Fish Master Premier Business Plan — Regulatory Position

Nile tilapia permitting, the indigenous Mozambique tilapia fallback, environmental authorisation and the aquaculture regulatory pathway.

Regulatory Position

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Requirement

Authority

Note

Alien species permit for Oreochromis niloticus

DFFE under NEMBA and the Alien and Invasive Species Regulations

Condition precedent. Requires a risk assessment and containment measures. Commentary indicates that some provinces have been reluctant to issue permits, so the province is chosen partly on permitting record

Environmental authorisation

Provincial environmental department under NEMA

Required depending on the listed activities triggered by construction, water use and effluent

Water use licence or registration

Department of Water and Sanitation

Abstraction and discharge. Recirculating systems have low discharge volumes, which assists the application

Aquaculture registration

DFFE Aquaculture Directorate

Registration of the facility and reporting of production

Veterinary and health

DALRRD

Fish health management plan, movement controls and disease reporting

Food safety for processing

Municipal health and DALRRD

Certificate of acceptability for the processing and packing area; HACCP where supplying formal retail

Company and tax registration

CIPC and SARS

Registration, tax compliance status and VAT

ADEP cost-sharing grant registration

the dtic

Reimbursable cost-sharing grant of up to R20 million of qualifying costs, claimed in arrears against qualifying spend

4.1 The species fallback, costed

If the Nile tilapia permit is refused or delayed beyond the construction window, the enterprise switches to Mozambique tilapia (Oreochromis mossambicus), which is indigenous to South Africa and far less restricted.

Parameter

Nile tilapia, as modelled

Mozambique tilapia fallback

Regulatory status

Alien species; permit required under NEMBA and the Alien and Invasive Species Regulations

Indigenous; far less restricted

Growth rate

Faster; supports a 700 g harvest weight within the modelled cycle

Slower; the cycle lengthens materially

Feed conversion

1.52 at maturity

Materially worse, raising cost per kilogram

Harvest tonnage at the same infrastructure

150 t by Year 5

Roughly a quarter lower

Effect on the plan

As modelled

The plan must be re-based before capital is committed