Invasive Fish Species Management

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Invasive Fish Species Management (IFSM) operates under the auspices of CapeNature
and SANParks, and collaborates with scientific institutions, assisting with scientific research and the removal of invasive fish from freshwater systems.

In the light of the recent article published by the George Herald, the below letter sent to Dr. Sooliman on December 5, ...
22/01/2026

In the light of the recent article published by the George Herald, the below letter sent to Dr. Sooliman on December 5, 2024 was an attempt to reach out and update GOTG as to critical developments around the Groenvlei Carp Project.

The letter to GOTG's Dr. Sooliman provides clear insight to the public as to the background of events that led to the collapse of our collaboration with GOTG.

To date, response or acknowledgement of receipt thereof was ever received from GOTG.

From: [email protected]
Sent: Thursday, December 5, 2024 4:48 PM
To: [email protected]
Subject: RE: Critical Update: Groenvlei Carp Management Project

Dear Dr Sooliman,

In light of the current circumstances, I would like to take this opportunity to provide a summary of recent developments between Invasive Fish Species Management (IFSM) and Gift of the Givers (GOTG).

Kindly note that the below content is shared without prejudice to the rights of myself or that of the Invasive Fish Species Management NPC, and that all legal and formal correspondence, and documents relating to this communication is available upon request.

Introduction

Established as a registered environmental Non-Profit, IFSM has spent nearly seven years leading the management of invasive carp in the Garden Route. During this period, we have removed close to 40 tons of invasive carp from freshwater ecosystems under the administration of CapeNature and SANParks.

Our efforts under the auspices of CapeNature, have consistently aligned with CapeNature’s conservation mandate, and have been supported by affiliations with Nelson Mandela University (NMU), the Coastal and Marine Research Institute (CMR), SANParks, and the South African Institute for Aquatic Biodiversity (SAIAB).

During the early stages of the COVID-19 pandemic’s national lockdowns, IFSM conceptualized and initiated a program to utilize its invasive carp catches for hunger relief. Recognizing the urgency of the situation, IFSM approached GOTG’s Western Cape Regional Manager (Mr. Mario Ferreira) with a proposal to donate its carp catches to support GOTG’s hunger relief mission in the Garden Route during that critical period.

Since May 22, 2020, IFSM and GOTG have engaged in an informal collaboration on the Groenvlei Carp Project under the auspices of CapeNature. Throughout this period, despite the absence of a formal agreement, IFSM has provided GOTG with over 25,000 kg of carp, supporting both IFSM’s environmental conservation initiatives and GOTG’s hunger relief mission. GOTG’s financial support has been instrumental to the project’s success, while IFSM consistently delivered expertise results in effective carp management.

On October 14, 2024, citing dissatisfaction over unaligned media representation objectives, GOTG’s Western Cape Regional Manager (Mr. Mario Ferreira) formally notified IFSM of the immediate withdrawal of funding for the Groenvlei carp removal project.

This decision followed after GOTG’s Western Cape Regional Manager informed us that he had "consulted with GOTG’s National Controlling Board and other project sponsors", in response to IFSM’s initial email dated October 9, 2024, in which we raised our concerns about media-related issues.

Additionally, despite of GOTG’s Regional Manager (Mr. Mario Ferreira) holding no official mandate over conservation and carp management activities at Groenvlei Lake, requested that all carp management operations cease immediately.

Following this decision, GOTG’s Regional Manager demanded the return of the following critical equipment:
• 560 meters of gillnets – Certain design aspects behind the majority of the nets was conceptualized by IFSM and customized to our specifications. After reception thereof, certain modifications were made to a number of nets which significantly contributed to project success between August and October 2024.
• Fish Finder – Conceptualized by IFSM, this equipment notably enhanced project outcomes between 2023 and 2024.
• Spears – Developed in collaboration with a leading manufacturer, the spears became essential due to habitat changes that rendered other carp management methods less effective. This method also notably contributed to project successes as of 27 July 2023.
• Two electric trolling motors – Key equipment for carp management operations.
• Boat trailer and tailboard – Essential components for project mobilization.
• Outboard motor – Preceded by a 1-day notice period, collected on October 10, 2024, which rendered IFSM’s vessel non-operational.
These tools were provided in the spirit of collaboration, with no formal ownership agreement established. Our records, including photographic documentation, substantiate the donation and usage of these items.

On October 25, 2024, following the prior arrangement thereof, GOTG’s Western Cape Regional Manager arrived at IFSM’s premises to collect the aforementioned equipment. IFSM returned only two deep freezers and other items related to the vessel, earlier this year sponsored to GOTG by the Oceana Group.

However, in the presence of our legal representative, we communicated our intent to retain the remaining donated equipment. Our legal representative informed GOTG’s Regional Manager that a formal legal letter outlining IFSM’s position regarding the retained equipment would be issued. In response, GOTG’s Regional Manager indicated that he would escalate the matter to GOTG’s attorney for further review.

Subsequently, a legal letter was submitted to GOTG’s Regional Manager on November 28, 2024.

To date, no legal response has been received from GOTG.

In an effort to restore the relationship and secure future funding, on October 21, 2024, IFSM presented a draft proposal to GOTG for formalizing our collaboration. This was followed by an informal meeting with GOTG’s Regional Manager (Mr. Mario Ferreira), held on October 31, 2024, during which both parties acknowledged the need for a formal agreement.

We also record that at this stage we received no formal response with regards to the aforementioned draft proposal presented to GOTG’s Regional Manager on October 21, 2024.

On November 6, 2024, IFSM submitted a comprehensive, well-researched formal proposal for a Cooperation Agreement to GOTG’s Regional Manager, which included our intent to return the requested donated equipment, excluding the specialized spears developed by IFSM. Our gesture to return the equipment demonstrated our commitment to resolving outstanding issues and fostering constructive dialogue to reach a mutually beneficial resolution.

On November 11, 2024, GOTG’s Regional Manager responded, indicating that GOTG would only engage in further discussions towards future collaboration, once all equipment had been collected, and that negotiations would only begin within seven days following the return of the equipment. Subsequently, IFSM agreed for the equipment to be collected on November 15, 2024.

On November 15, 2024, the remainder of equipment with the exclusion of the spears, was collected by GOTG. On the same day, GOTG’s Regional Manager committed to providing detailed feedback on IFSM’s proposed Cooperation Agreement’s specifics and clauses, within a seven-day period.

To summarize events at this stage:

The primary objectives of our proposed Cooperation Agreement were as follows:
1. To formalize the collaboration between IFSM and GOTG, laying the groundwork for constructive professional engagement and negotiations.
2. To present a comprehensive and quantified values and figures, based on accumulated data and financial records.
3. To offer a range of negotiable financial, and media related options and clauses that would benefit both parties in a fair and equitable manner.

On November 22, 2024, GOTG’s Regional Manager informed IFSM that the returned nets were received in a damaged condition and requested clarification thereof, and further stated that formal feedback on the specifics and clauses of IFSM’s proposed Cooperation Agreement would be contingent upon receiving this clarification.

In response, IFSM referred GOTG’s Regional Manager to our correspondence dated November 6, 2024, which had clearly outlined the removal of certain modifications to the nets that are intellectual property developed by IFSM, prior to the collection thereof. We record that the nets were not damaged as a result of the aforementioned modifications made. We also record that after the removal of our modifications, we ensured that sufficient scope remained for the nets to be further used through standard applications.

On November 23, 2024, GOTG’s Regional Manager dismissed IFSM’s clarification regarding the modifications made to the nets and subsequently stated that GOTG hereby reserves the right to take further action.

On November 23, 2024, after multiple requests, GOTG’s Regional Manager (Mr. Mario Ferreira) failed to provide specific feedback on the content and clauses outlined in our proposed Cooperation Agreement in its entirety.
Instead, his response selectively focused only on limited aspects of the proposal, per verbatim as follows: (With our comments added)

”As per your proposal:

Gift of the Givers are not interested in paying a monthly retention fee towards IFSM.
As per your proposal we are then obliged to continue paying IFSM even if acts of God hinders you from doing your duty or due to personal illness etc.
Why should Gift of the Givers carry the burden of a fix income if you are a service provider and not an employee?”

“You furthermore make your Rand per Kilogram calculations on uncleaned fish that includes the guts etc.
Filleted And dressed Carp are sold in supermarkets in South Africa at a retail price from R37/kg.”

Our Comments:

-One of the proposals in our Cooperation Agreement discussed the option of a Monthly “Retainer” Fee. We record that under no circumstances did we propose the option of a Monthly “Retention” Fee.

- We highlight that by definition, a business proposal entails a formal document that outlines specific offers or solutions to meet the needs of potential partners. It details the scope of work, objectives, timelines, costs, and terms of the project or service, through negotiations which involve structured discussions between parties to clarify expectations, align interests, and agree on the terms and conditions outlined in the proposal. The goal is to reach a mutually beneficial agreement that addresses the needs and concerns of all involved.

-With reference to the context of aforementioned point, we affirm that to date GOTG’s Regional Manager has yet to honour his commitment in providing detailed feedback through negotiations regarding our proposal.

-We question the manner in which your Regional Manager’s construes service delivery under Force Majeure, and we affirm that our proposal does not imply that regardless of Force Majeure, GOTG would be obliged to provide IFSM a fixed income. We highlight that our proposal, as any standard business proposal was presented to him on the basis of further constructive negotiations.

-Furthermore, in our proposed Cooperation Agreement on page 2 under “Clarification of Performance Quota”, the basis of our calculations is transparent and has been clearly explained and quantified. Furthermore, our proposal suggested several comprehensive financial options.

-We question the validity of GOTG’s Regional Manager’s statement regarding the availability of processed carp retailing in South African supermarkets from R37/Kg.

-We add that several online searches indicate the following:
Finding carp fillets for sale in South Africa appears to be a niche area within the broader fish retail and wholesale industry.

In South Africa, carp fillets are not commonly found in mainstream retail outlets such as large grocery chains (like Pick n Pay, Shoprite, Spar, or Checkers), as they primarily stock more popular fish species like hake, kingklip, or snoek.

Carp is often viewed as an invasive species in local waters, and its consumption is not widely mainstream.
It is, therefore, less likely to be readily available in typical grocery stores at a set price like R37/kg.

Furthermore, GOTG’s Regional Manager (Mr. Mario Ferreira), as per verbatim replies:

“Gift of the Givers is willing to make use of your services to provide us with carp suitable for human consumption on the following basis:

3. Carp to be supplied to Gift of the Givers frozen except otherwise agreed on from time to time between Gift of the Givers and IFSM.
2. Frozen Carp collections not to be below 300kg per collection.
3. Carp to be weighed on collection in the presence of Gift of the Givers.
4. We are willing to pay IFSM at a rate of R13 per kilogram for uncleaned frozen Carp that are good for human consumption.
5. IFSM to carry its own operational costs.

Our Comments:

With the numeric order of the above points unclear, we comment accordingly in the same order thereof:

3.) We question this condition and note that fresh, uncooled carp have on numerous previous occasions been provided to soup kitchens and communities by GOTG’s Regional Manager between May 22,2020 and October 2024.
2.) We question the basis on which this proposed minimum Kg quota per-collection has been determined. We request clarity as to on which basis it has been quantified.
3.) We record that this condition is an extract of one of the many clauses suggested to GOTG in our proposed Cooperation Agreement and note that numerous other clauses in our proposal have yet to be negotiated.
4.) We question the equitability of the proposed R/Kg value. We request for clarification as to how this value has been determined – as it stands in stark contrast to the financial values quantified in our proposal to GOTG’s Regional Manager.
5.) We strongly question the fairness thereof, as it is totally unreasonable, and directly contradicts past support received from GOTG.

It is worth noting that while the emphasis on carp suitable for human consumption is clearly highlighted in GOTG’s Regional Manager’s response, it strongly contrasts to GOTG’s Regional Manager’s promulgated compliance with health regulation protocols as to the consistency of microbiological testing for E. coli, Staphylococcus aureus, Salmonella, and Listeria monocytogenes.

1. The GOTG Regional Manager’s inconsistent adherence to health regulation protocols, particularly regarding the microbiological testing of carp for E. coli, Staphylococcus aureus, Salmonella, and Listeria monocytogenes, raises significant concerns.
2. As evidenced by our database records and laboratory test results obtained from and confirmed by the local laboratory that has conducted testing on behalf of GOTG’s Regional Manager, the distribution of large numbers of untested carp, poses serious public health risks.
3. These records highlight that there has been a concerning lapse in microbiological testing, thereby undermining public safety and the regulatory standards intended to ensure the suitability of food for human consumption.
4. Should additional verified records of testing be available, our database can accurately correlate and substantiate the quantities of both tested and untested carp distributed to communities in need.
Microbiological testing in South Africa is mandated to ensure compliance with health standards, such as testing for pathogens in food products to safeguard public health, and the potential health risks due to lapses in microbiological testing of food products, including carp, are significant under South African health regulations.

Pathogens such as E. coli, Staphylococcus aureus, Salmonella, and Listeria monocytogenes are harmful microorganisms frequently targeted in food safety testing.
Without consistent and rigorous testing, these pathogens can cause severe health issues including foodborne illnesses, outbreaks, and even fatalities in vulnerable populations.

Health Implications:

1. E. coli: Certain strains can cause severe diarrhea, urinary tract infections, and other serious conditions. It is often associated with contamination from f***l matter during handling or processing.
2. Staphylococcus aureus: Produces toxins that can lead to nausea, vomiting, and abdominal cramping. This bacterium thrives when food is not stored or handled under strict hygienic conditions.
3. Salmonella: Causes symptoms like fever, diarrhea, and abdominal cramps and can lead to life-threatening complications, particularly in children and the elderly.
4. Listeria monocytogenes: Particularly dangerous for pregnant women, the elderly, and immunocompromised individuals, causing listeriosis which can lead to meningitis, septicemia, or miscarriage.

The lack of frequent microbiological testing of carp distributed raises serious concerns about compliance with South African health regulations.

Consistent testing is not just a regulatory requirement, but a critical safeguard against foodborne illnesses, protecting public health, and maintaining trust in food distribution systems.
Without such testing, the risks posed by pathogens like E. coli, Staphylococcus aureus, Salmonella, and Listeria monocytogenes remain unaddressed, and has potentially endangered community health.

Compliance with health regulations is essential not only to ensure public safety but also to uphold transparency and ethical standards among collaborating authorities, including CapeNature and SANParks. Furthermore, adherence to these regulations reinforces the trust placed in GOTG by its sponsors, who rely on its administration to maintain safe and reliable standards.

In light of GOTG’s Regional Manager’s return proposal referring to carp suitable for human consumption, we kindly seek clarification on whether GOTG is aware of the broader implications and context of this matter.

On Monday, November 25, 2024, GOTG’s Regional Manager requested:

“Further to my mail of 23 November 2024, it will be appreciated if you will let me know if you wish to discuss the way forward should IFSM be interested or not to continue providing a service to Gift of the Givers”

In response, on Tuesday, November 26, 2024, we expressed our willingness to respond to GOTG’s Regional Manager’s return proposal, on the basis once full once full insight, and clear quantification were provided regarding how GOTG’s Regional Manager envisioned a fair and equitable collaboration.

We expressed our position in light of the inadequate response received, which only focused on limited aspects, and stood in stark contrast to a comprehensive and well-researched proposal we submitted on November 6, 2024.

In addition, we emphasized that the limited feedback as per the above significantly hindered the potential for in-depth, and equitable negotiations.

On Wednesday, November 27, 2024, GOTG’s Regional Manager’s subsequent response (available upon request) continued to disregard his commitment to provide us – as requested on several occasions – with detailed feedback as to the specifics and clauses of IFSM’s proposed Cooperation Agreement to GOTG.

Furthermore, GOTG’s Regional Manager has now demanded a clear and realistic answer as to his conjecture of the returned nets collected being in a damaged condition and stated that our clarification thereof will form part of how GOTG’s return proposal will read.

1. We note that the legal correspondence sent to GOTG’s Regional Manager on November 28, 2024, clearly detailed IFSM’s proprietary rights over the design specifications developed through expertise gained in the specialist field of our operational scope.
2. We reiterate that our correspondence dated November 6, 2024, explicitly outlined the removal of certain modifications to the nets—modifications developed by IFSM as intellectual property—prior to their collection by GOTG.
3. We affirm that the nets were not damaged as a result of the aforementioned modifications removed.
4. We reaffirm that following the removal of the said modifications, sufficient scope for further use through standard applications remained on the nets.
5. Kindly note that should further action be actioned with regards to the above; this matter will be vigorously defended.

Future collaboration

As a leader in its field and endorsed by several institutions that we are affiliated with, IFSM remains committed to protecting the environment through our consistent and successfully proven invasive fish management track record.

Regrettably however, we record that all efforts to reach an amicable resolution towards formalizing a collaborative agreement through numerous discussions with GOTG’s Regional Manager have been exhausted.

Moving forward independently, IFSM will consider supplying GOTG with frequently tested whole carp, either cooled or frozen, in full compliance with health regulation protocols.
This arrangement however will remain contingent upon GOTG’s Regional Manager’s presentation of a realistic and equitable return proposal, supported by quantified values and figures.

We look forward to your feedback.

Best regards,

Johnny Snyman
Director & Operations Manager

OPEN LETTER TO THE PUBLIC REGARDING THE TERMINATION OF INVASIVE FISH SPECIES MANAGEMENT'S CARP MANAGEMENT OPERATIONS📌 Th...
08/12/2025

OPEN LETTER TO THE PUBLIC REGARDING THE TERMINATION OF INVASIVE FISH SPECIES MANAGEMENT'S CARP MANAGEMENT OPERATIONS

📌 This statement will remain on Invasive Fish Species Management’s page for a limited period, after which our Facebook account will be permanently deactivated. Public comments have been disabled. For any official enquiries, please contact: [email protected]

📍 This public communication is made in the public's interest and in the spirit of transparency. The author reserves all legal rights.

After seven years of committed service, Invasive Fish Species Management NPC (IFSM) formally announces the conclusion of its invasive carp management operations at Groenvlei Lake, located within the Goukamma Nature Reserve under CapeNature’s jurisdiction, as well as at Island Lake, situated within the Wilderness Section of the Garden Route National Park governed by SANParks.

This difficult decision follows extensive effort, unwavering dedication, and measurable success on the part of IFSM in addressing invasive Common Carp in these ecologically sensitive freshwater systems.

Since March 2018, IFSM has successfully removed in excess of 40 tons of invasive carp from the Garden Route, including 21,463.88 kg through bowfishing alone, under scientific guidance alongside CapeNature and SANParks-issued exemption permits.

On 23 June 2025, IFSM formally notified CapeNature of its termination of carp management services, and returned all carp-removal equipment allocated for this purpose. In addition, IFSM returned all gillnets provided by the Institute for Coastal and Marine Research (CMR) at Nelson Mandela University (NMU), thus concluding a longstanding, respected collaboration built over many years of shared conservation goals. IFSM’s bank account has been closed, and the organization has ceased all operations.

🔹 BACKGROUND

The carp management initiative at Groenvlei was conceived, pioneered, and operationally implemented by IFSM in 2018. The organization undertook the scientific development of a bowfishing-based carp control method tailored specifically for Groenvlei's unique environment, including the import and refinement of specialized gear and procedures.

In May 2020, amid the COVID-19 pandemic, IFSM launched the Groenvlei Carp Community Feeding Program—a food-security initiative grounded in responsible harvesting and community benefit. It was at this point that Gift of the Givers (GOTG) became involved, specifically to assist with the distribution of carp catches captured exclusively by IFSM.

At no stage was a formal working agreement or joint framework put in place, despite IFSM’s repeated proposals to GOTG that a structured, cooperative relationship be established to safeguard roles, responsibilities, and shared credit.

🔹 KEY EVENTS

Despite IFSM’s standing as the project initiator, and its proven 7-year operational track record, a breakdown in ethical collaboration began to surface in late 2024, particularly in relation to the actions of GOTG’s Western Cape Regional Manager, who:

Withdrew all financial support and reclaimed all sponsored equipment previously provided to IFSM—without any prior notice or explanation.

Engaged in exclusive contractual agreements with local soup kitchens, which had the direct effect of blocking IFSM from continuing its community carp distribution efforts.

Made exaggerated public claims on social media about GOTG’s catches at Groenvlei, while failing to submit regular and transparent catch data to CapeNature.

Sought to recruit IFSM’s core field team member, undermining professional boundaries.

Distributed untested carp to communities without any form of microbiological testing, in contrast to health regulation requirements.

Furthermore:

A formal letter was sent by IFSM to Dr. Imtiaz Sooliman, founder of GOTG, in December 2024 in an effort to seek resolution and professional clarity. To date, no response has been received.

GOTG’s role was frequently misrepresented or misinterpreted in both traditional and social media outlets, often implying that the entire Groenvlei carp project was spearheaded by GOTG. This created widespread confusion among the public, undermined IFSM’s seven-year track record, and cast doubt on the integrity of stakeholder narratives.

Further concern was raised when GOTG was reportedly granted permission to introduce salt lick blocks into Groenvlei, a sensitive aquatic ecosystem. NMU CMR, a key scientific stakeholder, formally addressed concerns over GOTG being granted harvesting rights, citing the risk of methodological misuse and the lack of historical involvement in the project.

CapeNature, while asserting its neutrality during the dispute, approved GOTG’s independent exemption permits in expedited fashion—despite GOTG’s lack of field-proven experience in carp management or ecosystem-based harvest methodology.

The public record now shows that the very program developed and successfully operated by IFSM has effectively been adopted and rebranded by another organization, without acknowledgment of the foundational groundwork laid since 2018.

🔹 CLOSING

The ecological threats to Groenvlei and Island Lake remain critically unresolved, especially in the absence of a cohesive, science-led, and experienced operator in the carp management space. Both systems—one part of a provincial nature reserve and the other of a Ramsar-listed national park—now stand more vulnerable than ever.

To those within the Sedgefield and Garden Route community who offered encouragement, believed in the mission, and stood by IFSM throughout its evolution—thank you. Your support allowed us to serve with integrity and measurable conservation impact.

And now, to the broader public:

Has Groenvlei Lake become a mere funding platform for larger NGOs?
Or will those now occupying the stage be able to match IFSM’s professionalism, transparency, and seven years of unmatched success in invasive carp management?

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