"The rationalization if pushed through will result in a lack of focus on fisheries development since invariably fisheries will be given a lower priority in terms of funding allocation within each division as happened between 1987 and 1998 when BFAR was relegated to a mere staff bureau within the Department of Agriculture. It became in effect a second-class bureau," he said.
Yap, a former FAO expert and research head of the Southeast Asian Fisheries Development Center or SEAFDEC, said that from 1987 to 1998 the average annual growth rate of aquaculture by volume of production dropped to only 5.4 percent, from 13.3 percent during the previous 10-year period (1977 to 1986) and capture fisheries to only one percent from the previous 2.8 percent.
"The rationalization plan is supposed to eliminate duplication of functions inherent in the present commodity approach of the DA organization. In reality, fisheries cannot and should not be considered a mere commodity like rice, corn, coconut and sugarcane," he pointed out.
"Fisheries is multi-commodity, dealing with different species of both plant and animals whether for food or other uses," Yap stressed.
"For the past seven years after 1998 (1999 to 2005), the average annual growth rate for aquaculture rose to 9.7 percent and that of capture fisheries to 3.1 percent.
The period 1987 to 1998 represents the time when the government embarked on a reorganization which relegated BFAR to a mere staff bureau under the DA.
This in effect stripped BFAR of its autonomy to carry out programs and projects directly up to the regional and provincial levels," Yap said.
The period from 1999 up to present represents the time when BFAR regained its status as a line bureau with the passage and implementation of Republic Act 8550 (Philippine Fisheries Code of 1998, Yap noted.
BFAR Director Malcolm I. Sarmiento Jr. said the future of Philippine fisheries is once more put at stake under the proposed rationalization plan of agriculture department.
Sarmiento believes that "fisheries administration cannot be simplified by distributing its core activities in different supposedly functional boxes, for the simple reason that managing a resource-based sector like fisheries requires the attainment of that delicate balance between exploitation and conservation."
Yap said the "rat plan" assumes that fisheries can be integrated and subsumed within the agriculture bureaucracy handling crops and livestock. He said this is a wrong and potentially disastrous assumption for Philippine fisheries, because of the following reasons:
Fisheries cuts across all the ecosystems: terrestrial, freshwater and marine ecosystems. Agriculture is confined to the terrestrial ecosystem.
Fisheries deals both with natural resource management as well as with culture-based production while agriculture deals only with culture-based production. For this reason fisheries cannot be administered in the same manner as agriculture.
Fisheries itself is multi-disciplinary and therefore has its own various specializations just as agriculture is multi-disciplinary and has its own various specializations. Fisheries cannot be considered as a discipline within agriculture, it is a major discipline in itself.
Integrating fisheries activities within large humungous divisions concerned mainly with crops and livestock shows the following:
Clear lack of understanding of the nature of fisheries as a distinct science, distinct technology and distinct economic activity.
Clear lack of appreciation of its importance in an archipelagic country like the Philippines.
The former FAO consultant said the correct way to rationalize fisheries within the context of Philippine bureaucracy is to elevate it into a department.
"This is what Indonesia, another archipelagic country has done. Indonesia separated fisheries from the Ministry of Agriculture, removed marine resource management from their Ministry of Environment and created a Ministry of Fisheries and Marine Affairs.
Only in this manner will it be given the proper importance it deserves and eliminate the current duplication and redundancy with some functions of the Department of Environment and Natural Resources (DENR) particularly in the management of marine resources," Yap stressed.