Submission to the draft Rottnest Island Management Plan 2002 - 2007

Rottnest Island is the single most important recreational destination for many thousands of Western Australians and recreational fishing is very high on the list of activities undertaken there.

As the peak representative body for the estimated 645,000 recreational fishers in Western Australia, Recfishwest's major interests in the draft Rottnest Island management plan are issues and proposals that may impact on recreational fishing quality, access or amenity.

Recfishwest was looking forward to the draft plan containing constructive and innovative initiatives that could add to the Rottnest recreational fishing experience. Unfortunately from the moment of its release, this prospect has been completely overshadowed by the plan's marine zoning proposals.

Recfishwest has been stunned by the extent of the proposed no-fishing zones, the naivety of their rationale, the absence of objectives and the total lack of expert and stakeholder input into their development prior to formal release of the draft plan. We can only support our Premier who believed that these proposals had 'a snowball's chance in hell'.

For these reasons Recfishwest considers that it has no other reasonable option than to make two fundamental and important recommendations. They are:

That the marine zoning proposals are completely withdrawn from the draft Rottnest Island Management Plan 2002-2007; and

That a high level expert and stakeholder steering group be formed to separately consider, and recommend any desirable changes to the existing marine zones at Rottnest Island.

We urge that the Rottnest Island Authority seriously re-considers its approach and recognises the longer term outcomes and benefits that can be achieved by adopting the process we have recommended. Recfishwest is very firm in its position and will consider it unacceptable for the Rottnest Island Authority to do otherwise.

Whilst this submission addresses a number of the issues and proposals contained within the draft plan it principally focuses on the marine zoning proposals.

CONSULTATION PROCESS

A major issue of concern to Recfishwest is that the process undertaken to develop the draft management plan, in particular its marine zoning proposals, did not include stakeholders or any of the sources of expertise available in WA on marine zoning.

The production of this draft Plan does not in itself constitute effective consultation. Rather it represents a very clumsy short cut that has only served to greatly alienate many of the Authority's customers and at the same time set back the cause of Rottnest Island marine conservation by years.

Recfishwest view this as an abject failure on behalf of the Rottnest Island Authority for which they must be taken to task.

We draw to the attention of the Rottnest Island Authority a document recently released by the WA Premier entitled 'Consulting Citizens: A Resource Guide'. As the Authority is probably not aware of this document we enclose a copy and recommend that each of your Board members read it.

MARINE MANAGEMENT ZONES

It is difficult to know where to start with respect to commenting on the proposals to create or extend sanctuary zones in the Rottnest Island Authority marine area. Quite simply, Recfishwest has never yet received such an incompetent set of proposals for changes that would so greatly affect such a large number of users.

The arguments provided for both the size and the locations of the proposals are weak or non-existent, unsupported by any directly referenced research data, and contain no credible rationale. They simply do not demonstrate the utility of alienating large areas of the Rottnest Island Reserve from a significant number of users and user groups.

The draft Plan greatly suffers from a lack of strategic direction in respect of the rationale and longer term objectives for sanctuary zoning other than broad 'front end of document' platitudes about sustainability. We understand that the Authority has not yet undertaken any benchmark environmental studies on the existing suite of sanctuary zones. Such studies may have led to clear directions for further zoning and may have led client groups to conclude that the Authority may be able to adequately manage a larger suite of no-take zones.

For all of the above reasons, including the failure to consult with stakeholders, Recfishwest is utterly opposed to the sanctuary reservation proposals contained in the draft Plan.

Recfishwest hastens to observe that this position should in no way be construed to imply that Recfishwest is against marine reservation per se.

On the contrary we have, over the past few years, received numerous requests for comment regarding marine reservation, primarily under the provisions of Fisheries or Conservation and Land Management legislation. We have supported many of these proposals or have been able to give considered reasons as to why we were unable to so do. These include various large areas in the proposed Jurien, Barrow Island and Montebellos, and Dampier Archipelago Marine Parks as well as smaller areas such as for Lancelin Island Lagoon.

We have been able to provide such support and commentary because the proponent agencies or community groups invariably have presented a comprehensive set of supporting data or argument backed up by extensive community consultation processes, with a view to building a broad consensus. The Rottnest Island Authority has completely failed in this regard.

Your attention is particularly drawn to State Government policy as expressed in Fisheries Management Paper 152 - Guidelines for the Establishment of a Fish Habitat Protection Area, Marine Conservation Reserves - Initial Management Planning and Reservation Process (A Guide) and the Western Australian Government strategy document 'New Horizons - the way ahead in marine management'.

Recfishwest Policy on No-take Zones

Relevant Recfishwest policy on creating 'no take' zones is as follows, to be read together with a broader discussion paper as attached:

• Recfishwest is concerned at the potential for cumulative loss of recreational access to waters either currently utilised by recreational fishers or for areas that may be utilised in the future.

• However, Recfishwest also recognises that there are some justifications for the creation of marine reserves and no-take zones and that there will be situations in which these will outweigh the attendant consequential loss of amenity which may fall on recreational fishers.

• In general Recfishwest will support proposals for marine reservation and no-take zones where the following considerations are met:

- Areas proposed for reservation should have a clear reason for the conferring of exclusive conservation status;

- Decision making must be transparent and the rationale for reservation clearly articulated;

- Stakeholder consultation should be extensive and outcomes from consultation clearly result in equitable outcomes between and for existing stakeholders;

- The area to be reserved should be as large as is needed to fulfil its stated purpose, but no larger;

- Areas to be reserved should add to aggregate reserved bio-diversity; that is, areas should not simply duplicate reserves with similar ecosystems already reserved elsewhere unless there are compelling reasons to so do;

- In areas for which reservation is proposed, but for which there is significant current recreational fisher usage, there will be an increased onus for the proposing agency to articulate the benefits to the wider community which would justify the loss of amenity to the existing recreational fishing stakeholders;

- Where possible, a loss of amenity in one or more areas of a marine park should be compensated for by the creation of recreational fishing zones in other suitable areas of the same or different parks; noting however the legitimate rights of other stakeholders;

- Increases to the conservation estate should come with new monies for management requirements, but, in any case, should not be supported from the existing budget of the Department of Fisheries.

• Taking into account the reservations expressed above, Recfishwest is pleased to participate in the planning of marine parks and expects to cooperate constructively in their management. We look forward to the equitable consideration of the needs of Western Australia's 600,000 recreational fishers in future marine park planning.

The following comments are offered on the few statements offered in the draft Plan in support of the zoning proposals:

Values (Section 4.3)

Recfishwest notes and is supportive of the list of values of Rottnest Island's marine environment.

However, the values are also true of a very many lower west coast marine areas and as such should not be construed to intrinsically support a case for no-take zones. In particular, we take issue with the statement that the West End contains a "unique mixture of tropical and temperate fauna and flora species". This is simply not the case as they are represented in a vast number of other west coast habitats.

In the absence of a better rationale than a bland statement of 'uniqueness' Recfishwest objects to such being used as an argument for any specific area proposal.

Recreational Fishing ( Section 4.9.1)

This section claims that the proposed zoning scheme is justified, despite the acknowledgment that the impacts of fishing are not known, on the basis that the 'precautionary principle' should apply. We contend that this is taking the principle to an absurd length - lock it up because something might happen.

The precautionary principle applies in this context to the protection of biodiversity. The Rottnest Island Authority does not have the responsibility for maintaining Western Australia's marine ecosystems. This responsibility is carried by CALM and by the Department of Fisheries.

In practice, large reef fish such as dhufish, pink snapper and baldchin groper have long been reduced in abundance in the metropolitan coastal zone of which Rottnest is only a small part. This does not mean they are threatened from a biodiversity point of view. To establish a high abundance zone for dhufish could require perhaps a 20 km by 20 km reserve at least. Certainly Salmon Bay would not provide it.

On the other hand, the species most commonly sought at Rottnest are probably herring and rock lobster. The former swims from Western Australia to South Australia and back in its lifetime and would be scarcely affected by a reserve at Rottnest. Rock lobsters are demonstrably managed sustainably. Rock lobsters which recreational fishers do not catch at Rottnest would be caught by commercial fishers as they moved out to deeper water (usually at least 85% of each cohort of rock lobsters is caught in the year in which it reaches legal size).

Information provided from the Department of Fisheries indicates that no species are at risk in west coast waters although some areas of local depletion of some reef species may be occurring. In any case there is a keen ongoing debate as to whether sanctuary zones of the size proposed will have any broad beneficial impacts on stocks per se.

At the same time, if the objective of the zoning strategy is to provide a benchmark assemblage of stocks as for a 'virgin' area, it may well be that the zones proposed are of inappropriate dimensions as well as possibly not being proposed for appropriate locations.

Recfishwest is astounded that this section has been prepared without any reference to the existing available information. We believe that it should be withdrawn and replaced by a description prepared by suitably qualified persons.

West Coast Review

In late 1999 Fisheries WA (FWA) completed a review of the management arrangements for recreational fishing on the west coast of WA and released a discussion paper 'A Quality Future for Recreational Fishing on the West Coast - Fisheries Management paper No.139' for community input. This review was re-released as a final report in August 2001 (Fisheries Management Paper 153) by the Minister for Fisheries who again invited community input.

Recfishwest finds it extremely disappointing that the Rottnest Island Authority has not only failed to consider the review in the development of its draft plan, but appears to have been totally unaware of its existence. (neither Fisheries Management Papers are included in the list of references to the RIA's draft plan).

This is very surprising given that the Fisheries Management Papers contain a recommendation that a code of practice be introduced for recreational fishing at Rottnest Island. The proposed code achieved a very high level of support from the submissions received and Recfishwest recommends that the Rottnest Island Authority (RIA) consider the adoption of this code as recommended practice for the Island.

Anchoring (Section 7.6.2)

Recfishwest requests access to any evidence that may be held by the Rottnest Island Authority that anchoring on limestone bottom habitats causes damage as this is not our understanding. The draft management plan contains no supporting data. We believe that this matter is important considering the extent of this habitat in the RIA zone.

Spearfishing (Section 2.3.3.2)

Recfishwest does not support the recommendation to prohibit spearfishing within the boundary of the Rottnest Island Reserve.

The justification for this proposal is limited to a single sentence on page 24 of the draft report when it discusses the proposed 'Marine Recreation Zone'. This reads "This Zone also prohibits spearfishing within the Reserve to remove fishing by this efficient recreational fishing technique"

There is no evidence offered that indicates or even suggests that spearfishing is contributing disproportionately toward the overexploitation of any fish species let alone evidence that there is overexploitation to begin with.

Spearfishing is already prohibited within 800m of Rottnest Island so there can be no argument mounted that further spearfishing prohibitions are necessary on safety grounds. The current 800m prohibition zone provides sufficient protection of shallow reef areas if there is a case that this method of fishing is too efficient in these areas.

Recfishwest opposes proposals to declare prohibitions on compressed air assisted spearfishing, which at the same time would allow other forms of fishing, unless the proponents of prohibition can objectively demonstrate why prohibition is in the interests of resource sustainability or over-riding social or economic concerns.

Marine Zoning Conclusion

Recfishwest considers the draft Plan to be totally unsatisfactory in respect to all aspects of the marine environment and facilities.

The draft Plan fails to make any credible case for the proposed marine zoning and the Authority has not taken the slightest trouble to garner the necessary community support. We understand that not only were the Department of Fisheries and CALM not consulted in the production of the draft Plan but neither was the Authority's own Environmental Committee. This approach to planning is at best naive and, at worst, highly irresponsible.

Nevertheless, in an attempt to restore some commonsense to this issue Recfishwest make two very strong recommendations. They are:

1. That the marine zoning proposals are completely withdrawn from the draft Rottnest Island Management Plan 2002-2007; and

2. That a high level expert and stakeholder steering group be formed to separately consider and recommend any desirable changes to the existing marine zones at Rottnest Island.

The steering group must comprise representatives from the Department of Fisheries, CALM, MPRA and key stakeholder groups. This committee should develop terms of reference for a proper community consultation process together with guiding principles for marine zoning that would promote a considered and deliberate approach to ensuring both conservation and appropriate use of the Rottnest heritage for future generations.

BOATING ISSUES

There are a number of issues arising from the draft management plan, in addition to marine zoning, that affect recreational fishers. A principal issue of concern to Recfishwest is the management of private boats at Rottnest given that most of the boats using Rottnest waters are used to fish to varying degrees. We have made some specific suggestions that we believe would improve the Rottnest Island Management Plan and would be more generally acceptable.

Boating Advisory Committee

Recfishwest is very strongly supportive of the establishment of a Boating Advisory Committee. Recfishwest has asked for, and would certainly expect, membership as the community representative with fishing interests.

However we believe that in the past the recommendations of Rottnest advisory committees have often not even reached the Board (Norman Halse personal communication with Phillip Playford). We believe that some guarantees must be given that the advisory committees will be supported and that their deliberations will have some impact. If this does not happen the members lose interest and the committee becomes ineffective.

We recommend that an annual report from the Boating Advisory Committee be published as part of the RIA annual report.

Boating Capacity

Recfishwest believes that the number of moorings has been limited for many years.

We suggest that mooring licenses should be limited to the size of the largest vessel currently authorised to use that mooring. This would effectively prevent further growth in size of vessels without imposing any hardship on existing boat owners and it would give guidance to people contemplating new boats.

We understand that this will not completely prevent increasing boat pressure at Rottnest Island but it would make a start on the problem, which the recommendations in the draft plan do not do.

Boating Annual Admission fee

The third dot point within section 7.3.2.2 refers to an analysis of boating facility costs and revenues which concludes that all boating activity leads to a net loss of about half a million dollars per year. It also points out that the mooring license activity makes an annual profit of about half a million dollars per year.

Recfishwest has on a number of occasions, both in writing and at meetings, requested that the Rottnest Island Authority provide the details of this cost and revenue analysis. This request has been refused on each occasion.

This is not an insignificant issue. It is an important part of the lack of trust that exists between the Rottnest Island Authority and the boating community. In the past the Authority has claimed that it loses money on the mooring licenses. Now it says that while mooring licenses on their own are profitable there is an overall loss on boating activity.

Frankly, Recfishwest does not believe that a fair analysis of costs could possibly reach such a conclusion.

Given the recommendations contained within the draft plan, Recfishwest can understand the feelings of many Rottnest users who believe that components of the Island's administration have a prejudice against boat owners. The management plan proposes no increase in fees for day visitors, substantial increases for accommodation users and very heavy increases for boat owners, even though the management plan contains many potential items of additional expenditure on day visitors.

In the absence of any transparent analysis of costs and revenues, any increases in charges should be equally shared at the same percentage increase.

Licensed Moorings

The options for a new system for the allocation of recreational mooring sites are flawed in that they have not emanated from an appropriate working group that includes stakeholders ie. existing mooring licensees, authorised users and "would-be" mooring users.

The options proposed also have the disadvantage that they do not increase the availability of moorings.

Recfishwest recommends that the options for allocation and management of moorings in the draft plan be withdrawn and that the new Boating Committee be asked to consider any changes needed to the present mooring system to meet the objectives of a long term boating policy for Rottnest Island.

Recfishwest would support modifications that result in increased access to moorings by the public without alienating the existing mooring licensees.

Mooring Site Licence Fees

Recfishwest considers that the cost increases proposed in the draft plan for both mooring licensees and for authorised users are exorbitant. This is despite the extremely high profits acknowledged from these charges.

Unfortunately this issue has been seriously muddied by the purported analysis of boating costs and revenues which, as mentioned earlier, the Rottnest Island Authority will not make available. Unless this analysis can be satisfactorily examined Recfishwest cannot accept that the mooring fee increases are reasonable or warranted.

Recfishwest believes that boat owners may be prepared to accept a much smaller cost increase - at the same level of increase as a revised visitor landing fee.

Assessment of Submissions

There are a number of matters raised within the draft Rottnest Island Management Plan that have the potential to seriously disadvantage or impact upon recreational fishers and other users of the Rottnest Island resources.

Given this Recfishwest firmly believe that the submissions to the draft plan must be considered by an independent panel to ensure that the depth and breadth of community feelings on the issues raised by the Rottnest Island Authority can be objectively assessed.

Conclusion

In conclusion we urge the Rottnest Island Authority to recognise the gravity of our concerns and immediately withdraw the marine zoning proposals. However we reiterate that we would like to participate in a logical and appropriate marine planning process for Rottnest Island.



This page last updated on 30 December 2003.