Why new Fisheries regulations do not have any environmental preservation basis

So Bernard has been duped, once again, purportedly by the commercial fisheries sector (the ‘advisory council’??),  to get a regulatory revision through the system without seemingly any environmental consultation concerning the fact that such a revision has little, if any, impact on the preservation status of pelagic and coastal fish species in the Namibian section of the Benguela current?  He may have stalled some potentially hazardous phosphate mining in the past, but this latest action suggests an ill-conceived money-spinner – to get more bucks for bangs than bangs for bucks.    And knowing that Calle loves catching fish recreationally, I find it hard to believe he actually agreed to this!   

To wit –

Government Notices
No. 158


Under section 44(3) of the Marine Resources Act, 2000 (Act No. 27 of 2000) in consultation with the Advisory Council and with the approval of the Minister of Finance, I –
(a) impose, for the benefit of the Marine Resources Fund, a levy on the marine resources as set out in the Schedule; and
(b) repeal Government Notice No. 80 of 1 June 2002.


4. A person who lands any marine resources or portions of marine resources mentioned in paragraph 5 for recreational purposes, except for subsistence fishing, must pay N$ 1500 levy per month in respect of every fishing permit issued for the benefit of the Marine Resource Fund. 

While I don’t really object to the N$1500 monthly levy for recreational fishing (while it is significantly more costly than elsewhere in the southern hemisphere, it will keep at least some of the South African yahoo vistermanne out of Namibia), I do find the table representing the landed ‘values’ of commercially exploitable fish species in paragraph 5 utterly deplorable.   
For example – small pelagic fish such as pilchards (read sardines), anchovies, immature horse mackerel and herring species, which have seen the most significant population declines in Namibian waters as a result of over-fishing and resultant economic crashes in their respective (trawling and purse-seine) fisheries over the past 5 decades,  are valued at rock-bottom – $ 1.50 to N$ 4.40 per landed kilogram.  In contrast to N$ 20 – N$70+ values for presently economically lucrative large pelagic species (many of which are predators dependent on these small pelagic ‘forage’ fish!).    

More small pelagic fish are landed globally than any other type of fish. (Sadly, “landed” refers to the portion of the catch retained and not discarded at sea – that’s another ugly ‘by-product’ of the pelagic fisheries industry, constrained by politically-charged quota allocation schemes). Large-scale trawling for pelagic species, with a few notable exceptions, is most often linked to supplying fish feed and oil for industrial aquaculture of predators such as salmon. Small pelagic fish used to be among the most populous in the world, and demand for products derived from these fish is increasing.  Small pelagics are used to fuel the growing global demand for animal protein. Large-scale industries process forage fish using what is called “reduction”, which involves cooking, grinding and chemically separating the fat from its protein and micronutrients. The fat and protein form key ingredients in the chemical inputs to animal feed for aquaculture, industrial livestock, chicken farming, the pet food sector and bait. 

So while everyone is complaining about a N$1500 monthly levy to catch fish as a recreational activity, and looking for various devious explanations to convince fisheries inspectors that they are subsistence fishermen in spite of their shiny amaroks and hiluxes,  I grieve about the simple arithmetic (mis)used to calculate these absurd landed values for forage fish.   

Simply put,  why should an ever-decreasing, increasingly rare, population of forage fish be given such lowly landed values?  Because they have some intrinsically lower value as they are mostly reduced to fish meal?   This arse-about-face reasoning can only be the work of some environmentally-illiterate f*ckwits with degrees in economics or business administration;  the work of greedy fools, providing a skewed commercial value system for species of critical environmental resource value / concern.   Frankly, given the well-documented extent of these species’ depredation over the past 5 decades, and their intrinsic value as forage fish for larger predators and increasingly rare megafauna such as whales, sharks and dolphins, they should really have a net N$ / landed kg value far exceeding that of the predators.   Is this simply fish-quota allocation nepotism at its worst? 

For some comprehensive reading in this vein – dave boyer’s review in 2000 – e.g., 

While also factoring in more recent commercial harvest figures – 

After several decades of overexploitation, are Namibia’s marine resources truly showing any signs of recovery, as claimed by several economically-biased fisheries reports?

They attempt to impress with reports of monkfish catches having increased and become an important component of the deep trawl industry.  Sies tog! Just because they are processed to imitate crab and lobster flesh, doesn’t mean they would show up on the dining table in “the flesh” so to speak – 

The hake fishery has grown since Independence, although catches are still considerably below those of earlier years.  Whether this increase is sustainable is not clear, particularly as it is based largely on an influx of deep-water hake rather than an increase in abundance of local stocks.  The midwater horse mackerel fishery which made good catches in the 1990s, has declined since then.  Likewise,  the rock lobster fishery has declined, and the orange roughy fishery, which in the mid 1990s promised so much, has become effectively non-existent.  Of greatest concern is the failure of the small pelagic stocks, and in particular sardine, to recover. Indeed, at the end of the 1990s the stock was in a similar state to that of the late 1980s, and the anchovy stock, which helped carry the purse-seine fishery through the poorer years of the 1980s, has all but disappeared. 

Far more preservation-conscious management procedures need to be developed.  Increasing fishing levies on recreational fisheries, and setting high landed values won’t bring back size west coast Steenbras and Kob,  if harvesting levels are not also set to enable stocks to return to levels that will provide maximum sustainable yields.   
So what options are there (if we had a genuinely environmentally-concerned Ministry of Fisheries and Marine Resources) ?
Firstly, the west coast steenbras must, like the Galjoen, become a non-commercial, red-listed, no-sale species, meaning that it would become illegal to sell or buy this fish, anytime, anywhere.  
If stocks of this endemic species are to be recovered and managed wisely, there should be an initial moratorium on catching and keeping any size Steenbras for at least 5 years  (there is strong evidence, from studies of similar angling species in South African waters, for exploited fish species to recover stocks following protection within a marine reserve).

[I remain a vocal proponent of BOFFFF rules of fisheries management. BOFFFF = Big Old Fat Fecund Female Fish. BOFFFF are the larger, older females which generally produce a lot more offspring, more times per year, than younger females do (in long-lived species like our Steenbras!). Additionally, the offspring of larger females are often healthier and more likely to survive. Older fish are more likely to survive and contribute in the ‘bad years’ when bad environmental factors reduce recruitment to the fish stocks. For many species, one of the best ways to ensure long term successful reproduction and replenishment of the fish stocks is to protect the larger, healthy female breeders. I advocate the introduction of BOFFFF limits (maximum size limits and bag limits to protect large fish) for species like Steenbras, Kabeljou and Galjoen. We should return the big breeding fish to breed another day. We should maximise the protection for fish and habitat, while minimising the impact on, enjoyment of and access to recreational angling. We must also ensure that recreational anglers learn how to handle fish to ensure maximum survival when they catch and release these large fish.]
There are a few management methods available to conserve older fish in an exploited population like our west coast Steenbras:
Reduce the rate of exploitation of Steenbras significantly — even though it can be argued (by our local fisheries scientists) that this is an economically infeasible option, given claims made by the revenue generating tourist fishery (a daily bag limit of ONE west coast steenbras per permit holder, with no more than one specimen per permit holder transported per vehicle, ever);
Institute a smaller maximum size limit – a genuinely “edible” size – of say 45cm – for keeping — an option primarily available for fishes which can readily be released unharmed after capture;

Designate new marine reserves that set aside areas in which fishing for Steenbras is prohibited and older fish can survive and spawn — even though the extent of accessible coastline for our recreational fishery is already relatively small 

Change the attitude of angling tourists who visit our designation recreational angling areas.   The new costly monthly levy system may help this.  

Marine reserve and moratorium options (no-take zones) make sense, particularly for non-migratory, endemic species like our west coast Steenbras and Kolstert/Blacktail, where the full range of sizes and ages can thrive. No other method of management, not even BOFFFF limits, can preserve the potential for longevity as well as marine reserves and allow the contributions of older fish to accrue to the population. 

While no-take zones can be a hard sell to commercial fishermen and uneducated recreational anglers (have you ever seen the piles of litter left behind on our beaches by such recreation? That is, before the howling southwesterly wind disperses it?) the BOFFFF concept should make sense with fishermen who know the value of large spawners — if for no other reason than the fact that larger females produce more eggs, which result in more fish! 

Some seventeen years ago I had published an article in the Namibian, incensed by the environmental degradation resulting from wanton abuse of (power and) fish resources in one of Namibia’s (then) more pristine wilderness areas – the Skeleton Coast Park (SCP). As I recall, the tipping point for me was a government bakkie (pick-up) filled to brim with enormous Steenbras caught on one short day by a crew of Sam Nujoma’s recreational angling entourage north of Moewe Bay – with some bullshit excuse about testing the waters for a trip by Sam and his gang later in the week. A trip which eventually didn’t take place, thank gawd.
I think my concerns remain pertinent – while prices have gone up and fish quotas have been reduced, and we have yet one more new President who doesn’t like to fish (again thank gawd!), the wanton abuse of our coastal angling resources has not abated, with very few controls in place to arrest the slaughter.   
This needs to change – urgently – even if I never get to eat another Steenbras in my lifetime – so that my children and their children can.    And for fecksake ban the commercial exploitation of sharks and especially shark finning altogether. Like rosewood, rhino horn and pangolin scales, these environmentally destructive oriental tastes need to be obliterated.  
POST-SCRIPT – To read an excellent 2003 review article by Henning Melber – “Of Big Fish & Small Fry: The Fishing Industry in Namibia” – on the politics of Namibia’s fishing industry, do try one of the best hacks to come out of the former “eastblock” – where JSTOR is a “not-for-profit service” that charges US$46 for a download (so helping RICH scholars, researchers, and students discover, use, and build upon a wide range of content in a trusted digital archive) – this friendly site (http://moscow.sci-hub.cc) provides unadulterated access to Henning’s article – http://www.jstor.org/stable/4006748


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One comment on “Why new Fisheries regulations do not have any environmental preservation basis
  1. Kim Field says:

    Thank you Joris! Well said.


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