Just thought I'd post this - might help others in their submissions. Not saying I have all the answers, just my opinion . 

EDIT - I would also add that it's not my intention to influence anybody as to their opnion or perspectivess and you may will diagree with some of this content. That's ok

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The Hon. Norman Frederick Moore MLC BA Dip ED

Minister for Fisheries

4th Floor, London House

216 St Georges Terrace PERTH

WA 6000

CC Hon. Colin James Barnett MLA MEc

Premier

Hon. Eric Stephen Ripper MLA BA, DipEd

Leader of the Opposition

Hon. Jonathan (Jon) Robert Ford MLC JP

Shadow Minister for Fisheries

Dear Minister Moore,

As a recreational fisherman of 42 years and a West Australian voter, I am concerned and alarmed at elements within the New Recreational Fishing Arrangements that you propose from October of this year.

 

During my 42 years of fishing, I have always supported and practised sustainable fishing, and cherish the need to both ensure fish stock levels of all species and provide the same wonderful opportunity for new anglers that I enjoyed as a child, and continue to do so.

 

I totally support appropriate conservation measures based on GOOD data and encourage the government to substantially bolster the Department of Fisheries(DoF) budget. Thus enabling that department to embark on a much more effective enforcement. But the latter WILL only occur if the (DoF)finally receive a massive injection of funds and resources (equipment and staff).

 

My very deep concerns are based on the following:

 

PUBLIC CONSULTATION

As a member of the (fishing/voting) public, I’m unaware of any opportunity provided by your government/party/department for the public to make any submissions on this issue. Instead, you appear to have been mislead by a few conversationalist reports and goaded in to a very unpalatable/unworkable/poorly thought out and electorally suicidal knee-jerk reaction. Such prior consultation would have provided for stakeholder input and ownership and no doubt provided a much more workable, rational and equitable solution. I would suggest that many of the elements of this better solution are covered below. No doubt there are many more.

 

HUMAN NATURE, RESEARCH AND ENFORCEMENT

Human nature being what it is, will always result in a number of persons within any demographic group exploiting resources and braking the rules. These people do so, usually out of no or diminished conscience, a misguided or aberrant (to the larger population within that demographic) value set or a ‘eureka stockade like mentality’ that no one can tell them what to do; then proceed to anything but what is required. Recreation fishers (RFs)  are not exempt from this. As an avid fishing person, active on a number of fishing forums, I am convinced that the majority of RFs want to and do the right thing. But there is, unfortunately and inevitably, a number who do not. Sadly, the general (often under/misinformed) public at large often tar all RFs with the same (bad) brush. At it’s best, this can lead to irrational/unconstructive/poorly targeted debate. At it’s worst, such misguided public outcry can result in misconceptions by those charged with sustaining our fish stocks and actions implemented based on emotion and poorly researched conclusions.

 

For far too long, conclusions on fish stocks and management programs have been poorly conceived and expedited. Additionally, many of those charged with conducting such research have embarked with a preconception often tainted by emotion and feelings. Hardly the basis for impartial rational data collection methodologies and research conclusions. One only has to look at the WCB Creel Survey debate and debacle.

 

I have absolutely no doubt, that all of the forgoing will continue until such time as this state’s DoF is appropriately funded and resourced. Only with a comprehensive and effective enforcement infrastructure and program can we turn the current situation around without the need for ‘simple’ and extreme measures like closure areas, which, as you say only shifts the fishing effort anyway. There are many within the bad element of recreation fishers that flaunt bag limits etc because they believe they can do so with absolute impunity. Many of these misguided folk laugh at the rare presence of enforcement officers from a grossly under funded and resourced DoF.

 

EQUITABILITY

As you are aware, Western Australia has a number of State Government determined Bioregions. As a Mount Barker resident and RF, I fish from Albany which, as you are aware, falls within the (state determined) South Coast Bioregion (SCB). I target many species of fish, both demersal and pelagic, including Dhufish and (Pink) Snapper. There are many who feel that such stocks are under pressure within the SCB. Whilst I acknowledge that such pressure is far greater within the West Coast Bioregion (WCB) due to the far greater number of RFs that target demersal scale fish, the fact remains that such fish species aren’t restricted to the WCB.

 

Additionally, all RFs, not just those fishing from boats would benefit from better research and enforcement.

 

Therefore, surely it would be more equitable and appropriate to have a ‘Salt Water Fishing Licence’ for all RFs and to spread the cost of valuable species sustainment and enforcement?

 

Sure, as a SCB RF, I could sit back and rub my hands with glee at avoiding the $150.00 p.a. impost, but, to be fair to my WCB counterparts, I would rather see such impost be on those targeting such species – independent of the bioregion.

 

Amongst RFs, it is well accepted that 20% catch 80% of the fish, through more frequent fishing, better use of high end equipment and greater knowledge and ability to target these fish. The $150.00 does nothing to address this. With $20.00 day, $60.00 fortnight and $150.00 per annum costs, anyone wishing to target these fish species more than seven times per annum will pay the $150.00, with the highly likely outcome that they will fish more often and longer to justify the cost. Yes; people do fish during predetermined holidays, but many more fish when weather and marine conditions will allow. So, in the latter case, the $60.00 fortnight will be of no use and the $20.00 per day unworkable as a decision whether or not to go fishing is made late the previous evening when the latest weather and marine conditions are known. RFs that target these species every weekend will pay the same as the Mums and Dads that go out seven or more times a year!

 

ENFORCEABILITY

Even with the (very unlikely) prospect of massive improvements in  DoF resources and enforcement, I am at a loss as to see how the proposed rules can be enforced. To say the least, it is completely unrealistic to expect RFs not targeting these species to avoid catching them. If the DoF only target such a proposed program at the boat ramps, then one person on board that boat can simply say s/he caught the fish! Providing of course that party doesn’t infract species bag/size limits etc. What determines if RFs in boats are targeting these species and is such targeting intentional or unintentional?

 

INEFFECTIVENESS

Having watched your online ‘New Fish Licences Management Media Conference’ (2 July 2009) I can say right now that it is NOT as ‘simple as that’ – RFs will pay the $150.00 (begrudgingly) and it will NOT reduce ‘the catch’ by the desired 50% that you say is required. In any case, how can you seriously believe that there will somehow magically be any sort of accurate outcome relationship between the attainment of a 50% reduction in RF WCB scalefish demersal catches? Once again, I cite the 20% RF/ 80% catch rule – and these RFs will definitely pay the $150.00!  

 

Maintaining a database of boat based RFs will NOT tell you or the DoF what is being caught, or even what those licensed boat RFs are even targeting! The only way that such data will be provided is IF everyone completes a log book and forwards that for data collation. However, this assumes that everyone will do this, and complete the log books accurately and actually send them in. Though I support and practice the current VOLUNTARY log book program, to expect all boat RFs to do this (though they should) is NOT realistic. As said by Dr Brett Molony (2 July 2009 press conference video), the recreational sector data is gathered through Creel Surveys and ‘other methods’ (presumably through the voluntary log book program).  

 

By your video  ‘New Fish Licences Management Media Conference’ (2 July 2009), you ‘hope that these measures will get the fishery back into balance’. Given that you admit further and better research needs to be done – what baseline are you starting with and how will you measure the achievement (or otherwise) of this ‘balance’?  As you have confessed ‘we have no idea on how many there (demersal scale fish and other species) are’!

     

UNDESIRED OUTCOMES

Electoral Backlash – there is no doubt that the state Liberal Government will take a major hit on this issue at the next election. Simply because there’s been no individual stakeholder consultation and boating RFs, (who by the way ARE voters – you seem to have missed that point!) have been presented with, at best, a somewhat fluffy fête a comple’.

 

Reversal Effect – Your proposal could well see previously responsible RFs keeping more fish to justify the $150.00 p.a. fee. Again, it is well accepted that 20% catch 80% of the fish, through more frequent fishing, better use of high end equipment and greater knowledge and ability to target these fish. The $150.00 does nothing to address this. With $20.00 day, $60.00 fortnight and $150.00 per annum costs, anyone wishing to target these fish species more than seven times per annum will pay the $150.00, with the highly likely outcome that they will fish more often and longer to justify the cost.

 

Boat Hire – Those RFs previously hiring boats or booking onto Charters will now think twice. This will have a negative effect over and above their business that must already be heavily affected by the global economic down turn. Perhaps these should be exempt? 

 

Shifted RF Effort and other Bioregion Drain – The closure you propose (whilst I’m not completely against it) WILL result in greater pressures on other bioregion stocks and more boaties target the Scalefish Demersal Species in grounds outside the WCB – where, I might add, these species also exist!

 

Fishing Tackle Industry – Any downward shift in RF boating will have a corresponding negative effect on this industry, also already suffering!

 

 

CONCLUSION AND RECOMMENDATIONS         

Let me once again make it very clear! I am totally in support of sustainable fishing and fishing stock management. I also support a broad based salt water fishing licence – IF the money is targeted correctly, et al, better and more objective research and deployment of appropriate enforcement resources.

 

I’m also in favour of a ‘species habitat’ driven demersal scale fish boat fishing fee – not one based on one bioregion.

 

Compulsory log books are long overdue.

 

Far greater enforcement with better/more resources and equipment.

 

More research OBJECTIVELY based without preconceived or desired outcomes or tainted by ‘emotional argument’  or ‘convenient extrapolation methods’.

 

Yours Sincerely

Colin John MOLLOY