Please see below, the accumulative commentary, we hereby submit on behalf of our members in the hake long line sector in respect of the General Fisheries Policy on the Allocation and Management of Commercial Fishing Rights.
Section: 3 Purpose and Objectives
Comment: No mention is made with regards to the investment and employment
Section: 5.4 Allocation process determined by Clusters
Correction: There are 20 fishing sectors not 19 fishing sectors as stated
Section: 5.14 Access to information
To ensure absolute transparency throughout the process applicants should obtain their and others who applied score sheets at the same time as the results are released. This is furthermore required for preparing proper appeals too.
Section: 7.2.2 Form of Right Holder
Individuals have been precluded from applying. Given that Rights are currently held by Individuals this should be corrected.
Section 7.3.2 Employment Equity
Disabled persons have to be included as they too are classified as designated employees in terms of the Employment Act 55 of 1998.
Section: 7.4.2 Skills Development Act
There are many different skills development strategies across the various SETAS. The Department is encouraged to familiarize itself with these to ensure proper verification under this component.
Section: 7.16.3 Employment
Correction: One cannot classify employment categories under these proposed headings. As a way of example a permanent employee can by virtue of the employment relationship only work on a seasonal basis. This is very common in an industry like fishing which is largely seasonal by nature.
Section: 7.17.1 Local economic development and geographical considerations
It is a pointless exercise to reward applicants for their intention to land at harbours other than those not considered optimal for LED, when this is not managed during the term of the Right granted and vessels freely land at habours most suitable to meet market requirements irrespective of the initial harbour cited in the application.
Section: 7.18.2 Vessel and fishing efforts
Correction: SAMSA – South African Maritime Safety Authority
Correction: “being Suitable for fishing” – SAMSA
Certifies vessels as seaworthy first and foremost not necessarily suitable for fishing
Section: 10.2 Glossary
Correction: Asian persons have not been included under the definition of black persons.
On behalf of the
SAHLLA Executive Committee
Tel: 021 418 2696