Recfishwest submission on proposed arrangements for the managed West Coast and Gascoyne commercial "wetline" fisheries (originally Fisheries Management Papers 189, 190 and 191, and now 205, 206 and 207)

The Minister for Fisheries has invited further submissions on these topics with a deadline of March 24.

Recfishwest welcomes the opportunity for further comment on these papers. We welcome the progressing of commercial wetline management after a decade of waiting and hope that the implementation of an equitable result will effectively 'close the loop' by bringing all commercial fisheries under management. The recreational sector has taken a strong lead on the management of the scale fish resources of this state since the 1990-91 review of recreational fisheries.

There are a number of important principles which must apply in the implementation of this management review.

Firstly, the Fish Resources Management Act 1994 is definitive in its description of who can take species under a management plan. The implementation of formal management for the commercial wetline fleet provides some security of access to those who meet the objectively assessed entry criteria for this fishery. Those who do not have an entitlement however, have no legal basis to access the fish subject to a management plan. A scallop trawler for example is not permitted to retain any rock lobster taken with legal scallop trawling gear. This is well accepted.

The single most important issue arising from this review is the ability of those who do not obtain a managed fishery entitlement to take or retain wetfish, and the legislative capacity under which this might occur.

Recfishwest strongly advocates for an equitable and defensible strategy as has been adopted with other managed fisheries. No commercial fisher unless fishing under a western rock lobster managed fishery entitlement may retain a western rock lobster or use the gear specified in the management plan. A similar position was adopted with the Spanish mackerel management arrangements. Only those persons with an entitlement to take Spanish (and other similar) mackerel may be in possession while on a licensed commercial fishing boat. Recfishwest strongly supports a consistent principle applying with respect to wetfish under a management plan.

No boat or fisherman, unless endorsed under the wetfish management plan may have in their possession fish, or the implements for the taking of fish (i.e. fishing gear). This is legislatively consistent and allows for effective monitoring and enforcement. Recfishwest also strongly believes that this principle will benefit the commercial wetline fleet which will be able to access for optimum economic benefit, the commercial wetfish allocation as determined under the IFM process.

In theory, allowing the rock lobster fleet to have a recreational bag limit might have some superficial appeal however:

1. It ignores the superior gear and access to greater areas that exists with the rock lobster fleet, not just in comparison to the recreational fleet, but also compared to the wetline fleet with whom they will be directly competing for a share of the commercial allocation. The rock lobster fleet can access further grounds during a wide range of weather conditions which would prevent recreational fishers from venturing out to sea.
   
   
2. Approximately 400 rock lobster boats are unlikely to gain a wetline entitlement. An average of 2.5 people on the boat equates to a potential (legal and presumably reported) take of 1000 dhufish per day. At approximately 200 days equals 200,000 dhufish. If they average 5 kilograms each, this equates to 1,000,000 kilograms of dhufish or 1000 tonnes. It is expected that the total commercial allocation for this important species will be in the order of 250 tonnes, meaning that the commercial wetline fleet cannot possibly access this fish for commercial gain and that the potential to obliterate the recreational fishery is enormous.
   
   Even if the limit were to be set at a single dhufish per boat per day, 400 dhufish times 200 days equals 80,000 dhufish and 400 tonnes. We can see that if each boat without a wetline endorsement takes 125 average sized dhufish a year, the entire commercial allocation will be taken up by those who were not successful in gaining a formal entitlement. A massive 100 tonnes could be taken if each of the rock lobster fleet without an endorsement takes only one dhufish a week over a total of 50 weeks.
   
   
3. The wetfish take by the rock lobster fleet is currently not cost recovered and is being heavily subsidised by the community. Any management costs associated with any entitlement MUST be fully cost recovered (or subject to a resource rent levy) including on-costs. To expect the community to subsidise the lifestyle benefits of a profitable commercial fishery, especially if it is at a direct cost to a smaller and less lucrative commercial wetline fishery.
   
   
4. Any allocation to those who do not meet the objectively set criteria has the capacity to invalidate any spatial and/or temporal management outcomes arising from the IFM or a negotiation process. The ability of the efficient rock lobster fleet to impact on local stocks or areas of particular interest to the recreational fishing community is immense and acts as a significant disincentive for conservative and visionary management by the recreational sector. It will almost certainly impact significantly on the ability to implement a zone 5 metropolitan management zone for wet fish.
   
   
5. Recfishwest cannot see how a viable commercial wetline fleet can compete where those without history are given the capacity to take the entire commercial allocation from better boats and in areas where conflict towards the commercial industry in general will escalate. Recfishwest has strongly advocated for a small, viable and profitable commercial wetline fleet and we cannot accept this being compromised because the rock lobster fleet wants to continue its free ride on the community finfish resource. We are particularly disappointed that the CAP committee should have so blatantly stepped outside of its terms of reference to make a mischievous recommendation which reflected the personal agenda of some members rather than the task which they were given. We are confident that this superfluous recommendation will be ignored.

West Coast Management FMP 206

Recfishwest generally supports the proposals but wishes to offer the following specific points.

1. (See recommendations 7 and 12c) The proposed Metropolitan zone (from 31 to 33 degrees South latitude) is larger than the current area of intense recreational fishing effort. This allows for the projected expansion of both population and effort by the recreational sector and would allow spatial management to be proactive rather than reactive. The area from 31 degrees 20 minutes to 32 degrees 20 minutes is the current area of most intensive recreational and community interest and the one which requires immediate attention. Recfishwest strongly believes that the reporting requirements must include an ability to separate near shore (i.e. within three nautical miles) and offshore fishing effort. This delineation will also have to be applied to recreational catch and effort information. The majority of the area can be managed under the proposed 10 by 10 nautical mile reporting requirements.
   
   Integrated Fisheries Management is highly likely to impact on any proposed commercial allocation in the Metropolitan zone by imposing a spatial separation between recreational and commercial demersal fishers. It may be preferable to defer or make temporary allocations to commercial wetline fishers in this zone. Indeed the entire issue of local depletions and the differential importance of habitat types and locations with good access is a key driver in the metropolitan area and is becoming increasingly important in medium sized communities such as Jurien, Dongara and Bunbury.
   
   
2. A minimum holding for participants in the demersal wetline managed fishery is essential for good governance and viability of commercial operators. This need not apply as a knife-edge cut-off but should be a requirement within three years of the implementation of the fishery which would allow a less time constrained market to operate. The advantages of a minimum holding are:-
   
           The operators will be serious wetline fishers with properly equipped boats to insure the fish are marketed as a high quality product.
   
           The number of boats requiring compliance and VMS monitoring will be reduced keeping down management costs.
   
           Because of better returns per boat the fishery and marketing will be more economically stable.
   
           Interactional conflict will be reduced because there will be fewer boats to be seen, especially in areas of competition for the catch.
   
   Existing full time wetline fishers suggested in submissions that 25 tonnes per annum was needed to maintain an operation even at old fuel prices. A minimum holding of 10 tonnes to be achieved within three years would appear reasonable and provide a good basis for future management.
   
   
3. The issue of wetline take by licensed fishing boats without formal wetline entitlement was a controversial issue during the consultation process. The final recommendations, which reversed the draft recommendations in FMP 190, are reported in Section 7 of FMP 205 and 206 and should have been included as a recommendation in both papers. This is particularly relevant because an opposite view is included as a recommendation in FMP 207 which really should have been only concerned with access and allocation to the managed fishery.
   
   As discussed above, Recfishwest believes that this is a critical issue for the successful establishment of the managed wetline fishery and for the expected allocation of shares to this resource under IFM. RFAC believes the reasons set out in Section 7.1 of FMP 205 and 206 are articulate and extremely compelling.
   
   In addition, it was agreed in the initial report of the Management Planning Panel that any take from commercial fishing boats by commercial fishers without entitlement MUST be part of the total commercial allocation. This condition would be absolutely non-negotiable from a recreational fishing industry perspective. Allowing a significant take by those without a formal allocation would almost certainly be catastrophic for those who would be seen as the future stewards of the commercial wetline fishery.
   
   
4. The West Coast Demersal Gill Net and Longline Fishery (WADGNLF), which although described as a method fishery is generally regarded as a shark fishery, also catches demersal finfish. In order to insure that changes in practice in this fishery do not increase pressure on the demersal finfish resource the take of finfish should be capped. Given the concern about pressure on the resource, particularly in the Metropolitan zone, and the ability of this gear to specifically target wetfish, Recfishwest believes that it is necessary to cap the demersal finfish WADGNLF catches below historic levels. Recfishwest believes that fish taken by the wetline fleet will be of higher individual quality and should bring a higher return per unit and so should be encouraged from an economic efficiency perspective.
   
   
5. The target commercial catch for the West Coast demersal managed commercial fishery is estimated to be about 760 tonnes by the management panel on the recommendation of the Department of Fisheries. The actual commercial catch has been in excess of 1000 tonnes for several years now (1155 tonnes in 2002/3 and 1288 tonnes in 2003/4) and despite confusing results from CPUE estimates there is a general belief that the fishery is under pressure.

The significant increase in catch and effort (and overexploitation) of goldband snapper, especially in the Gascoyne region but also in the West Coast during the assessment period may result in an over-allocation and the proportional catch history is the primary allocation tool. The ability to allocate the correct tonnages, taking into account of the rapid fish down of goldband snapper needs careful and objective assessment. This opinion is supported by observations reported at the 2004 dhufish workshop.

Recfishwest believes that some action is required to reduce the high level of commercial exploitation. It would be disastrous if the implementation of the West Coast demersal scale fish fishery were to be delayed in any way, enabling the high current rate of exploitation to continue and building up the expectation of future access in those who do not meet the entry criteria. The recreational sector feels very strongly about this as there have been at least four major recreational fishing reviews with significant reforms since 1990, without any form of commercial control.

Consideration also needs to be given to reducing the TACC for this fishery to insure viability. Apart from the Kalbarri zone the catch rates are quite low and the best economic return will come from a harvest level well below the mean sustainable yield. It is likely that recreational fishers would also benefit from a reduced catch, lower fishing mortality, higher abundance and larger fish.


Gascoyne Management FMP 205

Recfishwest generally supports the proposals but wishes to make the same points with respect to FMP 206 in regard to the advantages of a minimum holding and particularly to the need to restrict the take of demersal scalefish to participants in an appropriate managed fishery. The impact of the goldband snapper catches confounding historical access and catch levels is of special concern in the Gascoyne region.

Recfishwest also wishes to point out that some of the recommendations for the inshore wetline fishery could conflict with future IFM decisions.

Access and Allocation Criteria FMP 207

Recfishwest objects strongly to Recommendations 18, 19 and 20. It also points out the inconsistency between these and Recommendation 21 should recreational wetline fishing ever be licensed (as is Recfishwest's stated preferred policy).

Recfishwest believes that it would have been preferable to limit access in both fisheries to those fishers who have concentrated on line fishing for demersal scalefish by having "knife-edge" access criteria. The reason for this is that this fishery is not going to be very profitable and the greater the number of fishers who get entitlement, the more liquidity will be required from those who eventually remain in the fishery, to purchase enough entitlement to achieve a viable operation.

The implementation of this wetline review is the single most anticipated management reform over the last ten years and virtually every single recreational fisher has a strong interest in the result.

We have attached our earlier submissions on these reviews for your reference and information. Recfishwest would be happy to discuss our recommendations or any other related matter at your convenience. Please feel free to contact me or the Recfishwest office on 9246 3366.



This page last updated on 23 March 2006.