for web publishing – 30 april 2012 · for web publishing – 30 april 2012 . executive summary -...

2009/10 PERFORMANCE REVIEW

OF FISHING RIGHT HOLDERS

Executive Summary

Limited Commercial and Full Commercial Rights Holders

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Executive Summary - Fisheries Performance Reviews - published on web - 2012-04-30 Page | 2

Contents Background ..................................................................................................................................... 4

Introduction and legal basis ............................................................................................................ 4

Segmented process design ............................................................................................................. 5

Key project milestones .................................................................................................................... 6

Review outputs ............................................................................................................................... 7

Report design ................................................................................................................................. 8

Sectors ‘by the numbers’ – A high level numerical summary ........................................................... 9

Limited Commercial Sectors: ....................................................................................................... 9

Demographics and Transformation ............................................................................................... 11

Limited Commercial: .................................................................................................................. 11

Full Commercial: ....................................................................................................................... 11

Utilisation ...................................................................................................................................... 13


Full Commercial: ....................................................................................................................... 14

Economics .................................................................................................................................... 15


Full Commercial: ....................................................................................................................... 16

Sector (co) management ............................................................................................................... 19

Conclusion…………………………………………………………………………..………………………21

Annexure A - General notes on methodology ................................................................................ 22

Annexure B – Project milestones .................................................................................................. 23

Annexure C – Themes and questions covered in the anonymous survey of Right Holders ........... 26


FIGURES

Figure 1 – Conceptual Summary of Performance Review Process ................................................. 5

Figure 2 - How RHs related to the process...................................................................................... 6

Figure 3 – Report Themes .............................................................................................................. 8

Figure 4 – Sector by Numbers: Limited Commercial RHs ............................................................... 9

Figure 5 - Sector by Numbers: Full Commercial RHs………………………………..…………………10

Figure 6 - Ownership demographics for Limited Commercial…………………………………………11

Figure 7 – 3 Ways of Looking at Levels of Transformation ............................................................ 12

Figure 8 – 3 Ways of Looking at Levels of Transformation ............................................................ 13

Figure 9 – Limited Commercial Catch over 3 years under review .................................................. 14

Figure 10 – Sector by Numbers: Full Commercial RHs ................................................................. 15

Figure 11 – Limited Commercial – Types of Agreements .............................................................. 16

Figure 12 – Sector by Numbers: Full Commercial RHs ................................................................. 17

Figure 13 – Number of RHs in Economic Units (per RFI) .............................................................. 18

Figure 14 – Average number of economic unit members per sector ............................................. 18

Figure 15 – Average number of sectors in which RHs operate ...................................................... 19

Figure 16 – Membership in Industry Associations ......................................................................... 20


Background

Over the course of 2005-6 the Department successfully concluded a long term rights allocation process. The process was highly contested with over 9000 persons and companies applying for rights across 22 sectors, of which approximately 50% appealed their decision. The result of this mammoth administrative process was 1503 Limited Commercial Right holders (‘RHs’) and 871 Full Commercial RHs spread across the sectors included in the scope of the Performance Review1.

Owing to the length (up to 15 years) of the rights granted, and the continued political and social pressure to fulfil the core mandates of the Marine Living Resources Act 18 of 1998 (‘MLRA’), Cabinet felt it prudent to introduce the notion of regular ‘Performance Reviews’ into sector specific policies in order to ensure that RHs continued to perform satisfactorily throughout the duration of the rights. These sector policies envisage that the Department should conduct periodic performance measuring exercises.

The Department initiated the first performance measuring and review exercise in 2009. This report is intended to summarise the key process steps and outcomes but should be read in conjunction with the overall Performance Review Summary and the separate State of the Sector reports/presentations .

Introduction and legal basis

There is no statutory framework for Performance Reviews. Nor are they dealt with in the General Policy which governs right allocation. The Cabinet brief to ensure regular reviews is contained in the sector specific policies. These state that the Performance Reviews are to ensure that the objectives of the fishery are being met in terms of maintaining or improving transformation, the creation of an environment for investment and job creation; supporting the economic viability and environmental sustainability of the fisheries and that management methodologies and procedures remain suitable.

Key criteria selected, and consulted on, for assessing performance included:

• Transformation; • Investment in vessels and gear; • Sustainable utilisation, and in particular the ecological impacts of fishing in the sector; and • Compliance with applicable laws and regulations.

As such, the Performance Reviews were not intended to impact directly on either current allocations or scientific research outcomes i.e. they are neither a basis for reallocating rights nor for setting Total Allowable Catch. The policies do not allow the Department to reallocate a right and the Department cannot cancel or withdraw a right except through proceedings instituted in terms of s28 of the MRLA.

The mandate to conduct regular Performance Reviews within the sector policies does not, in itself, represent a legal basis to undertake them nor a compulsion for RHs to cooperate and participate in them. Therefore, the Department used the 2008 annual permit application process to create a

1 Note: This review only deals with 17 of the rights based fisheries - 4 Limited Commercial sectors (HHL, Netfish,

Linefish and WCRL(I) and 13 Full Commercial sectors (Hake Deep Sea Trawl, Hake Long Line, Hake Inshore Trawl, KwaZulu Prawn Trawl, Horse Mackerel, Seaweed, Squid, Patagonian Toothfish, West Coast Rock Lobster, South Coast Rock Lobster, Demersal Shark, Small Pelagics and Tuna Pole)


legal basis for the review by requiring all RHs, as a permit condition, to participate in the review. Failure by RHs to participate and cooperate would therefore breach their permit conditions and might then result in s28 proceedings.

Segmented process design

The Performance Review was designed around four core sources of information collected by virtue of:

• Current Departmental data bases that store allocation, permit, compliance, levy and catch data;

• The outcome of forensic probes conducted into certain RHs as a result of either being ‘red-flagged’ by the Department, or because a specific complaint about that RH was lodged with the Department by virtue of an anonymous hotline established for this purpose;

• A Request for Information (RFI) that each RH was obliged, in terms of their permit conditions, to complete and submit; and

• An anonymous survey instrument that each RH was obliged, in terms of their permit conditions, to complete and submit.

Having collected the information, the Department would then build an integrated data base, assess the data and be in a position to produce:

• 17 State of the Sector reports, each detailing the current status quo of that sector; and • An individual report that would be sent to each RH who participated in the review.

The process followed is illustrated and explained below:

Figure 1 – Conceptual Summary of Performance Review Process

The four sources of information are all

combined into a data base. Pro forma

reports are generated before

being subjected to assessment, and if

necessary, amendment.

The recalibrated and accurate data base

then provides the basis for State of

Sector and individual reports


The exact process steps undertaken by the Department, and how the various RHs were obliged to respond, were segmented according to the nature of their right. The primary process differences are whether the process was manual/in person or electronic:

• Limited Commercial RHs : This group comprises RHs in Traditional Linefish (‘Linefish’), Netfish (‘Net’), West Coast Rock Lobster inshore (‘WCRL’) and Hake Hand Line (‘HHL’). These RHs are distinguished from others because they are generally: o Natural persons; o Small-scale; and o Less sophisticated and empowered and thus less likely to have capacity to respond to an

electronic process. • Full Commercial RHs: This group comprises RHs in all other sectors except those of the

Limited segment and they are: o All legal persons; o Small, medium and large scale businesses; and o Have access to electronic communication as well as legal and administrative support and

can therefore be expected to respond to an electronic process.

Figure 2 - How RHs related to the process

Step 3 is where the key process

distinction emerges – Limited RHs were asked to report in

person , with accompanying

documentation, on a pre-determined day

to a Departmental ‘Road-show’ venue

where they were interviewed. Full

Commercial RHs engaged in a fully

electronic process based on a uniquely

identified RFI and pre-populated being sent, and returned,

by email.

Note – a full list of the themes addressed and questions asked in the anonymous survey is available as Annexure ‘C’

Key project milestones

The following table represents the key project milestones:

Milestone Date Permit conditions amended October 2008 High level design completed and project scoped January 2009


Milestone Date Departmental concludes sector plans March 2009 Distribution of brochure explaining process to RHs June 2009 Full Commercial RFI published for comment July 2009 Limited Commercial Road-shows begin November 2009 Limited Commercial Road-Shows closed December 2009 Department publishes general responses to Full Commercial comments December 2009 Full Commercial RFI emailed to RHs February 2010 Department finalises Full Commercial RFI and Survey content March 2010 Limited Commercial initial analysis completed March 2010 Full Commercial RFI submission process closed April 2010 Full Commercial survey process initiated May 2010 Full Commercial survey closed July 2010 Assessment of Limited Commercial RHs March 2009 – January

2010 Assessment of Full Commercial RHs August 2009 – May 2010 Distribution of Limited Commercial Individual Reports March 2011 & Sept 2011 Development of State of Sector reports June – Sept 2011 Distribution of Full Commercial Individual Reports December 2011 Conclusion March 2012

Note: A full list of project milestones covering the whole period of 2008 – 2011 is available as Annexure ‘B’.

Review outputs

The Performance Review has resulted in a number of defined outputs which require deep, ongoing analysis and use by both the Department and, where in the interests of co-management, RHs. These are:

Individual Reports: • Each RH who participated in the Review will

receive an individual report which consolidates data from both the Department and RH; and

• The RHs performance is assessed against the Review criteria and, where appropriate, compared against the sector average. For example, the report will confirm catch data and compare it to the average catch data for the sector in a particular year or by virtue of a ratio that ensures comparison regardless of the size of the RH.

Forensic Reports and Summary: • The Review also entailed extensive forensic work,

particularly in the Limited Commercial Sectors; • Many RHs were selected for a forensic probe

either by virtue of allegations made against them via an anonymous ‘hotline’ established for this purpose, and/or because they were ‘red-flagged’ using a set of Departmental criteria;

• In total, nearly 200 RHs were investigated and reports and recommendations compiled accordingly.


State of the Sector Reports: • 1 Overall Summary of the Performance Review

was produced; and • 17 State of the Sector presentations were

produced (1 for each sector) each well over 100 slides containing an integrated data set from RFI and Departmental data.

RFI Database: • All RFI information (merged and validated against

Departmental data if available) is contained in a single data base with an easy to use front end ensuring that Resource Managers and Researchers will be able to use, add to and manipulate the data going forward.

• The data base allows for easy comparisons, and automatically graphs, data fields within and between fishery sectors.

Qualitative Survey Database: • All anonymous RH responses to survey questions

have been built into an easy to use data base allowing the Department to further analyse RH perceptions about its work and efficacy and the health of the fishery;

• The data base allows for easy comparisons, and automatically graphs, data fields within and between fishery sectors

Note – a full list of the themes addressed and questions asked in the anonymous survey is available as Annexure ‘C’

Report design

This document is an attempt to report, at a very high level, on a significant amount of individual and sector data stored in a very comprehensive data base. For purposes of this Executive Summary, only the following themes will be reported on:

Figure 3 – Report Themes

Note – a description of the methodology used for the reports that follow is listed under Annexure ‘A’


Sectors ‘by the numbers’ – A high level numerical s ummary

Limited Commercial Sectors:

The limited commercial sectors comprise 1503 RHs. Only 85% of RHs in the sector participated in the Review and submitted RFIs, with Hake Hand Line having the worst completion rate (61%). The sector is dominated by individual RHs except for Hake Hand Line, where 29% of RHs that submitted RFIs comprised of closed corporations. A summary of the sector is presented in a ‘sector by numbers’ table, below.

Figure 4 – Sector by Numbers: Limited Commercial RH s

Sample and Demographics HHL NET LIN WCRL (N) All

Number of RH 93 103 422 825 1 503

No. of RHs submitting completed records 59 96 386 740 1 281

Percentage completion 61% 93% 91% 89% 85%

Number of closed corporations 17 1 0 0 34

Industry Association members 7 4 145 271 427

Black RHs % 30% 47% 42% 93% 72%

Female RHs % 2% 5% 2% 24% 15%

Utilisation & Economics HHL NET LIN WCRL (N) All

% of RHs with permit all 3 years 19% 41% 35% 61% 50%

Total catch (2008) 261.33 tons 963 502 fish (harder); 167 940 fish 7,010 tons 356.15 tons 7627.48 tons

Average catch (2008) 854.80 kg 10 036 fish (harder); 1749 fish 2.80 tons 0.48 tons 4.1348

Total crew allocation 309 2505 62.37 2876.37

Average crew allocation 5.24 2.84 6.49 6.72 18.45

Total turnover R8.86m R 3.25 m R66.792 m R42.99 m R118.642m

Total investments R2.56m R 0. 97 m R22.62 m R4.37m R29.55m

Full Commercial:

The full commercial sectors comprise 871 RHs. Across all sectors, a total of 822 RHs submitted completed forms, resulting in a submission rate of 94% across all sectors with 6 sectors having a 100% submission rate. A summary of the sector is presented in a ‘sector by numbers’ table, below.


Figure 5 – Sector by Numbers: Full Commercial Right s Holders

Sample and Demographics All* HDST HLL HIST KPT HM SW

Number of RH 871 50 135 17 4 16 6

% of RHs submitting completed records 94% 100% 100% 94% 100% 88% 100%

Industry Association Members 773 47 125 16 4 12 4

Economic Unit Members 292 37 70 12 3 9 1

Number of RH Operating in Other Sectors 370 33 86 4 2 13 2

Ave Number of Sectors Operating In 2.23 2.32 1.96 1.81 2.5 3.14 2.67

Ave Number of Members in EU 2.88 5.2 3.9 1.88 1 1.71 0.33

Number of RH designated as Black ** 564 32 117 11 2 7 2

Number of RH designated as Female ** 157 3 31 2 0 2 0

Ave Shareholding - Black % 60.47 62.59 74.78 74.02 66.28 47.58 35.99

Ave Shareholding - Female % 23.57 18.69 29.66 32.19 9.65 18.79 10.13

Sample and Demographics SQ PT WCRL SCRL DS SP TP

Number of RH 119 5 221 13 6 109 170

% of RHs submitting completed records 94% 100% 91% 100% 100% 97% 91%

Industry Association Members 113 5 204 12 5 92 134

Economic Unit Members 22 4 77 12 2 47 2

Number of RH Operating in Other Sectors 27 4 72 6 6 71 44

Ave Number of Sectors Operating In 1.49 2.8 1.63 2.08 3 2.07 1.58

Ave Number of Members in EU 0.71 3.2 6.25 9.31 1 2.66 0.32

Number of RH designated as Black ** 49 2 170 7 5 80 80

Number of RH designated as Female ** 12 0 46 1 3 17 40

Ave Shareholding - Black % 48.14 54.85 81.52 56.74 63.46 73.07 47.05

Ave Shareholding - Female % 18.81 17.46 33.51 14.11 39.89 28.79 34.76

Demographics and Transformation

Limited Commercial:

Of the individual RHs (i.e. excluding closed corporation data)most transformed at 93% Black (comprising African, Coloured, and Indian RHs) and HLine the least, at 30% of RHs. The Rock Lobster, where 24% of individual RHs were female. Long Term Rights Allocation Management Processare held by individuals2. Of note is that this is the first time that ‘BlackAfrican, Coloured and Indian.

Figure 6 – Ownership demographics for Limited Commercial

Full Commercial:

When looking at ownership structures, wSeaweed, the majority of RHs in all other sectors have greater than Coast Rock Lobster has the highest average black shareholder ownership percentage, at 81.52%.

The average percentage of Black shareholder ownership was 60.47%,improvement from the 2005 average of 45%ownership has increased across all sectors, with the exception of Sand Horse Mackerel. In terms of those RH50% black shareholder ownershipeconomic perspective, the amount of fish caught by

2 The combination of an inability to sell rights, with ownership of natural persons means that ownership is

have changed in any material form 3 “Average” shareholder ownership % here refers to the average of actual % of Black shareholder ownership across all

RHs within a sector 4 “Black” shareholders refer to number of shareholders in sector >50% 5 “Black” catch is the amount of fish caught by a given RH times the percentage Black shareholder ownership of the

RH

Demographics and Transformation

excluding closed corporation data), West Coast Rock Lobster most transformed at 93% Black (comprising African, Coloured, and Indian RHs) and H

the least, at 30% of RHs. The four sectors are overwhelmingly male except for , where 24% of individual RHs were female. This data has not been compared to

Long Term Rights Allocation Management Process data to calculate improvements as the rights Of note is that this is the first time that ‘Black’ has been broken down into

Ownership demographics for Limited Commercial

structures, with the exception of Patagonian Toothfishs in all other sectors have greater than 50% Black shareholding.

has the highest average black shareholder ownership percentage, at 81.52%.

percentage of Black shareholder ownership was 60.47%, representing a average of 45%3. The average percentage of Black shareholder

ownership has increased across all sectors, with the exception of Seaweed, Patagonian Toothfish. In terms of those RHs designated as Black (number of RHs with greater

% black shareholder ownership4), 64.7% of all sectors are designated as ‘Black, the amount of fish caught by Black RHs5 may be the most accurate

The combination of an inability to sell rights, with ownership of natural persons means that ownership is

“Average” shareholder ownership % here refers to the average of actual % of Black shareholder ownership across all

“Black” shareholders refer to number of shareholders in sector >50% Black “Black” catch is the amount of fish caught by a given RH times the percentage Black shareholder ownership of the

West Coast Rock Lobster was the most transformed at 93% Black (comprising African, Coloured, and Indian RHs) and Hake Hand

overwhelmingly male except for West Coast This data has not been compared to

data to calculate improvements as the rights ’ has been broken down into

Patagonian Toothfish, Squid, and 50% Black shareholding. West

has the highest average black shareholder ownership percentage, at 81.52%.

representing a substantial . The average percentage of Black shareholder

atagonian Toothfish, with greater than Black’. From an

may be the most accurate

The combination of an inability to sell rights, with ownership of natural persons means that ownership is unlikely to

“Average” shareholder ownership % here refers to the average of actual % of Black shareholder ownership across all

“Black” catch is the amount of fish caught by a given RH times the percentage Black shareholder ownership of the


reflection of the level of transformation of the sector. The average catch was only 54% ‘Black’, and, using this measure, Prawn Trawl was the most transformed6.

Figure 7 – 3 Ways of Looking at Levels of Transform ation

In terms of gender, most sectors remain male dominated in terms of shareholding (only 18% of the RHs are designated as female) with only Demersal Shark having more than 50% of RHs with greater than 50% female shareholding. The total average female shareholding7 in 2009 was 24%, representing a slight increase from the 2004 average of 19%. KwaZulu Prawn Trawl, Seaweed, and Patagonian Tootfish were entirely ‘male’ with none of their RHs having greater than 50% female shareholding.

In terms of employee ownership , participation in shareholding by Employee Share Options (ESOP’s) has decreased from 10% in 2005 to 9% currently.

When examining directorships by race and gender, the average percentage of Black directors across all sectors is 63% - a dramatic increase from the 2004 average of 11%. The top salary earners , on average, were 49% black, with KwaZulu Prawn Trawl representing the highest percentage of top black salary earners at 85%.

The average percentage of female directorship was 25% and represented a slight increase from the 20% 2005 average. This was mirrored across sectors, except for Demersal Shark (NB: n=6) and KwaZulu Prawn Trawl. The top salary earners across all sectors were 19% female, with Demersal Shark representing the upper end of the spectrum (36%) and Patagonian Toothfish the lower end.

When asked about their perceptions on the rights allocation process, 60% of RHs agreed that the Long Term Rights Allocation Management Process was successful in transforming their sector demographics. Furthermore, the ownership figures are likely to increase rather than decrease going forward. In response to questions as to future intentions, only 0.7% and 0.5% of RHs felt they were likely to decrease Black and Female shareholding respectively going forward over the 6 Note that the analysis was conducted on catch reported by RHs – i.e. if certain RHs (Black/ non-Black) did not report

catch this would not reflect in percentages and could skew the third way of looking at transformation 7 “Average” shareholder ownership % here refers to the average of actual % of female shareholder ownership across

all RHs within a sector.

period up until their right expires, and 11.5% and 12.3% stated that they are likely to increase Black and Female shareholding respectively‘access to capital’ is the biggest obstacle to increasing Blaacumen’ and ‘fishing experience’.

Finally the review also sought to bring the industry in line with the dti Broad Based Black Economic Empowerment Codes of Good Practice the long terms rights allocation process. Thus the RFI asked for to be able to compare with the allocation data (as above) Codes. In this regard, 56% of RHs are Level 4 anda ‘deemed’ rather than a scored rating

Figure 8 – 3 Ways of Looking at Levels of Transformation

Utilisation

Limited Commercial:

Linefish RHs reported catches of a total of Netfish RHs; 264.13 tons by Hake Hand LineRHs. Across all species, catch increased over the seasons, except for a dip in 2008Coast Rock Lobster RHs.

Similarly, across all species but with the exception of increased over the seasons and Hake Hand Line- The average Linefish RHs caught and West Coast Rock Lobster RHs

In terms of crew-days, on average crew-days in 2008-2009, at an average7.09 crew-days for Linefish RHs, 6.81 for RHs.

8 The rest indicated they were likely to either stay the same (over 70% for both race and gender) or were unsure.9 The Codes allow an enterprise with a turnover of less than R5m to be ‘deemed’ a Level 4 simply by producing

audited financial statements or Level 5 if in addition

riod up until their right expires, and 11.5% and 12.3% stated that they are likely to increase Black and Female shareholding respectively8. In this regard it is worth noting that RHs stated that ‘access to capital’ is the biggest obstacle to increasing Black shareholding, followed by ‘business

Finally the review also sought to bring the industry in line with the dti Broad Based Black Economic Empowerment Codes of Good Practice (‘the Codes’) which had not been published at tthe long terms rights allocation process. Thus the RFI asked for Transformation related information

allocation data (as above) and certified BBBEE scores as per the Codes. In this regard, 56% of RHs are Level 4 and 25% are Level 5 with 80% of all RHs opting for a ‘deemed’ rather than a scored rating9.

3 Ways of Looking at Levels of Transformation

a total of 7,010 tons in 2008-2009, compared to 963 Hake Hand Line RHs; and 356.15 tons by West Coast Rock Lobster

Across all species, catch increased over the seasons, except for a dip in 2008

but with the exception of West Coast Rock LobsterHake Hand Line RHs’ average catch nearly doubled in 2008

caught 2.8 tons; Netfish RHs 1000 fish; Hake Hand LineRHs an average of 480kg of fish in 2008-2009.

days, on average West Coast Rock Lobster RHs used the highest number of 2009, at an average of 62.37 crew-days per year, compared to an average of

days for Linefish RHs, 6.81 for Hake Hand Line RHs, and 2.84 crew-

ey were likely to either stay the same (over 70% for both race and gender) or were unsure.The Codes allow an enterprise with a turnover of less than R5m to be ‘deemed’ a Level 4 simply by producing audited financial statements or Level 5 if in addition to the financials they show more than 50% Black shareholding.

riod up until their right expires, and 11.5% and 12.3% stated that they are likely to increase . In this regard it is worth noting that RHs stated that

ck shareholding, followed by ‘business

Finally the review also sought to bring the industry in line with the dti Broad Based Black Economic which had not been published at the time of

ransformation related information certified BBBEE scores as per the

25% are Level 5 with 80% of all RHs opting for

2009, compared to 963 502 fish by West Coast Rock Lobster

Across all species, catch increased over the seasons, except for a dip in 2008-2009 for West

West Coast Rock Lobster, average catch tch nearly doubled in 2008-2009

Hake Hand Line RHs 850 kg;

RHs used the highest number of days per year, compared to an average of

-days for Netfish

ey were likely to either stay the same (over 70% for both race and gender) or were unsure. The Codes allow an enterprise with a turnover of less than R5m to be ‘deemed’ a Level 4 simply by producing

to the financials they show more than 50% Black shareholding.

These catch and crew figures need to be placed in context insofar as permits for all 3 years under review West Coast Rock Lobster.

Figure 9 – Limited Commercial Catch over 3 years under review

Full Commercial:

Across all sectors, an average of only under the performance review (2006Trawl, Small Pelagics and Patagonian Toothfish. RHs were allocated a total of 618,196 tons and caught only 442,030 tons of fish—representing underwere reported in Hake Deep Sea Trawlanchovy and 83,464 tons of sardines). The average catch per RH was around 507 tonparticularly high average catches for For Total Allocated Effort (‘TAE’) sectors, the allocation was

These catch and crew figures need to be placed in context insofar as only 50% of RHs took out for all 3 years under review – 19% Hake Hand Line; 41% Netfish; 35% Linefish; and 61%

Limited Commercial Catch over 3 years under review

only 69% of RHs had permits across all three years examined under the performance review (2006 - 2008), and this was particularly low in

, Small Pelagics and Patagonian Toothfish. RHs were allocated a total of 618,196 tons and representing under-catching of almost 29%. The highest catches

Hake Deep Sea Trawl (108,489 tons) and Small Pelagics (267,520 tons for anchovy and 83,464 tons of sardines). The average catch per RH was around 507 tonparticularly high average catches for Hake Deep Sea Trawl, Horse Mackerel, and Small Pelagics.

sectors, the allocation was a total of 9515 crew days

only 50% of RHs took out ; 41% Netfish; 35% Linefish; and 61%

69% of RHs had permits across all three years examined 2008), and this was particularly low in KwaZulu Prawn

, Small Pelagics and Patagonian Toothfish. RHs were allocated a total of 618,196 tons and catching of almost 29%. The highest catches

(108,489 tons) and Small Pelagics (267,520 tons for anchovy and 83,464 tons of sardines). The average catch per RH was around 507 tons, with

, and Small Pelagics. days.


Figure 10 – Sector by Numbers: Full Commercial RHs

Economics

Limited Commercial:

Investments are relatively high in year one, potentially a reflection of the need for new entrants to invest once they were awarded the right. Linefish RHs made the highest investments by far, of R58.14m in 2006-2007, followed by Hake Hand Line RHs (R10.43m in 2006-2007) and West Coast Rock Lobster RHs (R6.20m in 2006-2007). Netfish RHs made minimal investments (R 1.38m in 2006-2007) in comparison to other RHs.

In terms of agreement types, the majority of RHs across Hake Hand Line, Netfish, and Linefish do not have agreements, whereas the majority of West Coast Rock Lobster RHs (63.95%) have catching, marketing, and processing agreements. Of other sectors with agreements, 12.5% of Hake Hand Line RHs have processing agreements only, and 12.5% of Netfish and 14% of Linefish RHs have catching agreements only as their most common agreement form.

The nature and number of agreements a RH has are key variables that drive revenue and profit. Catching, marketing and processing agreements may be seen as a proxy for ‘paper quotas’ and raise access to a vessel as a key policy issue for future allocation. When asked about the perceived value of holding any type of agreement, the majority (53.6%) of RHs believe these to be financially lucrative. Comparing agreement types across species, it appears that catching and marketing agreements for Hake Hand Line generate the most revenue, followed by catching and processing agreements for Linefish, and processing agreements for West Coast Rock Lobster. Extrapolating these findings, it appears that business links and direct access to vessels appear as key variables driving profit.

Figure 11 – Limited Commercial – Types of Agreements

Traditional Linefish has the highest Lobster at R42.99m in 2008-2009. Netfish sees the least turnover, with R3.25m in 2008West Coast Rock Lobster is the only sector where turnover has increased despite a dip in catch.

Despite ‘reliance on income’ being a criterion ofnarrow majority (54%) of RHs solely however, are majority Coloured/ White.

In all the sectors, turnover from sector activity is greater than alternative ithe highest turnover is Traditional Linefish (R66.79m) followed by R42.89m in 2008/09. Although it has the substantially higher turnover (R8.86m) than Netfish, tAlternate income forms a greater proportion of total income in the Netfish sector.

Confirming the trend across all species, closed corporations fared relatively worse than other categories of RHs. Low closed corporatdrawn to mitigate tax. Indian RHs maRHs comprise only 1% of RHs), followed by White and Coloured and finally made the least profit across all species. Although positive about resource availability, profit prospects are aligned with evidence that very few participants are financially successfulRHs indicate that the global downturn has negatively impacted their businindicate that it is more difficult to make money in the sector.

Full Commercial:

Across all sectors, catch sales generated R4.2billion, with the highest from (R1.97billion). Per ton, the average RH sold fish for R19total profit10 generated across all sectors was estimated to be R568m, with the average RH

10 Assessing revenue and profit across sectors is extremely difficult due to RHs reporting global revenue and profit yet

often operating across more than 1 sector (average 2.23 sectors). Theref

Types of Agreements

Traditional Linefish has the highest total turnover of R66.79m, followed by West 2009. Netfish sees the least turnover, with R3.25m in 2008

is the only sector where turnover has increased despite a dip in catch.

being a criterion of the Long Term Rights Allocation Processsolely depend on a single species. Those with alternate income,

however, are majority Coloured/ White.

In all the sectors, turnover from sector activity is greater than alternative income. The sector with Traditional Linefish (R66.79m) followed by West Coast Rock Lobster

it has the smallest number of RHs, Hake Hand Linesubstantially higher turnover (R8.86m) than Netfish, the smallest sector by revenue (R3.25m). Alternate income forms a greater proportion of total income in the Netfish sector.

Confirming the trend across all species, closed corporations fared relatively worse than other losed corporation profit (most ran at a loss) may be related to salaries

Indian RHs made the most profit on average across all species (NB: Indian followed by White and Coloured and finally African RHs, who

east profit across all species. Although positive about resource availability, profit prospects are aligned with evidence that very few participants are financially successfulRHs indicate that the global downturn has negatively impacted their business, and 46% of RHs indicate that it is more difficult to make money in the sector.

generated R4.2billion, with the highest from Hake Deep Sea TrawlPer ton, the average RH sold fish for R19, 454 per ton or R19.45 per kg of fish. The

generated across all sectors was estimated to be R568m, with the average RH

Assessing revenue and profit across sectors is extremely difficult due to RHs reporting global revenue and profit yet often operating across more than 1 sector (average 2.23 sectors). Therefore, to avoid double counting, profits for this

West Coast Rock 2009. Netfish sees the least turnover, with R3.25m in 2008-2009.

is the only sector where turnover has increased despite a dip in catch.

Long Term Rights Allocation Process, only a alternate income,

ncome. The sector with West Coast Rock Lobster at

Hake Hand Line has a he smallest sector by revenue (R3.25m).

Confirming the trend across all species, closed corporations fared relatively worse than other be related to salaries

the most profit on average across all species (NB: Indian African RHs, who

east profit across all species. Although positive about resource availability, profit prospects are aligned with evidence that very few participants are financially successful—49% of

ess, and 46% of RHs

Hake Deep Sea Trawl per ton or R19.45 per kg of fish. The

generated across all sectors was estimated to be R568m, with the average RH

Assessing revenue and profit across sectors is extremely difficult due to RHs reporting global revenue and profit yet ore, to avoid double counting, profits for this


generating R376,785 in profit. The average total investment in the sector amounted to R192 million.

Across the sectors, a total of 22,105 individuals were employed , with the majority in Hake Deep Sea Trawl (5916), followed by Small Pelagics (5203) and Squid (2998). The total wage bill amounted to R2.5 billion, with the highest average daily wage paid to employees in Horse Mackerel. There were 972 vessels in the sector, with a RH on average accessing 1.56 vessels.

When asked their perceptions, 83% of RHs indicate that they have made substantial investments since rights were allocated, but fewer RHs indicated that they would further invest in a vessel (46%). The amounts of indicative/possible future investment vary, with a majority investments below R1 million (58%).

46% of RHs indicated they most likely would employ more permanent workers but slightly fewer would employ seasonal workers (41%).

Figure 12 – Sector by Numbers: Full Commercial RHs

The prevalence of so-called ‘Economic Units’ is a notable feature of Full Commercial sectors. When submitting their RFI, RHs were asked to self identify as economic units if they were in any type of joint venture. This request was made in order to prevent double counting of investment, jobs and transformation figures. If a RH self identified as an economic unit then all members of the economic unit had to apportion jobs, investment and transformation data amongst themselves.

figure include those from RH operating in 1 sector. Given that RHs reported profit on earnings from more than 1 sector, catch sales and sales per ton figures are the most accurate and reliable


Figure 13 – Number of RHs in Economic Units (per RF I)

A total of 292 RHs self identified as being members of Economic Units. This means that 34% of RHs across all Full Commercial sectors are members of economic units. Hake Deep Sea Trawl has the highest concentration of economic units at 88%.

Figure 14 – Average number of economic unit members per sector

The average number of RHs in an economic unit across all sectors is 5.35 and South Coast Rock Lobster has the highest number with 9.31 while Tuna Pole has the lowest with 0.32.

When examining the ownership figures pertaining to economic units it is apparent that they play an important role as vehicles for transformation. The racial spread of economic units versus non-


economic members indicates that members of economic units are on average 71% Black compared to non-economic members who are on average 62% Black.

The relative concentration of the Full Commercial sectors can be seen when examining the number of RHs who fish in more than one sector. On average, 370 out of 822, or 43% of RHs across all sectors operate in sectors outside their own. This means that the average RH operates in 2.23 sectors including their own.

Figure 15 – Average number of sectors in which RHs operate

Sector (co) management

Co-management is a well established principle but membership of industry associations vary. While not shown in the figure below, membership in Limited Commercial fisheries is low and only Linefish has substantial membership.

The majority (88.7%) of the RHs in Full Commercial sectors are in industry associations, representing a high level of organisation. The majority of industry associations represent RHs on a scientific and management working group. When asked about the perception of industry organisations, the majority of RHs appeared satisfied with this representation, although a third of RHs are not sure, indicating that the effectiveness of these groups may be hard to gauge. 78% indicate that the industrial body is representative. 70% of RHs indicated that the recognised industrial body engaged effectively with the government and participates effectively in co-management activities (71%). Fewer RHs indicated their satisfaction with the level of assistance in skills development (14%).


Figure 16 – Membership in Industry Associations

When asked their perception of the rights allocation process , 32% of RHs indicated that instructions and timelines were poorly communicated but 71% of RHs indicated that the process of allocation was run efficiently. Over 50% of RHs neither agreed with the allocation methodology nor supported the criteria used for comparative balancing, nor agreed with the weighting of criteria, and 53% thought the criteria were unfairly assessed.

However, despite those figures, 67% of RHs thought that the process did succeed in achieving the objectives of the MLRA.

60% of RHs rated the Department’s communication on policy and regulatory changes as average or good. However, 32% of respondents rated the consultation process as poor and 29% rated the response on the observer program as poor.

23% of RHs indicate that there is corruption in the Department and that it has stayed the same or decreased slightly. Of those who believe it has increased, the majority (43%) indicate that it is because there is no fear of being caught. 82% say they would report corruption, and those that would not, feared inaction, or a lack of trust in the Department.

The majority of RHs believe that co-management is efficient (68%), but fewer believe that objectives are achieved. While interaction between RHs and observers is rated as average or good, the majority of RHs do not want this program extended to include having compliance observers on vessels.

RHs are broadly happy with the catch estimation process , with 85% indicating that the process is efficient, 82% that the results are accurate, and that the methodology adopted to estimate catches does the job (82%).

In terms of compliance , the majority of RHs interact with a Control Officer. Around 10% of RHs indicate that the Officers are not competent, and 14% of RHs indicate that the Officers do not undertake duties well. Their integrity was broadly not questioned.


The majority of RHs acknowledge the presence of environmental patrol vessels (60%), but do not appear to think they achieve their purpose (37%). Special Investigations Units are less visible (79%) and perceived to only partially serve their purpose.

47% of RHs indicated that the Department is not doing enough to stop poaching, and that the methods currently employed are ineffective (76%). Further, RHs perceive poaching to have increased (46%) largely due to inadequate information or economic methods.

Conclusion

This executive summary and associated sector reports marks the closure of the Department’s first attempt at a Performance Review. In addition to the valuable lessons generated by the process, the basis has been laid for future Reviews insofar as:

• The overall process design and methodology was effective and can be used to conduct future reviews. In this regard the following changes would be recommended: o A cross-departmental team should lead the project including the Chief Directors

responsible for compliance, research and resource management; o The need for and extent of forensic capacity required should be reviewed – it should

perhaps rather be procured on an ad hoc basis; o Complete overhaul of data bases and advance validation of Departmental information will

remove the requirement for RHs to validate; o Assuming the Limited Commercial process remains manual in nature, the use of

Departmental administrative staff in direct interface roles during the information collection stage should be reconsidered in favour of the responsibility being given to researchers and resource managers dealing with those sectors;

o If there is consideration of automating the Limited Commercial process to match Full Commercial, then it is imperative that maintaining a valid email address becomes a permit condition before the process begins; and

o Consultation with industry groups on the content of the anonymous survey – gaining input on what they will be interested in finding out would add value.

• A functional, easy to access, data base now exists which can be used to measure longitudinal progress in future reviews. It also has an up-to-date ;

• Analytical and reporting frames have been set; • The basis for all content required has now been set in terms of a draft RFI and questionnaire

per sector. In this regard there are small amendments which, based on this experience, will be necessary e.g. being clearer on measurement descriptions like kilograms and tons; and

• The industry has experienced a Performance Review and there is likely to be less anxiety and more cooperation the second time around.

As a result of the Review the Department should be in a manifestly better position to understand the fisheries they manage and the RH who make them up. There is every likelihood that the envisaged s28 processes, and any actions taken as a result of analytical outcomes and/or recommendations, will serve to enhance the productivity of the industry and further support the objectives of the MLRA. Similarly, if the Department uses the ‘mirror’ that the qualitative data represent and acts to shore up its areas of weakness, it will be in a better position to fulfil its responsibility as custodian of South Africa’s sea-based natural resources. As such, the foresight shown by Cabinet in 2005 to introduce the notion of Performance Reviews has been rewarded with the platform for Departmental and industry improvement.


ANNEXURES:

Annexure A - General notes on methodology

• The report contains analysis of all information as presented by the RH on the RFI • The analysis of the RFI data is presented together with the results of the perception survey.

Wherever the perception survey results are used, it is noted accordingly. For e.g., the section on demographics and transformation presents a snapshot of information of the sector demographics as presented by the RH on the RFI. This is followed by pertinent perception survey questions on demographics and transformation, as answered by the RH.

• Data is presented in a variety of graph formats, including: pie charts and bar charts. Where possible, data is outlined as percentage as well as raw numbers. For ease of comparison across sectors, percentage data is used for the analysis, e.g. 822 of 871 RHs in sector A&B submitted completed records, representing a submission rate of 94% for all sectors.

• Catch data is presented by calendar year for Sectors A&B, and by seasons for sectors C&D. Data for all three years is presented wherever available. This data reflects what was submitted by the RH in the RFI.

• RFI data is analysed by ‘total’ as well as ‘average’ amounts, e.g. ‘Total Catch’ representing total fish caught by all RHs in a given sector (in tons) as compared to ‘Average Catch’ representing the ‘average’ no. of tons of fish caught by each RH in a given sector. Where possible, total and average amounts are also presented by demographic cuts – e.g. ‘total Black catch,’ ‘average Black catch,’ etc.

• Economic data is presented in Millions of Rands, unless otherwise noted. • Catch data is presented in tons, unless otherwise noted. • Perception survey data is presented in percentage breakdowns by responses. In the analysis,

some responses are ‘grouped’ for ease of reference, e.g. ‘Agree/ Strongly Agree,’ in order to illustrate broader trends.


Annexure B – Project milestones

Step Deliverable Date

High Level Design

• A high level process design was developed, aligned to legal opinion and based on Departmental input made at three workshops. These workshops were facilitated by Resolve and included all Resource Managers.

• The design comprised of two separate processes for Clusters A and B, and C and D respectively. Each process entailed two components (a Request for Information [RFI] and qualitative survey) with two outputs (individual performance reports and ‘State of the Sector’ Reports).

• The process was mapped in sufficient detail to act as a platform for consultation with Right Holders

• The project was then scoped and Service Level Agreements were concluded

• Design completed 12 December 2008

• Design signed off by Department on 30 January 2009

• SLA with Resolve signed 12 December 2008

Draft Permit Conditions and Right Holder Brochure

• New permit conditions were drafted to provide a legal basis to compel Right Holders to participate in the process (Resolve ascertained that due to a failure to amend the MLRA to match the Long Term Rights Allocation Process [LTRAMP] General Policy, no legal basis to compel participation existed)

• A brochure was developed to provide Right Holders with an explanation of the purpose of the review, its policy antecedents and its legal basis. In addition, the brochure provided an overview of the two review processes.

• The brochure was distributed sent to the address of each right holder as well as distributed via Fishery Control offices. It was also published on the Departmental Web-site

• Permit conditions amended in October 2008

• Brochure designed by 20 March 2009

• Brochure signed off by Department on 17 April 2009

• Brochure distributed by 1 June 2009

Sector Design • Intensive internal Departmental consultation per fishery sector in order to o Developing high level performance indicators o Confirming policy criteria as remaining relevant o Understanding sector management imperatives

• The output of this process was separate Sector Performance Management Plans.

• Sector plans developed by 19 March 2009

• Sector plans approved by end March 2009

Consult on Performance Review plan and criteria

• A limited Promotion of Administrative Justice (PAJA) consultation process was embarked upon to meet the obligations set out in the Long Term Rights Allocation Process General Policy. o The draft RFI and a brochure describing the intended

process was sent to all Right Holder contact addresses, published on the Departmental website and distributed through FCO offices and Fishing Associations.

o In addition to describing the process, the brochure also contained the number for an anonymous ‘Tip-Off’ line maintained by Deloitte which enabled Right Holders to report illegal or inappropriate conduct of other Right Holders.

• While the Department was legally obliged to only consult on performance criteria, it also published the draft RFI and both encouraged, and responded to, comments on process.

• The comment process for A and B was extended twice to deal with late comments and to cater for the December shut-down.

• RFI published for comment on 1 July 2009

• Comment process closed on 31 August 2009

• General responses to comments published on 7 December 2009

Finalisation of Performance Review Tool set

• Two main measurement ‘tools’ were finalised after receiving comments during the consultation phase: o A Request for Information (RFI) form – this refers to the

form to be completed by each right holder indicating current status for performance measurement. � For clusters C and D the form was designed to be pre-

populated with Departmental data and then supplemented and corrected by face-to-face interview with every Right Holder in these four fisheries

� For clusters A and B, the form was designed for pre-population with Departmental data, and was to be

• RFI submitted to Department on 26 June 2009

• Survey submitted to Department on 11 March 2010

• Department sign off on survey 13 March 2010 and RFI on 23 December 2009



completed and submitted both electronically (for data base) and by Hard Copy (signed print-out for validation). The RFI for clusters A and B was designed to minimise submission requirements (i.e. as per SARS electronic submission requirements the right holders were required to maintain records and evidence of the information submitted to be available for inspection)

• Qualitative confidential survey tool or perception survey: o For clusters C and D this was designed as a short paper

based survey capable of immediate, anonymous completion immediately after interviews

o For clusters A and B it was designed as a web or email based application to be completed confidentially and submitted electronically.

C and D Road Shows

• 1496 Right Holders in sectors C and D were invited by letter, email and general communication to attend specific Performance Review road shows held in an area close to their address. Right Holders were warned that it was compulsory to attend and were requested to bring supporting documentation such as catch records and ‘bakkie slips’ to prove personal involvement

• 1267 Right holders attended the road shows and were interviewed by Department officials. After being assisted to complete their RFI’s, they were then asked to participate anonymously in a paper based qualitative survey. o 225 of these were the subject of additional investigation by

Deloitte Forensic after being identified as high risk and ‘Red Flagged’. This list was comprised of Right Holders who had either been identified through Departmental records and/or who were the subject of anonymous tip-offs.

• Of the 229 Right holders who did not attend: o 24 are deceased; o 177 did not provide reasons or could not be contacted; o 8 indicated they were not interested in being Right Holders

anymore due to changes in personal circumstances; o 5 were from Hondeklipbaai; o 5 were sick or out of town; and o 3 made alternative arrangements.

• The completed RFI’s and survey responses were then data captured and a date base was built for the purpose of generating individual reports and generating sector analysis

• The C and D road shows began on 16 November 2009 and were completed by 11 December 2009

• Data capturing completed and initial analysis generated by 12 March 2010

A and B RFI process

• The RFI for A and B was emailed to all 929 Right Holders and published on the Departmental Website on 1 February 2010. A unique, numbered RFI was emailed to each Right Holder and security measures included embedded software to generate new bar-codes for each page when printed in order to be able to ensure that the electronic and hard-copy submissions were identical. o Severe problems with the accuracy of the Department’s data

base of Right Holder contact details lead to numerous requests for the RFI to be sent to different email addresses. This was compounded by some Right Holders requiring extra support from the call centre due to old technology and consultants hired by Right Holders demanding that the RFI be mailed to their addresses.

o Owing to these problems, as well as legal pressure to extend, the Department extended the electronic submission date by 30 days to 30 April 2010 and the Hard Copy submission to 30 May 2010.

o No reasons have been given by those Right Holders who did not submit one or both RFIs and the Department is attempting to reconcile lists and contact missing Right Holders in person

• RFI emailed and posted on web on 1 February 2010.

• Final extension date for electronic submission 30 April 2010.

• Final hard copy submission extension was 30 May 2010.



A and B Survey process

• All A and B Right Holders were sent an electronic version of the survey and given a date by which to submit it. o Survey comprised of questions relating to MCM service and

efficiency, fishery management, compliance and poaching, transformation, socio-economic development and other qualitative categories

• Survey distributed electronically on 13 May 2010.

• Final submission date 18 June 2010 extended by 30 days.

Assessment and Data Analysis

• This phase included the processing, assessment and validation of all data received from all sectors.

• Data bases for A, B, C and D are capable of automatically generating individual reports based on set responses to data field options.

• Each individual report was assessed against the RFI submission and Departmental information.

• Sector information to be analysed and compared to Long Term Rights Allocation Process information

• Completed

Individual reports

• Every right holder receives an individual assessment report in the form of a letter from the Department that: o records the vital elements of the information they submitted; o Indicates where the Department accepts or does not accept

differences in information; o Notes changes in status and compares their results under

certain indicators to those of other Right Holders in their sector or Zone; and

• C and D letters issued in March 2011.

• C and D letters to replace the previous reports issued in September 2011

• A and B letters issued in December 2011.

Sector reports

• A ‘State of the Sector’ report was prepared for each sector which includes: o General information on the sector o Longitudinal analysis per RFI theme when compared to Long

Term Rights Allocation Process data o Comparative analysis per RFI theme using both RFI

responses as well as survey data o Conclusions

• Sector reports finalised in September 2011 and reviewed by Department.

• Sector reports to be published on website.

• Overall report and executive summary finalised in Jan 2012.

• Handover and conclusion on 30 March 2012.


Annexure C – Themes and questions covered in the an onymous survey of Right Holders

SECTION 1: MCM EFFICACY/CUSTOMER SERVICE

PART A - BUSINESS PROCESSES

QUESTION 1: FISHING PERMIT APPLICATION AND PROCESSING

QUESTION 2: EXPORT PERMIT ALLOCATION AND PROCESSING

QUESTION 3: FPE EXEMPTION QUESTION 4: VESSEL CHANGE APPLICATION INCLUDING: TEMPORARY CHANGE, PERMANENT CHANGE, ADDITIONAL VESSEL APPLICATION QUESTION 5: RIGHTS TRANSFER QUESTION 6: EXEMPTIONS FROM SPECIFIC PERMIT CONDITIONS E.G. REQUIRMENTS TO BE ON BOARD VESSEL QUESTION 7: LEVY PAYMENTS

PART B: COMMUNICATION, SYSTEMS AND FACILITIES

QUESTION 1: GENERAL COMMUNICATION

QUESTION 2: SYSTEMS AND FACILITIES

PART C - MARINE RESOURCE MANAGEMENT

QUESTION 1: RIGHTS ALLOCATION (2005/2006)

QUESTION 2: TAC

QUESTION 3: TAE ALLOCATION

QUESTION 4: WORKING GROUPS, SECTOR AND CO-MANAGEMENT

QUESTION 5: OBSERVER PROGRAM

PART D - MONITORING, COMPLIANCE AND SURVEILLANCE

QUESTION 1: SHORE-BASED COMPLIANCE

QUESTION 2: SPECIAL INVESTIGATION UNIT

QUESTION 3: LEGAL

SECTION 2: COMPLIANCE RELATED QUESTIONS

PART A: OVER-CATCHING

QUESTION 1: POACHING

QUESTION 2: OVER-CATCHING

QUESTION 3: ILLEGAL TRANSHIPMENT AT SEA

QUESTION 4: DUMPING AND HIGHGRADING

QUESTION 5: TARGETING BY-CATCH

PART B: OTHER COMPLIANCE ISSUES

QUESTION 1: PERCEPTIONS OF CORRUPTION WITHIN THE DEPARTMENT

QUESTION 2: RANKING OF INTEGRITY

QUESTION 3: S28

SECTION 3: RIGHT HOLDER PERCEPTIONS OF THE INDUSTRY

PART A: INDUSTRY STABILITY QUESTION 1: FULFILMENT OF EXPECTATIONS POST LONG TERM RIGHTS ALLOCATION MANAGEMENT PROCESS OBSTACLES QUESTION 2: INVESTMENT

QUESTION 3: WILLINGNESS TO EMPLOY (OR REASON WHY NOT)

QUESTION 4: PERCEIVED RISKS

QUESTION 5: CONSOLIDATION


PART B: INDUSTRY ASSOCIATION

QUESTION 1: MEMBERSHIP OF RECOGNISED INDUSTRIAL BODIES

QUESTION 2: EFFECTIVENESS OF THE RECOGNISED INDUSTRIAL BODIES (INDUSTRY ASSOCIATION)

PART C: INVOLVEMENT OF RIGHT HOLDERS

QUESTION 1: ROLE OF RIGHT HOLDERS

QUESTION 2: ROLE OF CONSULTANTS/LAWYERS

PART D: INDUSTRY ISSUES

QUESTION 1: JOINT VENTURES

QUESTION 2: CATCH, PROCESSING AND MARKET AGREEMENTS

QUESTION 3: VESSELS

QUESTION 4: VESSEL AND CREW SAFETY

QUESTION 5: ECONOMIC VIABILITY OF QUOTA (I.E. MINIMUM QUOTA)

SECTION 4: TRANSFORMATION-RELATED ISSUES

QUESTION 1: CURRENT LEVEL VERSUS FUTURE INTENTIONS

QUESTION 2: RANKING OF TRANSFORMATIVE CRITERIA

QUESTION 3: OBSTACLES TO GROWTH OF BLACK RIGHT HOLDERS

QUESTION 4: OTHER TRANSFORMATION MEASURES

QUESTION 5: SUBSISTENCE/SMALL SCALE POLICY

SECTION 5: RESOURCE RELATED ISSUES

QUESTION 1: SUSTAINABILITY ISSUES

QUESTION 2: RESOURCE TRENDS OR CHANGES

QUESTION 3: RELATIVE EFFORT/COST TO RETURN RATIOS

QUESTION 4: OPTIMALITY ISSUES REGARDING SEASONS

SECTION 6: SOCIO ECONOMIC ISSUES

QUESTION 1: ECONOMIC FACTORS AND FINANCIAL VIABILITY

QUESTION 2: IMPACT OF EXCHANGE RATE

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