Monday, May 13, 2013

DAFF's Line Fish Policy: 2013

The department's draft traditional line fish policy (2013) - which remains an ungazetted discussion document - is yet another cut-and-paste of the current 2005 Traditional Line Fish Policy. 

The draft policy is simply a regurgitation of the current Policy with a number of arbitrary additional objectives that are unrelated to the current Policy objectives and whether any of these have been met or to what extent the current policy objectives have been surpassed or not achieved. For example, one policy objective states that it is the intention of the department to "lay the foundations for the management of this fishery on a regional basis". Wake Up, DAFF! The foundations for regional fisheries management were laid back in 2005 when this policy objective was first mooted! They are laid; has it worked and what now in 2013? In clause 9.1, the draft policy confirms that South Africa remains committed to implementing an ecosystems approach to fisheries management by ... 2010! So, can we assume that by this failure to correct the cut-and-paste from the current Policy, we have FAILED to implement EAF in the fishery as undertaken back in 2005? 

Another policy objective case-in-point concerns transformation or the "promotion of black traditional line fishers". The most recent (outdated) performance review findings showed that 42% of traditional line fishers as at 2009 were black. How does this compare with transformation levels in 2001, 2003 and 2004 - the previous occasions data was collated on transformation levels in the line fishery? In 2004, black right holders accounted for 35% of traditional line fish operators. What accounted for the 7% increase in black right holders between 2004 and 2009? And how does DAFF intend "promoting" black line fishers and to what levels? 

The draft policy is frankly a poor and ill-considered regurgitation of the current 2005 Policy. For example, the draft policy states that the crew lists will be compiled from the last quarter of 2005! On the subject matter of "crew lists", the department has not still not published the 2005 and subsequent crew lists for any of the fisheries such as tuna pole and squid. Where are the crew lists DAFF? 

A further example of the ill-considered regurgitation is the continued definition of what are suitable and maximum length vessels for the fishery. Once again, DAFF has confirmed that it is so completely out of touch with the realities of the fishery that it continues to define a suitable vessel in terms of criteria that were relevant back in 2005. 

The draft policy again confirms that rights will be allocated to, inter alia, co-operatives despite the fact that the law does not permit this. However, it importantly recognises that individuals will continue to be able to hold fishing rights as recognised by the Marine Living Resources Act. 

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