2021
Expression of Interest for the
Exploratory Harvesting of
Crayfish
For the Application to the Ministry of Fisheries
and Marine Resources
Desired Duration of Venture: 3 Years
Date: May 2021
Compiled By: Ambrose West
Contact: 081 625 7369
Sinetemba Investments CC
CC/2013/09207
No25, Moses Garoeb Street,
P.O. Box 864
Walvis Bay, Namibia
Foreword
This report reflects the experience and research that we, as a company, have done in order to
compile a proper application for the experimental license. We have studied the task in terms of
investment, human resource, and capital to achieve the goals we want to achieve; as discussed
throughout the document.
We will be undertaking the mission to assess the biomass of the species, the total allowable catch to
preserve the biomass of selected species, the preferred catching and processing methods and create
a market for the caught product. This means developing the best standards for catching, processing
and packaging and selling a product from scratch.
We understand the fishing industry in Walvis Bay, how it operates, and what makes a venture like this
a viable option if successful. From our vast experience in the fishing industry, we have constantly
looked at niche venture possibilities to expand the Namibian fishing market, which will not only create
jobs (which is very important), but also generate other sources of revenue to contribute to exporting
thus increasing money flowing into the country (GDP+).
EXPRESSION OF INTEREST – CRAYFISH MAY 2021
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Contents
Foreword..................................................................................................................................................1
1. Introduction.......................................................................................................................................4
1.1. Background...................................................................................................................................4
1.2. The Namibian Fishing Industry.....................................................................................................4
1.3. Rationale.......................................................................................................................................5
1.4. Objectives......................................................................................................................................5
2. The Species to be Harvested...........................................................................................................6
2.1. The Species..................................................................................................................................6
2.2. Seasonality....................................................................................................................................6
2.3. Markets..........................................................................................................................................7
2.4. Local Competition.........................................................................................................................7
3. Materials and Methods......................................................................................................................8
3.1. Harvesting Method........................................................................................................................8
3.1.1 Traps and Pods........................................................................................................................8
3.1.2 Types of Traps and Pots.....................................................................................................9
3.1.3 Operating Equipment.........................................................................................................10
3.1.4 Vessel Characteristics.......................................................................................................10
3.1.5 Skills Base Required.........................................................................................................11
4 Risks and Uncertainties..................................................................................................................11
4.1 Technical Risks........................................................................................................................11
4.1.2 Biomass and Growth Rates...............................................................................................11
4.1.3 Consistency of Quality.......................................................................................................11
4.1.4 Extreme Weather Issues...................................................................................................11
4.1.5 Diseases and Predators....................................................................................................11
4.1.6 Water Quality.....................................................................................................................11
4.2 Market Risks.............................................................................................................................12
4.2.1 Price Risk...........................................................................................................................12
4.2.2 Shipping to Market.............................................................................................................12
4.2.3 International Competition...................................................................................................12
4.2.4 National R&D challenge to meet growth objectives..............................................................13
4.3 Major Costs Factors.................................................................................................................13
4.3.1 Labor......................................................................................................................................13
4.3.2 Fuel........................................................................................................................................13
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4.3.3 Equipment..............................................................................................................................13
5 Profitability Model............................................................................................................................14
5.2 CAPEX and Working Capital....................................................................................................14
5.3 Cashflow...................................................................................................................................15
5.4 Potential SWOT Analysis.........................................................................................................15
6 Conclusion......................................................................................................................................16
6.2 A New Market with Unique Challenges....................................................................................16
6.3 Job Creation.............................................................................................................................16
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1. Introduction
1.1. Background
Namibia is located in southwest Africa between latitudes 17°S and 29°S and longitudes 11°E and
26°E with a surface area of 823 680 km² and population of 2.1 million people (UNDP 2011). It is
surrounded by the Atlantic Ocean to the west, Angola and Zambia to the north, Botswana and
Zimbabwe to the east and South Africa to the southeast (Figure 1). The Namibian coast is a
hyper-arid desert, approximately 1500 km long. The coastal zone is sparsely populated and the
desert is not suitable for agriculture. The coastal area is thus free from the levels of pollution
commonly associated with large urban communities, and the coastline is relatively pristine.
The nutrient rich
Benguela upwelling
system creates one
of the most
productive fishing
grounds in the world
with abundance of
pelagic and demersal
fish populations
supported by
plankton production
driven by intense
coastal upwelling
(Shannon and
O’Toole 1998).
1.2. The Namibian Fishing Industry
The Namibian fishing sector is currently ranked 35th on the list of the world main fishing nations,
fourth in Africa by production and among the top 10 fish exporting nations in the world (FAO
2010). Fishing represents Namibia’s second largest foreign currency export earner (after mining)
with 90% of the national fisheries output being exported (INFOSA 2009). The infrastructure for
seafood processing is well developed with accreditations for export to the lucrative European
market. Over the last decade, the country’s total catches have been between 500 000 and 600
000 tons (INFOSA 2009). The fishery is strongly regulated and with all major stocks being fully
exploited (FAO) 2010 no increases are expected in the near future (MFMR 2007). It is within this
context that the Namibian government has in recent years identified aquaculture, especially
marine aquaculture, as an important potential growth area within the fisheries sector.
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1.3. Rationale
West coast rock lobster (Crayfish) fishing is already a well-established fishing industry in Lüderitz,
with internationally competitive standards in processing and packaging. Good potential for
creating new fishing areas in Namibian waters exist and the potential for this market is
considerable.
Figure shows the desired
location for an exploratory
trial for west coast rock
lobster traps on
commercial fishing gear.
The desired range of
exploration extends from
the 24 deg up to the 20
deg. There is insufficient
information on the
occurrence of rock lobster
in Namibian waters north
of the Lüderitz fishing
grounds. Development of
a rock lobster commercial
trap fishery will largely
have to depend on trial
fishing.
1.4. Objectives
The project involves the feasibility study of harvesting West coast rock lobster in Namibian waters
north of Walvis Bay. The specific objectives are to determine the:
Biological requirements of the species.
Most appropriate harvesting technology for the species and country
Economic viability of the envisaged harvesting.
Create another form of income and importantly, employment for Namibians
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2. The Species to be Harvested
2.1. The Species
WEST COAST ROCK LOBSTER (Jasus Lallandi)
West Coast rock lobster have a well-defined molting
and spawning cycle. Adults molt once per year, the
males in spring and the females during late autumn and
early winter (Beyers 1979). Mating takes place after the
females have molted. Egg-hatching peaks in October–
November and the phyllosoma larvae remain planktonic
for several months (Lazarus 1967, Pollock 1986),
drifting in oceanic sub-gyres until they reach the
puerulus (free-swimming) stage and subsequently settle
(Crawford et al. 1987). Females reach sexual maturity
about 4–5 years after settlement, at a greater length off
southern Namibia than north of about 26°S (Grobler and
Noli-Peard 1997) Maturing males grow faster than
females and reach a larger size, so the fishery, which is
subject to size limitations, is based largely on males.
Adults are generally distributed offshore of juveniles,
except off central Namibia, where the population is
constrained close to the coast by low-oxygen water
(Pollock and Beyers 1981).
In Namibian waters, the depth distribution of adult rock
The principal predators of rock lobsters (especially males) varies seasonally in
lobster are octopus, dogsharks, response to changes in concentration of dissolved
hagfish, whelks (on injured or oxygen on the bottom (Tomalin 1993, Grobler and Noli-
weakened animals) and young Peard 1997). Rock lobster feed largely on mussels, in
seals (Crawford et al. 1987). particular the ribbed mussel Aulacomya ater, which is
Cannibalism is known to be abundant in the rocky subtidal zone (Pollock and Beyers
common in overcrowded 1981, Griffiths and Seiderer 1980, as cited in Crawford
situations, particularly among et al. 1987). In areas of low mussel abundance, the diet
juveniles. consists mainly of echinoderms (sea urchins and
starfish), gastropods, bryozoans, polychaetes and
seaweeds
2.2. Seasonality
Rock lobster may not be harvested in Namibian waters during the period 1 May to 31 October,
both days included, as well as the area within 15 nautical miles from the high water-line. This
project will explore the potential for developing these resources in an ecologically sound and
responsible manner. Success in this venture will help to diversify the fishing industry and increase
total resource yields with the resulting economic and social benefits.
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2.3. Markets
More than 20 fish species are commercially exploited in Namibia. The domestic market is limited
due to the small size of the population and most of the country’s protein source is derived from a
meat-based diet. At13.3 kg per capita Namibia is among the lowest fish consuming countries in
Africa (FAO 2010).
The emphasis is generally on the export market, with the country exporting more than 90% of its
fish products. Horse mackerel (the dominating species in terms of volume) and canned pelagic
products are exported to the regional market (Egypt, Democratic Republic of Congo, South Africa,
Angola, Zambia, Zimbabwe and Botswana); hake is mainly exported to the EU and over 70%
goes to Spain, while fishmeal is exported to South Africa, Spain, Japan, Korea, China and Taiwan
(INFOSA 2009).
Strong market demand will continue to grow because of reduced supplies from many other parts
of the world due to over-fishing as well as increased demand of growing world population as well
as consumer preference for fish and fisheries products due to health benefits. It is estimated that
fish trade flows are predominantly from developing countries to developed countries (FAO 2010).
Prices should thus remain high and these factors present a good opportunity for Namibia to
increase its exports.
By virtue of various trade arrangements, Namibia enjoys easy access to a regional market of over
350 million consumers in SADC as well as access to lucrative markets in the rest of the world
through regional integration schemes and agreements.
Namibia needs to diversify out of the traditional market in Spain and develop new markets
elsewhere. The newly signed export agreements with China for meat and fish products (NCCI
2011) offer excellent opportunity for market diversification. Additional production from expanding
our range of products harvested will complement Namibia’s capture fisheries output.
2.4. Local Competition
Sea flower Lobster Corporation Limited (SLC) became a wholly owned subsidiary of FISHCOR.
The company owns and operates six lobster vessels as well as a processing facility in Lüderitz.
SLC is also a 66% shareholder of the NAMROCK brand, through which lobster products are
marketed. For the past 5 years, SLC has been the only company that processes lobster in
Namibia, as the size of the Total Allowable Catch (TAC) for this fishery is too small to sustainably
accommodate more factories. The lobster operation only runs for 6 months every year and 60
workers on a seasonal basis and 4 on a permanent basis.
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3. Materials and Methods
3.1. Harvesting Method
3.1.1 Traps and Pods
Fishing for rock lobster requires specifically designed ocean-going fishing boats precisely rigged for
longline trap-fishing. The boat operates with 2 000 – 6 000 design-shaped traps, which are tied to
longlines in sets of 100 – 200 traps, with a line of traps being 2 – 3 nm long. To operate this longline
trapping system, lobster boats typically require a large holding pen (often aft, behind the
superstructure) in which traps can be stacked, a powerful line-hauler with which to haul lines and
retrieve traps, and one or two chutes (port or starboard) to set gear. These traps are deployed on the
seabed for approximately 6 hours before being hauled aboard a boat for harvesting and rebaiting.
They are laid out in strings with a number of traps attached to a long rope.
Boats are furthermore equipped with modern navigational equipment and with an onboard processing
factory, packing and freezing facilities or specially designed live fish holding facilities. The longline
trap-fishing method is labor-intensive and each boat has a complement of approximately 20 officers
and crew. In addition to the sea-going compliment of the fishery, the sector employs land-based
factory (processing) and administrative personnel as well.
An advantage of trapping is that it allows some
control over the species and sizes of the fish you
catch. The trap entrance, or funnel, can be
regulated to control the maximum size of fish
that enter. The size of the holes, or mesh, in the
body of the trap can regulate the minimum size
that is retained. To a large extent, the fish
species that will be caught depend on the type,
model and characteristics of the pot or trap
being used.
Traps are simple, passive fishing gear that allow fish to enter and then make it hard for them to
escape. This is often achieved by: _ putting chambers in the trap or pot that can be closed once the
fish enters; _ having a funnel that makes it difficult for the fish to escape. Smaller traps are generally
fully covered except for the entrance or entrances, while larger traps that extend above the water
level are often left open at the top.
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3.1.2 Types of Traps and Pots
People in different parts of the world are not always referring to exactly the same things when they
use the words "trap" and "pot". In general, traps are large structures fixed to the shore. Pots are
smaller, movable traps, enclosed baskets or boxes that are set from a boat or by hand. A simple
system for the naming of traps and pots was produced by von Brandt in 1959 for FAO and is used in
this manual. General types of traps and pots include:
traps that form barriers to fish movement, including walls or dams, fences, fyke nets, gratings and
watched chambers that can be closed by the fisher after the fish enters;
traps that make hiding places (habitat traps), including brush traps and octopus pots;
tubular traps, which are narrow funnels or hoses that stop the fish from getting out backwards; eel
tubes fall into this category;
traps that are mechanically closed by the fish, including gravity traps or box traps, bent-rod traps
(whipping bough traps), torsion traps and snares;
baskets, which are enclosed traps and pots usually with a structure to make escape difficult; they
include pots made of wood, wire or plastic, conical and drum-like traps made of netting with hoops
and frames (e.g., drum nets) and boxlike traps made with strong frames;
large open traps or corrals with a part or mechanism to stop fish from escaping, which can be
fixed on sticks or anchors, set or floating;
traps set out of the water to catch fish such as flying fish that jump off the tops of waves and glide
over the surface when in danger; these can be box-shaped, rafts, boats or nets ("veranda" net
types); scoop nets are sometimes used for making fish jump. Pitfall traps can be used for marine
animals that migrate over land, such as coconut crabs.
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3.1.3 Operating Equipment
Trap handling equipment
As pointed out above, many traps and pots can be operated by being pulled up manually, using the
attached buoy rope. The use of trap/pot haulers and tippers on larger vessels using bigger traps can
increase the efficiency of the operation.
Bait storage
It is essential to find a suitable way to store your bait, both while you are fishing and onshore. Salted
or dried bait only requires a dry place on the vessel. Fresh or frozen bait should be kept frozen or on
ice or it will become rotten and unusable after a short time, depending on the temperature in which
you are working.
Equipment for handling and preserving the catch
To maintain the catch in good condition on board your vessel, you need to have the correct handling
and preserving equipment. This may include ice and ice boxes, freezers, brine tanks, filleting boards
or tables, gutting knives and catch washing equipment (buckets, deck hoses, etc.).
3.1.4 Vessel Characteristics
The vessel for the exploratory trial period will be less than 25 meters and under 25 tons with a fish
hold capacity of 35 tons or less. Provided that sufficient quantities of lobster can be located, the
fishery has a number of advantages for smaller boats, namely:
Modest capital investment is required
The method is very fuel efficient when compared with other catching methods
It is well-suited to seasonal alternative activity (if required) and adaptation of the vessel
Low catches can be commercially viable
The ratio of employment per boat to tons caught benefits local fishermen as more jobs can
be created to catch a required tonnage. More boats – more fishermen
Figure 1: An example of the vessel 59.9ft (18.25m) Fishing Vessel
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3.1.5 Skills Base Required
The local fishing community has a ready supply of labor, with the skills level required for the day to
day work associated with operating a jigging vessel.
However, the technical expertise and industry experience are required to “hunt” the lobster
species and successfully identify the lobster bearing fishing grounds; this would prove difficult to
initially source from within the community. In the initial setup and operational stages some
technical and management expertise would need to be sourced from Luderitz. Over the longer
term a local skipper will be trained to take over the captain duties.
4 Risks and Uncertainties
4.1 Technical Risks
4.1.2 Biomass and Growth Rates
The cold Benguela stream along the Namibian coast could have a very low biomass of the
exploratory species. It is therefore imperative that special care is taken to not overfish the species,
as well as to fully understand the species and its growth rates by the end of the trial.
4.1.3 Consistency of Quality
Standards have to developed for handling, processing and packaging of the rock lobster in
partnership with prospective buyers to ensure that the lobster harvested stays at a premium
quality and on par with international standards.
4.1.4 Extreme Weather Issues
Namibian waters do experience strong winds which could potentially disrupt operations. The
vessel must firstly be able to withstand these conditions and secondly adapted/modified to ensure
a safe workplace and environment for crew onboard the vessel. Special consideration will also to
taken to operate the vessel in off weather as this might not be an effective time to harvest the
lobster.
4.1.5 Diseases and Predators
While there are numerous diseases and predators with the potential to disrupt the harvest of
lobster, there are no major known diseases for the species. Top predators include various large
finfish species and seals. Special care will be taken as to select the best time, depth and position
in this regard.
4.1.6 Water Quality
The red tide can possibly be very detrimental to the harvesting of Lobster and cause the species
to move or even migrate to other habitats. It will therefore be imperative to understand the
patterns of the species by the end of the exploratory trials. Other factors such as poor oxygen
levels can also results in poor or limited fishing ground as lobster require highly oxygenated water
to thrive.
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4.2 Market Risks
4.2.1 Price Risk
Rock Lobster prices have enjoyed continual steady pricing over the last ten years. Annual price
increases have averaged 20.2% for plate grade product over the past 5 years. While the stable price
increases are an encouraging sign, any fluctuations in catch landed or demand can alter the price
dramatically. Special foresight has to be taken by management to buffer against such fluctuations.
4.2.2 Shipping to Market
Special care has to be taken to bring the best possible product to the market. The Namibian rock
lobster industry intends to be the preferred supplier of lobsters to global super-premium-fine-dining
(SPFD) consumers by 2030. A number of objectives has been set that define the Sinetemba’s
strategies as a company over the next 5 years:
1. Lobster products will be securely positioned in niche markets, predominantly in Europe/Middle
East and Asia.
2. The company will promote well established technologies and procedures for enhancement of
wild rock lobster stocks.
3. The culture of the Namibian based fishers and processors will become more integrated through
chain alliances, R& D investments, and adoption of e-commerce practices and tools.
Figure 2: Frozen Rock Lobster is predominantly exported to Europe and Japan
4.2.3 International Competition
In order to penetrate the international market, we will have to compete with established
Argentinian, Spanish, Chinese, Japanese, etc. rock lobster fishing companies. These companies
enjoy a competitive advantage due to, among other, their size, experience and longstanding
market relations. In order to be competitive, we must find the most efficient and best quality
harvesting methods. The company must leverage both the favorable conditions of the Namibian
waters and the advantageous conditions supplied by the government for trading and exporting.
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4.2.4 National R&D challenge to meet growth objectives
Recent studies have identified a number of primary trends in global markets.
• Consumers across an expanding range of markets have much improved access to fresh food.
This is primarily due to advances in refrigeration technology, packing and airfreight systems. In
some instances, this has stimulated increased demand for seafood products (e.g., sashimi,
sushi, live fish);
• Consumers are reducing their red meat consumption in Western societies, in response to
favorable reports on the health benefits of seafood, and a decline in real prices of some
species (e.g., salmon, catfish). The appeal and consumption of seafood is broadening;
• Global supply and marketing of seafood is improving. This is driven by the increasing ability of
the fishing industry to manage production and marketing, resulting in reduced uncertainty,
increased efficiency and increased market share.
• World seafood trade is expected to increase significantly in live/chilled/fresh finfish, frozen whole
fish and fillets, mostly to markets in USA, EU and Asia (Taiwan, Japan, China, Singapore,
Malaysia); and
• Real prices from 2000-2020 for crustaceans and high value finfish are expected to increase by
15% and could be potentially as high as 60% if fish stocks are threatened.
4.3 Major Costs Factors
4.3.1 Labor
The crew wage will be competitive in Namibia and will be fairly adjusted as to ensure all
stakeholders are earning their labor’s worth. An experienced captain will have to brought onboard
to train local officers how to catch lobster and this cost will include accommodation, salaries and
transport.
4.3.2 Fuel
Fuel will be a major expense. It is therefore important to start off with a smaller vehicle as to
reduce this cost. The small size of the vessel and it operational expenses will also then not be so
detrimental during price fluctuations of fuel.
4.3.3 Equipment
The jigger machine and jiggers will have to be sourced abroad. Special consideration has to be
given to consumables supply and equipment spares and backups.
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5 Profitability Model
The profitability model is aimed at considering a 5-year plan. The figures for costs were obtained by
consulting industry members, conducting interviews as well as from publications. Some vessels have
been identified for these exploratory trials and the costs of these vessels vary by some margin. The
other factor to consider is that some vessels need more work than others to modify into a lobster
catching vessel.
For this study it was estimated that the investment for the fishing vessel is N$1.5 million and
equipment (jigger machines and lights) N$0.5 million. Modification to the vessel was also considered
and other costs included the consultancy fee (captain) and staff training.
Variable costs that included operational expenses for 1 year such as fuel and sundries amounted to
N$ 1.5 million. Equipment spares expenses for the year would equate to N$0.5 million. Fixed costs
included salaries for 20 employees (N$2 million), admin fees such as licenses, rates and taxes, and
insurance (N$ 0.3 million). The setting up of the rock lobster fishing vessel will require a total
investment of N$6.5 million, consisting of N$2 million for capital expenditure and about N$4.3 million
as working capital over the 1-year planning period.
5.2 CAPEX and Working Capital
Capital expenditure will be used to pay for the purchasing of the vessel, and modifying the equipment
for rock lobster fishing.
Capital Expenditure Required (Estimated)
Item Cost (N$)
Fishing vessel 1 500 000
Equipment (lines, traps, weights, buoys, etc.) 500 000
TOTAL 2 000 000
The working capital will cover cost of the operational expenditure. The major cost contributors to the
cost of production include fuel equipment and spares, and salaries. form part of the variable costs.
Among the fixed costs (operational capital) the major expenses are fuel and equipment spares.
Operational Expenditure (Estimated) for 1 year
Item Cost (N$)
Fuel and Sundries 1 500 000
Equipment Spares 500 000
Employee Salaries 2 000 000
Administration 300 000
TOTAL 4 300 000
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5.3 Cashflow
The income will be generated from the sale of Rock Lobster at a wholesale selling price to cover
operational costs, salaries and other expenses incurred during the exploratory trials. The
European/Asian markets price at the time of compiling this proposal varied between N$ 200 and
250 per kg. In order to breakeven on the operational expenses (N$4.3 million) every year, an
average of 1.8 tons per month of rock lobster has to be caught, based on the current market
price of Rock lobster in Asian markets. This can be achievable as this then only required less
than 4.2 tons a week.
If the Return on Investment (ROI) where to be achieved within 5 years on the CAPEX, an
additional monthly 0.5 tons (rounded off) has to be caught monthly to service the dept loans.
This amounts an estimated average total monthly landing of 2.4 tons of rock lobster to
breakeven and service all loans and expenses. This value can change quite drastically as the
price can change, poor fishing landings, as well as the demand fluctuations.
5.4 Potential SWOT Analysis
Strengths Weaknesses
Seas – Most part of the Northern Namibian Fishing Grounds – Most of the Northern
waters is uncharted commercial fishing Namibian waters is uncharted rock lobster
grounds. fishing grounds which also mean we cannot
Technology – Rock lobster trap fishing has know how much biomass there is or the
already been fully developed to target a lack thereof.
single species with little to no bycatch. Species – The Migratory patterns of Rock
Environment – The traps are not permanent Lobster to the North has not well been
and do not damage the seafloor nor the documented and other species of lobster
surrounding habitat growing on the floor. might be present due to the warmer waters,
Production – Catching rock lobster in the which means the intended species may not
Northern waters of Namibia would boost the be a viable option.
Walvis Bay economy if the demand is Environment – Namibia coastal
sufficient and economically feasible. environment is very unpredictable with
Employment – New opportunities of algal blooms and Sulphur eruptions posing
employment can be generated. a threat to the catching of the species.
Opportunities Threats
Markets – Currently the market for fisheries Production – Unforeseen problems like
products is huge. The European and Asian the outbreak of diseases in the species,
markets provide for diversification of Namibia migratory patterns or poor biomass stocks
fisheries products. Namibia has an can have a detrimental effect on the
established access to these markets already. operation as a whole.
Export – There is an opportunity to grow the Markets – The Namibian fisheries sector is
export profile of Namibia if this venture is aimed at the export market and is thus
successful. vulnerable to the vagaries of the economies
of the importing countries.
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6 Conclusion
6.2 A New Market with Unique Challenges
The Rock Lobster market is already contributing a major part to the fishing industry of Namibia.
However further research is required to expand fishing grounds and thereby reducing overfishing on
concentrated areas, and creating more industry in Namibian waters. This exploratory fishing will
attempt to assess the viability of harvesting rock lobster in the northern Namibian waters from the 20
to the 24 degrees. Further effort has to be made into investigating which catching technique is the
best suited and on par with international standards.
6.3 Job Creation
The Namibian fishing industry has of late been hard hit by various obstacles including amongst
others, a claimed depletion of resources in quoted species such as sardines as well as issues
pertaining to labor and employment. It is thus pertinent that the industry diversifies and expands
beyond the current market segments in order to mitigate these sorts of pitfalls. The failure of the
industry to further explore and exploit the availability of species in the Namibian water impairs and
underserves the fishing industry placing at a disadvantage the nation’s economy and workforce. The
exploratory operation coupled with this license foresees creating a minimum of 20 to 30 jobs from the
startup.
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