4. Daily catch limits.
At present, there are no prescribed limits on what can be caught by a commercial license holder in any given period. The only limit is what fish are in the water, can be caught and what can be physically handled.
Some commercial fishing activities have a potential to take large quantities of fish from aggregations in a very short time, because there are no daily catch limits.
License conditions and areas which can be fished must use the precautionary principle and best available data to ensure that commercial fishing activities are managed for sustainability and equity, which may require the use of tools such as daily catch limits, closed seasons or closed areas for some species.
5. Unused catch.
Commercial fishing interests must use practices that guarantee the condition of their fish until delivered to their processor or reseller. Commercial fishing must take only the catch that can be processed and transported and for which a known and acceptable market exists.
All fish killed as a result of attempts to catch them must be counted in the total allowable quota. If commercial fishers can not sell the catch, they should not catch it.
Any fish caught and then dumped for any reason other than a small allowance for things which are out of their control, should be counted as twice that amount towards that license's catch quota, as a penalty for the waste of a community resource. It should also count as twice that amount towards the total quota caught.
6. Food fish only species.
Species of great importance for food should be declared "food only" species, where only a small amount may be used for non food purposes.
The species to be declared, and the non food amount allowed should be negotiated by Department of Fisheries and Peak bodies and supported by appropriate data.
7. Human consumption.
An argument often put forward in support of commercial fishing is that this provides the fish for consumption by the general Western Australian public who can not or do not wish to catch their own fish. We accept that this is a legitimate use of the community resource.
However, we do not accept this argument when it is used in support of any significant exploitation of any species which is (1) important to any other part of the Western Australian community, or (2) important to the environment or the marine food chain, if those fish are to be exported outside of Western Australia, because those consumers are not the owners of the resource.
As a guiding principle, we believe all edible fish taken by commercial fishing must be used for human consumption. There must not be any captures just to harvest parts of fish, eg fish roe, shark fins, etc. Marketing these parts is acceptable if all of the rest of the edible part of the fish is used for human consumption.
These conditions must be part of the license, sale and processing conditions. The conditions may include some concessions which allow a percentage of edible fish to be used for other than human consumption. These must be explicitly listed for each species, as set by sustainability issues and equity issues and as negotiated by Department of Fisheries and Peak bodies and supported by appropriate data.
All these conditions must apply as well to all the processors who buy the fish. It must not be possible for the commercial fisher or the Department of Fisheries to say "it's out of our hands once we deliver it to the processors."
8. Non human consumption.
There may be pressure to catch fish for other purposes, bait in particular, fish food, and for pet food and fertiliser.
Catches of edible fish for these low value or non-human consumption uses must be counted and managed as part of the conditions or concessions.
Offcuts, head, backbones, offal etc, can be used for what ever commercial purpose is available. "Recycling" of wasted fish and fish pieces for these purposes should be undertaken at the earliest possible time. Fish wastes are available from primary and secondary fish processors. There must be opportunities to develop other non fish based rock lobster bait and fish food.
The rock lobster fishing industry and aquaculture industries should investigate the use of alternative baits and foods so that the catch of wild fish for bait or fish food is minimised or phased out in as short a time as possible.
The catch for non human consumption must be only that portion which is in excess of recreational and human consumption needs. The catch must still be ecologically sustainable and any growth in recreational and human consumption needs must be at the expense of non human requirements.
9. Where and when commercial fishers can fish.
Commercial fishermen are harvesting a community owned resource, and are sharing it with the recreational fishing community. This sometimes leads to overlaps or conflicts in time or locations.
Some commercial fishermen use high technology equipment and are able to operate in areas away from the areas used by the majority of recreational anglers. Other commercial fishing from beaches, estuaries or for inshore species is more visible and can lead to issues with the community.
Some existing license conditions, agreements or formal or informal "codes of conduct" cover some of these potential interactions by setting the timing, location and conduct of commercial fishing activities.
The principle of negotiating and publicising such license conditions, agreements or codes of conduct to minimise any possible conflicts and ensure public awareness should continue and should be extended to all areas of real or potential conflicts.
Agreements should be negotiated with the local community, or with Department of Fisheries and the commercial and recreational peak bodies as appropriate.
In special cases, these could negotiate "recreational fishing only areas" in some areas close to high populations or of very special attraction to recreational anglers.
As a general principle, we accept commercial fishing should be possible at all times to suit the commercial fisher's needs and the availability of fish. However the agreements should recognise, if not already included, high recreational use times such as Christmas, Easter, Anzac Day and some long weekends, and must place limits on some types and locations of commercial fishing which could have a large impact on the success of recreational fishing at these times.
Real or potential bycatch from some commercial fishing activities is of great concern because of the impact on fish stocks, the marine food chain, and on some species of great value to recreational anglers.
Bycatch must be managed and must be a critical part of the decisions on where and when to allow commercial fishing, and what methods may be used.
An example is the claim by WAFIC in 1991 that it is virtually impossible to avoid catching tailor, saying that tailor school with mullet, bream and sometimes with whiting, and sometimes there can be a 30-40% mix of species.
11. Recreational only species.
Species of great importance to recreational fishing, and of limited value to commercial fishing should be declared "recreational only" species, where only a small amount of bycatch may be retained by commercial fishers.
The species to be declared should be negotiated by Department of Fisheries and Peak bodies and supported by appropriate data.
Species for early assessment and decision should include tailor and mulloway.
12. Impact on the environment.
Real or potential impact on the environment from some commercial fishing activities is of great concern for some types of equipment used for the reasons above.
Impact on the environment must be managed and must be a critical part of the decisions on where and when to allow commercial fishing, and what methods may be used.
13. Impact on the marine food chain.
The extent of some commercial fishing activities are of great concern because of the impact on the marine food chain, and the flow on effect on some species of great value to recreational anglers.
The impact on the marine food chain must be managed and must be a critical part of the decisions on where and when to allow commercial fishing, and what methods may be used.
14. Catch data in the "State of Fisheries Report".
The latest State of the Fisheries Report 2001-2002 on the Department of Fisheries website is for catches made in 2000/2001 or during "the 2001 season". As such, the data is at least 2 years old, if not considerably older, and does not show the significant changes in commercial catches over the last two years which have been of great concern to recreational anglers.
Up to date catch data must be available to the public. At the very least, this requires that the next State of the Fisheries Report must cover two years to catch up, and then progressive data must be published so that the public can be aware of trends as they occur.
Thank you for the opportunity to comment.
Secretary, Australian Anglers Association (WA Division) Inc.
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This page last updated 13 November 2003.