Environmental Affairs responds to public comments on listing of rainbow trout and brown trout as invasive species

The Department of Environmental Affairs (DEA) has responded to stakeholder comments on the listing of rainbow trout and brown trout as invasive species. Following the amendment to the National Environmental Management: Biodiversity Act’s Alien and Invasive Species Regulations to list Rainbow Trout and Brown Trout, there has been a petition against the listing of these species that is misleading stakeholders.

The department has responded as below:

Trout are invasive in suitable waters in South Africa and there is no scientific evidence to the contrary. The risk assessments for the species are clear, and they are on the basis of the decision to list the species. Therefore the DEA, the Department of Agriculture, Forestry and Fisheries (DAFF), the Department of Water and Sanitation (DWS), provincial authorities, supported by national and international ichthyologists, as well as the Operation Phakisa: Oceans Economy secretariat, recommended that trout be listed as invasive species.

It should be noted that the decision to list a species, or change its listing, goes through a long process that involves various role players. It has been proposed that the two trout species be listed as Category 2 species. Category 2 means that the species can be utilised, with a permit. This category is there to recognise that there are invasive species that have value, and can be utilised under conditions. For example, the forestry industry is not prevented from growing Category 2 pines, wattles or gums. Rather, areas are agreed upon where these Category 2 species may be grown, and they are given permits to conduct their work. The Department’s focus is to stop invasions of the species outside of the demarcated areas in which these Category 2 species may be utilised. There is no difference with respect to trout, or any other Category 2 species. Accusations that this categorisation of trout as Category 2 species will destroy the industry are untrue.

In the case of fish species like trout, there is also a recognition that most invasions are a fait accompli. It is hugely expensive � and often highly improbable � to try to recover from such invasions in rivers. This is why the focus is on trying to contain the spread and allow catch-and-release in the area in which such species are caught.

In these circumstances, it is intended that the following will happen:

1.1 Trout will be listed as Category 2 species.

1.2 Trout hatcheries will need to apply for permits. These are likely to be long-term permits (40 years is currently being considered), allowing hatcheries to breed, sell and distribute (live) trout. Those acquiring the live trout will have to have a permit for the trout. We see no reason to inhibit the further growth of the hatchery industry in the demarcated areas (based on the work done by the specialists, with input from the industry), providing conditions are met. There can be concerns about water quality, for example, that would need to be addressed.

1.3 Operation Phakisa has set transformation in the intended growth of the aquaculture industry in general, and for trout in particular.

1.4 As there is no intention to remove trout species from dams within the areas mapped by the authorities, scientists and industries as trout waters, the regulation of these will be done to reduce both administrative and regulatory burden. It is felt that a long-term permit might be the most efficient, and that these might even be able to be issued as through a self-administrative process with the industry. Note that these dams include private instream dams, even though that water does not belong to the owner of the dam. However, it forbids the introduction of trout into waters outside of these demarcated areas (except were there to be a permit justified by a risk assessment considered by the Department).

1.5 A permit will also be required for the introduction of trout into rivers, streams, wetlands, natural lakes and other bodies. These waters do not belong to any individual, so they have no right to stock it with trout, should they so wish to do so � just as they cannot put poison or sewage or any other material into that water body.

1.6 As experts in invasion biology, we are aware of the risks of other invasions � bass, carp and other invasive fish; extra-limital invasions such as by sharp-tooth catfish, and invasive pathogens. It is only through regulating such species that their spread into the so-called trout waters may be prevented. In other words, bass will destroy many trout waters, if their movement is not controlled.

Thus, notwithstanding what has been portrayed by some sectors of the industry, there is no threat to responsible trout aquaculture, or to the value chain. There is no reason why a responsible trout hatchery in a demarcated area should be inhibited in any way to grow its business. The same is true of a farmer with a dam with live trout, in a demarcated area, provided s/he takes the necessary responsibility. The same is true of a fly-fisher in a river, providing that they do not stock the river without a permit to do so. If trout die off in any numbers in South Africa, it will be because of other invasives, or habitat destruction.

It is the considered view of the Department and its partners (and the Senior Council who assessed the options for the Department) that the brown trout and rainbow trout are correctly listed as Category 2 invasive species. It is further our collective view that this listing poses no threat to trout aquaculture and the trout value-chain. Indeed, the invasive legislation � and its vigorous enforcement � is pivotal to sustaining these industries.

Source: Government of South Africa