Trout Stakeholder Reply to DEA media release 

The recent DEA media release on the NEM:BA alien and invasive species (AIS) lists and regulations has caused a lot of confusion among trout stakeholders and other interested and affected parties.


It gives the false impression that we have nothing to worry about and that we are making an undue fuss.  This is simply misinformation by the DEA who are under tremendous pressure to get invasive species lists published and so will do and say almost anything to get their way.

The idea put forward By the DEA that trout will be better off for being declared invasive is illogical:

1.            Logic says that one cannot nurture and protect the trout industry jobs and investments by declaring trout as invasive.

2.            Invasive species must be controlled.  NEM:BA says control means combat or eradicate or if this is not possible prevent the spread, regrowth or propagation of the invasive species.  This                can never equate to sustainable utilisation or management as alleged by the DEA.

3.            This means that the promises by the DEA that they wish to protect the trout industry cannot be true as useful species cannot be protected if they need to be controlled.

4.            The fact that trout are not invasive does not mean that they must not be regulated. Trout have been regulated for decades and that must continue especially if one is to achieve its development potential offered by trout for the benefit of South Africa.  Treating trout like other useful alien species is the only sensible way to achieve this. The suggestion that FOSAF or Trout SA for that matter is anti-trout regulation, is disingenuous.


See the FOSAF and Trout SA media releases for a fuller picture at: http://www.fosaf.co.za/  Look in the News tab or follow this link: http://www.fosaf.co.za/documents/FOSAF-response-to-the-DEA%20Media-release.pdf

It has been just short of eight years since deadline for promulgating a national list of invasive species expired. A major reason why the DEA has failed in its legal obligation to promulgate this list is its insistence that trout be on it. Yet they are still unable to offer any rational explanation why this should be so.

The reason for this debacle is twofold.

  1. First they have no policy for dealing with the management of aquatic biodiversity and consequently no norms and standards guiding how this should be done. This is essential if the DEA is to give effect to our environmental laws and allow human development, especially in the field of aquaculture and the development of a tourism-based recreational fishing industry to develop in a sustainable way.
  2. The second is that their failure to interpret the language of the NEM:BA in a way that is compatible with the above preferring instead narrow scientific definitions that ignore the need to promote human development in a sustainable way.

The result is that they are making it up as they are going along. This is why proper risk and benefit assessments have not been carried out even though every dictate of common sense and law tells you this must be done before you decide to list a species as invasive. This is the source of the confusion. The DEA is sending out mixed messages.

FOSAF has always supported a principled approach. We have been calling for the development of an policy and guiding norms and standards on aquatic biodiversity since the NEM:BA became law back in 2004. The DEA has ignored this plea for ten years and shows every sign that it will continue doing so.

Confusion is destructive of the kind of stability business and job creation need to survive. This begs the question why the DEA is trying to make laws without having formulated a policy?

We have called on government and continue to do so to moderate the DEA’s position not just in the interests of trout but more importantly in the interests of the thousands of South Africans whose lives benefit from the existence of trout.

The DEA has put forward the media release for your consideration but says it will only reply to all submissions after the Minister has approved the regulations and presumably the lists as well. This means that it is unlikely the changes mentioned in the media release will be made public!

We need you to write back to Ms Shishuba of the DEA (at: NSishuba@environment.gov.za) reserving your rights to comment further once you have had an opportunity to consider the next version of the NEM:BA AIS lists and regulations as well as the risk assessments and any other relevant information that the Minister took into account before making the decision to list all the listed species.  See the letter by Dr Tom Sutcliffe which appears below as a guide. You can also refer to the replies of 20/05/2014 submitted on 20/05/2014 at http://www.fosaf.co.za/documents/FOSAF-response-to-the-DEA%20Media-release.pdf.


Make your voice heard if you really want to protect the future of the trout industry.


Ms N Shishuba (per email: NSishuba@environment.gov.za )



Dear Ms Shishuba



Your media release, which I am sure was well intended, has caused doubt, confusion and apprehension in the widest fly fishing communities in this country and in the trout industry.

I refer to two specific statements in your press release, namely that there is ‘no threat to existing legal trout industries’ and that ‘trout should be exploited fully’. These sentiments clearly contradict the legal implications and consequences of a species being labelled ‘invasive’ and serve only to sow the seeds of growing concern among anglers, retailers, trout destination and syndicate owners, fly fishing retailers and the aquaculture industry.

I listened to a recent interview given by Dr Guy Preston, Director-General of the DEA, on Cape Talk Radio (20 May 2014) when it became clear that controlling trout as an invasive species is an enormous task and that the DEA has many other pressing needs that require its attention. One only has to look at the overall state of South Africa’s environmental wellbeing to agree with him.

Yet within all this, the capacity and resolve of fly fishers and riparian owners to safeguard the streams and rivers where trout are found, and the environs that surround them, is increasingly evident. Thus in many ways trout waters are a blessing to this country as they invariably promote sound conservation practises simply because the continued existence of trout is so tenuous and so dependent on pristine conditions.  As a consequence, many informal but advantageous self-regulatory systems are already in place in trout habitats, although the formal regulation of trout in South Africa, both as recreational and agricultural assets, has my full support and the support of FOSAF and Trout SA. In fact, it was the deregulation of trout that gave impetus to the formation of FOSAF in 1985.

I am not opposed to the principle of regulating alien invasive species, but in a near lifetime of fly fishing for trout in South Africa I have yet to be provided with any convincing scientific evidence that trout are invasive. The entire postulation being made by the DEA regarding their invasive listing and their future management is therefore, in my view, subject to serious question. Should any scientifically sound risk assessment of the relative value of trout as opposed to the risks they pose have been done, then the DEA should make this public as it is pivotal to this entire debate.

Given the views I express here, I urge the Minister to regard trout as a national asset and to encourage senior officials in her Department to again engage with representatives of FOSAF and Trout SA to determine an affordable, effective and implementable policy to secure the most advantageous management of trout in South Africa.

Finally, I am concerned that the changes noted in the media release appear not to be open for further debate and discussion with interested and affected stakeholders and thus reserve my Constitutional right to comment on any future adaptations to the NEM:BA AIS lists and regulations.

Dr T J Sutcliffe


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