Points from Durban Meeting
1. DEA PROPOSALS FROM DURBAN, AND FOSAF/TROUT-SA RESPONSES Proposals from DEA following the two Responses from FOSAF and Trout-SA meetings held in Durban 1 Brown trout and rainbow trout ("trout") will be Noted. listed as invasive species, in areas in which they do not occur in South Africa. 2 Trout will be listed as Category 2 species in Trout SA notes that most of these areas will be in such National Parks, Provincial Reserves, Mountain reserves and that the intention is to issue permits to Catchment Areas and Forestry Reserves management authorities where applicable and this is specified in terms of the Protected Areas Act. accepted in the spirit of compromise. However, those privately owned reserves like Mount Anderson, where trout are a major driver of the reserves’ existence, must be exclude from this listing. 3 Trout are not listed outside of these areas (#1 Agreed and #2), in systems in which they occur (including rivers, dams, natural lakes, wetlands and estuaries), and there is no requirement for "control" or a Permit in these areas.
2. GOVERNMENT POSITION ON SELLING LIVE SPECIMENS OF TROUT 4 • A Permit will be required for selling live specimens of trout. • Aquaculture facilities will be issued with a Permit to do so. • It was proposed that this be a five-year Permit, for multiple sales of live specimens. • The Permit condition will be to record details of each sale, and capture these on a confidential Website available to DEA Biosecurity. • The details should include the person/group to whom it has been sold, the area in which the live trout will be released, and the route that will be driven in taking the trout to the area of release. • (When the maps are completed, trout may not be sold to a person wishing to introduce it in an orange or red area, without a Permit from DEA for that introduction.) • A receipt with this detail will be required to be carried by those transporting the live specimens. Failure to produce such a receipt, or a Permit from DEA (where the trout have been obtained from someone other than at an aquaculture facility), will constitute an offence in terms of the Regulations.
3. FOSAF/TROUT-SA POSITION ON SELLING LIVE SPECIMENS OF TROUT 4 Trout-SA/FOSAF accept the proposed operational management procedures and objectives. In terms of the legal basis for permitting, it is proposed that the permitting of stocking trout from fish farms into unlisted waters not be done under a Category 2 Invasive listing because: 1) The industry sensitivity to the “invasive’ term; and 2) As trout are moving from unlisted aquaculture operations to unlisted waters there is no biodiversity risk. We propose instead that for the purpose of stocking unlisted waters, trout should be exempt as aliens under section 66 which allows for the imposition of conditions. Such conditions will cover and include all the aspects enumerated by Dr Preston. Mention was made of a secure Web site available to producers and DEA Biosecurity. Thus producers would record details of each sale: including, the person/group to which it has been sold, the location at which the live trout will be released, and the route that will be driven in taking the trout to the location of release. A receipt with this detail printed off the website, will be required to be carried by those transporting the live specimens. Failure to produce such a receipt, or a Permit from DEA (where the trout have been obtained from someone other than at an aquaculture facility), will constitute an offence in terms of the Regulations.
4. GOVT vs FOSAF/TROUT-SA ON PERMIT TO RELEASE TROUT 5 A Permit will be required to introduce trout into rivers, The word introduce must be replaced with natural lakes, wetlands, estuaries and public dams, “release”. While we have agreed to this in a spirit in areas where they currently occur. of compromise the alternative formulation noted above using Section 66 is preferred and proposed Such Permits will be granted to individual and as this avoids the “invasive” appellation but possibly groups (Legal to confirm) on a long-term achieves the same management objectives. basis, and for multiple introductions, in areas that are agreed by DEA and its partners, and the industry, to The requirement for stocking public dams is new be "green" in terms of the mapping that was co- and was not discussed. Trout-SA and FOSAF are ordinated by Dr Swartz. of the opinion that this requirement is not necessary as the stocking of public dams does This will be specified in terms of the Permit not pose a biodiversity threat. As all activities on conditions, rather than being written into the public dams are subject to Department of Water Regulations or Notices. Affairs authorisation and permit guided by dam I would propose that DEA, its partners and the Resource Management Plans the use of state industry agree on interim maps within the next two property for public and private benefit is already months. These maps will be further developed over provided for. the next two years, during which time it is hoped that an Invasive Species Green Paper, White Paper, Act and Regulations will be developed that can incorporate such a map in terms of demarcated areas.
5. GOVT AND FOSAF/TROUT-SA POSITIONS ON REMAINING POINTS 6 Trout will not be listed as Category 2 species for aquaculture facilities, Agreed in areas in which they currently occur. 7 Trout may be introduced into privately owned dams (human-made Agreed. But delete reference structures, as opposed to natural lakes) without a Permit. If the dam is to private dams leaving it as on a river, it may still be stocked with trout without a Permit. just a reference to dams. This will then be a natural consequence of not listing trout as invasive. 8 Trout ova may be imported into the country in terms of these Agreed Regulations, providing they go through a risk assessment and phytosanitary measures through DAFF. 9 We did not go back to whether it is necessary to have the existing Agreed. This must be subject Permits from Provinces valid for a two-year period. It does no harm to to constitutional space for keep that in, although I think there is now no need (for trout). provincial powers. 10 Where trout are being farmed without a Permit, this will be "regularized" Agreed. if within areas within which they currently occur. As trout are now not listed in such areas, and aquaculture facilities are not listed, I am not sure if there is any case where regularization will be necessary. However, there is that commitment. So (f) below may be redundant 11 I think it goes without saying that no Permit is required to fish for trout, Agreed. in terms of these Regulations?
5. FURTHER POSITIONS, INCLUDING ON SELF-ADMINISTRATION 12 DEA, its partners, Trout SA and FOSAF will issue a joint statement on Agreed the above, if the Minister approves after our respective consultations. a. Agreed. A degree of self-administration is already provided for, Consultation would be following Professor Britz’s suggestions regarding Permitting. undertaken regarding regulation of self-administration by trout industries. b. Government reserves the right to protect critically endangered and Agreed endangered fish in select discrete catchments, against invasive fish species. c. DAFF: “We briefly discussed how one would tackle "regularisation" of n/a the existing industry to ensure that impacts are managed properly and that we have a clear understanding of the distribution of the current sector. This applies primary to very small scale farm operation that may not have the correct permits.” d. DAFF: “We discussed setting up a workshop with the DEA, provinces, n/a SAIAB and SANBI to develop a guideline regarding areas where RAS systems may be acceptable, areas where tilapia have invaded and pond culture could be accepted and areas where even RAS systems would not be encouraged. In addition, the question regarding the risk of using the GIFT tilapia strain was posed as it is likely to be raised.”
Approach to Regulation of Invasive Species
The Approach to Regulation of Invasive Species 1. The approach to the control of listed invasive species, and the prevention of the introduction of potentially invasive species not yet in the country, is to ensure that the Regulations: meet the objectives of the Act, • recognize co-operative governance and mandates of other Departments and the Provinces, • • focus on priorities, and • . be practicable, sensible, enforceable and affordable. 2. The focus, in keeping with international best practice, is on: • preventing new invasions, • addressing early detection, and rapid response, • the judicious use of biological control agents, • focusing on where invasives are most harmful (such as high-altitude clearing), and • prioritizing the most damaging species. 3. Although the first requirement is a science-based assessment of the (potential) invasiveness of a species, the utility of invasive species must influence decision-making. A long-term view on control of species already in country (where “eradication” is virtually impossible) has been taken - e.g. • not listing jacarandas in urban areas, • recognizing National Heritage Trees (e.g. camphor trees), • differentiating measures where practicable (e.g. large Monterey pines in the South-Western Cape), and • the nuanced approach to gum trees.
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