permits, AIS

AIS stands for Alien and Invasive Species. This is a permit that is governed by the issue of the NEMBA Act of 2014. Basically prior to 2014 keeping niloticus as a species was illegal in South Africa, but now you can apply for a permit that gives you permission to keep the fish.

Don’t be too quick to celebrate however. The aquaculture industry can engage as many as 22 government departments in order to be fully compliant – the exact number is mostly unknown by all but the most expensive consultants who will spend your money happily on their time to advise you of the things you need to do.

The hardest of all, and the most important permit you will need is the AIS permit. This is issued by DEA, the Department of Environmental Affairs. This process requires that you submit a Risk Assessment (RA) report that relates to how you want to keep the fish, what you intend doing with them and so forth. It may require an EIA (environmental impact assessment) or an EIR (envionmental impact report – same as an EIA but in much more detail and ten times the cost) but this will depend on what scale you want to operate at.

The Risk Assessment MUST be conducted by a third party independent SACNASP registered authority. A basic RA will set you back between R5k and R15k.

And then the fun starts. The AIS is assessed at national level but in consensus with the provincial authorities. In other words DEA will consult with the provincial level equivalent and together they will come up with a consensus position on your application. Currently niloticus is considered sufficiently invasive enough for Limpopo, KZN, North West and Mpumalanga refusing permits to any applicants. So if you intend farming in these provinces your ambitions are over before they begin.

What we can tell you is that you should apply anyway. DEA have done demonstrably nothing since 2014 to address the issue and in the last three years they have ignored the industry and oddly their own colleagues in government (DAFF). Yes, they have environmental concerns about the species, but equally they have had at least three years to come up with something a little more concrete than “we’re looking at it”.

So the pressure is mounting and you are free to contact the man in charge GPreston@environment.gov.za and enquire as to what the status of the species is. We’d recommend asking him once a week or so. Let them know that now is a good time to start catching up on the work that should have been done already.

Once your application is in, by law they have to answer you within 90 working days. It’s part of the legislation. You will then receive a polite letter of rejection which you will need to keep. Once you have your file, once niloticus does become permissible to farm (and it will) you’ll be right in front of the pack to get your permit issued. In the meantime, you can farm quite happily if not profitably with mossambicus, for which you do not need an AIS permit. You will need other permits however, and the docs below will give you a head start.

Guide to Authorisation Requirements Aquaculture SA 2015 The User Friendly Legal Guideline for the Aquaculture Sector in South Africa National Environmental Management Act 107-1998 – Environmental Impact Assessment (20130211-GGN-36145-00101)

The User Friendly Legal Guideline for the Aquaculture Sector in South Africa

National Environmental Management Act 107-1998 – Environmental Impact Assessment (20130211-GGN-36145-00101)