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Thread: National Environmental Management: Biodiversity Act - 12 February 2014. - The End?

  1. #31
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    Tom Sutcliffe's NEM:BA objection
    The Ministry
    The Department of Water and Environment Affairs
    Dear Sir/Madam
    OBJECTIONS TO THE DRAFT NEM:BA REGULATIONS
    Please note my strongest objection to the proposed implementation of the draft NEM:BA Regulations particularly pertaining to the proposed classification of trout as alien invasive species.
    If promulgated these regulations will in my opinion embarrass the Department of Water and Environmental Affairs for two important reasons; firstly, the premise on which the invasiveness of trout is founded remains unsound and unproven and secondly, their implementation will not be possible without provoking significant legal and political challenges with their attendant costs and consequences.
    This is a decision of national importance in that it impacts on issues of heritage and on the constitutional rights of thousands of South African fly fishers and business people and workers in trout-related industries alike. It is a decision that government, therefore, simply cannot take lightly.
    Clearly if the Department does go ahead with the promulgation of these draft regulations, the negative impact on many retail businesses, trout-related tourism, trout-related property investments (including established trout syndicates and fishing lodges) and trout aquaculture will be enormous. This holds significant legal and financial implications for government.
    It is important to point out that this proposal has already provoked opposition, questioning and incredulity, not only in South Africa, but already from people in many countries overseas. This all essentially stems from basic questions about the questionable wisdom and the legality of the proposal.
    I believe the lobby against these draft regulations is going to grow to proportions that will be difficult for government to manage. I strongly urge, therefore, that the Department allows common sense to prevail and through a process of open dialogue, debate and negotiation, that an attempt is made to attain reasonable, practicable and implementable compromises to the satisfaction of all parties concerned.
    I therefore must put on record my total support of the submissions made jointly by FOSAF and TROUT SA.
    Dr T J Sutcliffe

    Objection close date is the 8th April 2014 at 4pm.
    Object here.
    http://www.flyloops.net/nemba.php
    So Long, and Thanks for All the Fish.

  2. #32
    Join Date
    Mar 2011
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    Richards Bay, Kwazulu Natal
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    Sent my objection in. Thanks for the reminder!
    Adopt the pace of nature: her secret is patience - "Ralph Waldo Emerson"
    www.flyordie.co.za

  3. #33
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    What is mind boggling.
    WIth the previous proposed act, the fishing fraternity, started "buying into" the special demarcated zones, that will be protected.
    With the new proposed act, all the "good will" that have been built up, to have the special protected areas, have gone out of the front and back door.
    Or maybe the Nature conservation authorities, shout "blanket clean-up" and will settle for the demarcated protected zones?
    Korrie Broos

    Don't go knocking on Death's door, ring the bell and run like hell. He hates it. (anon)
    Nymphing, adds depth to your fly fishing.
    Nymphing, is fly fishing in another dimension

  4. #34
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    Sep 2006
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    Quote Originally Posted by Korrie View Post
    What is mind boggling.
    WIth the previous proposed act, the fishing fraternity, started "buying into" the special demarcated zones, that will be protected.
    With the new proposed act, all the "good will" that have been built up, to have the special protected areas, have gone out of the front and back door.
    Or maybe the Nature conservation authorities, shout "blanket clean-up" and will settle for the demarcated protected zones?
    Have you looked at the new proposed Land Claims/Settlement yet??? That is another little bomb waiting to explode.
    Mario Geldenhuys
    Smallstream fanatic, plus I do some other things that I can't tell you about

    "All the tips or magical insights in the world can't replace devotion, dedication, commitment, and gumption - and there is not secret in that" - Glenn Brackett

  5. #35
    Join Date
    Dec 2009
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    gauteng
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    Has anyone seen the invasive species management plan they so speak of in there listing it under 1b cause I can't find it? Cause the way we can put a stone in this is to contradict there act against bad management within their plan.

    Sent from my GT-I9500 using Tapatalk

  6. #36
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    Quote Originally Posted by smallstreams.co.za View Post
    Have you looked at the new proposed Land Claims/Settlement yet??? That is another little bomb waiting to explode.
    sometimes I think there is big poefie on the way.
    Othertimes, I think that they cannot be so stupid to not see the poefie and make other plans.
    Othertimes I think they have no other ideas that can work.
    Othertimes I think they dont think
    and sometimes, I try to think what would I do if I were in their shoes?
    Korrie Broos

    Don't go knocking on Death's door, ring the bell and run like hell. He hates it. (anon)
    Nymphing, adds depth to your fly fishing.
    Nymphing, is fly fishing in another dimension

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