Australian Anglers Association, (WA Division) Inc.

Submission to Minister for Fisheries about the Management of the Commercial Catch of Finfish.

The following letter was sent to the WA Minister for Fisheries, Kim Chance on 20 March 2003, to express the Association's concern at delays in the announcement of effective management of commercial catches of finfish.

The reply from the Minister received in early May 2003 has been added below.

The Honourable Kim Chance, MLC,
Minister for Agriculture, Forestry and Fisheries
11th Floor, Dumas House
2 Havelock St
West Perth WA 6005

Dear Minister,

Management of Professional Fisheries.

I wish to bring to your attention an anomaly with the implementation of the Integrated Fisheries Management Review Committee's management plan which you have announced will take effect for Recreational Fishers from 1 July, 2003.

The anomaly is that a management plan is not yet ready for the professional fishing sector, with particular reference to the finfish stocks, and therefore the only group to be more tightly managed from 1 July is the recreational angler group. This is not a satisfactory arrangement and certainly worthy of comment.

This anomaly is of great concern to the members of the Australian Anglers Association (WA Division) and to most recreational fishers.

At Joondalup in early 2001, in front of a representative group of both professional and recreational anglers, Peter Rogers from Fisheries Department announced the commencement of the Justice Toohey investigation.

I, along with others, pointed out that we all realised the importance of the overall management of our fish stock to achieve sustainability, but that the implementation of this management needed to be at the same time for all parties for obvious reasons which have been covered in our previous submissions.

At that time that Gascoyne review was near completion and the West Coast review was underway.

Recently, Lindsay Joll, whose responsibility within the Fisheries Department is the management of the professional fisheries, was invited to attend the February delegates meeting of our Association to inform us how the professional management was proceeding.

I was disappointed to learn that Fisheries had only recently started to look at how they were proposing to implement management of the professional sector, and that you were about to announce the two committees to oversee this early in March 2003. I would have thought these actions would have happened early in 2001!

I point out that we agree there has to be proper management of our fish stocks, and to achieve this goal we have attended the numerous meetings and forwarded several submissions.

We want to see a balanced sharing of the resource so that both professional and recreational fishers may benefit in their respective activities and our fish stocks are properly managed for the future.

A serious concern is that fish which will not be caught by Recreational Anglers because of the changes proposed commencing 1 July will be taken by the professional fishers and there will be no nett change to the quantity of fish caught. Recreational fishers will be forced to exercise restraint, but professional fishers will be free to catch whatever they like.

I believe that if it is important to introduce changes for recreational catches on 1 July, then it is equally important that professional catches be properly controlled from the same date.

I urge that significant and effective controls on professional finfish catches be introduced by that date.

If this is not possible, then we of the AAA think in the interest of the Australian tradition of a "fair go", that you should delay the implementation of the changes in management of the recreational sector until the professional finfish management for a significant number of the species shared with recreational fishers is ready to be implemented.

If this is not done, then the view will be reinforced that the Government is taking the "soft option" of putting controls on recreational catches but not introducing any effective controls on professional catches.

I look forward to receiving your reply on this important issue.

Yours sincerely,

George Holman,

President, Australian Anglers Association (WA Division) Inc.


Reply from the Minister for Fisheries

Mr G Holman
Australian Anglers Association, (WA Division) Inc
P0 Box 2200, MARMION WA 6020

Dear Mr Holman

Thank you for your letter of 20 March concerning the development of new management arrangements for the commercial wetline fishery.

At the outset I believe it is important that I clarify a number of misconceptions contained in your letter particularly with regard to the introduction of integrated fisheries management. The introduction of a new integrated management system, as recommended in the report by the Integrated Fisheries Management Review Committee (Fisheries Management Paper 165). is currently being considered by Government. Integrated management is about achieving a long-term shift in the management of fisheries however the final form of such a new framework, or a timeframe for its implementation, has not been determined.

The date of 1 July 2003 you refer to in your letter applies to the implementation of the new recreational regulations that emanated from the West Coast and Gascoyne regional planning processes. The recreational reviews were required to account for the increase in recreational fishing activity that has occurred over the past ten years and to provide a better framework in which recreational fishing can be managed in the future.

I firmly believe that a more integrated management framework that builds upon existing management and planning processes is essential to meet the growing pressures on our fish resources. This framework must incorporate a regional approach to management, based on the distribution of fish stocks, the determination of sustainable levels of fishing and the allocation of catch shares to the various groups.

The Government is committed to introducing more effective management for all fisheries. This is essential if we are to provide a sustainable management framework, particularly for finfish stocks. Once these sectoral frameworks are in place, and a new Integrated system implemented, allocation issues will be able to be addressed.

On this basis, a number of major fishery reviews have been undertaken in recent years. These have included the implementation of management for the aquatic charter sector, the Gascoyne and West Coast regional recreational reviews, a review of the commercial mackerel fishery, reviews of the South Coast and West Coast commercial estuarine fisheries and the development of an aboriginal fishing management strategy (which will soon be released for comment).

Each of these reviews is aimed toward putting sectoral management on a similar footing and to put in place the appropriate frameworks and controls in which spatial and allocation issues can proceed.

The completion, or near completion, of these reviews means the Department is now able to dedicate the necessary resources to the wetline review. In practical terms, this has seen the transfer of two officers from the recreational program to the commercial program to undertake the review.

The final component of sectoral management required before we can shift towards an integrated system is the commercial wetline review. It is important to note at the outset that the wetline review is not necessarily aimed at resource allocation or reducing the commercial catch. The review is focussed toward implementing a more effective management framework for the commercial sector and to prevent further growth in this sector. This duplicates, and will complement, the objectives for the regional recreational reviews.

Two Panels are being appointed to undertake the wetline review - a Commercial Access Panel to develop criteria for determining the nature and level of access to the fishery and a Management Planning Panel (which will include a recreational representative) to develop specific management arrangements for the Fishery. I have enclosed a copy of the media release announcing the membership of the two Panels.

As was the case with the recreational reviews, the wetline review will involve a number of complex issues and require widespread consultation. The ability to "wetline" is seen as fundamental entitlement by many commercial fishers. Clearly a key objective of the review must be to restrict access to the wetline fishery and this will require the careful consideration of a range of legal and equity issues.

It is anticipated that the Panels will be in a position to release discussion papers in the later part of this year for public comment. Upon review of these comments, the two Panels will then provide me with their final recommendations. This is likely to be early next year. Legislative changes will then be required to implement the new plans and, as with the introduction of most new management arrangements, an objections process will be required.

A further reason warranting the implementation of recreational regulations ahead of the wetline review is the significant growth that has occurred in recreational fishing. Recreational fishing participation rates have more than doubled and effort almost tripled during the past 10-15 years. Annual surveys have reaffirmed that participation continues to be about 34-35% of the State population (which increases each year) and effort in terms of average days fished has also increased (now about 19 days/year/fisher). It is important to note that bag limit revisions are unlikely to affect the total recreational catch due to the high participation rate.

In addition, similar growth has also occurred in the recreational charter sector, from some 40 boats in 1990 to a managed fishery of about 250 boats. This has resulted in the implementation of specific management arrangements for this component of the recreational fishery.

There is no constraint on the growth of recreational fishing and the existing bag limits were extremely generous and essentially unattainable by recreational fishers on most occasions. These limits therefore provided no real constraint on the total recreational catch.

The West Coast and Gascoyne recreational surveys were undertaken in 1996/97 and 1997/98 respectively. In all likelihood, the recreational catch will have increased significantly since then due to a combination of effort, boats and technology and fishing knowledge.

It must be stressed the new regional plans are aimed at containing the recreational catch at existing levels and it is not considered they will reduce the overall recreational catch.

The reductions in bag limits may impact on some individual anglers on an occasional fishing trip, however it does not follow that this represents a commensurate reduction in the overall recreational catch. Recreational catch surveys indicate the vast majority of fishing trips do not result in capture of existing bag limits, or indeed the new limits. For example the average catch of dhufish is 0.4 fish per trip, so a reduction in bag limit from 4 to 2 is unlikely to alter the overall catch. With an average of three fishers per boat, even the new limits still allow for the capture of 6 dhufish per trip which itself would be a rare occurrence.

Similarly an assertion that any "saving" in recreational catch created by the new limits will be taken up by the commercial sector appears unlikely. Given the vast amount of recreational effort, particularly on the West Coast, it is more likely that any "saving" would be subsequently taken by other recreational fishers.

I believe it is also important to recognise the difference in the issues facing the commercial wetline fishery. Commercial fisheries in WA became limited entry in 1984 and no new Fishing Boat Licences (FBL's) are issued. Since this time the numbers of FBL's has decreased from over 1600 to about 1350, including the removal of 70 'wetline only' boats (boats without access to a managed fishery). During the same period, the number of commercial fisheries placed under more stringent management arrangements has increased from 7 to 35

Clearly the wetline fishery is the remaining commercial fishery requiring major review. There are about 150 'wetline only' boats and a total number of about 400 boats wetline each year. Therefore the key management issue is the removal of the considerable latent effort in this fishery (to prevent the catch from increasing) and the implementation of a management framework in which the catch can be constrained within target catch levels. I reiterate I am committed to this review and the introduction of more effective controls in the commercial wetline sector.

I appreciate your organisation's sentiments and commitment to a shift to integrated management. The transition to integrated management will be a 'step by step' process and I look forward to your organisation's continued involvement in these important initiatives.

Yours sincerely

Kim Chance MLC
29 April 2003
Ref: 8-12913

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