Tuesday, May 28, 2013

2013 Rights Allocation Process: An Update

The Fisheries Department held an informal meeting on 27 May 2013 to discuss the draft tuna pole application form. The meeting was chaired by the Department's Craig Smith and proved to be a rather useful meeting aimed at discussing and conceptualising a draft application form for the fishery. The meeting was attended by approximately 25 persons from the pole sector.

The draft application form presented was simply printout of the 2005 application form complete with out-dated references to medium term right holder applicants, right holder conduct during the 2002-2005 period etc. In short, the draft application form like the draft policies are at an early conceptualisation phase. The meeting yesterday, like the consultation meetings on the draft policies before that, was a meeting that can politely only be described as an early conceptualisation meeting; a meeting at which the department itself had little idea as to process, policy or timelines but was seeking industry input and bouncing ideas about prior to a formal consultation process on serious policies and application forms.

From previous rights allocation process experience, this important idea generation and conceptualisation phase usually starts about 18 to 24 months before the allocation deadline ... not 6 months.

So the meeting yesterday referred to the possibility of allocating rights by February 2014. What?

The draft form itself makes it plainly clear that what the department is attempting to do is to fit a VW Citi Golf body onto the engine and chassis of a Bugatti Veyron. You can try and force a fit but its going to look really bad and it's not going to work at all. The draft application form does not relate to the draft policy which, for example, makes provision for the allocation of fishing rights to co-operatives and individuals in the tuna pole fishery. The draft application has not been conceptualised or structured to cater for this obviously. The Schedule Notes and Explanatory Memoranda were designed for a process that simply is not the present one. The mismatch and irrelevance are profound.

Again, as is the case with the draft policies, it is simply not possible to force fit the current badly planned, late and visionless process over the framework of an allocation process that was designed over a period of 3 years and underscored by a comprehensive IT and software foundation designed specifically to receive, read and extract specific data from pre-identified fields in each sector form so as to immediately provide each decision-maker with a comprehensive profile of all applicants in each sector.

Where is the department's own IT system for this process? How will they receive application forms, data capture all the applicable data so as to understand the various quintiles and means of right holder transformation levels, investments, exploitation levels and so on? What is understood is that the department is going to rely on its own staff in resource management to manually input each data field into an Excel spreadsheet! Can you imagine the error rate for such a manual and tedious process? How long will that process take assuming a relatively conservative estimation that between 5000 and 10,000 persons will apply fishing rights? And if they are going to use their own internal staff for this process, who is going to process and administer the day-to-day work of receiving and issuing fishing permits, export permits, licences etc?

One can only conclude again that based on the discussions on the draft application form presented to the 25 tuna pole right holders that attended yesterday's meeting, a fair and proper rights allocation process is many, many months away, maybe more.

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