Archived page, Submission to the Tour Operator's Fishing Working Group on their discussion paper:-"Future Management of the Aquatic Charter Industry in Western Australia"

Introduction It is unfortunate that the WA Recreational and Sportfishing Council (Inc.), now entitled Recfishwest, was not consulted by the working group during the preparation of the discussion paper, however we are interested in being included in any further discussions on this activity.

We were surprised to see that the "benchmark date" for entry into the industry had been extended to September 12. As a general principle, giving additional opportunities to potential participants who have not previously made an investment in an industry is unfair to established operators and is likely to increase future difficulties with regulating impact and "buyback" costs.

We found the discussion paper a valuable canvassing of the issues. There appears to be a much greater concentration of attention on activities that include catching fish. This may properly reflect the emphasis in the industry; but it may have lead to specific needs of non-consumptive tours being overlooked.

Although the information collected from the industry is interesting, the compilation in Appendix C was not particularly clear (particularly pages 45-6). Further comments are made below on the recommendations by sections.

WA Aquatic charter industry

Recs. 1 and 2 Although the principle of integrated management is supported, it is not clear what outcome is sought. It is not likely or particularly desirable that specific arrangements by CALM could be amalgamated completely. It would be useful if Transport and Fisheries could delegate to one licensing authority. There is a need for Transport to review survey requirements for small charter boats.

Conservation and sustainability issues

Recs 3-4 In considering resource allocation issues, some consideration needs to be given to the situation of fishing clubs. A charter operation could be made to look like a fishing club, or vice versa, if there were any advantage in doing so.

Rec. 5 The recommendation, "......to maintain the catch from charter operators at sustainable levels", does not seem to adequately reflect the intention of the discussion paper. For example, the paragraph on the bottom of page 7 makes a number of suggestions such as changing recreational bag limits and gear or catch restrictions in specific areas. These arrangements are evidently not proposed to sustain fish populations generally; but rather to sustain the quality of charter fishing. Equitable resource allocation is supported; but such special arrangements would have to be negotiated with other sectors.

Rec. 9 How is resource allocation to be managed for non-consumptive charter activities, ie class b). Diving tours for viewing only are already important and likely to grow. Their needs do not seem to have been specifically addressed. Are they, in fact, less environmentally demanding and therefore should they have easier access to the industry? Should there be a way of providing minimum distances between such charters and others?

Rec. 13 This recommendation, "where there is likelihood of over-exploitation....minimum performance criteria should be developed for continuing eligibility..", is not clear as it stands. Read in context on page 12, it appears to be an attempt to eradicate latent effort by imposing minimum performance criteria for eligibility; but if there is over-exploitation how will it
help to say "unless you fish more often you will lose your license".

Rec. 22 This recommendation implies that there will be an assessment of the applications and a part of this assessment will include consideration of existing fishing effort in the area. This is strongly supported. Recfishwest believes it should be involved in this part of the process to recognise and allow for existing fishing effort.

Rec. 24 We are strongly opposed to any arrangements which may allow part-time operators or late applicants (using the September 12 deadline) to turn non-participation into a capital asset via a premium for licenses. Perhaps the Queensland system described in Appendix A is one way of avoiding this by issuing licenses for a limited period. We are concerned that reduction in licenses by a "buy-back" scheme is so quickly raised as an answer to localised stock depletion. Surely management strategies would be the initial reaction to reduce effort. If a "buy-back" scheme were adopted it should be clearly funded by the remaining participants and not a drain on other funds.

Economic Issues

Recs 29-32 The "user-pays" intention of these recommendations is supported. However, it is quite impossible that the survey and data collection for stocks of all fish used by charter fishing operators in WA could be funded by $50 000 per year. Presumably this allows for handling the data generated by the operators but this would not be good enough. For one thing, no one is going to fish where they don't catch any longer. No solution is proposed but the inadequacy must be recognised.

Environmental issues

Rec. 33 This recommendation gives no suggestion at all as to how environmental impact on fish and other resources is to be predicted in making access arrangements. This is another reason why long term tradeable licenses should not be issued. There may be a need to reduce unexpected impacts by changing access arrangements.

Social issues

Rec. 40 Although it is right that the aquatic charter industry should have representation on appropriate bodies, it should be clearly recognised that it is just a small special part of the very large recreational fishing activity.



This page last updated on 29 January 2004.