SAMLMA

South African Marine Linefish Management Association

Chairman: Mr B.Q. Mann                                            Secretariat: Ms C. Visser

Oceanographic Research Institute                                South African Network for Coastal and

P. O. Box 10712, Marine Parade, 4056                                   Oceanic Research (SANCOR)

Tel (031) 3288181, Fax (031) 3288188                                  P. Bag X2, Rogge Bay, 8012

Cell: 072 3566629                                                       Cell: 083 2683804

Email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it                                               Tel (021) 4023536, Fax (021) 4023675

Email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

________________________________________________________________________

8 February 2010

Minister Buyelwa Sonjica

Department of Water and Environmental Affairs

Branch: Marine and Coastal Management

Private Bag X2

Roggebaai

8012

Dear Minister Sonjica,

Comment on Government Notice 54 of 2010: Fees payable in respect of applications and the issuing of rights, permits and licences.

Being the official “Interest Group” representing various line-fishing sectors in terms of the Marine Living Resources Act (No. 18 of 1998), it was with grave concern that SAMLMA read of the proposed increases in fees mentioned in Notice 54 of 2010. The fee increases proposed under Section 2 (c) are totally unwarranted and they clearly do not represent a sustainable funding model for the Marine Living Resources Fund (MLRF). Most importantly, such fee increases would undoubtedly result in a considerable reduction in compliance by the majority of recreational users of marine resources in South Africa with devastating consequences for resource management. It is also of concern that the Revenue Department at MCM does not appear to have even attempted to consult with any relevant stakeholders involved in recreational fishing, including users, managers and researchers about the proposed increases prior to publishing Government Gazette No. 32898.

It is of paramount importance that the department responsible for the management of marine resources in South Africa i.e. Marine and Coastal Management (MCM) understands the full rationale behind the establishment of recreational fishing permits. This was not purely to generate funds for the Marine Living Resources Fund but rather to enable improved research and management of the various recreational fishing sectors and secondarily to provide a source of funding to help fund fisheries research and management. Marine recreational fishing (in all its various facets) is the largest fishery in South Africa in terms of number of participants (estimated at ~900 000 people). A recent study (2007) has estimated that the recreational fishery (marine and freshwater fishing) is worth at least R18.8 billion annually to the South African economy. Participants in the marine recreational fishery are not limited to the more affluent white minority but include participants from all of South Africa’s races and cultures (e.g. over 60% of recreational anglers in KwaZulu-Natal are Indian). In fact many recreational anglers come from less affluent sectors of society and recreational fishing and collection of marine resources represents an important recreational pastime, as well as an important source of supplementary protein. Wise and sustainable management of this fishery is thus extremely important and increasing the recreational permit fees to the proposed amount will simple result in the majority of users refusing to pay for a fishing permit. Similarly, the proposed application and permit fee for subsistence fishermen (i.e. R6 + R40 per annum, see Section 1 d, iv and Section 2 a, iv) is well beyond the financial means of most true subsistence fishers and it is highly unlikely that any of them will actually buy a subsistence fishing permit at this price.

Since the establishment of recreational fishing permits in 1998 following the promulgation of the Marine Living Resources Act (No. 18 of 1998), management of marine recreational permit fees in South Africa has been very poor. Continual requests have been made by SAMLMA and other angling bodies for an upgrading of the actual permit to a smart card or some other more durable system rather than simply a paper permit with a receipt stapled to it. In over 10 years no progress has been made in this regard. Similarly, continual requests have been made by SAMLMA and various research institutions for information from the Post Office (via MCM) on the number and type of angling permits that have been sold but again this information has generally not been forthcoming, largely through poor database design and accessibility issues. Finally, to add insult to injury, research funding from the MLRF has gradually withered away until in 2009 very few marine research projects continued to be funded by the MLRF through MCM/NRF provincial funding route. Increasing permit fees is clearly not the solution to remedy such mismanagement.

For the above reasons SAMLMA proposes the following:

1. Any proposed increase in recreational permit fees as indicated in Section 2 c, (i-x) should not exceed the current inflation rate (i.e. above 2009 prices).
2. Management of the recreational permit fee system needs to be greatly improved and a more durable card system needs to be introduced (e.g. such as a drivers licence).
3. The recreational permit fee database as operated by the Post Office needs to be upgraded and relevant permit sales data need to be analysed yearly and results made available to legitimate research institutions.
4. A better model for sustainable funding of the MLRF needs to be found. International examples such as in Florida, USA need to be studied where for example 90% of funds generated by marine recreational permit fees are ploughed back into the fishery (e.g. 30% on marine improvement, 30% on law enforcement and compliance, 30% on fisheries research, 5% administration costs, 5% inflation).

SAMLMA sincerely hopes that the Department of Revenue Management within MCM takes heed of the above recommendations.

Yours sincerely

Bruce Mann

(SAMLMA Chairman)