spike in his company's share price was due to market forces, he said.

Sunday, March 25, 2012

Did the DAFF say they could allocate fishing rights?

You may recall that on 17 January 2012, the Minister of Fisheries was frothing at the mouth trying to convince the fishing industry that her department was able to get itself ready and allocate commercial fishing rights come next year. If we recall further, Feike had directly questioned the department's ability to timeously allocate commercial fishing rights across some 8 commercial fishery sectors by 2013.

At the time, Feike issued a stern response noting 5 reasons why the Minister and her department could not be trusted to ensure a timeous and sustainable quota allocations process (See

Well, now we add reasons 6 and 7.

6. The Minister now admits that her totally dysfunctional and possibly corrupt department cannot even get its act together to issue a single tender to protect and manage our extremely valuable commercial fisheries. And instead of committing skills, money and other resources toward preparing for the next round of fishing quota allocations, her department will now be paralysed by historic tender allocation witch-hunts and "committees of inquiry".

7. The Minister has placed a moratorium on all tenders which means that with less than 20 months to go before fishing rights in most of the fisheries concerned expire, the Minister's dysfunctional and possibly corrupt department (in whom she says she has complete faith!) can't seek outside expertise to help it get ready for the next round of long-term commercial fishing rights. (Actually, we are not sure if this is a bad thing or good thing 'cause who knows to whom they may hand out a tender? Perhaps another fishing company to oversee the allocation of fishing rights!)

So, here we have a thoroughly dysfunctional department led by a Minister who has committed substantial time and energy over the past month screeching about moving fisheries to Pretoria so as to equitably spread fish across the country(!) but demands that we trust her department to allocate long term fishing quotas worth billions of rands come next year. I am more inclined to believe in the existence of the Easter Bunny.

The Minister though has attempted to silence the growing chorus of criticism against her by foolishly decreeing that she and her departmental officials will firmly stick their heads in the sand from now on and not answer the rapidly growing list of questions on her leadership ability. Apparently everything related to fish is now "sub judice"!

Feike's advice to the 1200 right holders in the traditional line fish, abalone, shark demersal, large pelagic, KZN prawn trawl, trek net, squid, hake handline and tuna pole sectors is that they ought to be gravely concerned as there is a real prospect now that their rights will simply be allowed to expire thus prejudicing their millions of rands in investments and the more than 11,000 jobs sustained by these fishery sectors.

6 Days to Go

With six days left before the end of March 2012, our Fisheries Minister continues to bury her head in the sand and not tell South Africa what will happen on 1 April 2012.

Thursday, March 22, 2012

Cartoon of Fisheries Minister

This Cartoon appeared in the Cape Times on 22 March 2012. We think it most apt!

DA Statement on Committee of Inquiry

This press statement was issued by the Democratic Alliance:

Minister Tina Joemat-Pettersson yesterday announced that she will be instituting an independent inquiry into the procurement processes and procedures at the Fisheries branch of her department. Given that the move is an acknowledgement of alleged irregular processes, the DA welcomes the initiative. As the minister is politically accountable for the department, the announcement essentially constitutes an admission of guilt. The DA is encouraged by the Minister's humility.

In order for the inquiry to be credible, however, its legitimacy should be secured in the following manner:

· The minister should appoint an opposition member of parliament, preferably myself, to serve on the committee. This act of good faith is a strong signalling device that the minister takes the investigation seriously. It has also served the DA well in similar contexts in Cape Town, giving teeth to inquiries which may otherwise be mere political point-scoring exercises.
· The terms of reference and/or scope for the inquiry must be made public, including a reassurance from the minister that she intends to take appropriate action in light of the investigation's outcomes and recommendations.
· The minister must ensure that the results are made public. Ultimately, taxpayer's money is at stake in any tender process, and tenders to the value of R800 million, for instance, must be impeccably administered.

Independence is indeed a necessary condition for credibility, and the minister's emphasis to that end is to be commended. However, it is not a sufficient condition. Following the above recommendations will indeed make the inquiry credible. As the minister has previously taught us, persuasiveness is impossible without credibility.

In the same vein, then, the minister should retract her assertion that 'from now until the Committee concludes its investigation, [the department] will cease to respond to or entertain any further allegations or queries as those would now be in the jurisdiction of the Committee'. Both the public protector and the competition commission will be investigating the department's tender processes. The minister should clarify that her department will be cooperating fully with both these endeavours.

Finally, the minister argued that Sekunjalo is an 'innocent company'. Sekunjalo is a politically connected consortium that won the R800 million tender which sparked this whole debacle in the first place. Thanks to DA pressure, the contract has now been withdrawn. The minister has no legitimate grounds on which to declare Sekunjalo's innocence, though. Its decision to not take legal action against the department is hardly evidence of innocence. If anything, the company's failure to sue suggests otherwise.

We Back the Fisheries Department

Feike backs the fisheries department's interventions yesterday in Hout Bay and we deplore the unlawful attacks on members of the Special Investigations Unit who attempted to arrest abalone poachers.

We have recently wrote about how Hout Bay harbour has become a thoroughfare for illegal goods including the free passage of illegally harvested lobsters and abalone. Feike has been passing on information we receive about the landing of illegal abalone and lobsters in Hout Bay harbour, and particularly at the repair jetty, to the fisheries department.

The action of fisheries control officers to stamp out this illegal trade must be supported. The conduct of certain elements of the Hangberg community to "protect" poachers must be condemned.

Wednesday, March 21, 2012

Minister Makes Startling Admissions

The Fisheries Minister called a press conference today (Human Rights Day) to announce that she is instituting a committee of inquiry into the procurement procedures and processes at the Fisheries Branch.

The Minister admits that the Fisheries Branch is responsible for threatening the continued management of our fisheries resources and failing to properly allocate a critical tender worth some R800 million. She states, without apology or remorse, that the fisheries branch under her watch is guilty of employing "flawed processes" and it was her department's "processes and procedures that failed"!

She is more concerned with Sekunjalo's reputation that has apparently been "tainted" rather than show any concern that her department cannot be trusted with the nation's fisheries resources.

Instead of taking the South African public and fishing industry into her confidence and explaining how she will ensure that come 1 April 2012, our fish stocks will be protected and fisheries research will not be compromised, we are told about the establishment of a committee of inquiry that will look into past tender allocations (read the 2005 tender allocation to Smit Amandla). As the Business Day pointed out on Tuesday (Editorial, 20 March 2012), this is a red herring; it is a waste of time and resources because, put quite bluntly, had there been any questions about the 2005 Smit Tender or any other tender in the previous decade, the Auditor General would have red-flagged it.

We have worked through the audit reports of past years and the only concern raised prior to 2010, was the disposal of the Eagle Star which was essentially given away. However, if the Minister is so committed to exposing corruption and fraud and the wrongful appointment of service providers by her department, she can simply start with the appointment of Anix Consulting that was unlawfully appointed by her current staff to illegally disperse public funds to certain right holders in the abalone fishery. In fact, this blatantly unlawful tender would be a good place to start, Minister.

And of course, her press statement fails to explain what she intends doing about the tainted Sekunjalo tender. Why has the DG who signed off on the tender not been fired? Why have those members of the bid committee identified by the forensic report not been suspended and are not subject to investigations and disciplinary processes? Are these officials being subjected to life style audits? Why have criminal charges not been laid against them? How can a Minister admit to flawed processes and procedures and then sweep it all under the carpet by confirming confidence in her senior management team at the Fisheries Branch? Huh, so no one is in fact responsible for these flawed processes and procedures that has plunged fisheries management into a complete crisis?

The more the Minister speaks, the more the questions. It is our view that the committee of inquiry is nothing more than a desperate attempt to distract the media and the public's attention from the deepening crisis surrounding the R800 million Sekunjalo tender. This much is clear from the Minister's ill-conceived statement that she "will cease to respond or entertain any further allegations or queries as those would now be in the jurisdiction of the Committee".

The Committee has not been formed as yet and it is not a court of law.

Monday, March 19, 2012

Sekunjalo seeks to Muzzle Feike

Sekunjalo today attempted to muzzle Feike by issuing us with a "lawyers letter" demanding that we stop publishing any apparently defamatory content against the "Sekunjalo Group of Companies" and Iqbal Surve.

Feike has of course rejected the demand out of hand. In response to Sekunjalo's letter of demand, Feike points out that the awarding of the R800 million tender –

(a) is currently the subject of an investigation by the Public Protector (and which has been widely reported on in various media);

(b) is currently being considered for investigation by the Competition Commission (and again is widely reported on in the media);

(c) was found to be seriously flawed by an independent forensic audit (which again was widely reported on in the media);

(d) has been widely condemned with numerous adverse aspersions cast on Sekunjalo's conduct by an array of media (including the Sunday Times, the Mail & Guardian, Politics Web, the Independent Group and Business Report) and the Official Opposition, the Democratic Alliance; and

(e) was most recently described by Corruption Watch in an extremely dim light (see In fact, David Lewis, executive director of Corruption Watch, commented that “The circumstances surrounding Sekunjalo’s bid suggest gross irregularities. We are pleased that the Competition Commission is investigating the apparent bid rigging aspects. However, there are also inferences of bid corruption and fraud that, on the face of it, warrant a criminal investigation.

We conclude that the threats against Feike are merely to intimidate and muzzle a small but independent company. As we stated in the Business Report on 19 March 2012, Feike will not be deterred by threats of litigation and we certainly will not stop asking the hard questions.

Fisheries Minister Implements Feike's Advice

A number of media have been reporting that the Minister of Fisheries has confirmed that she is currently engaging with the Minister of Defence to conclude an agreement whereby the South African Navy will step into the shoes of Smit Amandla and take over the management and maintenance of our fisheries patrol and research vessel fleet by 31 March 2012.

Feike had suggested this as the preferred option (the other was to extend the Smit Amandla contract beyond 31 March 2012) in a BLOG article back in February (see

On Sunday, the fisheries patrol vessel, Ruth First, coincidentally took part in the annual Naval Festival in Simonstown.

The benefits of using our Navy to operate our fisheries patrol and research vessels are numerous, particularly if our naval officers are also appointed as fishery control officers with the powers to board, inspect and arrest, regardless of whether they are on board a research or patrol vessel.

A flexible and expansive working arrangement with the Navy could allow South Africa to seriously increase its capacity to monitor and patrol its vast EEZ.

Thursday, March 15, 2012


The Business Report ( reports today that the Director-General of the Department of Agriculture, Forestry and Fisheries (DAFF) would "like to lay charges of corruption against Smit Pentow Marine" which is the predecessor of Smit Amandla.

How exactly he intends to do this in law considering that there is no such legal entity called Smit Pentow Marine is beyond us but of course the law is not necessarily relevant to our esteemed civil servants and politicians.

The Minister has alleged that she believes that the 2005 extension of the vessel management and maintenance tender to Smit Pentow Marine was somehow corruptly concluded. This serious allegation - effectively made against the current Deputy Director General of Oceans and Coasts in the Department of Environmental Affairs, Monde Mayekiso, and his former boss, Pamela Yako (who we understand left the department in late 2010 after being on paid suspended leave after she was accused of pilfering hundreds of millions of rands in November 2009) and current Minister of Tourism, Marthinus van Schalkwyk - is indeed extremely concerning.

On the other hand, it could merely be an attempt by the Minister to detract attention from the raft of accusations and questions needing answers in the Sekunjalo tender debacle. And unlike the bald and unsubstantiated allegations of corruption made against a non-existent company, the forensic report into the awarding of the Sekunjalo tender has serious findings based on fact and law.

However, while the Minister and officials play this blame game of trying to deflect attention from their series of follies and blunders, South Africa's fisheries seem to be the ultimate loser. There will be no fisheries patrol and research capacity with effect from 1 April 2012. There is no other service provider in this country that will be able to essentially fill the gap that will be left by Smit Amandla in 14 days' time.

How will the Minister explain to the South African public that we do not have a fisheries patrol and research capability and that we do not have any ability to manage and maintain our expensive fleet of patrol and research vessels?

A response to the Fisheries Minister

On 15 March 2012, the Fisheries Minister published an opinion piece in the Cape Times in which she seeks to explain and justify her stated intention to move the "fisheries department" which has historically been based in the Western Cape to Pretoria. She essentially claims that the Fisheries Branch has operated as an "island from the main body" thus creating duplication in job functions. She furthermore baldly states that there is apparent mismanagement and corruption (without providing any proof and without even the shame of admitting such under her watch!) that could be routed out if the fisheries department was based in Pretoria as all other government departments are headquartered there. We do of course note that none of the government departments based in Pretoria are afflicted by corruption and maladministration.

The Minister proceeds to justify her recent blundering statements by stating two "facts". Fact one is that there are duplicated roles and functions at the Fisheries Branch. She for example states that there is a duplication of financial, HR, IT and legal services functions. The Minister's statements on this score are a further indication that neither she nor her advisers know much about the governance and institutional systems regulating fisheries in South Africa. She may want to educate herself on the the provisions of the Marine Living Resources Act of 1998 (MLRA) and the Public Finance Management Act of 1999 (PFMA). In terms of section 10 of the Marine Living Resources Act, a separate government business entity called the Marine Living Resources Fund (MLRF) is established to fund the regulation and management of South Africa's marine living resources. In terms of the PFMA, the MLRF is listed as a Schedule 3 Public Entity, similar to other Schedule 3 entities such as the Isimangaliso Wetland Park Management Authority (formerly the Greater St Lucia Wetland Park), the Human Sciences Research Council and the Agricultural Research Council.

These entities are obliged by law to have separate accounting authorities who report to an accounting officer, which in the case of the MLRF, is the Director General of the Department of Agriculture, Forestry and Fisheries. Further, in the case of the MLRF, it must have separate accounting, IT and administrative support function because fisheries management is not solely funded from the national fiscus. The MLRF is a separate fund altogether receipting monies from the commercial and recreational fisheries who pay levies on fish landed and an array of fees for permits and licences. Is the Minister going to advocate that the Agricultural Research Council which reports to her DG also cease to have its own financial and corporate services functions because they are duplicating functions?

The second "fact" pronounced by the Minister is that by being based in the Western Cape, fisheries management is biased toward the "big" commercial sector and she then gives the example of how she opened the once banned abalone fishery. First, the Fisheries Minister does not seem to comprehend that some 95% of all commercial fish landed occurs in the Western Cape. And that is according to the United Nations and based on data her own department supplied. Further, this is not biased toward to the "big" commercial sector. In fact, the serious socio-economic harm that would be caused to small-scale and artisinal fisheries would be tremendous. That is because the Western Cape happens to be located adjacent to one of the world's most productive ocean currents - the Benguela Current - and as such the absolute bulk of all productive commercial fish stocks live in the waters off the Western Cape. No amount of political rhetoric and farcical pronouncements by the Minister on the "equitable spread of fish stocks" will change this! Further, it is unclear how the historic commercial bias that the Minister talks of will be corrected? Will she force fishing companies and fish processing establishments to move outside of the Western Cape and in terms of what laws? What will she say about the huge consequential job losses that will no doubt result?

To try and move fisheries management from the Western Cape, and particularly from Cape Town, Lamberts Bay, St Helena Bay, Saldanha, Hermanus, Gansbaai, Kalk Bay, Hout Bay, Arniston will only serve to crush the small scale fisheries sector who rely heavily on the proximity of the Fisheries Branch in Cape Town to conduct everyday business. It is entirely unclear what maladministration and/or corruption referred to by the Minister in her convoluted thinking caused the underdevelopment of fisheries in the Northern Cape, Eastern Cape and KZN. What the Minister and her advisers seem unable to comprehend is that you can not social engineer fish stocks as her government continues to seek to social engineer the racial profile of the Western Cape! The apparent "monopoly" the Western Cape has over the fishing industry is solely the result of its proximity to the vast majority of commercial fishing grounds, the investment over decades in more than R12 billion in fisheries infrastructure, the existence of Western Cape based vessel repair, building and servicing infrastructure, the existence of a network of foreign fisheries associations and companies and access to exporting infrastructure such as fish export clearing companies, airports and harbours. Afterall, of the 12 commercial fishing harbours in existence, 11 are Western Cape based - the 12th being Port Nolloth. How on earth does the Minister really foresee this changing "monopoly" and why must it change?

Port Nolloth has one small barely accessible fishing harbour that is unable to berth a fishing vessel larger than 20m. It has no processing infrastructure or airport from which fish such as high value tunas and hakes can be exported. The entire Northern Cape has a lobster quota allocation in Zone A of 30 tons, compared to the Western Cape allocation of more than 2000 tons! How does the Minister think she is going to grow fisheries there? Is she going to build an airport, re-build the entire harbour and re-stock the oceans off that coast with lobsters? KZN may have warm waters that are nice for tourists but these are not highly productive waters for commercial fisheries (other than tunas for example). The dedicated KZN beach seine fishery is minuscule in size with 35 quota holders that only operate during the sardine run and is considered an extremely marginal small-scale commercial fishery. The "big" commercial KZN prawn trawl fishery barely functions anymore with only 2 vessels operating. And it is the Minister and her department's continued bungling that has denied South Africa the ability to grow its tuna long line fishery.

Of the more than 2200 artisinal or small-scale commercial fishing rights currently allocated, more than 2000 are Western Cape based because these inshore fish stocks are located here. The Minister's refrain about how Eastern Cape based fisheries have not been developed is more a confirmation of her own and her department's failures to support quota holders and the development of fisheries in this province. For example, when was the last time that the Minister and her Deputy Director-General for Fisheries met with the significant contingent of commercial hake trawl, squid, hake handline and pilchard quota holders based in the Eastern Cape? The answer. NEVER. The fisheries minister never ever met with members of the South African commercial fishing industry since her appointment in June 2009. How is it possible that a fisheries minister can pretend to make such pronouncements over fishing, policy and management when she has never met with one of the 22 commercial and small-scale commercial fishing sectors in this country?

That perhaps explains why she for example states that in 2010 she lifted a ban on abalone fishing in "some parts of the Western Cape" and which ban was in place for about "five years". The South African small-scale commercial abalone fishery is located entirely in the Western Cape between Cape Columbine and Arniston and the closure affected the entire industry and "not some parts". The closure of the fishery was put in place by her colleague and current Minister, Marthinus Van Schalkwyk, and was endorsed by her ANC Cabinet colleagues on the scantiest of evidence. It is interesting to note how she (correctly) accuses her colleagues (including the current President) of endorsing a decision that had "taken away livelihoods from small black fishing communities".

We reiterate our well-worn advice to the the Fisheries Minister. She would be well advised to focus her attentions on employing professional fishery managers and competent staff at the Fisheries Branch in Cape Town instead of traversing nonsensical and irrelevant hobby horses that will only further the downward spiral of the parlous state of fisheries management in this country. Her own colleague in the ANC and member of the fisheries portfolio committee, Mr Salam Abram, has described the Minister's department has being dysfunctional. A change of scenery will not fix this and a fact finding study will no doubt cost us millions and be as useful as the multi-million rand harbour development report her department commissioned some years ago which to this day remains a dust collector.

Wednesday, March 14, 2012

DA statement on Fisheries Minister's About-Turn

This statement was issued today by the Democratic Alliance (

DA welcomes Minister’s about-turn on Fisheries move to Pretoria

Minister Tina Joemat-Pettersson has done an about-turn on the relocation of the Fisheries branch of her Department from the coast to Pretoria.

The Minister has assured Parliament’s fisheries committee that there will be no total move of the Marine Coastal Management unit of her Department from the Western Cape to Pretoria.

This follows pressure from the Democratic Alliance (DA) for the Minister to reverse the nonsensical decision to move coastal management inland.

Only a portion of staff comprising Human Resources and Legal Services will be located in Pretoria, with the majority of the operation remaining on the coast where it needs to be in order to manage South African marine resources.

While the Minister’s about-turn is welcome, the need still exists for some specialised legal services to remain at the current premises in the Western Cape.

The coastal management unit has a specific mandate to ascertain fish stocks. The Total Allowable Catch (TAC) for a given year, which is used to allocate fishing quotas, is derived from knowledge of these fish stocks. This task should continue to be operated from the Western Cape premises, as 80% of South Africa’s commercial fishing takes place in the Western Cape. The process of applying for fishing quotas requires specialised legal services.

People need to be close to where fishing is taking place in order to properly deal with these matters. We ask that the Minister handles any move that has a bearing on this aspect of the operation with caution and in consultation with the affected parties.

South Africa’s fish stock is of strategic economic value to the country as well as to the livelihoods of many small-scale fishermen.

While it is good that sense seems to be prevailing in the Fisheries Ministry, the DA will continue to monitor any changes to the operations of the coastal management unit to ensure that responsible decisions are made.

Open Letter to Sekunjalo

This is an open letter in response to what can only be described as a desperate, threatening and evasive diatribe issued by Sekunjalo and its Cherie Hendricks to questions which Feike published on this BLOG and which were published in the Business Report today (

Instead of answering any of the questions put to her, Hendricks threatens to sue Feike for "defamation", calls the Business Report the spokesperson for Smit Amandla and attempts to attack Feike's credibility by falsely stating that its Managing Director, Shaheen Moolla, was/is being investigated by the Serious Economic Offences Unit of the SAPs (Feike is in fact working with SAPs and the Fisheries department's special investigations unit to arrest a known conman and fraudster, Yusuf Achmat).

To really cap it all, Hendricks concludes that all of the negative publicity against her employer, Sekunjalo, can only be ascribed to the fact that it is a "black company". She farcically demands that her response as a "black woman" be published! How tragic. When you run out out explanations, justifications and defences, haul out the mother of all "defences" - racism!

We reiterate that both Sekunjalo and the Minister of Fisheries have refused to answer an array of critical questions posed to them. We do however trust that the Public Protector will indeed flush these out for us. Feike will not be deterred by threats of litigation and we certainly will not stop asking the hard questions.

Friday, March 9, 2012

Maritime Review Southern Africa Edition Out

The February 2012 edition of Maritime Review has been published. Feike's Shaheen Moolla provides a "Foreward to 2012", predicting what the fishing industry can expect this coming year.

Check out the online version at

Shaheen's article is on page 32.

Public Protector to Investigate Sekunjalo Tender Award

The Public Protector has confirmed that her office will investigate the circumstance pertaining to the awarding of the R800 million vessel management and maintenance contract to Sekunjalo in November 2011.

Feike understands that the Minister and her staff are in a desperate bid to convince the Public Protector that there is nothing to investigate as the tender has been withdrawn or Sekunjalo has withdrawn from the tender. This issue remains unclear and itself warrants scrutiny.

It is our view that even if the tender to Sekunjalo has been withdrawn or canceled, the fact is the tender WAS awarded and it was only because of the vociferous opposition that was launched by civil society and the DA, coupled with litigation launched by the losing incumbent - Smit Marine - against such a dubious allocation that it was withdrawn.

Feike has always maintained that the Minister and her staff have a lot to answer for and the Public Protector has a Constitutional obligation to expose any maladministration, corruption or blatant incompetence.

Based on the forensic report, statements by the Minister herself and Sekunjalo's staff and information leaked to Feike, the following questions require answering:

  • Who were the members of the evaluation committee and what technical skills and qualifications did they have to adjudicate such a complex tender?
  • Have they and their family members been subjected to lifestyle audits before and after the adjudication of the tender?
  • Why did the Minister rush to announce the decision when the forensic report highlighted so many significant concerns?
Then for some harder questions:
  • Did Sekunjalo break any South African law or any JSE rules?
  • Sekunjalo admits to submitting four separate bids under different company and consortia names but with identical financials etc. What they effectively did was submit four connected bids despite signing an SBD Form which states that each bidder should not have any knowledge of any other competitor's bid contents. Does this not constitute bid rigging?
  • Does Sekunjalo Marine Services actually exist? There is no record of such an entity on the CIPC database.
  • Why did DAFF ignore the PriceWaterhouseCoopers report?
  • Who gave the instruction to award this contract despite all of these concerns?
We trust that the Public Protector will vigorously pursue these unanswered questions and provide the fishing industry and the broader South African public with the answers we need. We certainly can not afford to allow the Minister to have this matter swept under her carpet.

Thursday, March 8, 2012


The Fisheries Department has issued a red tide warning confirming that certain shell fish north of Cape Columbine are not safe to consume.

The affected shell fish to be avoided at this stage are mussels, oysters, clams and any other filter-feeding shellfish.

DAFF has confirmed that rock lobster remain safe for consumption.

Red tides are caused by a mass proliferation of phytoplankton and can essentially be various shades of orange, yellow, purple or brown depending on the type of phytoplankton, densities and even the sun.

Visit for a very informative piece on red-tides and the dangers it poses to human beings consuming affected fish.

Wednesday, March 7, 2012

Farmers & Fishers in Same Boat

It's not only the fishing industry being subjected to the incompetence of the Fisheries Minister and her inept officials, but farmers too!

Our Agriculture & Fisheries Minister, responsible for two critical food security sectors, is hell-bent on destroying both sectors. In a recent BLOG article on the author bemoans the parlous state of the farming sector. Here is an extract of his article:

Recent statistics showed that the sector shrank every quarter of last year. Employment (on a like-for-like basis) in commercial agriculture declined from 764 000 jobs three years ago to 630 000 jobs in the last quarter. Agricultural output – or services and products generated by the sector – declined by 0,4% for 2011.

The Department of Agriculture, Forestry and Fisheries is rudderless, with its three main actors reportedly not seeing eye to eye. The department is in a state of limbo. And this is reflected in the state of agriculture. Nothing is happening. Rather, the minister of agriculture, forestry and fisheries, Tina Joemat-Pettersson, has been busy explaining hotel bills and expensive chartered flights.

We need a strong political head of agriculture who can confidently steer the sector through the next couple of years while land reform is intensified. We need a minister who will ensure the sector grows – in terms of output and employment – while the target for land transfer is reached.


The lead editorial in the Cape Times this morning perhaps encapsulates just how surreal and farcical the Fisheries Minister's suggestion to move the Fisheries Branch to Pretoria is.

The editorial reminds us of a story dating back to the 1980's of a meeting between the apartheid government and Zambia's Cabinet, where Zambia's Prime Minister introduced his Minister of the Navy to South Africa's PM, BJ Vorster. Vorster interjected asking why does Zambia have a Minister of the Navy when it's a land-locked country. Zambia's Kaunda retorted by asking why does apartheid South Africa have a Minister of Justice!

When a Minister in a Cabinet so plainly becomes the butt of such comedic errors one would hope she would have the decency to resign and retire to her holiday home in Sweden that she reminds us about.

Tuesday, March 6, 2012


The National Fisheries Minister was right! Feike can now exclusively expose that the Democratic Alliance - the governing party in the Western Cape and South Africa's official opposition - has been found to have placed a sophisticated signaling device on the roof of Foretrust Building (the home of the Fisheries Branch in Cape Town) which controlled the swimming patterns of all fish in South Africa's EEZ. The DA flatly denies this.

We understand from secret sources that this device might have been developed by the late Libyan leader, Gaddaffi (who mistakenly switched it off one night and that is what led to the uprising in his country). The device essentially convinces the fish that they must stay in waters off the Western Cape province even though the waters are terribly cold (try dipping your toe in the water at Clifton) and as the Minister and all other people know, the waters off Durban are just so much more balmy and so warm (even in June).

The Minister was therefore quite correct to insist that her Fisheries Branch be exported to the relative safety of Pretoria so she can switch of this terrible fish controlling device and allow all of South Africa's fish to swim freely so they can choose to spend their lives in warmer waters near Durban, Port Elizabeth and East London. Personally, I would never venture voluntarily to Port Nolloth or even Hondeklipbaai in the Northern Cape - its terribly windy and cold because of that bloody Atlantic ocean and the cold Benguela current.

(Editor's note: Great exclusive but if the DA did put this fish "mind" controlling device in place, how does this explain the centuries of commercial and subsistence fishing in the western cape region. For example, the traditional linefishery dates back to pre-Van Riebeeck days, the Stillbaai feike (yep that is where we got our name from) or fish traps are thousands of years old and we know the San and Khoi were substantial consumers of fish. Just a thought.)

Fish dont swim only in the Western Cape!

Timeslive reports this morning that our foolish Fisheries Minister remains convinced that by moving the fisheries branch to Pretoria she will improve fisheries management!

She is quoted this morning as saying "Fish do not swim only in Western Cape. There are fishing stocks in Eastern Cape, Northern Cape and KwaZulu-Natal."

Hey Minister, we know that! But clearly what you and all those clever advisers around you don't know is that not every fish and "fishing stock" can be commercially harvested! And there are two obvious reasons. One, the commercial value of any species is determined by the existence of a market. I know BMW communists like the fisheries Minister don't really care about the "market" 'cause in lala land it does not really matter, but in real life, no market means no value means poverty.

Second, the "fish stock" needs to be sufficiently large and healthy to support a commercial fishery.

Now, if the Minister has identified all these fish swimming in the Northern Cape, Eastern Cape and KZN, why has her department not started experimental fisheries and new fisheries in these provinces to address the horrible and terrible historical imbalances that made all the fish swim in Western Cape waters.

Why has the Minister not fixed all the ridiculous obstacles preventing the growth and expansion of our tuna long line fishery which could substantially help places like Port Nolloth? Why has the Minister not commercialised abalone and east coast rock lobster harvesting in the Eastern Cape?

And if this Minister is so interested in improving the lot of the South African fishing industry (big and small), why is she not selling and marketing our fish at international fish exhibitions and shows? Instead, she constantly bemoans the fact that the fishing industry is dominated by large players (yes and that is a good thing because they create thousands of well-paid secure jobs as opposed to poverty mired artisinal and interim relief sectors and have access to critical foreign markets where South Africa is minuscule player) and constantly repeats the factually incorrect "apartheid is to blame" refrain.

Why does the Minister not actually read up a little bit on fisheries management; employ some people around her who know a bit about fisheries management; get some good advice and make some sane, knowledgable and rational pronouncements? Instead, it appears that her clever advisers just keep handing her another spade and that hole just gets deeper.

Monday, March 5, 2012


Feike has been provided with copies of a number of invoices and statements (particularly in the abalone sector) issued by the fisheries department to quota holders for levies that are supposedly due and payable.

On studying these invoices and statements, it is apparent that the invoices have only been raised after requests from right holders and that these invoices are effectively "backdated" as they were not issued when allegedly raised. Further, and with respect to abalone, we have noticed that the rate at which the levy is charged varies from R25/kg to R31,24/kg, which is a violation of the September 2010 Levies Notice - the most recent levy notice.

Further, the invoices and statements charge a "finance charge". It is unclear under what legal authority such a charge is levied when neither the department nor the Marine Living Resources Fund (MLRF) are known to be registered as credit or finance providers under the National Credit Act, 2005. Further, the process of charging a levy does not amount to advancing credit or a loan to any quota holder.

The confused and questionable invoicing practices of DAFF require further investigation and our advice to quota holders is to utilise an effective and free service available to them which could end up saving quota holders many thousands of rands. We would advise that industry bodies, such as FISH SA and others lodge a complaint with the National Consumer Commission (NCC) and request that the NCC investigate the invoice raising and billing practices of the DAFF. Remember, the NCC recently issued 45 compliance notices against the City of Johannesburg with a fine of R1 million per notice for that city's unlawful billing practices!

Sunday, March 4, 2012


Over the past few months the Department of Fisheries has inexplicably and rapidly dumped an historic and justifiable policy of not getting involved in commercial disputes between quota holders and members/shareholders of quota holders.

The reasoning behind this long-standing policy is simple. Firstly, and most pertinently, the department lacks the legal jurisdiction to involve itself as a type of self-appointed arbiter of commercial law disputes. Departmental officials simply have no authority under any South African law to involve themselves in and to decide such disputes.

Secondly, the department's officials are simply not skilled in commercial litigation and commercial law to intervene and understand such inter partes disputes. The proof of this is in the various disputes departmental officials have elected to involve themselves in recently and hold one or more parties ransom to the demands of others in utter violation of South African law.

Thirdly, to allow officials to become involved in such disputes simply opens the door to allegations of bias, corruption and maladministration. Departmental officials have no legitimate role to play in such matters.

For example, the managing member of a close corporation decides to conclude an agreement with a third party involving the corporation's fishing quota. It subsequently emerges that the other members of the corporation did not consent or are in fact not even members of the corporation any longer. These "unhappy members" then approach the department to halt the issue of the corporation's fishing permit. The department then obliges these "unhappy members".

In such circumstances, the department's conduct is blatantly ultra vires and therefore unlawful under the MLRA, the fishing permit conditions and the fisheries regulations. The conduct also violates rights and obligations of the managing member under the Close Corporations Act. Where a member of a close corporation believes that the conduct of another member has prejudiced his own rights and interests, the law does not permit him to run to the nearest government official and seek an unlawful intervention of the kind now being offered by departmental officials. The law is clear.

The aggrieved party must seek the intervention of a court of law, alternatively, an arbitrator appointed in terms of the Arbitration Act of 1965.

The question which we believe requires urgent answering by the minister is why has her department and certain officials elected to now embroil themselves in commercial disputes between contracting parties when such conduct is blatantly unlawful and beyond their legal mandate.

These officials should instead focus their energies on addressing the serious backlog concerning applications for the transfer of commercial fishing rights (with some applications having been submitted 2 and 3 years ago) and other matters which they are legally obliged to attend to.

Should the department continue to unlawfully involve itself in such commercial disputes between contracting parties, we believe that the public protector should be called in to investigate under what legal provisions such interventions are occurring and the motivation for each intervention. We would furthermore demand that the Fisheries Minister start subjecting her officials and particularly those in decision-making positions to comprehensive lifestyle audits.

Friday, March 2, 2012

Minister Denies WC contributes 80% to Fisheries

The Minister of Fisheries yesterday flatly denied that the Western Cape accounts for some 80% of commercial fish landings and activity in the country. Her motivation for the unsubstantiated denial is based on her sudden desire to move the administration of fisheries from Cape Town to Pretoria. The depth of her (and those of her advisers and senior officials) ignorance and lack of knowledge is extremely profound.

According to the most recent FAO data on SA fish landings by region /area (and this will be data supplied by her very own department!), the Western Cape in fact accounts for no less than 95.7% of all commercial fish landings (see FAO data table below). We do admit that since 2004/2005 there have been significant migrations of pilchards (for example) further east and the expansion of the squid fishery which is now largely based in the Eastern Cape. This would have contributed to a shift in fisheries economic activity to regions such as Port Elizabeth. This fact is supported by the reduction in fishing economic activity on the West Coast in towns like St Helena and Saldanha for example. On the flip side, fisheries such as the KZN Prawn Trawl fishery based in KwaZulu-Natal has all but collapsed with little or no prawn trawling taking place any longer.

The tuna long line fishery which could have provided an economic boon to Richards Bay, Durban, Port Nolloth and Port Elizabeth has essentially contracted and South Africa's tuna long line fishery is in serious trouble as quota holders cannot even attract foreign vessels and skills required to harvest these tunas due to the Minister's own bureaucratic bungling, ensuring that obstacles remain firmly in place scaring off foreign partnerships and investors which are desperately needed.

So Minister, your populist rant about poor people being denied access to fisheries is caused solely by your own bungling. Why dont you ask the Port Nolloth community why they cannot even get one of their 5 tuna long line fishing permits onto a vessel? To date, South Africa continues to bungle and drag its feet failing to negotiate a larger Souther Bluefin tuna allocation from CCSBT. So we are granted a paltry 40 tons of SBT which is one of the most valuable of all tunas sold on the Japanese market.

I repeat. This Minister and her bungling officials remain the greatest threat to effective and efficient fisheries management in this country. Instead of mouthing off populist and ill-informed rants about "previous governments" and "spreading fish across the country", this Minister should try and learn a bit about fisheries management and she could start by employing some professional experts to advise her and to run the Fisheries Branch. It does not help when the Minister's Special Adviser is an education specialist and the head of the Fisheries Branch is the current senior administrator in the office of the DDG.

In closing, the Minister may want to "apply her mind" to the South African Country profile map on the FAO website ( This may help her and her advisers picture why the bulk of all commercial and recreational fishing takes place from the Western Cape Province.

The table below is taken from the Food and Agriculture Organisation's website (

Landing sites (from North West to South and East)

Annual landings

Main fisheries/species

Approx. Tons


Port Nolloth

1 200


Rock lobster/linefish/demersal

Lamberts Bay



Pelagic fishery/some rock lobster

St Helena Bay

153 000


Pelagic fishery – anchovy and pilchard

Saldanha Bay

120 000


Pelagic & demersal some line and rock lobster.

Cape Town



Demersal - some rock lobster and linefish

Hout Bay

48 000


Pelagic/demersal/rock lobster/tuna/linefish

Kalk Bay

2 300


Pilchard/Linefish, rock lobster


2 000


Abalone/linefish/rock lobster/shark





Mossel Bay

22 000



Port St Francis

7 000


Squid and linefish

Port Elizabeth

11 000



East London

1 000




1 000




538 000


All fisheries

Thursday, March 1, 2012

The Minister's response to the DA elicits feedback

Our posting below has a elicited some of the most hilarious commentary which has not been kind to our foolish Minister of Fisheries.

One of the best responses has come from a leading international fisheries scientist who prefers that his name not be published. He states:

"My advice in this matter to your Minister (care of Mark Twain): Better to keep your mouth closed and be thought a fool than to open it and remove all doubt".
A former fisheries minister states:

"Normally such ministerial statement would be something concocted by Evita se Perron or other diabolically funny comedian in order to ridicule and offend someone. And we're dealing with a reality show! Very hard to take in. Is there NOBODY around the poor witless minister who can protect her against herself?"
Another comment received from a Southern African journalist:

"Waiting in anticipation for the announcement of a tender for FISH WHISPERERS to convince the fish species to relocate and distribute themselves fairly across the entire coast of SA!"

Fisheries Minister issues Statement on moving Fisheries to PTA

The Fisheries Minister today issued a statement in response to the statement issued by the DA yesterday about the proposed relocation of the fisheries branch to Pretoria.

In defending her proposal to move the fisheries branch to Pretoria, the Minister states that -

"Van Dalen's (DA Shadow Deputy Minister for Fisheries) claim that 80 percent of commercial fishing activity took place in the coastal region of the Western Cape was both untrue and unsustainable.

"Yes, historically the previous government concentrated commercial fishing in the Western Cape [and] created this artificial strength," she said.

In the process, KwaZulu-Natal and the Eastern Cape were under-developed and the Northern Cape completely ignored.

If the playing field was levelled and fisheries spread across the country, the Western Cape would represent far less than 80 percent of commercial farming.

It was also important to note that the fishing stocks were depleted in the Western Cape and resources were being spread to other parts of the country, including in the rivers for aquaculture."
The Minister's statement is so farcical and far-removed from reality that it boggles the mind! Her statement simply further confirms how removed she is from understanding fisheries management.

Is she suggesting that the "previous" government forced our commercial marine fish species to congregate in the waters off the Western Cape province and that is why commercial fishing is concentrated in the Western Cape (which she incidentally denies initially!).

Is she suggesting that by relocating the Fisheries Branch to Pretoria where all other national government departments are based, that somehow the fish will all decide to swim and live in waters off the Eastern Cape, Kwa-Zulu Natal and Northern Cape so that these provinces are not "ignored"? Is she suggesting that by relocating fisheries to Pretoria, her dysfunctional and failing department will miraculously succeed?

Minister stop being an national embarrassment!

The reason why 80% of all commercial fishing takes place in the Western Cape (and yes this is a fact which you cannot just deny because it does not suite your political ideology!) is because - wait for it - the bulk of all commercial fish species are found in waters off this province! Its not a Democratic Alliance conspiracy! And apartheid is not to blame either!

Blame evolution, God, global warming, ocean currents including that damn horrible Benguela Current which is just so darn productive with all that upwelling nonsense which keeps fish happy and unfairly discriminates against the Eastern Cape and Kwa-Zulu Natal!

So Minister, you cant "level the playing fields" and "spread fisheries across the country"! Perhaps, the Western Cape must start demanding "equitable" access to the Northern Cape's abundant marine diamond fields; And what about all that gold unfairly located in Gauteng- we want gold "spread across the country"!

And Minister, why are Western Cape based fisheries depleted now? Is it because your department has hopelessly failed to combat poaching of line fishes, lobsters and abalone? And if these fisheries are so depleted what are your doing to ensure their recovery? Your department's fancy plans and presentations to Parliament are completely silent on this. Are you planning to expand river-based aquaculture to such an extent that it would "level the commercial playing fields"?

What species of river fish are you going to farm in such large quantities and in which river systems? Are there markets for these species? Or don't you care or even know? Again, none of these plans are evident from any of your department's plans or presentations.

Do you know that South Africa's total farmed abalone production - which is by far the most valuable (and almost entirely located in the Western Cape!) has stagnated at about 1000 tons (worth more than R270 million annually), primarily because of demand stagnation? Our entire freshwater (ie rivers and dams) aquaculture production stands at a mere 1,200 tons worth a paltry R43 million annually.

Our commercial fisheries produced approximately 800,000 tons of fish in 2010, worth more than R5 billion of which some 80% were landed, processed in and marketed from the Western Cape.

Minister, short of convincing fish stocks to migrate to other provinces (is that not what Jimmy Manyi once suggested, albeit not about fish?), the fact is that the Western Cape will remain the heart and sole of commercial and recreational fishing in this country and no amount of foolish and ideologically warped thinking will change that.

Finally, the Minister fails to address any of the substantive criticisms raised about her ridiculous proposal to move fisheries to Pretoria. For one she does not explain how fisheries will be practically managed from land-locked Pretoria (even if all other government departments are based there - though none are responsible for fisheries); she is silent on the transfer of some 700 staff from Cape Town to Pretoria and related costs; she is silent on why this proposal is not in any of the department's multi-year plans or why she made no mention of it in her budget speech especially since the costs of such a move would be astronomical.

Or is this ridiculous proposal just a quick after-thought to detract from the Sekunjalo tender debacle and the many questions she must still answer?