Yep, Ive posted more on here in a couple of days than the last few years. But the more I think/ read/ understand the proposed rest of state proposal, the more angry/ worried I get. 

Ive been speaking to an ex senior fisheries mate who is both an avid rec fisherman and understands the commerical side of things a lot more than I ever will, and together (with admittedly my small contribution, a majority of the work is his) this response to the loaded (just like the mid west bio region) survey DPRIB has out about the rest of state proposal is the end result. 

If you think its worth copy/ pasting into responses to the survey. feel free. If not, cancel all your future trips north unless your like me an either allergic to fish or a pure sportsfisherman (Im both so not that much skin in the actual game besides being pissed off at the total lack of thought and pure stupidity in the proposed new rules....)

Maintaining quality recreational fishing experiences in Western Australia: A review of statewide finfish management (NOT including West Coast Demersal Scalefish Resource proposed management package). DPIRD, August 2022.

Statewide Finfish Bag and Boat Limits

Proposal 1. Do you support protecting the quality of recreational fishing in regional Western Australia by introducing a total mixed species bag limit of three demersal scalefish with no individual species bag limits (outside of the West Coast Bioregion)?

A mixed bag limit of three demersal scalefish is still a generous amount of fish and is designed to ensure the available recreational catch is shared amongst recreational fishers, particularly around popular regional tourism centres. Removing individual species bag limits is designed to reduce the need to release demersal scalefish with fishers being encouraged to retain the first three demersal scalefish they catch regardless of species.

This proposal is not supported for three main reasons with further information provided in each section below.

1.       It is not equitable fisheries management as catch reductions are limited to one sector (recreational fishing).

2.       The impacts of the proposal have not been clearly articulated to regional recreational fishers.

3.       With a reduced commercial catch of demersal scalefish on the West Coast region, fish prices will go up and commercial catches in the regions may increase to fill the void. This will make catch reductions by the recreational sector pointless.  

1.       It is not equitable fisheries management as catch reductions are limited to one sector (recreational fishing).

If recreational fishing regions adjacent to the West Coast are to have their demersal scalefish catches cut by at least 40% (i.e., from 5 to 3 fish per person) then the commercial demersal scalefish fisheries should be equally cut.  If this does not occur then the recreational sector is disadvantaged in any future Integrated Fisheries Management (catch sharing) decisions, which have been based on historical catch allocations.  This proposal further reallocates the regional demersal scalefish resource from the recreational to the commercial sector. The proposal will result in the following regional reductions for the recreational sector (Table 1). 

Table 1. Summary of proposed regional (outside West Coast) recreational and commercial demersal catch impacts.

*It is unclear to the public from these proposals if recreationally caught Bight redfish on the South Coast are to be included as demersal finfish species in the proposed new limit of 3 demersal fish.  On the South Coast you currently may take 8 Bight redfish, 8 yelloweye redfish and 8 swallowtail, PLUS a mixed daily bag limit of 5 other demersal finfish. On 5/9/2022 DPIRD management advised the author that Bight redfish were included in the proposed demersal limit of three fish.

Total demersal catch comparisons between the recreational and commercial sectors for regions outside the West Coast are summarised in Table 2.  The figures indicate that if there is a need to reduce total demersal catches, then the catches from the various commercial fisheries in each region far exceed the recreational catch. Without a discussion around total catches for all sectors being included (as has been done for the West Coast proposals) the public does not have the information to properly consider proposals about sharing a public resource.   

Table 2. Summary of total regional (outside West Coast) recreational and commercial demersal catches. Source: State of the Fisheries Report 2020/21.

2.       The impacts of the proposal have not been clearly articulated to regional recreational fishers.

Such inequity makes this “statewide recreational finfish management review” appear like an ad hoc, afterthought tacked on to a separate process for the West Coast region.  Most regional fishers are not aware their recreational demersal bag limits are being considered for a minimum 40% reduction and there are no examples provided in the proposals of what these reductions actually equate to under various scenarios, such as extended trips at sea. Media attention has been focussed on the West Coast “being closed to recreational fishing for 9 months”. Even DPIRD’s “Catch” recreational fishing news email to recreational fishing licence holders of August 2022 has the lead story as, “West Coast Demersal Consultation Open”. There is no mention of regional reductions, there have been no regional public meetings or targeted regional media to date.  Equitable management actions are required for both sectors and a proper, transparent process needs to be developed if significant recreational fishing changes for the regions are to be implemented. 

3.       With a reduced commercial catch of demersal scalefish on the West Coast region, fish prices will go up and commercial catches in the regions may increase to fill the void. This will make catch reductions by the recreational sector pointless. 

The basis of the argument that recreational fishing bag limits need to be reduced as effort may be displaced from the West Coast Bioregion to adjacent regions also applies to the commercial fishing sector. No reference is made to catch reductions in any regional commercial fisheries, other than Zone 1 of the Southern Demersal Gillnet and Demersal Longline Fishery.  Zone 1 of this fishery aligns with a small section of the South Coast recreational region from Black Point, Augusta to west of Walpole (~60 nautical miles).

A 50% cut in the demersal scalefish commercial catch on the West Coast will reduce demersal scalefish supply to WA consumers and result in an increase in the price of demersal scalefish. Further, longer closed seasons for recreational fishers on the West Coast, or whatever means is used to reduce the recreational catch by 50%, will reduce the amount of recreationally caught fish kept and consumed by metropolitan households. This will increase demand for purchased commercially caught demersal scalefish and increase fish prices. Most of WA’s population resides and fishes in the West Coast region and if they can’t catch their own demersal fish, a proportion will choose to buy it, eat it more at restaurants etc.

A combined decrease in supply and increase in demand for demersal scalefish could provide the financial incentive for regional commercial fisheries (e.g. the South Coast Demersal Line and Trap Fishery and Zone 2 of the Southern Demersal Gillnet and Longline Fishery) to fish harder to fill that void.  Both of these commercial fisheries have ample opportunity to increase their catches if the financial incentives are provided to do so, thus making recreational reductions ineffective.

South Coast Bioregion Specific Comments

In the South Coast Bioregion, it took from 1997-2021 (24 years) to bring the commercial ‘open access’ wetline fishery under a legislated management plan. This commercial sector was obviously not a high priority or properly resourced by government, despite cries for regulation from both the commercial and recreational sectors over decades.  It is therefore very puzzling that in 2022, after this delay and record high South Coast commercial wetline catches, that only the recreational sector has a proposed minimum 77% demersal scalefish reduction.    

A proper review of the South Coast demersal scalefish resource would include critical issues, such as the targeting of hapuka spawning grounds on the edge of the continental shelf.  Commercial hapuka catches are at record levels in recent years on the South Coast (2020/21 State of the Fisheries Report p. 226). Anecdotally, the average South Coast hapuka size has decreased over the last 10-15 years from 10-20kg fish on average to around 3-10kg fish.  Ongoing targeting of bight redfish aggregations by both sectors are also concerning. Bight redfish on the South Coast have been aged at 84 years old, so in terms of a “risk based approach” to management these would surely be the priority.  Fishers in both sectors are travelling further to find smaller aggregations and the spawning aggregation sites are well known.  A lack of resourcing towards adequate scientific assessment to quantify these decreases may lead this region down the same trajectory as the West Coast. 

Gascoyne Bioregion Specific Comments

While somewhat understandable in locations such as Coral Bay and Exmouth that historically experience a higher volume of fishing related tourism (and just went through an unprecedented COVID-19 driven influx of tourism), a blanket approach to bag and boat limits is unreasonable and not required. For example, townships such as Carnarvon which experience relatively low fishing tourism needs to be considered. The main productive fishing grounds (Bernier and Dorre Islands) are inaccessible by recreational fishing boats for around 70% of the year due to distance (25 nautical miles to the closest point) and weather which contributes greatly to maintaining the current healthy fish stocks in the area. The only identified at risk species in the area is pink snapper, and this is primarily a result of long-term overfishing of spawning aggregations by the commercial sector. As a result, the spawning areas in the region are already subject to a closed season, which should be sustained.

Other fishing locations that are similarly inaccessible (such as the Monte Bellow Islands) also experience the same protection from fishing pressure due to logistical and distance challenges. Under the current proposal, a recreational boat travelling less than 30 minutes to fishing grounds in Coral Bay or Exmouth is subject to the same species and boat limits as a boat completing a multiple day trip to remote offshore islands (being 9 fish total).  

Simplifying rules has merit but implementing blanket regional recreational fishing rules for such a massive State without considering the diverse collection of species, locations and risk profiles of areas is not smart fisheries management. The recreational fishing rules for demersal scalefish outside the West Coast are effectively being consolidated into one region. This is similar to asking all commercial finfish fisheries in WA to comply with one legislated management plan, without considering the particular management issues for different areas or operations.

Management of the inner Shark Bay pink snapper populations through area specific limits (both size and bag/ boat limits) is an example of where specific management has been successful and can be implemented on merit where warranted.

Removing Individual Species Bag Limits

This proposal is not supported for the following reasons.

Many recreational fishers and spear fishers have the ability and knowledge to specifically target dhufish, coral trout and blue groper for example. Experienced spear fishers could take nine coral trout between three fishers in the Gascoyne/Pilbara and the same applies on the South Coast for blue groper. This is not an improved sustainability or resource sharing outcome. Similarly, many boat fishers on the South Coast target known dhufish grounds and could shift their fishing behaviours towards catching three dhufish per person. Fishers would be reluctant to keep a smaller demersal fish of lesser eating quality in the knowledge they could keep three dhufish each. This proposal promotes inter-species high grading and targeting of the highest priority demersal finfish, particularly when combined with a reduced bag limit from 5 to 3 demersal fish (or 13 to 3 on the South Coast).

Statewide Finfish Bag Limits

Proposal 2. Do you support protecting the quality of recreational fishing in regional Western Australia by introducing a boat limit of three times the bag limit of demersal scalefish? This proposal allows a boat with three or more licensed fishers on board to retain up to nine demersal scalefish on a fishing trip (outside of the West Coast Bioregion). This is a generous amount of fish and will accommodate most existing practices but prevent excessive amounts of fish being targeted and retained.

This proposal is not supported for the following reasons.  

Recreational fishers with bigger boats able to fish with more people on board are disadvantaged most by this proposal and those who take extended trips at sea (e.g. take their own boat to offshore Islands camping/exploring).  The following example in Table 3 highlights these impacts, which are not mentioned in the proposal or explained to the public.

Table 3. Impacts of proposed recreational boat limit of 9 demersal fish on overnight stay- example assumes three people on board.

This proposal could encourage more boats to fish unnecessarily which increases the carbon footprint of recreational fishing. A proportion of recreational fishers in regional areas will be reluctant to take more than 3 persons on a boat given these boat limits and the reduced bag limits.

If people choose to take less people on their boat it increases costs for those sharing in the trip, particularly for those with larger boats who have the ability to travel further from boat ramps and decrease the potential for localised depletion of fish stocks surrounding major ports/ramps at popular regional tourism centres. The proposal penalises those who choose to share the recreational fishing experience with more people. 

In addition, the charter sector limit remains at 20kg of fillets per fisher (the previous recreational possession limit), however those with private boats can only take 3 demersals per fisher (maximum of 9 fish with 3 or more fishers on board).  It is inequitable and confusing as to why people who choose to go on an extended charter are advantaged over those who own private boats. The proposal appears to imply that by paying thousands of dollars to a charter business you receive a ‘privilege’.

Private vessel owners pay thousands of dollars every year in running and maintaining vessels after the initial purchase price. They also pay all of the State government charges for vessel and trailer registrations, insurances, boat fishing and skippers’ licences, flare replacement, EPIRBs etc. all required by government to go boat fishing.  The effort and cost of owning their own boat in the regions with all these additional restrictions imposed with little sustainability basis is

More recreational fishers will consider it’s not worth the effort and cost of owning their own boat in the regions with all these additional restrictions imposed with little sustainability basis which is not inline with the proposal to accommodate existing fishing practices.  

Statewide Finfish Size Limits (also applies to commercial fishers)

Proposal 3. Do you support maximising the overall utilisation of our fish resources by removing size limits for demersal scalefish and large pelagic finfish species with estimated post-release mortality rates equal to, or above 50%? Minimum size limits do little to benefit overall egg production for species with high to very-high post-release mortality rates. Removing minimum size limits for these species is designed to reduce the need to release these fish and maximise the overall utilisation of our fish resources.

The proposal is not supported for the following reasons:

1.       Removing size limits for the demersal species listed will be less effective from a sustainability basis if combined with the proposed substantial bag limit reductions.  Recreational fishers with new 40% - 86% bag limit reductions imposed in the regions will be less likely to retain small fish and the proposal may promote high grading. For example, on the South Coast if the recreational bag limit drops from 13 fish (5 demersals and 8 bight redfish) to three, then people will try and maximise the size of those three fish kept and probably travel less far from boat ramps to minimise travel costs. This is particularly the case in regions where adverse weather prevents recreational fishers with small boats from fishing frequently. When the weather does permit people to go fishing for demersal fish, they want to maximise their experience.

2.       Recreational line fishers on the South Coast experience very little shark depredation, unlike parts of the West Coast and just about all of the north of the State.

3.       Spearfishers selectively spear fish and this could encourage inexperienced spear fishers to spear small tuskfish or blue groper, for example. Similarly, shallow water boat fishers (e.g. less than 20m) may also increase catches of long-lived demersal species in their juvenile habitats, which could have survived if released.  

4.       Also of concern is the removal of the maximum size limit for the Blackspotted Cod (Malibar) currently at 1000mm/ 30kg. While acknowledging this species susceptibility to barotrauma mortality, in many locations within the northern regions of the state, populations of the Malibar cod exist in shallow (less than 10m) environments. By removing the maximum size limit, this exposes large breeding fish to spear fishers targeting them directly due to their location (shallow water) and inquisitive nature (making them an easily targetable species). This is compounded by the removal of the species specific bag limits. As an extreme example, three fishers could capture nine 30kg+ Malibar in one day while still complying with the proposed laws as long as the fish are kept whole until returning to shore.

Statewide Finfish Possession Limit

Proposal 4. Do you agree that the current finfish possession limit provides the right balance between ensuring our vulnerable demersal scalefish stocks are able to be shared and enjoyed by current and future generations of Western Australians, while allowing recreational fishers to accumulate an appropriate amount of fish on a fishing trip? The current finfish possession limit allows recreational fishers to accumulate up to; • 10kg of fillets (or pieces) of fish of any species, plus 10kg of large pelagic fish (with skin attached for identification purposes); or • 10kg of fillets of any species and one day’s bag limit of whole fish; or • Two day’s bag limit of whole fish; or • 20kg of fillets (or pieces) of fish of any species while participating on an extended fishing charter.

The proposal is supported with the exception of the limit of 20kg of fillets of fish of any species while participating on an extended fishing charter. This inconsistency between recreational fishers on charter vessels and recreational fishers on private vessels is discussed in Proposal 3 and needs to be clarified by fisheries management from a sustainability and equity perspective.

The 10kg demersal finfish possession limit, if adequately enforced, will help reduce the impact of potential recreational effort shifting from the West Coast to other regions. The 10kg demersal limit should mean only around a couple of days fishing by tourists before that demersal possession limit is reached.  You cannot transport recreationally caught fish unaccompanied, so if people aren’t abusing the system, regional recreational demersal catches may have already decreased. Assessing the impacts of the first year of this possession limit reduction trial (i.e. since the COVID-19 regional tourism boom prompted the changes) would be important before introducing additional recreational fishing management restrictions.