Archived page, Submission on "Draft Plan of Management for the Cottesloe Reef Proposed Fish Habitat Protection Area", Fisheries Management Paper No. 150

INTRODUCTION

Recfishwest wishes to thank Fisheries WA for the opportunity to submit comment on the Fisheries Management Paper No. 150 "Draft Plan of Management for the Cottesloe Reef Proposed Fish Habitat Protection Area".

Recfishwest wishes to make very clear in this submission that it has a number of strong general objections to the Fish Habitat Protection Area (FHPA) process. These objections have already been forwarded to Fisheries WA directly and also outlined in our preliminary comments on the Cottesloe Reef FHPA initial draft plan. The crux of this objection is that it is inappropriate to use the provisions of the Fish Resources Management Act to establish a community marine reserve that has no special significance to fish resources at all.

However, Recfishwest wishes to make it clear that it supports the objectives of the local community group in trying to preserve the natural ecosystem of the Cottesloe reef area as far as possible despite the heavy human use.

Recfishwest is also pleased to see the recognition in the current draft plan that the recreational angling which is carried out in the Cottesloe reef area is not considered to be incompatible with the overall objectives of the plan.

GENERAL COMMENT

Having thoroughly considered the draft plan Recfishwest remains unaware of any special characteristic within the Cottesloe reef area that makes it important as a fish habitat. In describing the values of the area the draft plan recognises that the area contains no unique natural features. Indeed from a variety of criteria, the Cottesloe reef system is one of the least unique systems in Western Australia.

Along the entire Mid West and Lower West Coast from Geraldton to Fremantle the coast consists of a repeating succession of sandy beaches, sunken reefs and surface platform reefs. Recfishwest believes that if it was important to preserve more of this ecosystem in areas additional to Marmion Marine Park and Jurien Bay, there are plenty of places that do not have the complication of heavy human use.

The draft plan points out that the Cottesloe reef system is notable because it is close to a densely populated urban area and within close proximity to the shore. This may justify giving it special management so that different human activities do not conflict with each other but the FHPA system is intended to look after fish rather than people.

Fisheries WA is facing intense financial pressure in endeavouring to improve fisheries management through Integrated Fish Resource Management, ensuring sustainable development of fisheries and at the same time facing budget cuts. It does not seem appropriate that it should be diverting funds to manage human recreational use of metropolitan marine areas.

SPECIFIC ISSUES IN THE PLAN

Unsubstantiated Assertions and Recommendations.

Recfishwest is extremely disappointed with the quality of the Management Paper. It contains numerous unsupported or unsubstantiated statements, claims and recommendations. Consequently, and unfortunately, the paper reads like a hearsay document. Some examples of this include the following:

"The value of the Cottesloe reef system to Aboriginal people is significant." (Section 5.2.2 p8)

"Damage from boat anchors is also considered to present a threat to the integrity of the reef..." (Section 6.1 p9)

"Nutrient-rich storm water....is thought to contribute to seasonal algal blooms." (Section 6.3 p10)

The recommendation to "Prohibit shark fishing by any means." (Section 7.2.1 p12)

The significant extent to which the document relies upon unsupported or unsubstantiated statements, claims and recommendations is unacceptable and inappropriate for a Fisheries Management Paper.

Boat Anchoring and Mooring.

The Plan recommends the prohibition of anchoring of boats because of possible damage. Although few boats do anchor in the area, there would be no harm at all from boats anchoring in sand areas. Further there is no evidence presented that boats anchoring on the Cottesloe reef are doing any damage.

In this respect we note that in the Abrolhos Islands FHPA, and in particular its reef observation areas, lobster potting is not prohibited. The impact of commercial lobster pots lifted and dropped daily on the fragile coral communities of the Abrolhos Islands is likely to be much greater than the infrequent boat anchoring on the limestone reef in the high energy Cottesloe reefs area.

Indeed the management strategy adopted in 1994 for the Abrolhos Islands FHPA was limited to first determining whether any action was necessary by evaluating the impacts of potting and reef damage over time.

We object to the inconsistent approach used between the Abrolhos Islands FHPA and the Cottesloe Reef FHPA and, in the absence of compelling supporting data, we therefore oppose the overall prohibition on anchoring in the area.

We note the recommendation to install moorings in the area and we recommend that Fisheries WA carefully consider all aspects before pursuing this course of action.

Recfishwest has corresponded under separate cover with the Fish Habitat Protection Program on the topic of installing environmentally sensitive public boat moorings in the Cottesloe reef area.

Promotion of Tourism.

Recfishwest consider it surprising that the draft plan actively promotes that the area be increasingly used for commercial eco-tourism activity. The Cottesloe reef area is already heavily used by the public and some of the recommendations in the plan are directed towards reducing conflict between users. Educating existing users about the ecosystem will help to preserve the reefs. Introducing new commercial activities can only increase human pressure on the area.

CONCLUSION

Although Recfishwest commends the objectives of the Cottesloe Marine Protection Group it believes that it is inappropriate to use the provisions of the Fish Resources Management Act to establish a community marine reserve that has no special significance to fish resources at all.



This page last updated on 30 December 2003.