Indicative Management Plan for the Proposed Geographe Bay/Leeuwin-Naturaliste/Hardy Inlet Marine

Thank you for the opportunity to provide comment on the Indicative Management Plan for the Proposed Geographe Bay/Leeuwin-Naturaliste/Hardy Inlet Marine Park (Management Plan).

Recfishwest is the peak body representing the interests of the estimated 788,000 recreational fishers in Western Australia. We are formally recognised and funded by the Government in this role. Recfishwest places the highest priority on safeguarding the future of recreational fishing and the resource it depends on in Western Australia. The habitat in which fishing is carried out and access to that habitat is of particular significance to Recfishwest.

Recfishwest recognises that a marine park is a resource for the entire community and although it is vital to have local community involvement, the importance of a strategic, state-wide viewpoint can not be discounted.

Recfishwest expressed particular concern on several occasions about the Capes Marine Park advisory process, including the exclusion of government recognised recreational fishing representation on the Capes Marine Parks Advisory Committee (CMPAC). As the major stakeholder, recreational fishers are the group most affected by these proposals. However this should in no way detract from the diligent contribution of local recreational fishing members of the CMPAC, Ray Walker and Graeme Walker, who were able to achieve what Recfishwest largely believes are sensible outcomes for recreational fishers in the Management Plan.

We are encouraged by more recent efforts of the Department of Environment and Conservation Marine Policy and Planning Branch (DEC) and the Marine Parks and Reserves Authority (MPRA) to engage Recfishwest and recreational fishers in a meaningful way in the marine parks planning process.

Recfishwest believes that the Marine Park challenge in terms of recreational fishing is to adequately provide for the conservation values of a marine protected area in an equitable, integrated and sustainable manner while minimising the impact on the historical and social values of recreational fishing. There appears to be several limitations to achieving this outcome and a general lack of understanding of the economic and social benefits of ecosystem scale impacts of recreational fishing in terms of Marine Protected Areas (MPAs) or biodiversity conservation.

The plethora of marine natural resource management processes that are available to effectively manage the impact of recreational fisheries in marine parks should be considered in lieu of almost solely focusing on sanctuary zoning. In certain circumstances management options other than sanctuary zoning can lead to better outcomes more acceptable to recreational anglers and also deliver the conservation values of the marine park.

The justification behind the proposed sanctuary zoning needs to be far more transparent to assure recreational fishers that DEC is able to equitably implement a marine park proposal that is able to meet clearly defined biodiversity conservation objectives.

There appears to be little justification on the basis of risk assessment for most of the proposed sanctuary areas in the Management Plan. The Interim Marine and Coastal Regionalisation of Australia (IMCRA) process requires that "no-take" areas are based on a known level of threat. Under the auspice of the Australian and New Zealand Environment and Conservation Council (ANZECC) process, Australia has agreed to general principles that should be followed when marine parks are established. One of the principles of this process is that "no-take" areas should be established and sized based upon the level of threat.

If it is proposed that areas are designated as "no-take" solely as a precautionary approach based on little or inconclusive research, then at least the risks should be identified so that the most appropriate strategies can be used to mitigate those threats. Recfishwest believes the criteria used to select representative areas and the criteria used to select sanctuary zones and their subsequent sizes needs to be far more transparent.

There are substantial gaps in our understanding of recreational fisheries in terms of usage, gear, catch and the variability through time within proposed MPA boundaries, within proposed zones, adjacent to proposed boundaries and outside proposed boundaries to increasing distances and importantly before and after declaration of MPAs as in the establishment of zoning processes. This information is important when planning MPA zoning arrangements and as a consequence of the liberal application of the precautionary principal this sort of information does not appear to be a priority for MPA research.

The proposal to study some of these parameters as part of Western Australian Marine Science Institute Node 3 for Ningaloo and Jurien have so far failed to engage recreational fishers at the design stage. This potentially comprises the objectivity of these projects and particularly those with socioeconomic objectives.

Recfishwest believes that the size of areas DEC is proposing to close as no-take areas will have no effect on recruitment of the species predominantly targeted by recreational anglers in the Capes region including salmon, herring, tailor, whiting, silver trevally, snapper, Samson fish, bonito and southern bluefin tuna; all of which are schooling or pelagic species.

There is limited justification for most of the proposed sanctuary zones. Why are the sanctuary areas the sizes they are? How are sanctuary areas protecting that which is at risk by excluding recreational fishing? Are there alternative management strategies that can be applied through existing Department of Fisheries legislation to achieve biodiversity conservation outcomes?

Appropriate fisheries management has a far greater potential for the long term conservation of these fish, than closing insignificant areas (relative to the distribution of these species) to line fishing. DEC must be considerably more prescriptive regarding the risks that threaten the representativeness of the particular area that it contends to be protecting.

Recfishwest is concerned the information made available to the public for comment is lacking in both quality and quantity. The wider community has not been adequately informed about the reasoning for each proposed zone area. Descriptive documents themselves did not contain enough information regarding the reasons for or risks associated with the representative areas proposed for zoning. Furthermore several inconsistencies and what seem to be clumsy errors appear in the Management Plan, making comment on the proposals at times challenging;

• Several inconsistencies appear in the permitted usages table (pg.20).
• Confusion exists between options for the proposed Busselton Jetty Sanctuary Zone. The maps options and text options do not correspond.
• There is no textual justification provided in the Management Plan for the proposed Central Geographe Bay Sanctuary Zone.
• There is confusion regarding the Lefthanders Special Purpose (surfing) Zone and what it actually refers to. Is this the Ellensbrook Zone?
• There is confusion regarding which Special Purpose (surfing) Zone allows recreational rock lobster potting. Is it the Margaret River" or "Lefthanders" Special Purpose (surfing) Zone?

Recfishwest believes that consideration must be given to objectives that are realistic and socially acceptable for this area, and to prescriptively assess activities that are a risk to the areas under question to achieve those objectives. Other pressures on these areas need to be taken into consideration, particularly those activities such as eutrophication, run-off and lack of water flow (Ellensbrook) from terrestrial sources that may have considerably greater impact than the activities proposed to be banned. Only then can those threats be appropriately managed. It was encouraging to see acknowledgement in the Management Plan (pg V. par.3) of the impacts of adjacent land use activities and infrastructure developments on fish populations, sea grass meadows and water quality, but sadly little in the way of management proposals to mitigate or even study in an ongoing way their historical or cumulative impact.

The following comments refer to each proposed zone within the Management Plan.

Sanctuary Zones

Eastern Geographe Bay Sanctuary Zone
Recfishwest has no strong objection to this proposed sanctuary zone. We support the 300m offset buffer from the shore line to allow line fishing from shore, we believe there to be negligible benefit in banning recreational line fishing for finfish from the shore or by wading in this area. The intended sanctuary zone is professed to be representative of mixed perennial seagrass and we contend that shore based line fishing will have no impact on that environment. We also consider that fishing for pelagic species will pose negligible risk to benthic structure and related communities that this area is proposed to protect.

Recfishwest would like to see some form of anchoring management if the primary target of protection for this area is the sea grass and associated limestone reef system. If there is an identified risk from anchor damage to benthic structure then appropriate anchor management is much more likely to effectively protect benthic biota than simply zoning an area as a sanctuary zone. Anchoring restrictions to designated areas and or moorings or prohibited anchoring in areas that are perceived to be at risk will have far greater benefit in terms of conservation values.

The DEC Mooring Policy does little to tackle the risk to the proposed seagrass meadow protection area from indiscriminate anchoring. Proclaiming the area a sanctuary zone without an anchoring management strategy fundamentally fails to address an obvious and also manageable risk.

Busselton Jetty Sanctuary Zone Options
It is difficult to provide support or otherwise for this proposal due to the inconsistency between the text and the maps in the Management Plan depicting the proposed options for the zone. The map depicting Option 1 is actually Option 2 in the text and the map for Option 2 refers to Option 1 in the text. This error means that any indicated preference from submissions merely stating option 1 or option 2 can not be relied upon, and should not be considered in an analysis or summary of submissions unless the submission clearly indicates which option is preferred in terms of; the current FHPA or the entire end of the jetty. Recfishwest strongly supports the option for the sanctuary zone to have the same boundaries as the current S43 notice of the Fish Resources Management Act 1994.

The end of the iconic Busselton jetty is of considerable importance to recreational fishers for many reasons that include history, community stewardship and opportunity. The end of the Busselton jetty has been fished by recreational anglers for over 100 years with little impact on the coral and/or invertebrate communities, which have coexisted with recreational fishing since the jetty's construction.

The end of the jetty provides the unique opportunity to fish for large migratory pelagic species such as bluefin tuna, yellowfin tuna, yellowtail kingfish and Samson fish that do not frequent the main length of the jetty, but more frequently sweep around the end of the jetty.

The area is one of the very few fishing platforms on our entire coastline that offers a deep water fishing opportunity for the many anglers including the elderly and infirm who do not have access to a boat and would thus generally not have exposure to this type of fishing. The end of the jetty importantly allows the exclusive opportunity to fish during the prevailing strong southerly and south easterly winds.

The jetty is an asset which belongs to the whole community. Historically recreational fishers, both individuals and fishing clubs have played a significant role ensuring the Busselton jetty was preserved and maintained at a level that allowed the whole community to enjoy what it has to offer. Considerable contributions were also made toward the repair of the jetty from taxpayers' funds through the Government's Regional Infrastructure Fund.

Recfishwest accepts that some area free from recreational fishing may be required for safety of divers and to preserve resident fish around the observatory so that users get a good experience from visiting the observatory or diving in the area. Recfishwest continues to support, a 50 metre radius exclusion zone around the underwater observatory. However recognition of the importance of the end of the jetty to shore bound recreational anglers must not be ignored.

The Shire of Busselton carried out extensive public consultation and ultimately decided to support a 50 metre radius exclusion zone around the underwater observatory. The proposed option to increase this exclusion zone ignores the Shire's clear and transparent measurement of the public's opinion and we believe the more restrictive option is not in tune with the opinions of the greater community.

Central Geographe Bay Sanctuary Zone
Recfishwest is disappointed at the textual omission of this zone in the Management Plan. The zone is identified in the map at the rear of the Management Plan but no justification is provided for this zoning. What is it proposed to protect or be representative of?

This is an example of Recfishwest's concerns that the information provided to the public for comment is lacking in both quality and quantity. The wider community has not been adequately informed about the reasoning or justification for this proposed zone area.

It is extremely difficult to provide support or otherwise for this proposed zone, or even suggest support if changes were made. We cannot assume the reason for the zone and as such we are unable to comment. Recfishwest seeks clarification as to the need for two zones that are almost exactly the same in their ecology and that are so close together. It was stated at two public meetings that the main reason for both these areas was to monitor the effect of terrestrial out-flow from two distinct sources around Geographe Bay. If it is to monitor the effects of water quality then why is there a need to impact fishing. One area is sufficient to be "representative" and I feel there needs to be more work done to determine a more appropriate site.

Eagle Bay / Meelup Sanctuary Zone
Recfishwest believes that the proposal for this sanctuary zone initially grew from a suggestion to increase the protection around the HMAS Swan. We agree that the area concerned is important to a range of stakeholders. Recfishwest does not oppose expanding the fishing prohibition zone around the HMAS Swan to a one kilometre diameter, and zoning this area as a sanctuary zone to give non-consumptive recreational divers an increased buffer zone around this unique and popular dive structure. We must acknowledge that this is an artificial structure that was put in place to provide an easily accessed dive site and it is a valuable tourist attraction.

It is difficult to comprehend how the popular form of boat fishing in this area, predominantly trolling and drifting for salmon, bonito, southern bluefin tuna, whiting, herring, skipjack trevally and squid could possibly impinge on the benthic habitats that the proposed zoning implies to protect. Surely a sensible anchor management program will do far more to protect this habitat?

Recfishwest will not support the proposed zoning unless shore based recreational fishing is allowed along the entire zone. We point out that the Meelup beach area is regarded as one of the most important family fishing locations in the south west region. It is an area where families with young children who cannot fish from rocks are able to fish from shore in safety and have done so for many years. The beach has easy access and receives considerable protection during strong westerly and south westerly winds making it a favourite salmon fishing location for families during the Easter break and the May school holidays.

Also note that this is the only location that we request is left open to beach-based fishing contrary to the proposals presented within the Management Plan.

Cape Naturaliste Sanctuary Zone Options
Recfishwest notes that option 2 was the primary choice developed through the advisory committee process and we have concerns that it has been presented in the Management Plan as an alternate option to that described in the main chart giving the perception that it is actually the 2nd option. This is disappointing, because the more suitable option 2 was actually developed through extensive discussion by the CMPAC.

Recfishwest has received community feedback regarding the proposed sanctuary zone around Cape Naturaliste. We are disappointed that important safety issues were ignored concerning the frequent need for small boats to take cover from the strong prevailing east and south easterly winds by sheltering on the western side of the Cape, and still be able to fish in the area while waiting.

The majority of boats fishing the area are small in size and are launched from the Dunsborough boat ramp. A considerable distance is travelled to reach the general surrounding area which provides the unique opportunity of allowing small boats to access deeper water for species of fish not so prevalent in the shallows of Geographe Bay itself. The area in the immediate vicinity of the Cape is also an important recreational rock lobster fishing area for recreational divers.

Recfishwest strongly believes that the southern boundary of the proposed sanctuary zone should be moved north to a point level (in an east - west direction) with Cape Naturaliste. In compromising these boundaries it is suggested that the western boundary be expanded by a further one and a half kilometres westward.

If the proposal to adjust the boundary of this zone is not accepted we do not support this option, but will support Option 2 as developed by the CMPAC. Recfishwest sees little gain in disallowing shore based fishing in the proposed sanctuary zone for the reasons made earlier in this submission and based on the limited number of people that make the effort to fish in such remote locations.

Yallingup Reef Sanctuary Zone
Recfishwest supports the no-take zone within Yallingup lagoon to allow adults and children to dive and snorkel. We also recognize that the area at the southern end of Yallingup beach is of great significance to holidaying and visiting recreational anglers. The southern corner of Yallingup beach has for many years provided protection from persistent swells, allowing children and adults to fish for salmon, herring, skipjack and whiting. We support the Sanctuary Zone proposal to allow recreational shore-based fishing from the southern extreme of the Yallingup sand beach at the outer north western end of the proposed zone.

Reef trampling especially by surfers was identified as the major issue in this area. We note that the Yallingup lagoon area is protected as a Fish and Fish Habitat Protection Area under Department of Fisheries legislation and has significant community support.

Wyadup Sanctuary Zone
Recfishwest supports this proposal as it allows access to important beach fishing areas adjacent to the proposed Injidup Sanctuary Zone whilst ensuring adequate representation of equivalent shoreline in the Wyadup area. We are however concerned that this proposal was not part of the extensive consultation process and we have recently been made aware of the importance of this area to shore-based spearfishers.

Injidup Sanctuary Zone
Recfishwest supports the modified boundaries of this proposed sanctuary zone. We believe that the Injidup area is of particular importance to land-based recreational fishing and local Aboriginal communities. We have received little feedback regarding offshore fishing and consequently are unable to make comment with respect to boat fishing in the proposed area.

The Injidup area has special value to shore based anglers who are prepared to make the considerable effort to get there. This area is one of the few locations that provide access to deep water from the shore. It can only be fished under very calm conditions.

Cape Freycinet Sanctuary Zone
Recfishwest supports the proposed sanctuary zone and the 200 metre offset where recreational fishing will be allowed. We believe that shore based fishing should continue in the area as it is in close proximity to DEC camping areas. The area, including Bob's Hollow and Contos, represents a very popular family shore based fishing location.

Hamelin Bay Sanctuary Zone
Recfishwest agrees in principle to the protection of the intertidal areas and inshore reefs around Hamelin Island.

Cosy Corner Sanctuary Zone
Recfishwest supports the proposed sanctuary zoning at Cosy Corner. In earlier versions of the proposed zone we held concerns over the means by which the area was proposed. The CMPAC changed the proposed boundaries from an area which had some acceptance by recreational fishermen to one that suited professional abalone fishermen and issues regarding potential compensation. The end result was a zone which effectively excluded recreational fishing from a very popular fishing location.

The area is easily accessible and used by many recreational anglers who take advantage of this area that can be fished during strong winds. The headland area has long been renowned for the large fish that can be caught from the shoreline. Recfishwest strongly supports the proposal to allow recreational fishing from the shoreline in this proposal.

Cape Leeuwin Sanctuary Zone
Recfishwest has no strong objection to this proposed sanctuary zone.

Flinders Island Sanctuary Zone
Recfishwest broadly supports this amended zoning.
East Flinders Bay Sanctuary Zone
Recfishwest supports the proposed sanctuary zone boundaries in recognition of the strong recreational values of this area, in particular the very popular fishing location at Bessie's Reef.

Dead Water and Swan Lake Sanctuary Zones
The Dead Water is becoming progressively smaller as the river mouth moves further east. Recfishwest has been provided with anecdotal evidence suggesting that decades ago the mouth of the Blackwood River entered the ocean at the eastern end of the Dead Water and was moved west to the Colour Patch by human intervention. Over the past twenty to thirty years the river mouth has progressively returned toward its original course and at present has almost returned to its original position. It is believed that at the present rate of movement, the area known as Dead Water will not exist within a few years. Declaring the area a sanctuary zone could be perceived as a waste of the states time and resources.

Swan Lake has historically been used by local recreational anglers, especially people from East Augusta, who fish for crabs, King George whiting, cobbler and occasional black bream. It is also acknowledged that the Swan Lake area is a significant nursery for estuarine finfish.

North Bay Sanctuary Zone
The proposed sanctuary zone shallow water area is of particular importance to catch and release sportfishing and fly-fishing anglers targeting black bream and other estuarine species. We believe that consideration should be extended for the insignificant impact of catch and release fishing within this area.

Recfishwest contends that sanctuary zoning is not the solution to the problems in Hardy Inlet. Problems within the inlet have stemmed from poor environmental health in the catchment from salinity and nutrient run-off, which has historically resulted in significant fish kills.

Special Purpose (Surfing) Zones

Recfishwest acknowledges the world-class value of this coastline to the surfing community and we do not have any objections to the proposed Special Purpose (Surfing) Zones in the spirit of resource sharing and safety.

We must however point out that several inconsistencies appear in the permitted usages table (pg.20). The spirit of the resource sharing negotiations with local surfing representative Reg Massie and the then CEO of Surfing WA Mark Lane were centred on the issue of safety. The intent of the zones is to ensure that surfers are not put at risk by floats and ropes associated with commercial and recreational rock lobster potting only.

There seems to be confusion in the Management Plan regarding rock lobster fishing. There are fundamentally two ways by which recreational fishers catch rock lobster, one method is "potting" the second method is by "hand". The activities prescribed in table 2 (pg.20) refer to "non shore-based" and "shore-based". The intent was never to ban "shore-based" rock lobster fishing by "hand" as evident by the permitted activity of "taking of invertebrate on compressed air" in the same Special Purpose (Surfing) Zones. The activity that was intended to be restricted from this zone is recreational rock lobster potting, not the taking of rock lobster by hand. Recfishwest supports the recreational take of rock lobster by hand in the Special Purpose (Surfing) Zones.

There is also a great deal of confusion within the Management Plan regarding the Lefthanders Special Purpose (surfing) Zone and what it actually refers to. The Lefthanders zone does not appear in the coloured maps at all, but it appears in the text (pg.26). The coloured maps do show the zone immediately south of Cowaramup Bay as the Ellensbrook Special Purpose (Surfing) Zone. Is the Lefthanders zone actually the Ellensbrook Zone? This sort of error makes it difficult to provide informed comment on proposed zoning.

Further confusion arises in the Key for the table of permitted activities (pg.20) where it states with regard to no recreational rock lobster fishing in Special Purpose (Surfing) Zones "k. to ensure consistency with Fisheries rock lobster closures in the proposed marine park, recreational rock lobster fishing is only permitted in the Margaret River Special Purpose (Surfing) Zone." However in the text (pg.26) it is stated that " Commercial and recreational rock lobster fishing is not permitted in all Special Purpose (Surfing) Zones, except for the Lefthanders Special Purpose (Surfing) Zone, in which commercial rock lobster fishing is prohibited but recreational rock lobster fishing is permitted". Which zone is it intended to permit recreational rock lobster fishing potting? Margaret River or Lefthanders?

Recfishwest supports the Margaret River Special Purpose (surfing) Zone to allow recreational rock lobster potting. The zone is a considerably large area and its proximity to the boat ramp has historically made this an important recreational rock lobster potting area that has coexisted for many generations with surfers.

Special Purpose (Shore - Based Activities) Zones

Eagle Bay Special Purpose (Shore - Based Activities) Zone
Recfishwest support the proposed Eagle Bay Special Purpose (Shore - Based Activities) Zone but as per our comments for Eagle Bay/Meelup sanctuary zone we believe that the community should be allowed to fish from shore in the Meelup area to reflect the historical and social importance to family fishing.

Recfishwest would prefer that shore based recreational fishing is allowed along the entire zone. We point out that the Meelup beach area is regarded as one of the most important family fishing locations in the south west region, it is an area where families with young children who cannot fish from rocks fish from shore in safety and have done so for many years. The beach has easy access and receives considerable protection during strong westerly and south westerly winds making it a favourite salmon fishing location for families during the Easter break and the May school holidays. Also note that this is the only location that we request is left open to beach-based fishing contrary to the proposals presented within the Management Plan.

Cosy Corner Special Purpose (Shore - Based Activities) Zone
Recfishwest strongly support this area in acknowledgement of the high social value and long tradition of line fishing from the headland at Cosy Corner.

Recreation Zones

Cowaramup Bay Recreation Zone
Recfishwest strongly supports this area in acknowledgement of the high historical recreational usage in the area. Recreational line fishing has occurred for many years in this popular bay, it represents the only protected fishing location for a considerable distance and is patronised annually by many families that take advantage of the protection and fish from shore or boat for the likes of herring, squid and free diving for lobster and abalone. We also note that Cowaramup Bay is already protected under Fish and Fish Habitat Protection as the Cowaramup Reef Protected Area.

Again there seems to be confusion regarding the take of rock lobster by recreational fisher in terms of take by potting versus take by hand. There are fundamentally two ways by which recreational fishers catch rock lobster, one method is "potting" the second method is by "hand". The activities prescribed in table 2 (pg.20) refer to "non shore-based" and "shore-based" the permitted activity of "shore-based" conflicts with the non permitted activity of "taking of invertebrate on compressed air" in the Recreation Zones. Recfishwest supports the take of rock lobster by hand by breath-hold divers and those using compressed air from shore. Recfishwest believes that the intent of the CMPAC was to restrict recreational rock lobster potting in this zone, not the taking of rock lobster by hand.

Recfishwest also contends that "non-shore based" rock lobster fishing should be allowed in the proposed Recreation Zone to correlate with the Department of Fisheries commercial rock lobster closures permitted activities. The Bay is traditionally a very popular recreational rock lobster potting location. Recreational Rock Lobster pots are customarily set in the deeper waters of the bay to the west of the northern point extending across the Bay to deeper water. Recfishwest have concerns that the safety of small boat recreational rock lobster potters will be compromised if they are forced to set pots outside the Bay

Hamelin Bay Recreation Zone
Recfishwest in general supports the need for recreational zoning of this area. We agree that there is a need to manage activities in this area, and that prescription of appropriate activities will need to be identified through further consultation. Recfishwest maintains that prescribed activities must include provision for recreational fishing in this area.

Recfishwest does accept that boat traffic in the area needs to be managed to reduce conflict between boat and snorkellers and other usage. However, we note that recreational snorkellers are not being asked to make a single concession anywhere in this plan and this may represent an occasion where keeping the snorkellers away from the boats is in the best community interests. Using boat channels and speed limits in a boating management plan would be useful since the boat ramp is situated in the middle of many activities and is clearly the responsibility of another government authority.

Our previous comments regarding the recreational take of rock lobster also apply to this proposed zone. There again seems to be confusion in the Management Plan regarding rock lobster fishing. There are fundamentally two ways by which recreational fishers catch rock lobster, one method is "potting" the second method is by "hand". The activities prescribed in table 2 (pg.20) refer to "non shore-based" and "shore-based" this is both confusing and misleading. The intent of the proposed zone and allowable activities was not to ban the take of rock lobster fishing by "hand" but to prohibit "potting". Recreational rock lobster potting was the activity intended to be restricted in this zone, not the taking of rock lobster by hand. Recfishwest supports the recreational take of rock lobster by hand in Recreation Zones.

Other Zoning Issues

Kilcarnup/Gnarabup Area
Recfishwest in general supports the need for special purpose zoning of this area. We agree that there is a need to manage activities in this area, and that prescription of appropriate activities will need to be identified through further consultation. Additionally Recfishwest believes that some proviso for recreational fishing should be maintained in the area. Without specific proposals no further comment is possible at this time.

Further consultation needs to be undertaken with the Shire of Augusta Margaret River and stakeholders to identify appropriate management strategies for the area. The area in question is in proximity to residential and holiday accommodation it is an important area where rock lobster are taken by recreational divers, prescribed activities must
include provision for recreational rock lobster fishing and line fishing from shore.

Conclusion
Recfishwest believes the justification behind the proposed sanctuary zoning needs far more transparent exposure to assure recreational fishers that DEC is able to equitably implement a marine park proposal that is able to meet clearly defined objectives.

Recfishwest is concerned the information made available to the public for comment is lacking in both quality and quantity. The wider community has not been adequately informed about the reasoning for each proposed zone area. Descriptive text did not contain enough information regarding the reasons for, or risks to the representative areas proposed for zoning. The other major risks to biodiversity conservation are terrestrially derived and outside of the influence of the MPRA process.

Recfishwest insists that, as part of the management plan for the proposed marine park that research be undertaken to address what impact recreational fishing for the pelagic species will have on the representativeness that is under protection. Recfishwest does not have any fundamental objection to closing limited explicit areas to the taking of specific species of resident fish, but these areas would have to be explained and justified.

Please do not hesitate to contact our office should further information or clarification be required.

Yours sincerely



Frank Prokop
Executive Director

15 December 2006

CC Hon Tony McRae, Minister for the Environment
Hon Jon Ford, Minister for Fisheries
Peter Millington, Acting CEO, Department of Fisheries.
Doug Bathgate, Chair, Recreational Fishing Advisory Committee



This page last updated on 22 December 2006.