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Australian Anglers Association, (WA Division) Inc.



Comments on Proposed Jurien Bay Marine Park Indicative Management Plan.



The Plan Co-ordinator
Jurien Bay Marine Park Indicative Management Plan
Marine Conservation Branch
Department of Conservation & Land Management
47 Henry Street, FREMANTLE, WA 6160

5 January 2001.

Dear Sir

Submission on the Jurien Bay Marine Park Indicative Management Plan

Enclosed please find the Submission as above from this Association, following discussion among and advice from our Member Clubs, and information received from various sources including officers from CALM Marine Conservation Branch.

We trust that this Submission will be given serious consideration, representing as it does, some 5000+ Members of the Association's Member Clubs. This Association is the largest recreational and competitive angling organisation in Western Australia. The great majority of the Clubs' Members are regular anglers who travel to many and varied areas of WA, and have vast experience of the coastline, the fisheries and the marine habitat.

Yours faithfully, Secretary, Australian Anglers Association, (WA Division) Inc.

This submission has been prepared for and on behalf of the Australian Anglers Association (W A Division) Incorporated. For convenience hereinafter referred to as 'the Association'

Background:

The Association is based in the Perth metropolitan area and it's membership is in excess of forty clubs whose locations extend from Kalbarri in the North to Esperance in the South-East.

Membership is via direct affiliation of This Association and it's member Clubs with the Association, and the total membership of affiliated clubs is in excess of 7 000 members whose specific interests are land based and / or boat angling.

The Association is the largest organised angling body in Western Australia. Its main activities revolve directly around shore and boat based angling and dry-casting. The Association also plans, coordinates and conducts competitions in the following divisions;

State Beach and Rock Angling Championship
State Boat Angling Championships
State Estuary Championships and
State Dry-Casting Championships.

Competition within these divisions is strong and is expanding. Venues for these events are scheduled throughout the lower half of the State, with regions within the proposed Jurien Bay Marine Park included as venues for some of these events.

As such, the Association's main interests and activities in the proposed Jurien Bay Marine Park relate to recreational angling. Individual affiliated Clubs and their members are also interested in other tourism and recreational activities.

In general the Association and its members actively promote the concept of fishing for the future and also support and promote conservative angling. To this end the Association and its member clubs actively support and promote species angling rather than 'heaviest bag' competitions.

General Comments.

The Association wants to make a clear distinction between shore based recreational line fishing, and other shore based recreational fishing such as collecting shellfish, etc. from the shore. It also wishes to differentiate itself from other boat angling activities such as SCUBA and free diving for the purposes of taking fish and crustacea,

In general the Association's Boat and Shore based recreational anglers target mobile fish such as tailor, herring, garfish, whiting, Westralian Jewfish, mulloway, skipjack trevally, sharks, assorted mackerel and other similar pelagic species. These fish have seasonal migrations along the West Coast and have seasons when they are present and seasons when they are not present. They also regularly move significant distances along the beaches over short period.

Our Association competition and Club capture records tend to indicate that there are minimal captures of demersal species of fish and it is felt that generally they would have no significant impact on fish populations, particularly when compared to commercial net fishing activities.

To this end the Association feels that there should be no restriction limiting shore based recreational angling access to areas such as Sanctuary Zones, as there will be minimal impact on the fish stocks within the proposed 100 metre restriction in these areas.

It is recommended that consideration be given to another zone type called Special Purpose (Shore Based Recreational Line Fishing) Zone.

The proposed Marine Park covers many kilometres of coastline. Unfortunately not all of the coastline is suitable for shore based recreational line fishing for the types of fish most people want to catch.

Some of the coast within the proposed area is shallow, some is rocky, some is invariably located adjacent to major weed banks, and when these are combined within the regular strong sea breezes, shore based line fishing in these areas is difficult at best and often unrewarding. To be successful in shore based recreational angling requires that the sought species be within the areas that are fishable or that they are able to readily pass through the area.

So the equity of the proposals cannot be measured merely by the percentage of coastline still available for recreational angling. Even though this percentage maybe very high, the part lost appears to include some of the most suitable parts of the coast. The Association feels that far too many of the good areas for shore based line fishing would be lost through being included in the proposed Sanctuary areas.

The size and shapes of many of the proposed zones appear to reflect major compromises. Many do not appear to have enough area or width to be effective as sanctuary zones. The proposal relies heavily on the presence of large areas of Special Purpose (Scientific Reference) Zones to back up the Sanctuary Zones, but as covered elsewhere in this submission, the application of these Special Purpose (Scientific Reference) Zones is badly flawed.

This Association is also concerned with the structure and make up of the Review Committee. It would appear that many members of the committee have vested interests of commercial fishing activities. Member Clubs of this Association have also expressed concern with the lack of recreational input on the committee.

This Association, albeit the largest in the State, was not consulted on membership of the committee, nor was it requested to provide names for potential members of the committee. Therefore we ask:- how could recreational anglers have had direct input to the committee during its deliberative stages.

This organisation provides a Board Member to Recfishwest, and in fact was the prime driving force behind the establishment of this body.

The Special Purpose (Scientific Reference) Zones as proposed remove 17 percent of the Marine Park from recreational line fishing from boats. A further 4 percent of the Marine Park is closed to recreational line fishing from boats in the Sanctuary areas.

This is a total of 21 percent of the proposed area lost to recreational line fishing from boats and is definitely excessive and inequitable. This Association is curious as to how the proponents of this plan expected to get community support for such a major loss of access.

It is patently clear that commercial fishing activities in the proposed park area will hardly be affected. The loss of access to only 4% of area in the Sanctuary Zones to commercial fishing activities is ludicrous, and it seems that they won't even lose access to these areas.

This Association feels that access to these areas must be totally restricted to ALL FORMS of angling and fishing activities if the proposal is to be credible.

Section 2.1, Vision Statement.

This Association fully supports the Vision Statement for the proposed Marine Park, but notes the sentence "will be considered an important asset by the local community".

Due to its proximity to the Perth metropolitan area and to mid-west rural farming areas, it is important that the proposed Park also meets the needs of the residents of these areas, without compromising the main purposes of the Park.

This again is a prime example of the biased outlook of the planning committee. It shows that minimal consideration has been given to potential income that can be derived from tourism activities such as recreational angling, in the region. In addition to the direct spending of recreational anglers on directly related services, there is also the consideration of the secondary and tertiary spending in support of this.

The flow on effect to local businesses with spending on items such as accommodation, fuel, and meals, etc. has obviously not been considered. This lack of forethought on the part of the committee causes concerns when looking at the implementation of the proposed plan. What other areas have they glossed over as not being worthy of consideration? As previously indicated, the make up of the planning committee causes this Association some concern.

Section 2.2, Strategic Objectives.

This Association supports the strategic Objectives as stated in Section 2.2, but does not believe that the details in later sections actually follow, or will achieve these objectives. More details relative to this matter are dealt with later in this submission.

Section 7.1.1, Geomorphology.

Management Objective number 2 under this section is "to ensure that coastal landforms within the park are not degraded by recreational access and use". This objective is fully supported by this Association. However, we cannot support this objective being used to completely exclude recreational angling access to specific areas. Does it also mean that commercial fishing shore based activities are not included in this?

As suggested as one possibility in the "Background" section of the Management Plan Proposal, unless this is the ONLY possible way this protection can be achieved, AND if it is critical that such protection be provided, then ALL should comply.

The alternative of providing made access tracks, boardwalks or roads, as appropriate, is far preferable to exclusion. Where provided, it is important that the layout of these does meet the legitimate needs of all users.

Section 7.1.2, Inter-tidal Reef Platforms.

The Management Objective is to ensure the species diversity and abundance of marine flora and fauna on inter-tidal reef platforms of the park are not significantly impacted by fishing and reef walking activities.

The important words are "significantly impacted" and these need to be better defined. Without such a definition, the concern is that any visible impact may be considered significant, and lead to more unnecessary and unenforceable restrictions. It should be noted that if restrictions are to be imposed, then they must be enforced; this then leaves the poor alternatives of 'user pays for policing', or 'no access at all', which defeats the purpose of being able to walk and view the unique wildlife found in this region.

This Association generally supports this objective in principle, but considers that it should not be applied where it would result in a significant loss in access for reasonable and sustainable recreational activities. As indicated, inter-tidal reef platforms around the offshore islands are barely used because of access difficulties, so they should be used as the reference baseline, rather than restrict access to mainland inter-tidal platforms.

It is felt that collection of any marine life from the reef surface should be controlled by bag limits and closed seasons, such as are used to control the recreational abalone fishery. This would impart some control over the marine environment, and would go some way towards reducing human activity and thus impact on the reef surfaces.

This suggestion is consistent with the long-term target No 3, which is that the abundance of targeted flora and fauna species on inter-tidal reef platforms is maintained at sustainable levels - which allows some impact provided the populations are sustainable.

Section 7.1.3, Water Quality.

This Association fully supports this Management Objective to maintain this important feature of the park. Rigid controls definitely need to be put in place to cover any extractive activities or other usage of the waters of the park, that may have a detrimental effect on any area of the park.

This specifically includes activities such as aquaculture and commercial fish farming, where wild stock are captured and grown out on a commercial basis or juvenile fish are purchased and then grown out.

Section 7.1.4, Seagrass Meadows.

This Association fully supports this Management Objective to maintain the seagrass meadows as important habitat, vital to the sustainable future of fishing activities both recreationally and commercially within the proposed park area.

Researchers in Queensland, operating for and on behalf of the Queensland Commercial Fishermen's Co-operative, have found that the seagrass meadows are a fundamental and vital link in a viable fishery. Not only are these areas a vital nursery area and filter system for the environment, they also appear to control wave and tidal action, and thus play a major role in the regional environment.

Section 7.1.5, Macro-algal Communities.

This Association supports this Management Objective to maintain this vital element of the food chain. Again as with the seagrass meadows, the retention of the macro-algal communities is vital for the future well being of the resource.

Section 7.1.6, Seabirds.

This Association agrees with the strategy to educate park users about the park's seabird population. Many anglers, particularly boat based anglers, use feeding seabirds to locate schools of feeding pelagic fish. Knowledge and understanding of the avian species provides assistance in determining what fish may be feeding and at what depth they are working.

Section 7.1.7, Invertebrate Communities.

This Association supports the Management Objective to maintain the food chain and population of invertebrate species. The Association wishes to have direct input to any proposals for changes to current regulations or the drafting of new ones.

Section 7.1.8, Finfish.

The Management Objective is to ensure that species diversity and abundance of non- target finfish species are not significantly impacted by human activities in the Park. However the background also infers control of targeted species, eg baldchin groper - which should be included under sections 7.2.3 and 7.2.7.

This Association supports and endorses proposals to reduce and if possible, eliminate commercial fishing by-catch. While this Association realises that commercial fishing is an important industry, we believe the level of by-catch has been completely unacceptable in the past.

Some Clubs indicated that the by-catch is in effect by-kill, as it is returned to the ocean in very poor state. Indications from observation of various commercial operations, such as trawling, show that there is a very poor recovery rate for commercially unwanted species returned to the environment as a result of these activities.

This Association actively endorses and supports ethical methods and restraint in recreational fishing, to the extent that many of our members voluntarily limit their catches to less than the quantities of fish permitted under current Fisheries WA recreational fishing regulations.

Fishing methods and catch care principles are used which provide all unwanted fish a high probability of successful release back into the ocean. The Association actively promotes, supports and uses the National Code of Practice for Recreational Angling as adopted by all State and Territory Governments as well as the Federal Government.

Recently, Fisheries WA produced a discussion paper covering Recreational Fishing on the West Coast, which obviously includes the area covered by the proposed Jurien Bay Marine Park.

This Association and many of its member Clubs submitted comment and feedback on that document, and supported many of the proposals in it. However, this Association and its Member Clubs strongly believe that recreational fishing regulations should be uniform throughout the State.

This Association feels that Sanctuary Zones and/or closed seasons should be used to manage pressures on particular species of fish. We strongly disagree with a total prohibition on catching particular species of fish from particular areas where recreational fishing is generally allowed, unless in exceptional circumstances such as dense spawning aggregations. In such conditions, short closed seasons which cover the spawning aggregation period are preferred.

This Association feels quite strongly that if there is to be research done to 'identify finfish species that will be protected from recreational and commercial fishing in the park and provide necessary legislation to achieve this', then that research should be done so that the commercial and recreational sectors may benefit from the research. The research that has previously been done in other areas where this proposal was made was all done on the commercially important species in that region.

Section 7.1.9, Sea Lions.

This Association supports this Management Objective.

Section 7.1.10, Cetaceans and Turtles.

This Association supports this Management Objective, and considers that current legislation to be adequate in the controls of activities associated with them, such as CALM restrictions on whale-watching.

Section 7.2.3, Commercial Fishing.

This Association supports the three Management Objectives listed. In particular, this Association endorses objective number two, which is "to ensure that commercial fishing activities in the park are managed in a manner that is consistent with maintaining the park's values."

Objective number three which is "....maintenance of a viable commercial fishing industry...." is of course important, but must not be used to allow commercial fishing activities which are not compatible with the requirements of the park.

This Association is quite concerned about the equity of access to many areas of the park. The proposed size of Special Purpose (Scientific Reference) Zones, combined with their use for rock lobster catches is an example where objective three appears to have been given far too much emphasis over objective two. It is again a prime example of inequitable resource sharing and is indicative of the bias in the input received by the planning committee.

Section 7.2.4, Aquaculture.

This operation is a major source of a variety of marine and environmental pollutants. This Association believes quite strongly that it is not an acceptable industry operating within or adjacent to the precincts of the proposed park.

Doctor T V R Pillay, (former Program Director, Aquaculture Development and Coordination Program, Food and Agriculture Organization of the United Nations) in his book Aquaculture and the Environment (p3) says "... Cage farming in protected bays and other areas involves the use of highly intensive stocking and feeding which results in increased sedimentation, biochemical oxygen demand, and nutrient loading. The overcrowding of fish pens and cages in semi-enclosed areas has sometimes resulted in autopollution and transmission of diseases."

This can lead to problems such as obstruction of water flow, destruction of seagrasses and other benthic flora, hypernutrification and eutrophication, excessive chemical residue and a host of other associated problems including introduction of exotic diseases. There are several recent incidents which only too well highlight this, and they have had a massive effect on a variety of commercial fishing activities including aquaculture.

Section 7.2.5, Coastal Use.

This section deals with litter, and with the use of Recreational Vehicles.

Litter is a social problem wherever people do not respect the environment and do not follow common courtesy. The fact that there will always be a minority of people who will litter, despite all the publicity and education, should never be used as an excuse to limit access by the majority who will do the right thing, and who will treat the environment with respect.

This Association believes that a combination of education and enforcement should be used so that those who do litter and get caught will pay a price, preferably high enough so that it makes them do the right thing in future.

Similarly, unsuitable Recreational Vehicle use is also a social problem, and once again must never be used as an excuse to limit access by the majority of people who will do the right thing.

Recreational Vehicle use can be benign or can be very damaging. Recreational Vehicle use on sandy beaches has a very transient affect, and is often completely eliminated by the next strong sea breeze or high tide. People who value their access to and along such beaches generally would not do anything that might compromise that right.

Unfortunately there is a small minority of socially irresponsible people who do things like damage vegetation or drive on sand dunes or drive dangerously near other beach users. This Association believes that a combination of education and enforcement should be used so that those who use Recreational Vehicles irresponsibly and are caught acting irresponsibly, will pay a price, preferably high enough so that it makes them do the right thing in future.

The Association has a documented policy pertaining to the use and operation of off road vehicles in sensitive areas. This policy is endorsed by the clubs and is generally enforced through peer group pressure. Where club members disregard the policy they are promptly dealt with. This policy has been adopted 'in principle' by all clubs and is well supported.

Section 7.2.6, Seascapes.

This Association supports this Management Objective.

Section 7.2.7, Recreational Fishing.

This Association supports this Management Objective with the reservations already expressed. Refer to previous comments under 7.1.8, Finfish, and comments on zoning, etc.

Section 7.2.8, Water Sports.

This Association generally supports this Management Objective. Concern has been expressed about the use of Personal Water Craft (PWC) and feels that operators should be licensed and restricted to areas where there is minimal risk of pollution. This includes visual, environmental and resource degradation resulting from the operation of these craft.

Section 7.2.9, Marine Nature Based Tourism.

This Association generally supports this Management Objective, but not the use of powered water sports craft, such as Personal Water Craft in Sanctuary Zones. See other comments on zoning, etc.

Section 7.2.10, Petroleum Drilling and Mineral Development.

This Association considers that the most stringent examination, precautions and penalties should be applied to all such proposals within the Park.

Legislation should include the stringent prior conduct of a detailed Environmental Impact Study. Additionally, there should be a requirement that specific guarantees be in place to ensure minimal harm may be done to the region and its resources before any activities associated with any extractive industries are considered in, or adjacent to the park and adjacent areas.

Section 7.2.11, Scientific Research.

This Association generally supports this Management Objective, however it believes that the proposals have major flaws. See other comments on zoning, etc.

Section 7.2.12, Education.

This Association supports this Management Objective. The Association is actively involved in marine education through its clubs and through other related activities such as regular public fishing clinics and public awareness programs conducted in conjunction with Association events such as its annual State Angling Championships for the four disciplines under its control, and the Sunsmart Mandurah 500 Family Fishing Competition.

Table 2. Uses Permitted in the Zones.

Commercial Rock Lobster Fishing.

This Association strongly disagrees with allowing commercial rock lobster fishing within the Special Purpose (Shore Based Activities) Zone and the Special Purpose (Scientific Reference) Zones.

Regardless of how important to the region this commercial activity is, it does not make sense to allow commercial rock lobster fishing within the Special Purpose (Scientific Reference) Zones. Section 8.1.2 proposes that "the primary purpose of these Zones is to provide large areas where natural processes can be studied free of significant human influence".

Commercial rock lobster fishing must be considered a significant human influence since it is removing what we believe is a significant part of the food chain, and is using methods which have a potential to cause damage to the seabed and environment.

It does not make sense to allow commercial rock lobster fishing within the Special Purpose (Shore Based Activities) Zones adjacent to sanctuary areas such as Boullanger Island and North Head.

Also since these areas are only 100 metres wide, from the shoreline, it is not known how much use commercial rock lobster fishers will be able to make use of this area. It is felt that there is a significant potential for dangerous situations involving lobster pots and ropes and recreational fishermen casting from the shore.

There is also a considerable difficulty with checking and confirming compliance because the rock lobster fishing boats would need to transit the Sanctuary Zones to get to these Special Purpose (Shore Based Activities) Zones.

Recreational Rock Lobster Fishing.

This Association strongly oppose allowing recreational rock lobster fishing within the Special Purpose (Scientific Reference) Zones, for the same reasons as above, and since no other recreational collecting is allowed in these Zones.

Surface Water Sports.

This Association and its Member Clubs strongly disagree with allowing surface water sports using power craft such as jet skis, and water skiing, particularly in Sanctuary Zones and to a lesser extent in Special Purpose (Scientific Reference) Zones. The Association considers that these sports represent a significant and avoidable disturbance to the environment and as such should not be welcome.

The Association does support and has no objection to other non-disruptive surface water sports such as surfing, windsurfing, kite surfing, etc. in any area.

Comments on Proposed Zones.

Special Purpose (Shore Based Activities) Zones.

This Association recognises that an effort has been made to make provision for shore based recreational fishing in all of the Special Purpose (Scientific Reference) Zones and some parts of the Sanctuary Zones.

This has provided a significant length of coastline for shore based recreational angling. As far as they go, the Association supports all of the areas shown in the document. However, when we look at the location of the proposed Sanctuary Zones that exclude shore based recreational angling, the most vital concern is that the planning committee has selected many of the best areas for recreational angling from the shore.

Conversely, many of the areas in which shore based angling is to be permitted are not really suitable. Thus we do not think that there are enough of these Special Purpose (Shore Based Activities) Zones in Sanctuary Zones.

Sanctuary Zones.

This Association supports the general concept of Sanctuary Zones where they are essential to provide a reservoir of fish stocks, and where the proposed Zones will be effective in doing this.

The Association feels that there are alternative methods available to meet the need for preserving fish stocks. The Fisheries WA discussion paper covering Recreational Fishing on the West Coast proposes significant changes to recreational fishing, aimed among other things, at preserving fish stocks in the entire West Coast region.

These include a tightening of controls at a time when stocks of many recreational fish targeted by shore based recreational line fishermen are at their best levels for many years. As indicated in your section 7.2.7, research and monitoring of the target species and the effects of recreational fishing on the Park's values need to be undertaken. This would indicate to us that there is no data yet available and Fisheries WA is once again using 'knee jerk' reaction to preclude any use, sustainable or otherwise, of the resource.

This would indicate that there is an urgent need for the implementation of Sanctuary Zones throughout the region for the purposes of preservation of the variety of species caught by recreational anglers. It is for this reason that this Association proposes that there should be another zone type called Special Purpose (Shore Based Recreational Line Fishing) Zone.

We accept that Sanctuary Zones have other uses, in particular for tourism, and for preservation of reef fish and invertebrates, and we accept that these would be valid reasons to have Sanctuary Zones. However we believe that shore based recreational line fishing would not be incompatible with the primary aims of these areas, as described in the proposed Management Plan.

Target Rock Sanctuary Zone.

This zone contains an important shore based fishing area at Target Rock. The Association cannot support the restrictions on shore based recreational line fishing in this area. The shoreline should be zoned as either Special Purpose (Shore Based Activities) or Special Purpose (Shore Based Recreational Line Fishing).

Grey Sanctuary Zone.

The Association believes that the shoreline in this area should be zoned as either Special Purpose (Shore Based Activities) or Special Purpose (Shore Based Recreational Line Fishing), and would recommend amendment of the zoning of this region.

Boullanger Island Sanctuary Zone.

The Association believes that this Special Purpose (Shore Based Activities) Zone should be extended to cover the entire shoreline of this Sanctuary Zone.

North Head Sanctuary Zone.

The proposed loss of access to the beach area east and southeast of North Head is significant to members of Clubs associated with this organisation. This is because this area is an important shore based recreational angling area located within a region that has few other alternatives.

The beach area within the proposed Pumpkin Hollow Sanctuary Zone is less suitable, and access to the beach area from there, south towards Jurien is understood to be difficult because of a mining lease.

The reef platforms at North Head are important recreational line fishing areas, because they are accessible from the shore. They can however, only be used under favourable conditions of tide, swell and wind. Similarly, the beach and reef areas North of North Head are also important shore based recreational angling areas.

Section 8.1.2 says that the purpose of Sanctuary Zones includes the opportunity to obtain comparative data with areas of the park where extractive activities are permitted and/or where environmental impacts may be occurring. However it seems that by including North Head in a Sanctuary Zone, there is no similar area which can be used as the comparative area where extractive activities are permitted and would actually occur.

The Special Purpose (Shore Based Activities) Zone or Special Purpose (Shore Based Recreational Line Fishing) Zone should be extended to cover the entire shoreline of this Sanctuary Zone, and this Association would support such a proposal.

Special Purpose (Scientific Reference) Zones.

This Association has major objections to the way in which it is proposed these Zones are to be applied and regulated. The application of Special Purpose (Scientific Reference) Zones is flawed, and we wonder how the proponents hoped to obtain community support for this proposal.

The major flaw in this proposal is that they are de facto sanctuary areas for all purposes except rock lobster capture, and by this they will exclude recreational angling activities from boats.

This Association and its Member Clubs have considerable experience in fishing from boats within this area. The Association and many of its affiliated boating Clubs hold regular competitions within the area,

As these areas are some distance from the major population and access points, the loss to recreational boat angling could be considered insignificant, however, if these areas are to be available to recreational rock lobster fishing from boats, then the same should be available for recreational boat angling

It would appear that the commercial rock lobster fishing industry has received a major concession by the proposal to be permitted to continue captures in these areas. It would also appear that recreational rock lobster fishing will also be permitted in an attempt to demonstrate equity, but we wonder how much use can and will be made of this.

We realise that prohibiting rock lobster fishing within Special Purpose (Scientific Reference) Zones will in effect make them Sanctuary Zones. But the outcome would be much better if there were to be adequate Sanctuary Zones, because they then also could be used as Scientific Reference Zones.

The Committee claims that the Scientific Reference Zones will enable the effect of rock lobster fishing to be assessed by a comparison of these Zones with Sanctuary Zones where no activities are allowed. Should that be the case, then surely such large areas (17% of the park) are not required, and the Sanctuary Zones (4%) are far to small to be adequate reference areas.

If it is finally decided that rock lobster fishing will be permitted as proposed, then the Association recommends that the proposals should not try to hide the real use of these zones.

The name of these zones should be changed to something which truly represents their use, such as Special Purpose (Rock Lobster Extraction) Zone, so that the meaning and use of the Zone is absolutely clear to everyone.

The Association wishes to thank the planning committee for their efforts in the preparation of this proposal and also the opportunity to respond to it.






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This page last updated 10 February 2003.