Archived page, Submission Principles for Resource Sharing under Integrated Fisheries Management

Introduction

Recfishwest welcomes the integrated fisheries management initiative outlined in Fisheries Management Paper no. 135. It has consistently advocated a holistic approach to fisheries management. However, the historical approach to fisheries management in Australia has concentrated largely on the management and control of commercial fishing operations. In many instances, 100% of the estimated available resource was allocated to commercial fishing interests. In some cases, such as pearl oyster and northern prawn fisheries, this was appropriate and is unlikely to be challenged today.

In many fisheries there has been a significant recreational fishing component that was not explicitly acknowledged or accounted for in fisheries management decision making. The net result of this approach has frequently created inequities which need to be addressed and in the worst case ensured the over-exploitation of the resource through unaccounted for recreational fishing effort.

An integrated management approach is therefore extremely important in order to address these historical inequities and to ensure that a holistic approach to management will ensure that all sectors together do not over exploit the resource. The need for the application of such an approach is particularly appropriate for the commercial wetline (open access) fishery, which largely overlaps the principal recreational target species.

The vast majority of Western Australian recreational fishers target wetfish (also referred to as scalefish or finfish) as part of a recreational fishery estimated to have over 620,000 participants per annum and generating around $550 million in economic activity. In contrast, the commercial fishing industry in Western Australia concentrates mainly on invertebrate fisheries and only around $10 million is generated through commercial wetfish fishing efforts. Although perhaps an oversimplification, it is immediately apparent that the maximum community return for wetfish stocks lies in the recreational exploitation of these fisheries.

Integrated management makes the need for resource sharing more apparent. Recfishwest has prepared this paper as a submission directed towards the principles which it believes should apply to all the fisheries resource sharing processes.

While recreational fishers are significant stakeholders in the fisheries resource, they are not the only group which needs to be considered. Other stakeholders in the fisheries resource of Western Australia include commercial fishers, environmental needs and indigenous fishers.

Recfishwest believes that there is a need to closely examine the principles which should underlie such resource sharing processes. In the recent past there have been a number of resource sharing negotiations undertaken on a case by case basis, such as Cockburn Sound crabs and the South Coast estuaries. In the absence of an overall framework, such as should be an outcome of an integrated management process, Recfishwest believes that the outcomes of past negotiations were somewhat inequitable.

Previous negotiations were based on an assumption that the recreational fishing sector was responsible for any conflict and/or over exploitation and that they and the community should be responsible for any direct compensation or management accommodations. This resulted in a domination by the interests of commercial fishers and paid insufficient attention to the sustainability of the resource under pressure from increasing community demands for recreational fishing.

Recfishwest has prepared this submission to deal with the broad principles that we believe should apply to a change to integrated management. We reiterate that we support such a change. We have previously made submissions on some of the papers associated with this initiative and have attached these as appendices.

Rights of recreational fishers to the fisheries resource

The aquatic resources of this state are a community resource. As a very large part of the community, recreational fishers have substantial rights to the use of fish resources of Western Australia.

The most basic of the rights that recreational fishers have to take fish is the right that each member of the community has to share in the common resources of the community. The way in which this can be right can be fairly exercised is discussed under resource sharing objectives. As part of the community resource, recreational fishers have the right to harvest their personal share of the common property themselves. The majority of recreational fishers in Western Australia still fish for food for themselves and their families.

Recreational fishing in WA involves the expenditure of more than half billion dollars per annum in carrying out the activity representing a significant portion of the gross domestic product of Western Australia. Fishing is one of the most common forms of outdoor, active, recreational activity in Western Australia. Such activities are regarded as desirable and promoted by the government on behalf of the community.

Recreational fishers have the right to enjoy the experience in a natural environment which is clean and is well managed by the community and the government vested with the overall stewardship responsibility for the aquatic environment and its biodiversity.

Responsibilities of recreational fishers

In recognition of the rights of recreational fishing, comes an acceptance of the responsibilities which consequently flow. The economic benefits from a healthy recreational fishery and the accumulated activities of the recreational sector should not allow the overexploitation of the resource, thus denying future generations the opportunity to make use of the renewable resource.

Recreational fishers recognise that their activity must be sustainable. Fishers must not do anything that imperils the future viability of the fisheries.

Recfishwest recognises the need for intergenerational equity because future generations should have access to fisheries of the same quality as they enjoy today. This means not only that the species are not threatened but the range of size classes and genetic diversity is maintained and managed for in the population.

Recreational fishers must respect the rights of other stakeholders to the fish resource, including ensuring biodiversity.

Consequent upon the need for sustainability and resource sharing in the new integrated management system is the requirement for substantial additional funds for research and monitoring to achieve these objectives. However, in the absence of comprehensive data, the precautionary principle should be applied to ensure that the resource is not over-exploited. The responsibility of recreational fishers in contributing to such funding is dealt with later in this paper.

Commercial fishing issues

Recfishwest recognises the need for the community to have access to fresh fish. However, the provision of this product should not be at the expense of recreational fishing. An attempt to quantify the community need for fresh fish must fully consider the replaceability of fresh product (enshrined in the Constitution through freedom of trade between the states) a definition of 'local' and the desires of the consumers with respect to product.

For example, many consumers would rather purchase snapper taken from Port Phillip Bay in Victoria if it meant that there was lower commercial exploitation of juvenile snapper from Wilson Inlet near Denmark. It could be argued that the true commercial marginal value of these fish is the premium which a consumer would pay for Wilson Inlet snapper OVER what they would pay for a Port Phillip Bay snapper. In addition, it is essential to determine if the community would rather catch gill net caught mullet from WA estuaries or white fleshed fillets taken as part of the Pilbara fish trap fishery.

For inshore and estuarine waters, Recfishwest believes that the lifestyle needs of a small number of commercial fishers should be overvalued compared to the recreational fishing and community conservation lifestyle values of the majority. Their fresh fish needs are able to be met through a wide variety of sources without direct impact.

Charter boat fishing issues

Recfishwest regards charter fishing as an activity in which the participants (clients) are recreational fishers under the same rules as all others with respect to bag limits, boat limits and possession limits.

Charter boat operators are engaged in a special activity which requires guidelines and special rules to address the higher efficiency which recreational fishers can obtain through access to the expertise of the charter boat operator. Recfishwest must be a participant in any discussions of such rules or guidelines.

Recfishwest is concerned about the processes which are currently in train for the management of the charter boat industry in Western Australia. Fisheries are proposing to implement a licensing system which will include some form of access 'right' under the definition of the Fish Resources Management Act 1994. Fisheries WA are sequential and subsequently proposing additional management controls on charter boats such as have been proposed in the West Coast regional review process.

Historically, the reduction of the scope and operation of a fishing entitlement has attracted tribunal or legal attention, with compensation being met through community funds. Recfishwest strongly supports the allocation of access and licensing in the charter boat industry on the explicit understanding of the need for overall catch controls on the sector.

An example might be that a charter operator has a boat that can carry 20 paying recreational fishers and applies for access through the charter boat management process. This boat could then take 20 recreational bag limits for the majority of species to correspond to the number of fishers on board. Fisheries WA then imposes (say) a four bag limit maximum for charter boats. The operator claims that he has had his/her right reduced and may claim compensation for loss consistent with the reduction in effort and catch. The case may be strengthened if capital (frequently overcapitalisation) were to be invested on the basis of utilising the 20 bag limit entitlement.

Recfishwest strongly advocates the allocation of the entitlement with the catch controls finalised. Any claims for loss of entitlement would therefore be on the strength of the management rationale and not on the application of potentially discriminatory future management controls. Recfishwest would ask the integrated management committee to carefully examine this area.

The objectives of resource sharing should include the following principles

In any resource sharing process it is essential that the proposed total catch is sustainable. There is also a need to ensure that the catches of the various sectors are monitored to ensure that the rapid mobilisation of effort does not result in over exploitation. It is therefore necessary to develop independent decision making models which allows the adjustment of the take to prevent ongoing over exploitation.

At present there is insufficient information for many targeted fin fish species to determine sustainable catch levels or to estimate recreational catch. It is therefore necessary to build up this knowledge as soon as practicable to ensure that emotive debates on the status of the stock to not result in an inability to effectively manage catches and catch shares. However, Recfishwest believes that the precautionary principle should apply, especially given the long recovery time for stocks should over exploitation occur.

Recognition of the need for an "environmental" share of the resource as an allocation priority. The availability of a share of the resource which is not open to exploitation further strengthens the robustness of the stock and ensures that there is biodiversity within the ecological communities and diverse size, age and genetic structures for fisheries.

A first principle starting point for recreational fishers and commercial fishers in any resource sharing process is on the basis of equal rights for the resource.

In many instances, an equal share will not be the most appropriate outcome. Recreational fishers do not seek significant access to certain fisheries (such as pearling and offshore prawns) because of spatial considerations or fishing method.

In other cases, the economic return from the recreational fishery will be overwhelmingly in favour of recreational catch shares being increased. This might reasonable result in 100 per cent recreational allocation of a fishery with high recreational value and comparatively low commercial importance. An example might be the Australian herring fishery, where a commercial fishery worth approximately $400,000 takes similar or greater catches than the recreational fishing sector.

Australian herring forms the major catch (greater than 50%) in an area from Two Rocks to the SA border where over 75% of the recreational fishing pressure occurs. Noted economist Dr Paul McLeod believes that the marginal value from a commercial caught Australian herring to be around $0.03 - $0.04. For a resource shift to be justified on the basis of maximising community return from the community resource, the marginal value of a recreationally caught herring must only exceed $0.04 which it would obviously meet.

Recfishwest believes that a new start is needed with integrated management, departing from historical precedent as the principal determinant in resource sharing.

Recfishwest believes that in most cases the resource sharing process can proceed by negotiation to a mutually satisfactory conclusion. There may be a reluctance to accept maximising the community return from the available resource as a basis for making resource allocations. Recfishwest would then claim, on behalf of the recreational fishing community, rights to a greater share of fish by arguing that the whole community should be given an opportunity to harvest fish on its own behalf. For some of the larger commercial fisheries, almost all the product is exported and the only realistic access to the resource is through recreational fishing.

Past resource sharing processes relied on buying out existing commercial fishers as the basis for any re-allocation of catch shares. Recfishwest believes that it is inappropriate for the recreational sector to have to "buy" back a portion of the catch which should, through the application of the objects of the Fish Resources Management Act 1994 and earlier legislation, have been theirs in the first place.

Such 'rights' trading has legitimacy within the commercial sector but is not suitable for sharing between the commercial sector and other stakeholders, such as recreational fishers. As recreational fishers have never had explicit catch shares allocated to them in the past, there has to be a process for dealing with the social implications of change. While in some cases payments may be suitable, this should be explicitly determined on the strength of individual circumstances and not accepted as a part of the general process. Any compensation must be part of a process which is separate from the determination of rights to the resource.

Recfishwest believes that traditional fisheries management can address many of the resource sharing issues, without applying compensation. These include commercial area closures, seasonal and time closures to reduce conflict, differential size limits, recreational only species and gear restrictions. These tools can enable the full and equitable allocation of the objects of the Fish Resources Management Act 1994, without penalising the community which has already been historically disadvantaged by past management allocations.

Recfishwest recognises that there can be indigenous rights for fishing; but in view of the breadth of the issues and the difficulties of negotiation and resolution Recfishwest will not attempt to define the extent or application of those rights but rather will respond when required.

The funding of the additional research and monitoring management required for integrated fisheries management

Coastal development levy.

Throughout the 1990's governments have increasingly moved to apply the user pays principle to community or government supplied goods and services. The application of this principle to common property natural resource access such as recreational fishing or to make use of National Parks has met with resistance and a potentially significant political cost.

None the less, as populations increase, the delicate terrestrial and marine environments of Western Australia are put under increasing pressure through urban, industrial or rural development and subdivision. The areas which are undeveloped become, by definition, more valuable and in need of more intensive protection and/or management. This management has a significant cost which is becoming increasingly difficult to recover from the community, leading to an increasing dilemma for strategic natural resource management.

Recfishwest is proposing that a levy of 1% to 1.5% of the overall cost be imposed on all new developments within 3 kilometres of the state's coastline, rivers and estuaries and those in close proximity to designated streams or inland waterways.

This revenue could be vested in a Trust or other like body with wide representation and then distributed on a "proposal for grants" process to community organisations, government agencies and other groups who have demonstrated their bona fides.

One option for the utilisation of these funds could be to prescribe 15% allocation of funds to Fisheries WA, CALM (Conservation) and Water and Rivers Commission, 10% to Department of Environmental Protection and 10% as contested government funds (which includes contingency money for natural or pollution disasters).

Ten per cent of the fund would be preserved for local projects which do not impact on the natural environment. Twenty five per cent would be available as contested funds for transport, tourism and community groups to be allocated on the strength of their submissions.

It is not expected that such a scheme would provide all the funds needed for better recreational fishing management. Nevertheless, it is a proposal that could make a valuable contribution to protection of the marine environment.

Recreational fishing licence

A way of obtaining the necessary additional funding which meets the "user-pays" principle and would provide a consistent level of funding would be additional recreational fishing license fees. At present licenses apply to recreational fishing for rock lobster, abalone, marron, net fishing and southwest freshwater angling.

Recfishwest has agreed that license fees for finfish would be acceptable if and only if there is no reduction in the existing general revenue contribution to recreational fishing and the license fees are specifically made available for recreational fisheries purposes through a dedicated trust fund.

If all recreational fishing were licensed, allowing for exemptions and concessions, the fees from only half the present estimated number of recreational fishers could amount to an additional $5 million per annum. This would approximately double the funding available for recreational fishing in the Fisheries WA budget. On the figures available for the level of expenditure on recreational fishing in Western Australia, the license fee represents one cent for every $1 that recreational fishers currently spend on fishing.

Resource Rents

Recfishwest supports the equitable allocation of the resource and consequentially the equitable recovery of costs for the management of the fishery. The recreational fishing licence issue should be matched by the application of resource rents for commercial fisheries.

Currently major commercial fisheries meet the costs of the management of those fisheries. This substantially undervalues the community return for the access to the resources and, in a number of cases results in true economic profits being realised by a small part of the community who harvest the resource.

The minor commercial fisheries contribute little or almost nothing towards the management of the resource and in return expect to have their historically inappropriate over-allocations protected by Fisheries WA. The activities of minor commercial fisheries are being heavily subsidised by the community and in some cases recreational fishers, who are being disadvantaged by current management arrangements.

Recfishwest believes that resource rents represent an equitable means for the community to recapture part of the premium which is currently being applied to the small number of commercial fishers with exclusive access to the community resource.

A resource rent in the order of 7-9 % is often used throughout the world and represents a reasonable return to the community. In conjunction with a general recreational fishing licence, a resource rent should allow better research, compliance, education and management of our soon to be integrated fisheries.

Other cost recovery mechanisms

For high value species it is possible to sell the ability to take fish in the form of single use tags that must be applied by both commercial and recreational fishers. This mechanism is used with Pacific salmon and Eastern rock lobsters for the commercial sector in NSW.

Funding summary.

The new integrated management initiative will benefit fisheries management but requires additional funding. Neither recreational fishers nor commercial participants in the wetline fishery are meeting current management costs.

A coastal development levy would be a valuable source of funding for marine management but it would vary between years and would have to be shared with many stakeholders. With additional income for recreational fishing from license fees, money could be allocated to enable recreational fishers to organise and participate fully in the resource sharing process. Without additional income and license fees, recreational fishers will be forced to capture an increasingly contested portion of consolidated funding in direct competition with roads, police, hospital and education services from the State Government.

The capture of community levies through resource rents will ensure that there is adequate funding to address the challenges which increasing populations and a degrading environment will place on the aquatic resources of this state.

Without the extra funding it will not be possible to do enough research and monitoring to sustainably manage and allocate fisheries resources. This problem will be particularly acute in the coastal and estuarine finfish fishery.

If additional funding were provided, Recfishwest would expect to see an expanded research activity in Fisheries WA which would be focussed on management issues and key applied outcomes. There would be an increase in catch monitoring and considerable emphasis given to predictive modelling.

Recfishwest supports an extension of the recreational fishing license scheme to enable adequate funding of integrated fisheries management. Recfishwest has strong views on the conditions for expenditure of license fees. These are outlined in the appendices.

Key management issues requiring urgent resolution

Rock lobster wetlining

There is significant inter-sectoral and intra-sectoral competition between rock lobster boats targeting wetfish, especially in the rock lobster off season, and other users of the resource. The rock lobster boats are generally large, state of the art as far as design and technology and efficient. They can generally out compete the dedicated commercial wetfishing fleet.

The main business of rock lobster boats is obviously to operate in the lucrative and highly profitable commercial rock lobster fishery. Under the Fish Resources Management Act 1994, the ability to take wetfish is no longer an essential part of the commercial fishing entitlement.

Recfishwest strongly believes that only those boats with a significant and confirmed historical take of wetfish should be allowed to take wetfish (other than perhaps to recreational limits and then not for sale).

Benchmark Date

The Minister for Fisheries, Monty House MLA has written to Recfishwest on 21 October 1998 (attachment) which says in part "Let me also assure you that the benchmark date of 3 November 1997 applies to all commercial fishing boats, including the rock lobster fleet."

Recfishwest strongly believes that there is no case whatsoever for the allocation of any wetfishing access on the basis of any history accumulated after 3 November 1997. The integrated management committee must confirm the benchmark date and ensure that recently accumulated history is not incorporated into the allocation of entitlements. There may have been significant over reporting of some catches after the benchmark date in an attempt to establish history which may ultimately have a commercial benefit if formal entitlements result.

Charter Boat Fishing

Recfishwest has outlined our concerns on charter boat management and entitlement allocation elsewhere in this submission. However, the resolution of the issues which sit around competition between recreational fishers, charter boats and commercial fishers needs full consideration. The capacity of some commercial operators to carry out chartering operations and then sell excess catch, while being examined through the existing management and compliance frameworks, should not be underestimated as an issue which may impact on integrated management.

Possession Limits for recreational fishers

Although not popular with some sections of the recreational fishing community, possession limits perform an extremely important form of overall catch control for recreational fishers. Limiting the possession of fish has been successfully used in Ningaloo Marine Park since 1991, is now used with abalone and Shark Bay Western Gulf pink snapper and should be used as a general rule for recreational catch control.

Protection of spawning aggregations

Identified spawning aggregations of all species should be protected if possible. At the very least, the animals should be able to breed before being exploited.

There are significant lessons to be learned from the Shark Bay snapper over exploitation and the precautionary principle should be applied wherever possible in implementing management which provides an additional safety net for the stocks. Most commercial and recreational fishers support the use of seasonal or area closures to protect fish when they are particularly vulnerable to over exploitation.

It is to this end that Recfishwest and the Conservation Council have advocated the expeditious closure of the Cockburn Sound snapper fishery during the period of spawning aggregations.

Value adding of commercial catch

Recfishwest strongly believes that commercial fish should achieve the maximum economic return per unit of catch. There are still some fisheries in Western Australia that do not have immediate access to ice and fish may take many hours to be chilled, affecting quality and value.

In addition, wherever possible priority should be given to commercial fishing methods which maximise the economic return for the catch. This is generally going to result in preference for line fishing over trap fishing and preference for trap fishing over trawl fishing. The ecological impact of these methods is also an important consideration in allocating catch priorities.

By-catch

The capacity of other commercial fisheries to impact on recruitment, growth and fishing mortality of significant species must be fully considered in the development of integrated management protocols. Recfishwest has been disappointed in Fisheries WA's concentration of effort in eliminating large mega fauna from the by-catch of prawn trawlers and not reducing the incidental take of recreationally (and frequently commercially) important species.

The incidental capture or targeting of recreationally important species by fisheries such as the demersal gillnet and longline fishery (traditionally a shark fishery) has the capacity to increase conflict and complicate resource sharing debates.

The legislation which pertains to the retention of crabs by the prawn trawl fleets is also unclear and has apparently been accepted by Fisheries WA as legitimate without full reference for a legal opinion. This has disadvantaged the recreational sector and increased assertions of significant client capture within Fisheries WA.

Integrated ecosystem management

When the pilchard stocks in Australia were significantly impacted upon by the herpes virus, the impacts on the commercial fishery were investigated and action taken. However, the overall impact on the ecosystems, on which many larger fish depend has not been given significant consideration. This failing could lead to ecosystem collapse, especially if other prey species are targeted as compensation for the loss of the pilchard fishery by affected commercial fishers.

In addition, the issue of local versus global depletion is significantly undervalued, particularly by research scientists undertaking global stock assessments. Localised stock depletions, especially of forage species can have a significant impact on local fish stocks and downstream impacts on local tourism and infrastructure if recreational fishing quality is impacted.

Recfishwest urges careful attention be paid to the importance of local depletions, particularly given the localised fishing pressure from recreational fishers (centring largely on access points) and the need for a large standing stock to enable less skilled recreational fishers to have a reasonable catch expectation.

Biological reference points

Biological reference points are extremely useful for determining acceptable exploitation levels. These biological reference points should be used in conjunction with independent decision making models which objectively describe management actions to be undertaken if stock levels reach certain predetermined points.

Recfishwest supports the establishment of models to utilise independent decision making components provided that all users are represented and research makes every effort to provide accurate and timely information to be used.

By using objective decision making processes, the denial of any impact can be avoided if stock levels decline to the point where remedial action is required.

Management focus for research

While Recfishwest fully supports significant additional research, the focus should be on meeting the needs of management. Research must be able to provide additional information to improve the management of the fishery and answer questions which assist adaptive management. Pure research can still be carried out by tertiary institutions.

Much of the research still needs refinement. Examples include the use of CPUE data for recreational fishers which is of limited use due to the extreme variations in angler success rates. In addition, many of the recreational creel surveys, while providing important additional information, require massive extrapolation of limited data sets which may magnify sampling or design errors. The reported recreational catch of blue groper on the west coast by spearfishermen resulted from one or two specimens being extrapolated in such a way that indicated a significant over exploitation may be occurring.

CAESS refinement

CAESS, the commercial catch reporting system is largely unable to provide data resolution to be of assistance in wetfish resource sharing debates. The blocks are too large and frequently do not follow the boundaries of fisheries, giving misleading information which can be misinterpreted and increase conflict.There is an urgent need to review the existing CAESS system to enable the data to meet the needs of existing and future management.

In addition, there is a need for independent validation of many catch returns. Future access entitlements may be granted on the basis of reported catch, which is rarely validated. This results in a strong incentive to over report or under report catches depending on the commercial advantage which may result.

The matter is further complicated by the anecdotal evidence which suggests that significant quantities of high value recreational species such as dhufish may not have been reported as they form part of a cash economy.

This significantly complicates resource sharing debates and reinforces the need to ensure that only validated catch returns from before November 3 1997 are considered.

Structure of Fisheries WA

Recfishwest believes that the application of integrated management will necessitate a restructure of Fisheries WA. The dogmas associated with the organisational segregation of commercial and recreational fisheries are not conducive to the facilitative application of integrated management.

Recfishwest would like to see a single manager responsible for the commercial and recreational (and community) issues associated with fisheries management. The management advisory committee processes should reflect the benefit which is accrued by the relevant sectors.

A possible solution administratively may be to have State managed fisheries (where the benefit is largely derived through export and value adding of the fisheries, generally through commercial fishing) and Community managed fisheries (where the majority benefit is derived by the community, generally through recreational fishing).

Expected Outcomes of integrated management approach

Recfishwest expects that the outcome of a successful and adequately funded integrated management and resource sharing process would lead to: -

Maintenance of western Australia's high quality recreational fishing, albeit with some reductions in maximum catch quantity. The continuation of a small profitable commercial wetline fishery. Fishery management advisory groups based on a fishery with representation of both commercial and recreational representatives. Changes in the structure of the fisheries agency to reflect the increasing importance of recreational fishing and the integrated management approach.

A process and structure in fisheries management that can cope with future change.

Comments on Proposals in Integrated Management Paper

9.1 Proposal 1

Recfishwest supports the principles and strategies for integrated management and much of this submission concentrates on this area.

9.2 Proposal 2 and Proposal 3

Recfishwest does not necessarily believe that the regional approach to management is the most suitable in many instances. The lack of strategic direction, such as should result from the integrated management process has led to confusion and inconsistency in the application of regional management proposals for recreational fisheries in the Gascoyne and West Coast regions.

Recfishwest believes that the distributions of the vast majority of species indicates a more likely biogeographic boundary at the northern end of Shark Bay. A second, but more arbitrary boundary could be put in place at Black Rock as suggested by Fisheries WA.

Recfishwest believes that where possible, integrated management should be implemented in a holistic manner across WA, with regional management for those issues or species where the differences are significant enough to justify specific management measures. Recfishwest is concerned about the potentialduplication of administration or the development of inconsistent management regimes for species which straddle one or more regions. Recfishwest believes that the recommendations should be critically reviewed in consultation with the reference group.

9.3 Proposal 4

Notwithstanding comments on proposals 2 and 3, Recfishwest supports the establishment of a peak Fisheries Resources Council. The composition of this committee is crucial and the selection of the council will determine its ability to give effect to the complex task with which it is proposed to be charged.

9.4 Proposal 5

Recfishwest supports this recommendation, pending the resolution of the need for and basis of the biogeographic regions and the relationship with holistic, statewide management.

9.5 Proposal 6

Recfishwest believes that it is essential that the principles which are derived through this integrated management process should determine the applied management for any regi0on or fishery. Therefore recfishwest strongly recommends that any regional management process should be reviewed or rejected outright in the context of the integrated managment process.

Recfishwest believes that many of the exisiting commercial or proposed recreational management plans should be comprehensively reviewed together to ensure that the principles of holistic management should be fairly and equitably applied to future management rather than be dictated by historical management practices.

Recfishwest does not wish to compromise on the fact that holistic management should drive applied management rather than vice versa as implied by this recommendation. Recfishwest believes that there is considerable merit in elaying the implementation of proposed management reforms such as the Gascoyne Regional recreational Review, the South Coast Estuarine Review, the West Coast Regional recreational Review and the Fish and Fish Habitat protection areas such as at Cottesloe. Once the appropriate overriding principles that apply to all user groups have been finalised and are able to be applied, these reviews can be implemented. Failure to follow this protocol leaves the review process open to criticism that the traditional sectoral management process continues to be utilised.

9.6 Proposal 7

Recfishwest believes that the regional resource allocation process, particularly as it relates to straddling stocks or species specific fisheries needs far greater consideration.

9.7 Proposal 8

Recfishwest supports the need to give full consideration to the future funding needs for fisheries management and has discussed a range of options in detail within this paper.



This page last updated on 30 December 2003.