Archived page, Recfishwest Submission West Coast and Gascoyne Reviews, Response to the Minister for Fisheries call for comments. Gascoyne and West Coast Regional Recreational Fishing Reviews

1.0 INTRODUCTION

Recfishwest welcomed the opportunity to provide comprehensive and considered comment on the Gascoyne and West Coast Regional Recreational Fishing Reviews. Recfishwest appreciates the Minister providing the opportunity for the community to provide additional comments on these proposals.

This new opportunity is important given the length of time since the public comment period for these reviews (Gascoyne review closed August 1999). This is the first time that the public has been able to see how these two reviews will complement each other and provide a basis for reviews of the remaining regions.

Recfishwest and most recreational fishers support the general thrust of the papers and the recognition of the need for an evolution in recreational fisheries management. Our greatest concern, particularly as we move towards integrated management is the lack of management equity in this proposal. It is this lack of equity, which is very widely recognised by recreational fishers, that forms the basis of the Recfishwest position.

Recfishwest also believes that the review process has failed in two fundamental ways:

* The reviews have failed to meet one of their prime objectives which was to keep fisheries regulations simple; and

* Failed as the reviews infer that the recreational fishing sector was being held responsible for primary management accountability of wet fish stocks.

In addition there is insufficient coordination between the regions and the implementation of the reviews will create serious inequities in the Pilbara/Kimberley and South Coast which will not be subject to the 'new' management arrangements for the same species.

2.0 MAJOR ISSUES

2.1. INEQUITIES FORM THE BASIS OF THE RECFISHWEST SUBMISSION

There is deep concern that whilst the reviews have proposed significant effort reduction measures for the recreational fishing sector there have been no complementary effort reduction measures proposed for the commercial fishing sector. Recfishwest believes that this has seriously compromised community acceptance of the review proposals. The strongly held view exists that the catch forgone by the recreational sector as a consequence of the effort reduction measures will merely be taken as increased catch by the commercial sector with no benefit to the fish stocks as intended.

Recfishwest seriously questions the third dot point contained within the introduction of the Minister's initial responses to final reports of both the West Coast and Gascoyne Recreational Fishing Working Groups. This reads that the regional management strategies have as an objective, to "Position recreational fishing so it can be incorporated into an integrated management framework in which resource sharing issues can be addressed."

Neither the West Coast or Gascoyne Recreational Fishing Working Groups were informed of or directed that this statement be one of the objectives of their deliberations. Indeed the outcomes of the working groups may have been significantly different had they been so directed.

Converse to the intent of the objective suggested above, the reviews have heightened community scepticism in respect to the principles of resource sharing. There is a general view that the review outcomes may negatively position the recreational fishing sector with respect to future management or re-allocation processes. Indeed the implementation of the effort reduction measures may ultimately be a disadvantage to the recreational fishing sector when resource allocations are made as an outcome of the 'Toohey Committee' process. The recreational catch may have been significantly reduced to the direct advantage of commercial fishers or indirectly through establishing a baseline recreational fishing catch which is significantly limited in comparison to an unfettered commercial fishery.

This is especially important given the often repeated position of the WA Fishing Industry Council that current catch shares should be the only factor taken into account when determining initial resource allocations for each sector. Recfishwest opposes this position and believes that the future needs of the community need to be taken into consideration when making resource allocations.

The Western Australian Government and Recfishwest are both committed to integrated management of fish resources, which will, in the near future, involve a resource sharing process in which recreational fishers will be principal stakeholders. The implementation of the West Coast and Gascoyne reviews will result in a substantial reduction in recreational fish catch. Commercial fishers in the open access wet line fishery, who compete with recreational fishers, have had no parallel reduction in catch imposed.

2.2 Implement Possession Limit Now

In light of these serious concerns Recfishwest strongly recommends that whilst the key possession limit initiative should be implemented immediately, all other species specific management recommendations should be deferred until we receive Government assurances that complementary effort reduction management measures are defined and a timetable for their implementation is in place for the commercial fishing sector.

Recfishwest believes that it has a particular mandate in respect to this position on the basis of results of a questionnaire on this issue from Recfishwest members and corresponding members. Please find attached copies of the questionnaire responses.

2.3 Regional Regulation Disparities

Recfishwest reiterates that it does not support the concept of regional management for recreational fishing. The principle reason for this is the increased complexity in the management rules that would be imposed between zones on fishers, many of whom fish in more than one region.

We believe that that the introduction of regional rules that are further localised within regions with different bag and size restrictions will be too complex for most fishers to achieve effective compliance. It completely negates the stated objective of the strategy that, "Fishing rules be kept simple and where possible and practical, made uniform across the region."

A comparison of the West Coast and Gascoyne Reviews highlights this concern. There are numerous inconsistencies or unnecessary complexities between the reviews. Following are a number of the more important examples:

* The Gascoyne Review proposes a total mixed daily bag limit of 10 for category 2 fish whilst the West Coast Review proposes a total mixed daily bag of 16;

* The Gascoyne Review proposes a total mixed daily bag limit of 30 for category 3 fish whilst the West Coast Review proposes a total mixed daily bag of 40;

* The Gascoyne Review proposed a coral trout bag limit of 1 (where the species is abundant) whereas the West Coast Review proposes a bag limit of 2 (where the species is less common;

* The Gascoyne Review proposes that pink snapper have a daily bag limit of 6 and a minimum size limit of 410mm. The West Coast Review proposes that pink snapper have a daily bag limit of 4 and a minimum size of 450mm;

* The Gascoyne review proposes a bag limit of 6 for North-west snapper whereas the West Coast Review proposes a bag limit of 4;

* The Gascoyne review proposes a bag limit of 4 for mahi mahi whereas the West Coast Review proposes a bag limit of 2;

* The West Coast review proposes an increase in the size limit for mulloway to 500mm whereas no change is proposed in the Gascoyne review. (It should be noted that Recfishwest advocate an increase in the minimum size for mulloway to 600mm;

* The Gascoyne review proposes a potential bag limit of 10 for skipjack/trevally (as mixed species) as part of a Category 2 mixed bag limit whereas the West Coast review proposes a species bag limit of 8 as a part of a mixed bag limit of 16 for category 2 species;

* The Gascoyne review proposes an allowance of one bait trap whereas the West Coast review is silent;

* The Gascoyne review proposes a mixed bag limit of 50 for shellfish and sea urchins whereas the West Coast review proposes separate limits for some species in units of litres or numbers.

One of the worst examples of inconsistency between the reviews is unfortunately with tailor, one of the icon recreational species.

* The Gascoyne Review proposes that tailor be regarded as Category 1 species with daily bag limit of 6, a slot limit of two over 50cm and a minimum size limit of 250mm. The West Coast Review proposes that tailor be regarded as a Category 2 species with a daily bag limit of 8, no slot limit and a minimum size of 300mm.

Recfishwest proposes that an extensive re-examination of the reviews be undertaken with a view to simplifying and aligning the recommendations as much as possible.

2.4 Working Party to Assess Two Reviews for Consistency

To achieve optimum conformity between regions, a small working party should be appointed to reconcile the two sets of proposed regulations, making them as uniform as possible.

The recommendations as set out in the West Coast and Gascoyne Reviews considerably complicate existing fishing regulations, particularly in respect to bag limits. Our submission highlights some of the complications in this regard, with the tailor proposals for the two regions being perhaps the most glaring example. This situation will almost certainly be further compounded following reviews of the Kimberly/Pilbara and South Coast regions.

There will be some circumstances where different regulations should apply in different regions, or locally within some regions. However, the principle should be that the regulations should be consistent and simple wherever possible, except where a case for local/regional management can be clearly made.

2.5 Working Party to Assess Reviews for South Coast and Pilbara/Kimberley

The small working party proposed above should also be responsible for developing appropriate sets of similar recommendations for the Kimberley/Pilbara and South Coast regions.

The implementation of the proposed management measures for the Gascoyne and West Coast regions will result in significant differences in management rules between theses regions and the adjacent Kimberley/Pilbara and South Coast regions.

If the comprehensive reviews of the two remaining regions are undertaken using existing processes, these differences will remain for several years.

Having been through two major reviews, the general thrust of opinion from recreational fishers has been identified. Many fishers are very concerned about the complexity and the rationale for significant regional differences in management. However the need for conservative recreational fisheries management, matched by commercial fishing controls which recognise the importance and community benefit of recreational fishing for the fish resource, will largely be similar for all regions.

Recfishwest believes that, given the significant workload which will be necessary in dealing with the integrated management and associated resource sharing processes, it would place an unjustifiable and undue drain on scarce resources to embark upon two further regional reviews. We strongly believe that a working party could address the vast majority of issues in a timely manner.

To overcome the looming disparity between regions and to maximise the use of resources Recfishwest proposes that the small working party proposed above be responsible for developing an appropriate set of similar recommendations for the Kimberley/Pilbara and South Coast regions. These recommendations could be circulated to existing groups (Recfishwest and regional RFACs) for comment, with a public consultation period. The need to develop and implement corresponding commercial fisheries management and the considerable time it seems to take for the development of legislative reforms further reinforces the Recfishwest position that there should be a delay in implementing the two existing reviews.

2.6 Need for Greater Involvement of Commercial Sector in Reviewing Size Limits

The difficulty with addressing minimum size limits within both reviews is that they will also apply to commercial fishers. The lack of formal consultation with the commercial fishing sector as part of the review has meant that the recreational reviews have had a much stronger emphasis on bag limit reforms. In many cases, however, there is a stronger biological reason for reviewing size limits. The fact that size limits are more likely to apply equitably to both sectors further reinforces their value to the wider community.

To ensure equity, commercial fishers should have opportunity to address and comment on the size limits proposals. However, their views need to be assessed in the context of the community value and benefit for fin fish, which clearly falls to the recreational sector.

This is yet another important reason to delay the implementation of the reviews of bag and size limit recommendations.

2.7 Funding for Recreational Fisheries Management

Recfishwest supports the principle of recreational fishing licences, including for fin fish, because of the need for additional resources to protect recreational fishing for the future. However this support is conditional upon the following principles:

*A guarantee that additional licence income would not be used to reduce existing Government contributions;

* Agreement on the categories of expenditure for the additional licence income;

* Agreement on some Recfishwest participation in the decision making on licence income expenditure;

* Consideration for appropriate licence relief for some of the community such as children and seniors;

* That the integrity of funds expenditure is maintained via development of appropriate and agreed business rules.

Recfishwest supports the equitable allocation of the resource and consequentially the equitable recovery of costs for the management of fisheries, especially fin fish fisheries. A recreational wetfish fishing licence should be matched by the application of appropriate and significant resource rents for commercial fisheries.

2.8 Charter Boat Limits

Recfishwest has had considerable input into the development of regulations for the management of the fishing charter industry via a reference committee. Recfishwest supports the orderly development of the charter industry but recognises that charter fishing vessels have the capacity to place extremely high fishing pressure on specific locations. This is because charter vessels generally have a high level of technology and 'otherwise average' anglers can 'purchase' the expertise of the skipper and vessel. In addition charter boats carry large numbers of anglers to more remote grounds which significantly adds to local or regional pressure on sensitive stocks.

Following is a formula previously advocated by Recfishwest for calculating the total daily bag limits that should be permitted to be taken during fishing charters.

1 fisher 1 bag
2 fishers 2 bags
3 fishers 2 bags
4 fishers 2 bags
5 fishers 3 bags
6 fishers 3 bags
9 fishers 3 bags
12 fishers 4 bags
16 fishers 4 bags

The charter boat limit = (no. of fishers)-2 increased to the next whole number x bag limit.

3.0 OTHER ISSUES -West Coast Review

3.1 Species Recommendations

3.1.1 Breaksea Cod

The proposed bag limit for this species (2) is too low. This proposal values breaksea cod as highly as WA dhufish, which is not supportable. Recfishwest believes that this limit should be increased to 4.

We are very concerned that there are no size limits on this species and that this is being justified by there being insufficient biological data. Recfishwest believes that a precautionary limit is better than none and that the data available suggests that the choice is only between 25 and 30cm. The Recfishwest view is that it should be set at 30 cm and reviewed as the data comes to hand. It is incomprehensible that a bag limit of 2 is proposed with no size limit.

Recfishwest believes that the overall exploitation of the species is not of concern but that the exploitation of juveniles should be avoided to ensure good recruitment into the adult stocks. This species is considered a 'bread and butter' species for the offshore fishing fraternity. As such we do not agree that it should be included in the Category 1 list.

3.1.2 Coral Trout

Recfishwest supports restrictive bag limits for Coral trout due to their high value and apparent vulnerability in some areas to fishing pressure. However, we are at a loss to understand the rationale for the inconsistency with the proposed bag limit of 1 for the Gascoyne (where the species is abundant) and 2 for the West Coast region where the species is significantly less common.

3.1.3 Mulloway

Recfishwest believes that mulloway should have a 60 cm minimum size limit on biological grounds. This is a fast growing species and the size at maturity is greater than 60cm. The implementation of a 60cm minimum size would remove the necessity for a slot limit. Whilst this will cause some difficulty in areas where smaller mulloway are traditionally caught, we believe that increased community acceptance of size limits and higher survival of released fish means that the limit will have significant stock benefits.

3.1.4 Harlequin Fish

There should be a size limit implemented for harlequin fish based upon the best available data. This can be refined as further data emerges.

3.1.5 Cods

It is not clear whether the proposed bag limit for cods is 2 per cod species or a bag limit of 2 cods overall. This needs to be made clearer and should reflect the differences between this large and diverse group of fishes.

3.1.6 Sharks

The rationale for this recommendation needs to be documented. There are numerous shark species each with different growth characteristics. The Gascoyne review does not propose a maximum size limit for sharks and to set a one-size fits all limit for the West Coast only is extremely spurious.

Recfishwest believes that the recreational harvest of large sharks is currently very small and the restrictive bag limit proposed acts as sufficient management control, particularly when assessed against existing commercial over-exploitation for many shark species.

3.1.7 Yellowtail Kingfish

The size limit for yellowtail kingfish should be 60cm. This has been shown to be more appropriate for this species by NSW fisheries. This also makes commonsense in that it will alleviate concerns arising from the common confusion between yellowtail kingfish and sampson fish, as they would then have the same size limit.

3.1.8 Skipjack Trevally

There is difference of opinion on this proposal. A number of people are very concerned that the skipjack trevally size limit is proposed to stay at 20cm. They propose that the limit should be at least 25cm. They acknowledge that this may have some impact on fishing for sand skippy, particularly in Cockburn Sound, but believe that the overall conservation needs of skippy are greater.

Other fishers strongly believe that it would be inappropriate and discriminatory to introduce a general minimum size limit for skippy that would effectively make it illegal to take sand skippy given that they would all be undersized.

One potential compromise is for a special size limit to be introduced for Cockburn Sound. However noting the range of views, Recfishwest proposes that this issue be a matter referred to the working party recommended earlier in this submission for resolution.

3.1.9 Cobbler

As Recfishwest has previously stated, we strongly believe that the minimum size limit for cobbler should be increased to 50 cm due to sustainability concerns and that this more closely reflects this species size at maturity.

3.1.10 Snook-Pike.

The proposed minimum size is inappropriate, as it is too big for pike and too small for snook. Recfishwest does not accept that the same size limit should be implemented for both species, apparently on the basis that they are too difficult too tell apart, yet they have been placed in different categories with different bag limits.

Recfishwest proposes that the snook minimum size be increased to 50cm and the pike minimum size be reduced to 25cm.

Inconsistencies such as these, and others pointed out elsewhere in this submission, cast aspersions on the credibility of the review process.

3.1.11 Shellfish

Recfishwest is strongly opposed to the proposal to make the collection of 'all other' shellfish as protected species. This proposal will effectively wipe out recreational shell collecting and mean that other species such as turban shells; whelks and beche- de-mer would be eliminated as recreational species. The wording as it exists in the proposal appears to also apply to commercial fishers and would affect the commercial specimen shell fishery.

Recfishwest supports the ban on the take of live coral and believes that this should be extended to commercial fishing operations as well.

Recfishwest proposes a 'catch all' bag limit of 2 litres for 'all other' shellfish species.

Recfishwest believes that the 2 litre bag limit for sea urchin (especially whole specimens) is not well considered and lacks a rationale.

In view of the problems above Recfishwest recommend that that this section as a whole needs further work.

3.1.12 Crabs

Recfishwest understands and supports the proposed total commercial and recreational crab fishing closure proposed for Geographe Bay in October.

3.1.13 Dhufish

The dhufish proposal is causing considerable controversy within the recreational fishing sector. Recfishwest recognises that this very highly valued species needs to be managed to ensure that its stocks are not threatened. More than any other species there is a need for commercial fishing controls to be put into place to ensure that any recreational catch controls do not immediately benefit the commercial fishing industry rather than the stocks themselves. Indeed Recfishwest and the recreational fishing community are particularly sensitive about commercial exploitation of dhufish and this is one of the main reasons behind our support for accelerated wetfish management.

Recfishwest is concerned that the proposed limit of two fish may result in 'high grading'. Recfishwest does not condone this practice but it may negate at least part of the benefit of any management reforms. Recfishwest acknowledges that it had previously supported the proposed bag limit of 2. However, we are acutely aware of the strong views of the recreational fishing sector on this matter.

Accordingly Recfishwest would like to suggest that the bag limit be reduced to 3 with a boat limit of 6 dhufish being introduced. This regulation should be reviewed as soon as research data is available.

Although we realise it would be difficult to prove offences in court, Recfishwest believes that special penalties should apply for 'high grading'.

3.1.14 King George whiting Recfishwest has significant concerns about this proposal. We believe that the slot

limit is unnecessary and imposes a much greater control on the boat based open water angler who rarely if ever catches smaller King George. We recommend that the slot limit be removed and the bag limit become 8 overall.

3.1.15 Mahi Mahi

Mahi mahi is a very fast growing, extremely abundant species that is under no risk of overexploitation. Recfishwest can only conclude that it is proposed as a Category 1 species by virtue of its size and striking appearance.

Noting this, Recfishwest believes that whilst mahi mahi may remain a category 1 species there is no reasonable justification for the low bag limit proposed and recommend that it be increased to 4.

3.1.16 Blue Groper

The West Coast review Final Report recommends a size limit of 600mm for Blue Groper whilst the Minister's response document contains a minimum size limit of 400mm. We assume this is an error and that the size limit should correctly be 600mm in both documents.

Recfishwest fully support the 600mm minimum size limit recommendation for this species given the large size to which this species grows (frequently above 1metre).

3.2 Other management proposals - West Coast

3.2.1 Possession Limits

This proposal is strongly supported by Recfishwest.

Recfishwest believes that whilst possession limits should be implemented immediately for the whole of Western Australia, the implementation of all the other species specific controls (size and bag limits) should be deferred until we receive Government assurances that complementary effort reduction management measures are defined and a timetable for their implementation is in place for the commercial fishing sector.

Recfishwest has become aware that there is general confusion in respect to whether the possession limit applies 'per person' or 'per fishing party'. This needs to be clearly and widely explained when the possession limit is introduced.

3.2.2 Closures

We note that the Minister has proposed a closure for the take of baldchin groper within the Fish Habitat Protection Area at the Abrolhos Islands during the period November to January.

However the final report of the working group recommended the closure extend from November through to March. The Minister's variation from this was not flagged in the paper as have other changes proposed by the Minister. We question whether this was simply an error or an oversight. If this was a deliberate change, we would appreciate some advice in respect to the Minister's rationale for the change.

Recfishwest notes the different views and approaches within Government in respect to marine reserves planning and management. We seek your strong support for multiple use marine reserve planning (which accommodates recreational only zones).

3.2.3 Netting

Recfishwest is totally opposed to netting other than prawn drag nets and cast or throw nets. The Minister's response significantly liberalises netting in the Leschenault estuary which cannot be justified in the light of the 1990 review of all recreational fisheries and the 1994 recreational netting review, both of which clearly indicated the phasing out of gill and haul netting.

Recent research in the Blackwood/Hardy estuary indicates that the freshwater wedge effect in winter means that black bream are found at certain times in shallow water (down to 30cm) and are highly vulnerable to netting, including those nets being set supposedly to target mullet only.

We are also opposed to commercial netting in the Hardy estuary. We believe that at the very least a significant closed season should be implemented to reduce the impact of commercial netting on the vulnerable black bream population in the lower Blackwood River.

We draw attention to Research Report 104, which indicates an extremely large by- catch of species other than mullet from netting in the Leschenault and Peel Harvey estuaries.

Recfishwest remains opposed to the use of set and haul nets. Given the controversial nature of recreational netting the Minister may wish to consider a further instalment of a state wide netting review so that the vast majority of the public opposed to netting, other than throw and prawn drag netting, have the opportunity to make their views known to the Minister.

3.2.4 Throw Nets

Recfishwest supports the recommendation in respect to throw nets in that they should be permitted in ocean waters except for any waters currently specifically closed to throw netting.

Recfishwest further believes that throw nets should be used only for the capture of bait. Species subject to specific bag or size limit controls, other than garfish and mullet, should not be permitted to be taken in a throw net. Garfish and mullet are specifically targeted for use as bait.

3.2.5 Prawn Drag Nets

The Minister's proposal does not address the incidental capture of crabs, which has been a long standing problem for the local community.

The area of greatest concern for crab by-catch by drag nets is actually approximately 400m upstream and downstream of the new traffic bridge at Mandurah. A closure in this area would be more appropriate.

Recfishwest cannot reconcile the proposal to permit the use of gillnets in the Leschenault estuary, given the near 100% mortality of by-catch, while prohibiting prawn drag nets for reasons not explained.

3.2.6 Fishing Competitions

Recfishwest, in conjunction with the major fishing associations, is currently developing a code of conduct and does not believe that the Fisheries Department is an appropriate body to undertake this work. It is also not appropriate to legislate for codes of conduct.

3.2.7 Boat Limits

Recfishwest believes that with the implementation of possession limits the need for boat limits becomes much less important. If for any reason possession limits are not implemented then this issue will need to be revisited.

Noting this position, Recfishwest has recommended a boat limit of 6 for dhufish which we believe most appropriately meets the future needs for this species. (see section 3.1.13)

3.2.8 Filleting at Sea

Recfishwest fully understands the rationale and need for the prohibition of filleting or dismemberment of fish at sea. However we are also aware of the significant difficulty and restriction this imposes upon people who stay at sea onboard their fishing vessels for significant periods of time. This rule will prevent them processing larger fish and thereby improving the quality of fish product.

Noting this Recfishwest recommends that this matter be referred to the working party, proposed earlier in this submission, for further consideration.

4.0 OTHER ISSUES - Gascoyne Review

4.1 Species Recommendations

4.1.1 Pink snapper

The special conservation measure recently implemented in the western gulf of Shark Bay is included as a recommendation within the review. This measure was introduced as part of a package of measures aimed at addressing the stock decline and should be subject to regular review on the basis of improving information from existing research programs rather than be locked in for a five year period.

Recfishwest strongly believes that the target breeding stock of 100 tonnes for the eastern gulf of Shark Bay should not be a target for the reopening of the fishery but instead should be the minimum stock level. Future catch levels should be determined that avoid the potential for subsequent stock collapses. If the minimum stock level is reached then further fishing should once again cease until stocks rebuild.

4.1.2 Chinaman cod.

This species should be moved to Category 2. There is no evidence of overfishing and this species is locally important but of lower recreational fishing value. This species is considered a 'bread and butter' species for the offshore fishing fraternity in this region. As such we do not agree that it should be included in the Category 1 list.

4.1.3 Trevally species

The trevally species are separated into different categories. Even taxonomists find it difficult to identify some species, which will lead to confusion and compliance difficulties. Turrum for example, which are in a different genus, are not mentioned and the controls for this species are not clear.

4.1.4 Parrot fish

Parrot fish should be listed as a category 2 species. It does not have the attributes necessary to be deemed a category 1 species.

4.1.5 Mangrove Jack

Whilst the value of this species is recognised they are frequently caught in conjunction with fingermark bream which is listed as a category 2 fish.

Recfishwest believes that a size limit should apply to both species and consideration given to introducing a combined bag limit of 5 for fingermark bream and mangrove jack as part of category 2.

4.1.6 Wahoo

Recfishwest believes that the review should have taken the opportunity to increase the minimum size of wahoo to 900mm to be consistent with the new Spanish mackerel size limit.

4.1.7 Job Fish

Recfishwest believes that a size limit should be introduced for job fish.

4.1.8 Mud Crabs

The Gascoyne review proposes a possession limit of 5 and a boat limit of 10 for mud crabs. However there is no reference to mud crabs in the West Coast review. Recfishwest questions whether this means that the current statewide bag limit is to be revoked. This issue requires clarification.

4.2 Other management proposals - Gascoyne Review

Recfishwest notes with some concern that different editions of the Minister's Initial Response document for the Gascoyne Review contain differing text information. (ie. Strategy G10 paragraph 3)

4.2.1 Netting

Recfishwest's position opposing the continuation of recreational gill and haul netting is reiterated. It should be noted that if the recommendations are introduced as proposed then there must be an accepted definition of 'creek' developed for the region.

Recfishwest believes that there is a strong case for a statewide review of recreational netting.

Recfishwest has no concerns in respect to the use of throw nets for the capture of bait in rivers and creeks in the Gascoyne region. However we suggest that, with the exception of mullet and garfish, only fish not covered by specific bag limits be permitted to be taken by throw nets.

4.2.2 Maximum Size for Cods

The Gascoyne Review - Final Report Recommendation 12c, proposes that the maximum size for cods should be reduced to 1 metre. Recfishwest supports this recommendation.

However this recommendation is not included in the Minister's response document nor is it highlighted as a change to the final report being proposed by the Minister. We seek clarification of this omission.

It should be noted that public comment received on this recommendation may not reflect an assessment of the original proposal to reduce the maximum size for cods to 1 metre given that members of the public may have only read the Minister's 'Response' document.

4.2.3 Term of the Strategy

Recfishwest does not support the Recommendation 2 - 'Term of the Strategy' within Appendix 1 of the Minister's Responses. Recfishwest believes that given the number of inaccuracies and inconsistencies between the two reviews there will be significant teething problems. Noting this Recfishwest recommends that a process to refine the regulations after an introductory period be implemented.

4.2.4 Recommendation 10c - Fish Transportation Deeming Clause

Recfishwest strongly supports this recommendation. The possession limit is a key management proposal. Its credibility hinges upon the capacity to control the transportation of fish product from some areas whilst the consignees continue to fish further.

The important task of developing detail necessary to successfully introduce a possession limit should be referred to the working party proposed earlier in this submission.

4.2.5 Recommendations 17 to 19 - Resource Sharing.

Recfishwest requests that it be invited to work with the Department of Fisheries and the commercial fishing sector in relation to the identification of recreational only fishing areas.

Recfishwest fully supports the proposal in the Minister's response to prohibit commercial fishing from 100m around all jetties in the state.

4.2.6 Recommendation 22(a) - Artificial Reefs

This recommendation is supported by Recfishwest. However Recfishwest proposes that the recommendation be expanded to include a commitment to develop a habitat enhancement program within Western Australia.

4.2.7 Recommendation 25 - Community Education and Awareness

Recfishwest supports this recommendation but stresses that all key stakeholders must be fully involved in the strategy development.

5.0 Proposed Management Changes to the Recreational Abalone Fishery

Recfishwest originally submitted comment on the proposed abalone management changes when the paper "Future Recreational Abalone Management Arrangements" was circulated in late 1999. We have taken the opportunity to review our original comment in light of the re-release of the proposed management changes.

As a result Recfishwest has concluded that its original comment remains relevant. A copy is attached.

Indeed Recfishwest believes that given the implementation of the 'Toohey Committee' and progress toward Integrated Fisheries Management the key principles contained within our original comment has assumed greater importance.

Recfishwest has now adopted a very firm position that there must be no management changes to the recreational abalone fishery prior to the completion of the Toohey Committee process and determinations of sector allocations for the abalone fisheries.

Recfishwest contends, given the high ratio of abalone taken by commercial fishers as compared to recreational fishers and no indications whatsoever that the current total take is unsustainable, that there is no defendable basis for any reduction in recreational abalone take.

6.0 Conclusion

Recfishwest has appreciated the opportunity provided by the Minister for the community to provide additional comments on these important proposals. We have endeavoured to provide constructive comment in relation to most of the review recommendations.

However, of overriding importance to Recfishwest is the need to ensure balance and equity in the implementation of management changes and that the changes actually meet objectively developed goals.

To achieve this, Recfishwest believes that it is imperative that whilst the key possession limit initiative should be implemented immediately, all other species specific management recommendations should be deferred until we receive Government assurances that complementary effort reduction management measures are defined, and a timetable for their implementation is in place for the commercial fishing sector.

Recfishwest has proposed that a working party be established principally to undertake a review to ensure compatibility of the West Coast and Gascoyne regional recommendations and to fast track the assessment of management arrangements for other areas in the state.

Recfishwest is happy to make itself available to participate in such a process in whatever capacity that may be requested. Recfishwest would also be more than pleased to meet with the Minister for Fisheries should there be a need to clarify or further expand upon elements contained in this submission.

Submission prepared by Recfishwest



This page last updated on 30 December 2003.