Recfishwest submission:-
Stokes Inlet Draft Management Plan 2007.

Mr Mieke Bourne
Department of Water
Policy Officer - Estuary Management Plans
PO Box 525
ALBANY WA 6331

Dear Mr Bourne

Re: Draft Stokes Inlet Management Plan

Thank you for your letter of 19 October asking for comment on the Draft Management Plan for Stokes Inlet.

The principles and issues which you and we have raised in response to this draft are being replicated, frequently in a similar fashion, throughout Western Australia and beyond. Recfishwest believes that our efforts are best spent in providing input into the development of such plans, rather than in commenting on full proposals.

In this case, we could have provided a briefing on the research and history aspects associated with recreational fishing. The government representatives are not always in the best position to provide objective information.

Recfishwest has long been concerned about the development of equitable management strategies for the South Coast estuaries.

The South Coast commercial fishery was the beneficiary of a substantial readjustment package, with more than $1 million of taxpayers money spent to reduce the number of licensees. It was an explicit condition of the Cabinet approval for this Fisheries Adjustment Scheme (FAS) that there be a tangible shift in the resource from the commercial to the recreational fishing sector. In fact, the catch has not reduced, yet the commercial fishery has been the beneficiary of a taxpayer funded restructure.

Recfishwest has been advocating, as a matter of highest priority, for Stokes Inlet to have commercial and recreational netting prohibited for more than 8 years. Included are several examples of correspondence on this matter over many years.

The Department of Fisheries has made no attempt to discuss recreational fishing concerns about this management plan with either Recfishwest, the peak body, or RFAC, the statutory body, on this matter.

Recreational fishing is clearly an important activity at Stokes Inlet. With the increase in interest in catch and release fishing for black bream, the most important species in the estuary, the opportunity exists for Esperance and associated areas to gain significant benefit from tourism. Low impact recreational fishing is to be encouraged.

Specific comments on the recommendations:

Action F1: Recfishwest believes that Stokes Inlet should not have either commercial or recreational netting permitted. This should be implemented immediately.

Recreational gill netting is not consistent with the ethos of recreational fishing, although it is strongly supported by a small number of people who use nets. By-catch is high and many nets are used to take species other than mullet. Recreational netting has been scheduled for removal since 1992 a position which was reinforced in 1996 in a recreational netting review and should now be removed along with commercial netting.

Recfishwest, as the peak body, recognises that this will not be universally popular, but the commercial adjustment should have been made as part of the FAS and recreational netting has been on notice since 1992, which is more than generous.

As with Walpole estuary to the west, Recfishwest believes that there will be considerable economic and amenity value increases in encouraging recreational line fishing in Stokes Inlet.

Action F2: There is no reason why on social, economic or political grounds (given the Cabinet decision) that commercial netting should be permitted in Stokes Inlet. Implementing something that should have happened nearly 10 years ago makes this recommendation superfluous.

Action F3: The issue of allocation of the black bream stocks in Stokes Inlet is not a priority for the Integrated Fisheries Management process. Recfishwest has made recommendations for additional species such as blue manna crabs and these have not been supported.

Action F4: We support monitoring Stokes Inlet bream populations, but need to recognise that a major study, including an assessment of bream stock enhancement has now been concluded for the Hardy estuary. The Murdoch study on the South Coast is being finalised and replicating it is not likely to be cost effective. A low level sampling project to determine spawning success would be more appropriate.

Recfishwest is concerned that this recommendation is being used to avoid taking on the real ecological issues in Stokes Inlet and the surrounding catchment.

Any monitoring program must have tangible and measurable management responses as part of the process. Otherwise the collection of data for its own sake is not supported.

Action F5: Much research has already been undertaken and this will be an expensive exercise. Recfishwest strongly supports an attempt to get greater participation in the Angler Log Book program run by the Department of Fisheries.

There has already been considerable work done on the survival of released black bream, including considerable work by Challenger TAFE in the Blackwood estuary and by NSW Fisheries on hooking mortality and by Victorian Fisheries on movement and migration patterns of black bream. The Department of Fisheries should be able to provide the committee with these papers.

Action F6: As a rule, Recfishwest does not support artificial manipulation of the bar. The recent, fully supported decision by the EPA regarding Wilson's Inlet that a management plan must include an assessment of impact should also apply to Stokes Inlet. This will require a commitment by the Department of Water to prosecute anyone interfering with the bar opening as we hope is happening as a result of the recent breaching at Torbay.

If the bar needs to be breached, then the timing should take into account biodiversity benefits and the opening should be timed to allow maximum exchange of species out of and into the estuary which is an extremely important nursery.

Action F7: Recfishwest supports identifying refugia areas in upstream areas. Murdoch University in particular has special expertise in this area and should be engaged with the Department of Fisheries.

This action requires a clear commitment from the Department of Water and other authorities to take remediation action to protect these refuges.

Recommendations A1 and 2: In recent years, it has been pleasing to see a considerable cultural shift within DEC, culminating in an excellent process for the management of Walpole-Nornalup.

However, we are cautious about a greater vesting of areas in DEC who have reduced recreational fishing amenity in a number of areas on the South Coast by closing off access tracks with limited or no consultation. These recommendations need careful monitoring.

Actions A5 and A6: Recfishwest is aware of the issues involving the interaction of water skiers and recreational fishers and canoeists. The problem is one where the enjoyment of many can be impacted upon by one person ignoring the rules and 'showboating' outside of designated rules.

We recognise that this is a challenging issue for the committee. The issue of wash derived erosion is one that is generally poorly handled. A speed limit of 5 knots reduces speed related incidents, and makes the water ski issue moot, however, for many boats this is the speed at which the greatest wake is generated.

Recfishwest believes that the speed and activity regulations for Stokes should be jointly administered by staff of DEC, DPI and Department of Fisheries and all should be trained in handling on the water compliance issues in a sensitive manner.

Action CH2: A total ban on four wheel drives to the mouth of the inlet is an unnecessarily adversarial approach to an important and sensitive issue which should be worked through.

Recfishwest believes that a sub-committee should be set up with traditional owners to see if access can be maintained that does not impact on the cultural values. For example, Recfishwest has worked with Doc Reynolds for many years and has found him to be an excellent promoter of workable outcomes.

Action CE4: Stokes Inlet is an important local resource but it is also important to the wider community both from an access perspective and the fact that it acts as a nursery for bird and fish species with a very wide distribution. It is therefore important that the working group engages the wider community, which perhaps it could have done better in the development of this plan.

Recfishwest would be pleased to provide further information on this submission. Please feel free to contact the office on (08) 9246 3366.

Yours sincerely

Frank Prokop
Executive Director
Recfishwest

25 November 2007

Cc. Hon Jon Ford - Minister for Fisheries
Hon David Templeman - Minister for Environment
Hon John Kobelke - Minister for Water
Peter Millington - Director Department of Fisheries
Doug Bathgate - Chairman RFAC
Alan Longbottom - Chair Esperance-Goldfields RFAC

Extracts from the draft management plan October 2007 appended here so that Recfishwest's comments can be read in context because the DRAFT document is no longer available on the WAWater website.

Draft:- Proposed Action F1. Educate the community about the sustainability of the commercial fishery and its management.

Explanation: Stokes Inlet is one of 13 estuaries that make up the South Coast Estuarine Fishery. Community perception of the commercial fishery at Stokes Inlet suggests that there is not a good understanding of its management or purpose. Community education about how the fishery is managed and its sustainability, including recent restrictions to the fishery, catch data and the results from recent research would be beneficial to improve this. This could take place through the media, workshops or presentations. This action will form part of a broader education action and should therefore be overseen by the multi agency management group. It is expected that the Department of Fisheries will provide information relating to the fishery to assist in the implementation of this action.


Draft:- Proposed Action F2. Request that the Minister for Fisheries reconsiders the current sharing of Black Bream between commercial and recreational fishers.

Explanation: A section of the community believes that commercial fishing should be reduced at Stokes Inlet. As there is no evidence that the commercial Black Bream fishery is unsustainable the issue is considered by the steering group to be more one of equity and resource sharing rather than stock sustainability. It is proposed that the Stokes Inlet Management Group write to the Department of Fisheries requesting that the Minister for Fisheries reconsider the sharing of Black Bream etween commercial and recreational fishers at the inlet based on the information and submissions to this plan. Possible options to improve the perceived sharing of the Black Bream fishery include:

• adjust boundaries of the commercial fishery to exclude estuarine reaches of the Young and Lort rivers to reduce user conflict in the river areas,

• restricting the number of fishers who are licensed to fish the inlet to those that have fished it historically, and

• reducing the amount of time each year that the inlet can be commercially fished.


Draft:- Proposed Action F3. Promote Stokes Inlet as a priority for Integrated Fisheries Management.

Explanation: Department of Fisheries anticipate reviewing the allocation of fin fish resources for the south coast, including the fishery at Stokes Inlet, through the development of Integrated Fisheries Management (IFM). There is a need for this approach at Stokes Inlet and it is recommended that the Department of Fisheries highlight the inlet as a priority for the IFM.


Draft:- Proposed Action F4. Support continued monitoring of the Black Bream population size and health.

Explanation: The Centre for Fish and Fisheries Research at Murdoch University has undertaken studies of estuarine fish populations for many years. Given the importance of Black Bream, monitoring of this species needs to continue into the future. One outcome of the present studies should be to recommend a cost effective method of long term monitoring.


Draft:- Proposed Action F5. Promote research into the impacts of recreational fishing on Black Bream with a focus on catch and release survival rates.

Explanation: Black Bream in the inlet are slow growing and are likely to be caught and released many times before they reach the minimum legal size. The impact of recreational fishing on the population and the survival rates of the released Bream is not well understood. Existing information needs to be researched and options explored to assess the survival rates and additional research may need to be undertaken, that could include tagging. Additionally, little is known about the catch rates and effort associated with the recreational fishery. Supporting existing volunteer programmes is one way of gaining this information as is conducting intensive surveys at the inlet.


Draft:- Proposed Action F6. Interference with the sand bar should not be supported.

Explanation: It has been suggested that artificial opening of the bar could lead to greater fish recruitment and flush the inlet when salinities are too high. Bar interference at other estuaries along the South Coast has not been very successful. If a bar is opened before sufficient water levels are achieved to cause a natural break then the water exchange is severely limited and often results in wave action closing the bar soon after. As Stokes National Park extends to low water mark the bar is part of the park and hence managed by the Department of Environment and Conservation.


Draft:- Proposed Action F7. Describe the fish faunas of upstream pools and identify pools that have the potential to act as refugia for fish species in the Young River.

Explanation: The importance of upstream pools as refugia for fish species has been demonstrated in other inlets. Significant upstream pools that have the potential to act as refugia for fish have not yet been identified in the upstream pools associated with Stokes Inlet. Salinities within the basin and estuarine reaches of the tributaries of Stokes Inlet are approaching those known to be lethal to all but one species of fish that inhabit this system with increased frequency. There is thus a strong need to identify upstream pools that act as refugia on the tributaries of Stokes Inlet and to determine the number of species, densities of fish and species compositions in these pools.


Draft:- Recommendation A1. Investigate options for changing the tenure of the inlet.

Explanation: The present tenure of the inlet and parts of the Young and Lort rivers below the South Coast Highway are of concern as they are not vested in any management authority and their purpose and value is not recognised. This needs to be addressed so these areas can be better protected. Changes in tenure should involve public consultation and be accompanied by adequate resources so that the area can be managed effectively.


Draft:- Recommendation A2. Support the maintenance of, or increase in, the number of rangers at Stokes National Park.

Explanation: The community value the ranger's presence at Stokes National Park. This role is vital in maintaining the facilities, access and wildlife values. As such this plan supports the Department of Environment and Conservation, in the retention of adequate staffing levels.


Draft:- Proposed Action A5. Ensure any application to gazette a water-ski area or large boating activity at the inlet is considered by the Stokes Inlet Management Group and other affected parties.

Explanation: Any gazetting of a water ski area is likely to result in a higher usage of the inlet by water-skiers and this would negatively impact the serenity of the inlet. Additionally the infrastructure required for turning and parking areas in the park are not available. The same applies for large recreational boating events that are expected to lead to noise or disturbance.


Draft:- Proposed Action A6. Erect signage at the inlet to alert users to navigable water regulations for power driven vessels.

Explanation: Inappropriate boat speeds can cause increased noise levels and disturbance. Signs should be erected at both north and south camps to alert boat users to existing restrictions. If possible, signage should also alert users to hazards, such as submerged objects.


Draft:- Proposed Action CH2. Protect the freshwater pools located near the mouth of the inlet from four wheel vehicles.

Explanation: Four-wheel-vehicles sometimes access the ocean beach by driving over the dunes at the mouth of the inlet. This threatens the freshwater pools that are valued by the Traditional Owners, which lie between the dunes. Access to the pools needs to be restricted and longer term management of the site will be covered in the management plan for the park.


Draft:- Proposed Action CE4. Actively encourage community participation in implementation of this plan.

Explanation: Community ownership and participation is an integral part of the ongoing management of the inlet. This participation could be encouraged through a range of activities and should involve local schools.

End of extracts from the draft management plan October 2007 appended here so that Recfishwest's comments can be read in context because the DRAFT document is no longer available on the WAWater website.

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This page last updated on 28 November 2007.