Listing of Trout

May 1st, 2009 by Chris

he Editor of The Complete Fly Fisherman (TCFF), P.J. Jacobs, lodged objections to the responsible authority, The Department of Environmental Affairs and Tourism, against the listing of trout as an invasive species. He also invited concerned parties to contribute to the campaign by sending their support by e.mail to TCFF, magads@gonet.co.za. The letter follows :

The Department of Environmental Affairs and Tourism
Attention: Bonani Madikizela
Fedsure Building
315 Pretorius Street
Pretoria

30 April 2009

By e-mail – bmadikizela@deat.gov.za

Dear Mr Madikizela

This letter serves as the lodging of a formal objection to the proposed
regulations for the NEM:BA Act 10 of 2004 (as published in the Government
Gazette on 2 April 2009), on behalf of the Complete Fly Fisherman Magazine,
its employees and shareholders, and specifically as far as the listing of
trout is concerned.

We wish to place on record the following:

1.   Trout are non-invasive in South Africa, and there exists no scientific
proof to the contrary. Its present listing as “alien invasive” in terms of
Schedule 3 is therefore incorrect, and can only be based on incomplete,
incorrect information or assumptions. This is contrary to the requirements
of the Act.
2.   Where they presently occur, trout present no threat to any indigenous
species and are naturalised.
3.   Trout are self-regulatory and need not be zoned. Zoning and the permit
system will have a detrimental effect on the trout industry.
4.   The present listing of trout will do great harm to the trout industry,
with a consequent substantial loss of jobs, especially in the lower income
segment.
5.   Trout fishing is a way of life for many South Africans, and the present
listing infringes this right.
6.   Trout contribute enormously to the economy, and the present listing
will limit that contribution in the future. It also impairs the right of the
industry to expand and grow.
7.   The listing is flawed, in that correct procedures were not followed as
stipulated in the Act, inter alia in so far as not enough funding was made
available to properly research the status of trout prior to and leading up
to its listing as “alien invasive” in terms of Schedule 3. Many interested
and affected parties were not consulted or invited to workshops,
insufficient workshops were held and evidence presented at workshops were
not procured or evaluated as is prescribed in the Act.

Consequently, we request that trout be re-listed as non-invasive in terms of
schedule 1.

We reserve all rights.

Yours faithfully,

PJ Jacobs
Editor

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