Archived page, Recfishwest comments on the Premier & Cabinet Discussion Paper:
Bioregional Marine Planning in Western Australia

Introduction
Recfishwest congratulates the Government on commencing this important initiative. We believe bioregional marine planning is now needed before any further spatial allocations are determined for Western Australia's coastal waters.

Recfishwest represents the interests of the estimated 643,000 recreational fishers in Western Australia. Many recreational fishers feel extremely uncomfortable about the marine conservation processes used to date and the disproportionate impact on recreational fishing interests without adequate engagement of the sector or an objective assessment of the impact.

Recreational fisheries management, coupled with changing community attitudes has made enormous strides in implementing a more conservative approach to aquatic natural resource management. Indeed, recreational fishers have instigated seasonal closures for pink snapper in the metropolitan region and total protection for species such as the hump-headed Maori wrasse.

However, the paper as presented does not recognise any current fisheries management and the role it might play in helping to protect biodiversity in the wider environment. Rather anglers are concerned about an agenda that seems to be just trying to lock up the best fishing spots.

Recfishwest has some specific comments on the process suggested in the framework paper and these are set out below using the headings of that paper.

Part 1
Introduction

In this section the objectives are set out on the first page as a series of 10 dot points. It is suggested that although all the objectives are valid, it would be better to group them and set them out in a logical sequence so that from the very beginning this logical progression is made clear. A possible re-ordering is set out below with the place in the existing list noted at the end of each item.

Description

1. Set out what is currently known (2nd dot point).

2. If necessary note further requirements for biological inventory and environmental baseline studies (4th dot point).

Objectives

3. Identify the objectives in terms of abundance, sustainability, water quality etc. to meet the community's objectives for their values in these marine regions (part of 5th dot point).

4. Identify the threats which currently or could potentially exist and which could prevent the meeting of these objectives (part of 3rd dot point).

Management responses

5. Determine the management responses needed to meet the threats to the attainment of objectives (part of 3rd dot point and 8th).

6. Put in place a system for monitoring, reporting and performance assessment including the need for areas of no/minimum disturbance as reference areas (part of 5th dot point).

Planning multiple use

7. Identify community interests eg. industrial, indigenous, recreational, resource developmental (6th, 7th and 10th dot points).

8. Put in place a plan which minimises conflict as far as possible and where necessary identifies priorities (1st,9th and 10th dot points).

The perceived advantage of this grouping and re-ordering is that it clearly separates the description, the objectives, the management strategies and the actual planning. This order approximately represents the chronological sequence which needs to be followed. Planning for the sea along the metropolitan coast started with the Southern Metropolitan Coastal Waters Study and the Perth Coastal Waters Study and then CSIRO undertook a community consultation exercise for the EPA which led to the EPA's Perth Coastal Waters - Environmental Values and Objectives. This led to a draft Environmental Protection Policy and Interim Management Plan for Cockburn Sound.

The grouping and order also helps to identify the two stages at which community input is most important. These are firstly the values and objectives and secondly the planning for multiple use. The first stage of description of the area is clearly a task for experts and the preparation of management responses is similarly mainly an expert task.

The comments on page 4 relating to scale and the difficulty of many in understanding the process is unnecessarily insulting. While bioregional planning is important, it will also result in a number of local debates over particular issues or habitats. What is crucial and poorly defined in the paper is the relationship between the strategic bioregional planning issues and the local application of those principles.

One of the reasons why informed recreational fishers no longer trust the MPRA and CALM process is that the insistence on only local involvement does not allow for an objective assessment of the planning process against a State wide planning framework. The definition of community ownership of the process is not clearly defined and will be interpreted by some as being only those locals who support a protectionist philosophy. Recfishwest believes, in the case of the Cape to Capes region where the majority of those using the area are non-locals, consultation must include wider State interests.

If this document is intended to provide the strategic direction for bioregional planning and its application at the more local level, it has a long way to go.

The paper states "All government agencies and each organisation involved in developing the plan would be responsible for its implementation and sectoral processes would be required to operate within the framework of the plan."

Recfishwest contends that a lack of cooperation, duplication and political manoeuvring between departments has resulted in the current unsatisfactory situation where fisheries and community management are often confused or manipulated to suit circumstance. The paper needs to be more prescriptive about the roles and responsibilities of these currently competing departments under the new arrangements. A cooperative committee is important, but the operation of bioregional management in a government context needs to be clearly defined.

Otherwise, Recfishwest will continue to work through and advocate for the government's Integrated Fisheries Management framework as the primary aquatic natural resource management mechanism as it is more likely to deliver an equitable outcome for recreational fishers and the proper management of Western Australia's fisheries resources.

The Policy Framework

Although it is valuable to have the list of international obligations and the various conference agreements that have been reached it should not mean that this is an important driver of the process. Australia has a comparatively good record in terms of its marine management.

At a recent international conference in Cairns on marine protected areas, theme speakers identified Australia as leading the world in terms of marine protected areas. In addition, most speakers agreed that meeting international obligations was by far the weakest reason to pursue a marine conservation agenda with the Australian public. This conference, which had a significant fisheries focus is not referred to in the discussion paper, while the Durban conference which had little stakeholder involvement, is accepted as dogma from first principles.

In contrast to Australia's poor performance on issues such as greenhouse gases, other countries are more likely to be trying to catch up with us in Western Australia in respect to marine management; particularly for fisheries. This was also clearly enunciated at the Cairns conference.

Recfishwest strongly objects to the 6th and 7th paragraphs on page 7. In face to face meetings with the Premier and other senior Ministers, we have been assured that 'targets' evoke an emotive response and are not constructive. Further, to assert that the government supports targets, without giving them, causes great concern as a large number could be inserted with the assertion that 'targets' were supported through this consultative process.

Scientific opinion on targets for marine conservation sanctuary zones needed to optimise fishery or biodiversity management varies from zero to ca.75% depending on the fishing intensity and the existence of other fishery management measures. The frequently quoted Californian scientific congress which supported massive sanctuary zones was based largely upon American examples where limited entry commercial fisheries and restrictive recreational fisheries management is not in place. In Western Australia, there are very few stocks which are over-exploited, a fact which is not acknowledged at all.

Indeed, where stocks have been identified as being over-exploited, drastic remedial action has been taken, as with Shark Bay snapper. Recfishwest finds it very unfair and misleading that conservation organisations such as CALM point to the Shark Bay inner gulf snapper situation as indicative of the need for third party conservation intervention in fisheries management. What is never portrayed is the fact that recreational fishers were actively lobbying for action for several years prior to the closure but this was politically unacceptable. Importantly, once the situation was enunciated, recreational fishers and particularly Recfishwest were strong public supporters for the closure which has successfully allowed the stocks to rebuild, especially in the eastern Gulf. In addition, it was Recfishwest which initiated the precautionary seasonal closure to protect spawning pink snapper in Cockburn Sound.

It is this continual tainting of information relating to recreational fisheries management and an attempt to suggest that recreational fishers are not sufficiently responsible to manage the resource of this state which we find offensive and groundless. This paper does nothing to put the current fisheries resource management philosophy and initiative into context. The continual demonising of recreational fishers in the biodiversity conservation debates (or at the very least failing to recognise positive initiatives) will have severe political ramifications if current biases and failure to engage the sector are not fundamentally addressed.

Bioregional planning and marine conservation planning is not an issue in terms of absolute biodiversity or species extinction. Indeed, a risk assessment approach would determine that fishing is not a major threat in most cases to biodiversity conservation yet it is singled out for restrictive management controls through the process. On the other hand Recfishwest recognises that there are essential reasons for some MPAs for research monitoring etc.

The conclusion in the last paragraph of page 7 is valid, but there is no attempt to present the contrary case where smaller areas of sanctuary zone could similarly be justified where there is high quality management of the marine resources. It is again this lack of balance which causes recreational fishers great concern about this and related processes.

Part 2

Proposed trial of bioregional planning on the south coast.

The proposed trial appears to try to jump too far ahead by expecting a regional resource management group to start developing management strategies and a marine plan on the South Coast before the Western Australian community has been consulted on values and objectives for marine management. Even the natural resource information for the South Coast has not yet been made available to community stakeholders and this takes time to study and consider.

All of the major stakeholder groups represented at the meeting on May 21 emphasised that the proposed timelines for the process were quite unrealistic. Even active peak bodies usually meet no more frequently than monthly so it can take up to seven weeks for any significant issues to be given proper consideration, depending on the timing of the meetings in relation to first notice. Once an issue is on the agenda, turn-around can usually be expected in a month.

Major stakeholder groups also complained about lack of adequate representation if consultation is done solely through regional committees. It may be that the nature of natural resource management funding by the Australian Government motivates such an approach but stakeholder groups representing large sectors of the population are very concerned. The recent MPRA planning day held at Perth Zoo indicated that these concerns are wide ranging, yet we see an almost identical consultative process which was seen as inadequate being proposed within this over-arching policy document.

The comparatively small population of Western Australia's regional areas means that it is often difficult for stakeholders to identify suitable representatives for community consultation groups who live in the region. In addition the major users for such regions may be from other parts of the State. The Gascoyne recreational fishing review found that 90% of the fishers came from outside the region. Most came from metropolitan Perth.

Recent CALM Marine Park advisory committees for Ningaloo and the Cape to Cape proposed reserve have highlighted this problem by deliberately excluding representatives from peak stakeholder bodies. This places an unfair responsibility on regional representatives of those interests and severs the link between strategic and operational management.

Recfishwest has consistently criticised the stakeholder reference group model of CALM as patronising and inadequate. To place the sole responsibility for stakeholder consultation on volunteer groups while intra-governmental consultation is fully funded is irresponsible. Recfishwest has expended vast amounts of its extremely limited resources attempting to keep from being actively victimised by a CALM dominated process which seeks to attribute the threats to marine biodiversity conservation almost wholly with recreational fishers. If the government is committed to community engagement and ownership of the process and the outcomes (see the Premier's document on Consulting Citizens for guidance), then this integral part of the process must be funded.

The community is cynical that there are sufficient resources for glossy brochures with seals and whales, but none for community engagement. At the recent Cape to Capes planning process, representatives from CALM, Department of Fisheries, Water Corporation, Tourism Commission, Department of Environment, DPI, and local government were all funded through various sources to attend meetings. Recfishwest, WAFIC, Rock Lobster Council, Abalone industry and Conservation Council were not resourced and found it difficult to allocate enough time and resources to the process. However, a failure to participate would see agreement that was detrimental to our sectors implemented without formal reference.

The processes proposed are almost exclusively government driven with token or no community engagement and certainly no representation relative to impact from the proposed bioregional plan.

Recfishwest suggests that the first four steps proposed are fundamentally flawed and almost certainly unable to give an equitable outcome and broad community support.

Recfishwest has consistently suggested that there is an urgent need to establish a peak body reference group (as part of step 1) to provide a useful strategic perspectives on regional and local issues rather than rushing into implementing a regional plan in the absence of an agreed framework.

Additionally, all committees must have significant representation from those who will be impacted upon through the planning process and not just those who will benefit as has been the case in Ningaloo.

Recfishwest is cynical about the application of step 2 c on page 11. In the past, recreational fishing interests have been significantly under-represented or a conservationist who rarely fishes (and is clearly primarily motivated against fishing) has been put forward as a representative of recreational fishing interests. Someone who fishes occasionally is very, very different to someone who sees themselves as being able to represent or put forward a recreational fishing perspective.

In the Cape to Cape process, even though recreational and commercial fishing are being held accountable for biodiversity conservation, sector representatives constitute a small minority on the committee and are being consistently outvoted as proposals are seemingly being rammed through. This cannot result in a strong consensus position.

These committees continue to be manipulated by CALM; both through their selection and the administration such as ensuring almost all presentations are from CALM or 'lock-out' supporters.

Establishing a marine conservation reference group appears (step 4) to be an obvious duplication and could be interpreted as the establishment of a quango group to deflect criticism from community groups.

Page 13 proclaims "Innovative decision making tools are now available to assist in the integration of the various sectoral approaches .." Recfishwest has seen no evidence in the existing processes or in those being proposed to be replicated through the paper to support this view. The 'innovative decision making' appears to be in finding new ways to interpret submissions to make it appear that there is majority support for proposals developed by a select few.

The existing processes are totally unable to reconcile the weight of a submission from a group like Recfishwest which represents 643,000 anglers against two individual submissions that support the proposals. The paper must address this difficulty and provide an equitable solution or all proposals will have to be fought as a numbers campaign by those who stand to lose the most.

Page 13 describes the three main components for the bioregional plan and then lists four points. Thus far, Recfishwest has seen no commitment to, or resourcing for the final two points. What Recfishwest has seen in the MPRA/CALM marine reserves process is that there is a mad rush to implement the next marine park without attempting to properly monitor the existing marine reserves or determine what made the most recent one work, or not, and why.

There has been next to no research at Ningaloo, yet we are being asked to accept major further restrictions on the same 'precautionary' approach as 10 years ago. This is no longer acceptable to a community which demands meaningful consultation and courtesy, consistency and equity in marine park planning processes.

Already, many middle Australians who quite clearly philosophically support the principle of Marine Park and biodiversity planning are being lost through process failures. Unless bioregional marine planning addresses these concerns and provides a clear path forward for all constituents, it cannot possibly work.

Recfishwest does not expect to win all the time, or even the majority of the time. However, when we take considerable time to prepare a considered submission which proposes reasonable alternatives which do not compromise biodiversity objectives, we expect a process by which those proposals can be objectively assessed and a reasoned and responsible response is provided.

It is the clear view of Recfishwest that this fundamental issue must be addressed if we are to have a fair and effective bioregional marine planning process with strong community support.



This page last updated on July 2004.