Archived page, Submission Mandurah Estuarine Interim Management Arrangements

Submitted 12 Dec 2002

General

While Recfishwest understands the rationale for administrative changes to the fishery, and has provided comment on a number of specific issues, our principal issues of concern are that there must be no commercial fishing effort increases or resource sharing conflicts created as a consequence.

We note that this is also the position of the Department of Fisheries.

Therefore to ensure that this does not occur, or can be appropriately remedied should it occur, we recommend that there be a formal requirement that the fishing practices and catch levels are assessed annually, for at least the first three years following implementation of management changes. If effort increases or resource-sharing conflicts do occur, then a review of the fishery management arrangements must take place.

Recfishwest believes this to be essential given the importance of the Mandurah estuary system to the Western Australian community and the recreational fishing sector in particular.

Specific Comments

Gear Usage

a) The proposal that a maximum combined length of 1000m of haul net and set net to be used at any one time is supported. However the proposal is silent on the permitted maximum length of haul net.

It is Recfishwest's position that the current 500m maximum permitted length for haul nets in this fishery should be maintained.

Crab Pot Entitlements

Recfishwest endorses the position of the Department of Fisheries that it would not support any application for crab pots by the two operators in the fishery who have not fished for crabs for several years.

We note that another fisherman has been permitted to take crabs in Comet Bay (outside the boundaries of the Mandurah Estuarine Fishery) and may become endorsed to do so following completion of the review of the Comet Bay Crab Fishery. If this fisherman is successful in gaining access to the Comet Bay Crab Fishery then we support the recommendation that he must not be allocated any crab pots entitlements for the Mandurah Estuarine Fishery.

Crab Bycatch

Recfishwest supports the proposal that, to effect the move to a crab pot fishery, licence holders must not use set nets, haul nets, scoop nets, drop nets or beam tide trawl nets to catch crabs.

However it is of concern that the Fisheries Department has simply acknowledged that there may be a small by-catch of crabs taken occasionally in these nets. This passive approach does not address the prospect that crabs may be targeted using nets, with the catch being recorded as bycatch.

To overcome this prospect we recommend that all live crabs, caught by gear other than crab pots, must be returned to the water. We believe it should be deemed an offence, for an operator who is not fishing with crab pots, to be in possession of live crabs.

Effort Levels

We note the proposal that 3000 gear based fishing days should be deemed to be the appropriate effort level for the fishery. While Recfishwest does not specifically oppose this proposal we have not been provided with the information necessary to make an informed assessment of whether it is an appropriate level.

Recfishwest does not dispute that the proposed 3000 gear based fishing days reflects the current total fishing effort. However we believe that this effort level may not be deemed appropriate or optimal if a social and economic assessment of the fishery were undertaken.

Recfishwest recommends that there must be pre-determined actions established that must be triggered should the effort levels in the fishery exceed 3000 gear based fishing days.

Fishing Units

Recfishwest does not support the proposal that a fishing unit comprise 1 main vessel and two dinghies, all of which are up to 6.5m in length. While we do not believe that 3 large vessels are necessary for the estuarine fishing operations, our principal concern is that the use of a greater number of larger vessels will inflame resource-sharing conflicts. As already mentioned, this is something that the Department of Fisheries has stated that it would like to ensure did not happen.

Recfishwest first preference is that a unit be comprised of a main vessel and one dinghy (both being less than 6.5m). If this is not supported then our second preference, if the fishery remains as an owner-operator fishery, is that a unit be comprised of a main vessel (being less than 6.5m) and a maximum of two associated dinghies (being less than 5.5m).

Owner Operator provision

The proposal that the fishery remain an owner operator fishery is supported. However we are uncomfortable with the suggestion that this may only remain in place until a management plan is introduced.

Recfishwest considers that an owner operator provision is an important element in the management of estuarine fisheries in which there are resource-sharing tensions. We firmly believe that it should be a permanent feature of the eventual management plan.

We point out that in its justification for a 3 vessel fishing unit the Department of Fisheries has stated 'As the fishery will be an owner-operated fishery, the number of boats in a fishing unit is immaterial as only the owner-operator may use them.' Noting this argument, and if there is any intention to revoke the owner operator provision in this fishery then the Recfishwest position in respect to fishing units would be firmly that they be comprised of one main vessel and one dinghy.

Dinghies/FBLs

Recfishwest fully supports the requirement that each of the boats comprising a fishing unit, if being used at the same time, must operate as an integrated fishing unit. (ie. the boats must be working together in the same fishing operation under the direct control of the holder of the licence)

Recfishwest endorses the proposal that dighies/FBL's must be purchased on the open market.

Enforcement

The conversion from nets to pots for taking crabs has been seen as a beneficial move by Recfishwest. However the longline technique to set and retrieve pots has intrinsic difficulties with respect to enforcement of pot numbers. A string of pots is only marked at the beginning and end and the number of pots being used at any time can only be verified when they are set or pulled. To overcome this concern we believe it essential that the frequency of checks undertaken by Fisheries Inspectors must be increased to ensure compliance.



This page last updated on 30 December 2003.