Archived page, Submission Draft Bycatch Action Plan for the Shark Bay Prawn Managed Fishery

Recfishwest commends the Department of Fisheries for recognising the issues and concerns associated with trawl fisheries bycatch and that it has a responsibility to lead and coordinate efforts to manage bycatch.

However we are disappointed that the document, whilst still only in its public comment phase, is already out of date in respect to the implementation of bycatch reduction devices, the key initiative of the plan.

Implementation of Bycatch Reduction Devices

The action plan centres around the introduction of bycatch reduction devices (BRDs) into the fishery and details a requirement for the Department of Fisheries to achieve full implementation by commencement of the 2002 fishing season. This has not been achieved and it is our understanding that this may have been due to trawl operators not yet being satisfied with the outcomes of the BRD trials. If so, this is not acceptable to Recfishwest.

It is our view that the use of BRDs in the Shark Bay Prawn Managed Fishery must become compulsory by the commencement of the 2003 fishing season at the latest, regardless of whether the trials have concluded to the full satisfaction of operators or not.

The deferral of this stated action to date is seemingly legitimised by an inappropriate statement within the draft Plan that 'the overall objectives of the bycatch gear trials were to determine the most effective combination of BRDs in reducing bycatch without damaging the prawn catch and lowering its commercial value.'

Recfishwest strongly recommends that this statement be amended by replacing the word 'without' with the words 'whilst minimising'.

BRD Protocols

Action 2e, "Develop a decision-making process and protocol for use of BRDs in high density weed" is of concern to Recfishwest.

Recfishwest notes that, while at times, BRDs may become weed clogged, it would probably be the case that nets without BRDs would also become weed loaded in the same circumstances. In such scenarios it is likely that the entire 'catch' would be dumped as sorting for the target species would be uneconomic.

However, where this would occur, the problem would not be with the BRD but with the high levels of weed in the fished environment. In practice under extreme weed conditions trawler skippers will either cease fishing or move to areas unaffected by weed, irrespective of whether BRDs are being used.

BRD weed clogging occurrences must not be used to ratify protocols that provide for windows of opportunity to trawl without BRDs and must not be used as a pretext to further delay full BRD introduction

Action Timelines

Recfishwest believes that it is essential that all key actions have timelines attached.

It is of particular concern that there is no time line set for the completion of necessary data gathering for re-assessment of trawl ground boundaries. It has been suggested that this may have been linked to uncertainties surrounding the securing of external funds to undertake the research. This would be unacceptable to Recfishwest. A timeline for completion of the work must be set and that if external funds are not secured, then cost recovered industry funds must be used for this purpose.

Environmentally Sustainable Development Consideration

Recfishwest is deeply disappointed that, after so many years, there is still a paucity of data on which to be able to make even the most superficial ESD assessments in this fishery. While a number of statements/suppositions are made or implied in the Plan to the effect that existing levels of trawling are relatively benign or in an equilibrium state, it remains the case that we simply do not know. This lack of data must be urgently addressed.

It is entirely possible that the net environmental impacts of this fishery, taking into account long term and possibly irreversible damage to both the marine environment and changes to species mixes, has been such as to completely outweigh the socioeconomic benefits to the greater good of the community (as opposed to the economic advantage of a relatively few fishers and processors). Again, we do not know because we do not have the data.

We are therefore very concerned that the draft plan does not propose the conduct of investigations to determine whether there is an overall sustainable and acceptable level of bycatch in the fishery.

Recfishwest consider that these investigations are essential and must be included as an action requirement within the plan. We further recommend that the action plan must propose 'actions' that will ensure that the fishery does not exceed the levels determined.

As above, if external funds can not be secured for these then cost recovered industry funds must be used for this purpose.



This page last updated on 30 December 2003.