Archived page, Submission to the Second Round of Consultation for the Mackerel Fishery (Interim) Management Plan

Submitted the Department of Fisheries 20th December 2001

The Fisheries WA update of 6th March 2001 and invitation to provide further comment suggests that comment should be limited to the relative merits and disadvantages of the two management options developed as a consequence of the submissions to the original proposed management plan which was released for comment in October 2000. However Dr Lindsay Joll informed attendees at a meeting held in Fremantle on 26 March 2001 that the original proposed management plan remained an option for consideration. As such our comments are based upon all 3 options for management.

Recfishwest is disappointed that there appears to have been little consideration of our initial submission in the development of further proposals, some of which run counter to the principles espoused by Fisheries WA in the original proposals.

Our comments and position follow.

1. Recfishwest strongly opposes the proposal to leave the area south of the Shark Bay Snapper Fishery as an open access fishery for mackerel.

In part Fisheries WA have justified this proposal on the basis that the area will be brought under management when the Integrated Fisheries Management Strategy (IFMS) process is finalised.

However the nature of the outcomes of the IFMS process are not yet known and unlikely to be finalised in the short term. It is Recfishwest's understanding that the IFMS process is addressing broad management principles only and not management outcomes for specific fisheries.

As such Recfishwest consider this to be an excuse for the deferral of a contentious issue that, properly, should be addressed as part of a total package of management.

Fisheries WA's principal rationale for the proposal is that the area south of Shark Bay is at the southern range of the fishery, and has relatively low levels of commercial mackerel fishing and catches.

Recfishwest believes it to be illogical to suggest that management and effort reduction is essential in areas where the species are in greater abundance and yet not necessary in areas where the species is low abundance. A similar incongruity has finally been addressed with restrictive commercial fisheries controls for barramundi in the Pilbara region.

Recfishwest believes that if management is to be introduced for a species or fishery it must be on the basis of managing the whole of the fishery and not just a part of it. Recfishwest therefore strongly opposes this proposal.

A more responsible rationale and one accepted in the barramundi fishery, which was part of our previous position, is that mackerel be managed as a commercially protected species with applicable bycatch limits in the southern part of the fishery.

Having considered the summary of submissions to the original proposed management plan and associated catch data we believe that there is a strong case to extend our earlier proposal.

2. It is the position of Recfishwest that in waters south of Shark Bay (Carnarvon) mackerel should be managed as a commercially protected species with all commercial fishing operations restricted to the bycatch limits proposed within the covering letter circulated with the original draft plan (ie. a daily boat limit of two and a possession limit of twice the daily bag limit.)

The basis for this position is unchanged from our previous submission.

3. Recfishwest maintains its strong support for the original proposed management plan (ie. the option released for comment in October 2000) appropriately amended to include point 2 above.

However should the management decision become a choice between the new options 1 and 2, the Recfishwest preference is clearly in favour of the new option 1.

This preference is principally due to the knife-edge access, limited entry model of the option. The option 1 entry criteria would result in fewer licences, with each being more economically viable and able to adapt to long-term management of Spanish mackerel stocks.

Option 2, which relies upon the implementation of a complex and expensive management and monitoring system seems to be driven by a perception in fisheries management that the stocks which had been advocated as seriously under threat, can accommodate significant latent effort formalised in a mackerel fishery. Recfishwest cannot accept this option.

We trust that this second round submission will be given more appropriate consideration.



This page last updated on 30 December 2003.