Recfishwest DRAFT submission on allocation of demersal fish.

Recfishwest DRAFT Submission to the Integrated Fisheries Allocation Advisory Committee (IFAAC) - Fisheries Management Paper 237 - Draft Allocation Report West Coast Demersal Scalefish

Recfishwest has developed its submission based on issues and concerns raised at the series of public consultation meetings held last month. A MS Word version is available at http://www.recfishwest.org.au/Submissions.htm#Latest

RFW are keen to receive any feedback you may have on this submission.

PO Box 34,
North Beach,
Western Australia, 6920
Tel (08) 9246 3366
Fax (08) 9246 5955
email

RFW would also urge recreational fishers to put forward their own submission to this important document.  Please feel free to utilise any components of Recfishwest's submission in developing your own personal submission. Submissions to IFAAC close Thursday 30 September 2010.

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DRAFT version 1, 30 August 2010.

Integrated Fisheries Allocation Committee
Locked Bag 39
Cloisters Square Post Office
PERTH WA 6850

Dear Mr Longson,

Recfishwest Submission to the Integrated Fisheries Allocation Advisory Committee (IFAAC) - Fisheries Management Paper 237 - Draft Allocation Report West Coast Demersal Scalefish.

RECFISHWEST POSITION

Recfishwest does not support an Integrated Fisheries Management (IFM) allocation for the whole suite of west coast demersal scalefish species (48 species) as described in Fisheries Management Paper 237.  Nevertheless, Recfishwest believes IFM can become a functional framework for management in this fishery and recommends IFAAC consider applying in the first instance an allocation for key individual species such as dhufish.


Thank you for the opportunity to provide comment on the integrated fisheries management draft allocation report for West Coast Demersal Scalefish.

Recfishwest has undertaken extensive consultation with the recreational fishing community around this issue.  As part of this consultation a number of concerns have been indentified around the suitability of IFM for this fishery as proposed in the draft allocation report (FMP 237).  Recfishwest has developed this submission after considering the many current and future challenges facing the West Coast Demersal Scalefish fishery.

The West Coast Demersal Scalefish fishery is an extremely important and highly valued fishery to the recreational sector.  This importance has been highlighted by the unprecedented numbers of the recreational fishing community attending the public consultation meetings detailing IFAAC's draft recommendations for allocating this resource. 

Strong sentiment reflected at these public meetings has highlighted that the recreational sector is currently very sensitive to further decisions being made regarding the future management of this fishery.  The recreational sector is anxiously awaiting research advice to determine if the introduction of reduced bag limits and the implementation of a closed season have achieved the required 50 percent reduction.  Until the effect of recent management changes can be quantified, support from the recreational fishing sector towards further management reform will be difficult to bring together.

Recfishwest believes that a decision of allocation in this fishery should not be rushed and would strongly urge that IFAAC consider a staged approach to implementing IFM in this complex fishery.

Given the importance of West Coast Demersal Scalefish to the recreational sector, Recfishwest believes that it is essential that the guiding principles which underpin IFM are closely adhered to in developing allocations.  Recfishwest has made numerous submissions on these principles over the last nine years and must continue to stress two key facts.

Firstly, all fisheries resources in Western Australia are common property.  They are owned by the entire community and administered through legislation by the Department of Fisheries which is required to ensure that there is an optimum community return from the available resource.

While this seems an obvious point, the needs of the community are, and must be, the key driver for determining the allocation.  In the case of the West Coast Demersal Scalefish fishery, any allocation must reflect the highly participative recreational components of the fishery in preference to a relatively small commercial fishery.  For instance, the large proportion of the 70 000 Recreational Fishing from a Boat licence holders fish for species which constitute this fishery compared to only 41 'wetline' vessels in the second half of 2007/08.

Secondly, Recfishwest insists that an allowance for a degree of natural community growth be accommodated within the allocation process.  Failure to provide any accommodation for this natural growth automatically disadvantages the wider community and specifically the recreational fishing sector.

Recfishwest is concerned about the high level of biological, social and economic uncertainty still associated with the West Coast Demersal Scalefish fishery and the risk this presents in allocating the shares proposed in FMP 237.  A biological, social or economic risk assessment was not undertaken in the resource report (FMP 247).  Such an assessment should form the basis for determining future management.

Recfishwest believes that certain aspects of IFM and the allocation process (detailed below) are seriously flawed and must be addressed before moving towards IFM of any individual species from this fishery.  These aspects are critical to the successful implementation and ongoing administration of integrated fisheries management.

Catch data

Recfishwest shares frustrations with the IFAAC over delays in more recent Department of Fisheries recreational catch estimates being made available to assist in the allocations process.  If these delays continue into the future, it is unlikely that the Department will have the capacity to collect timely enough data with the level of accuracy needed to manage this suite of these species within the proposed IFM framework.  For example, the recreational sector is currently waiting on 2007/08, 2008/09 and 2009/10 creel survey data.  Furthermore, past creel surveys have been shown to be inaccurate such as demonstrated by adjustments made to the 2005/06 survey by the IFAAC based on the review of Steffe (IFAAC's Recommendation 9) and in the case of the recent Peel-Harvey crab estimates.  Timely and accurate recreational catch data will imperative to the future success of this IFM in this fishery.

Recfishwest has consistently supported Recommendation 2 of the Toohey Report (FMP 165) which states "The development and funding of a comprehensive research and monitoring program encompassing all user groups is essential to provide the necessary information for sustainability and allocation issues to be addressed under an integrated framework.".

Capping the total recreational catch requires extremely concise estimates of the recreational catch.  This information must be cost effective and provided in a timely manner.  It must also include the catch distributions within the recreational sector so that explicit management which provides the correct response in catch controls can be delivered. The catch data must be close to 'real time'.

Recfishwest believes that it will be extremely difficult to achieve such a framework which encompasses all species within the West Coast Demersal Scalefish fishery.  However, we believe that frameworks such as these can be developed and implemented for the most important species in this fishery, such as dhufish.

Recfishwest is reluctant to commit to the introduction of new management measures without adequate resources and funding to suitability monitor annual catches.  We believe a failure to deliver this will even further exacerbate conflict and community concerns about the entire management process.

Allocation and Reallocation

Recfishwest believes that management measures should accommodate the growth in recreational fishing participation.  We insist that the natural growth in the recreational sector must be accepted and included in the decision making process for this fishery.
Capping the recreational sector allocation at current, or, historical catch levels automatically forces intra-sectoral resource sharing issues to emerge.  Recreational fishers must compete amongst themselves for a smaller portion of the catch simply because there is natural population growth.  Those who wish to access their share of the common property resource should not be disadvantaged by having to compete against other recreational fishers, particularly given the spatial constraints regarding access in the West Coast Demersal Scalefish fishery.

Recfishwest believes that the combination of multiple species spread over a large geographical area will be highly problematic for the IFM process if the Department of Fisheries were to proceed with allocating the fishery as a whole.  We believe that it will be almost impossible to effectively manage all species under a single harvest level given the highly variable nature of the fishery throughout the West Coast Bioregion.  Factors such as species recruitment, species distribution, species abundance and the commercial and recreational catch distributions often exhibit substantial variations between Kalbarri (26°30'S) and Augusta (115°30'E).  Further variation will likely occur through time as the economic and social values of the resource change.

On the contrary, dhufish exhibits much less variability across its distribution than the combined West Coast Demersal Scalefish fishery of which 48 species are proposed to be monitored for management purposes.  Undertaking IFM on an individual species basis will therefore have much less complexities in terms of management.  For example, within the West Coast Bioregion, a single species will display similar biological traits, such as growth, reproduction and habitat preference.  Perhaps more importantly, a single species will, within each fishing sector, have a similar value (social and economic) and similar fishery drivers and motives for participation.

Recfishwest is concerned that mechanisms for reallocation of resource share in the future remain unclear, although it appears that a market based approach will eventually prevail.  For this reason Recfishwest see value in applying IFM to commodity type fisheries such as rock lobster and abalone where the major aim of recreational participation is to maximise catch.  In single species fisheries such as these the value of a harvest unit is relatively simple to determine based on 'free market' principles. 

This procedure is greatly complicated in a multi-species fishery in which the 'market value' varies considerably between individual species and, in which, the major driver of recreational participation is not necessarily to maximise catches of these species equally.  Consequently, the value of a transferable harvest unit in this multi-species fishery will be considerably difficult to determine.  For example, in order to increase its catch of pink snapper will the recreational sector have to buy units based on dhufish prices? 

The effectiveness of reallocation of multi-species catch shares between sectors will be uncertain as each sectors utilise this resource in different proportions often at different times and different locations.  Furthermore, harvest unit reallocation might deliver detrimental consequences as catch is transferred between areas due to the largely variance in spatial fishing activity between sectors. 

Recfishwest believes that that dhufish does indeed share many traits with the commodity type fisheries of rock lobster and abalone and would therefore make a suitable candidate for reallocation using a market based approach.  However, Recfishwest remains cautious to committing to the implementation of IFM on any of these important demersal species until the mechanisms of reallocating shares have been clarified.

Social and economic value

Although social and economic values have been considered in the allocation process, they have not been given any weight when determining allocations between sectors utilising this fishery.  Recfishwest acknowledges that these values are very difficult to quantify and only limited information is currently available.  Nonetheless, Recfishwest believes that social and economic considerations are extremely important and the allocation process must endeavour to reflect these values.  The social importance of the West Coast Demersal Scalefish fishery is widely recognised and is highlighted in the Department's Ecosystem Based Fisheries Management framework (EBFM) in which the risk of social impacts from management changes in this fishery was deemed to be severe.

Social values and changes in recreational fisher behaviour are very difficult to predict.  This complication could be somewhat addressed by managing individual species which have high values and developing systems to predict/monitor how these change over time to ensure allocations maximise benefit to the community.  Recfishwest would like to reiterate that we recognise the many difficulties in determining these values based on the limited information currently available.  Given the importance of this fishery to the recreational sector, Recfishwest does not believe that an IFM allocation can be made until more accurate estimates of respective social and economic value can be resolved.

Comments on the allocation process described in FMP 237

If a single species such as dhufish is allocated by IFAAC in the future, the following points should be addressed if considering allocations based on the 2005/06 catch data:

"    It is not apparent how much of the commercial 2005/06 catch was taken by boats that were not allocated participation in the West Coast Demersal Scalefish Managed Fishery.  A total of 1250 boats had the capacity to 'wetline' in 2005/06 and 239 reported catch.  However, 61 currently have this entitlement in the managed fishery.  Recfishwest believes that a large number of boats which added to the commercial catch of 2005/06 were excluded from the fishery in 2007.  IFAAC must investigate how much catch these boat contributed to the total commercial catch and subtract that amount for the purposes of allocation.

"    Recfishwest believes that the commercial catch taken in 2005/06 from the metropolitan zone of 119.5 t should be given greater significance in the allocation process.  Many members of the community believe that the Minister at the time made an explicit allocation decision granting this fishing zone to the recreational sector only.  As such, we believe that this catch, or the catch of any individual species within it, should be added to the recreational catch when calculating allocations.

"    Recfishwest welcomes the IFAAC's proposed adjustments to the 2005/06 creel survey data based on the review of Dr Aldo Steffe.  However, the phone diary estimates (Appendix 2, FMP247) suggest that catches of the key indicator species were approximately 30 % greater than those estimated in the creel survey (FRR 177).  Hence, in contrast to the IFAAC, we deem it more appropriate to allocate a further 30% (rather than 20%) to that reported by the creel survey in order to account for underestimates.  In addition, Recfishwest agrees that it is appropriate to allocate a further five per cent to account for lack of diving data as proposed by IFAAC.  We therefore believe that for allocation purposes the recreational catch should be considered to be 35% greater than catches reported in the creel surveys (FRR 175 and 177).

"    The 2005/06 season was the fifth consecutive year that the commercial 'wetline' fleet were catching above the proposed target range of the fishery.  The target catch of this fishery was set at 558 - 798 tonnes in 1999/00.  Recfishwest has concerns that the IFAAC has made allocations to the commercial sector based on catch levels exceeding the acceptable limit.  Catches of all 3 indicator species (dhufish at 181 t, pink snapper at 278 t and baldchin groper at 34 t) exceeded their target catch ranges in 2005/06.

"    Recfishwest believes that the IFAAC should not make allocation recommendations for any species taken in the Western Deepwater Trawl Fishery as is the case in the draft allocation report.  This is a commonwealth managed fishery which operates outside of the 200m isobath.  The management of this fishery is outside the jurisdiction of the Department.  The scalefish catch of this fishery is highly variable, for instance in 2005/06 this fishery caught 5.04t of scalefish, in 2004/05 the catch was 67 t of scalefish (mixed spp.) and in 2001/01 it was 243 t.  In addition to being outside of the control of the Department, the Commonwealth does not release detailed catch information for this fishery.  Some of the species likely to be targeted by this fishery such as Ruby Snapper and Tangs Snapper feature on the demersal scalefish list (i.e. closure list of 48 species).

Recfishwest is very cautious about entering into large-scale management reform in such an important fishery given such a high level of uncertainty provided by the Department.  The risk for the recreational sector is far too high to endorse the proposed allocation of shares in this fishery at the current time.  Many recreational fishers do not wish to see a system implemented which institutionalises historical discrepancies and for which they have to pay to regain a fair share of the resource.

Recfishwest has some concerns about the Department's commitment to the IFM process given recent restrictions in recreational rock lobster management that overlooked some of the guiding principles of IFM.  The credibility and success of this initiative clearly rests with the Department of Fisheries to demonstrate that community benefit can be realised through this process.

Recfishwest commends the IFAAC for the time and effort which it has put into this difficult task.  Recfishwest has presented its views on a sectoral basis, representing what it sees as the interests of the significant recreational fishing sector.

Recfishwest is keen to discuss our proposed position with IFAAC in further detail.  We look forward to meeting with the allocation committee once they have received and considered submissions on the draft allocation report.

Thank you for your consideration of our submission.  Further information can be obtained from our office on 9246 3366.

Yours sincerely

Andrew Matthews
Chairman
Recfishwest
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ATTACHMENT 1

Recfishwest would like to propose a workable and equitable solution to the difficult task confronting the IFAAC.  Recfishwest would like the IFAAC to consider making an allocation for dhufish based on the calculation below. 

Recfishwest proposed dhufish allocation.



186 tonnes dhufish recreational creel survey
186 tonnes plus 3.5 tonnes for Abrolhos = 189.5 tonnes
189.5 tonnes plus 66.3 tonnes (35% of recreational creel plus Abrolhos) = 255.8
255.8 tonnes plus 20.1 tonnes (charter catch) = 275.9
275.9 tonnes plus 43.1 tonnes (metro dhufish commercial catch) = 319

Allowable harvest level for the recreational sector with 50% reduction = 159.5 tonnes

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End of DRAFT version 1, 30 August 2010.


Tony Halliday's picture

Posts: 2500

Date Joined: 14/06/07

a meal on a reel, one day

Mon, 2010-09-06 08:20

a meal on a reel,

one day this will be a old-mans yarn only.

We beeing locked out slowly but firmly from fishing.

I still think we need to get more fish on a take only by line bases for recs only, removing commercial pressure on the fish in danger.
I have posted this before, but I thibk it needs again to be up.

____________________________________________________________________________

Tony Halliday: ~Meals on Reels ~

 It takes a strong fish to swim against the current. Even a dead one can float with it

"It is always in season for old men to learn." Aeschylus (525-456 BC)

"In a mad world only the mad are sane." Akira Kurosawa (1910-1998)

roberta's picture

Posts: 2773

Date Joined: 08/07/08

All I know is

Mon, 2010-09-06 09:07

in my heart , listening and watching what the pro's caught in the two month ban last year (Leeman/Jurien Bay).  Was very disturbing indeed.  To see dhuie's over 15kgs, baldies, snapper caught by more than one pro in Leeman was very sad to the eyes.  Yes they have to make a living but with there technology, bigger boats, stay out for a couple of days, compared to what us the amatuer can catch is in my eyes, heart, criminal (criminal might be a bit harsh) to say the least.  I know on average  when the amatuer goes out it really is hit and miss, not every boat catches their limit, so to me how do the experts/fisheries know exact figures how much a amatuer catches.  To add the charter boats to our bag limit to me is very misleading as even going out in a charter, its hit and miss.   I haven't read the above, just my thoughts on this subject.  I'm for preserving future fish stocks for future generations.  Do we stop the pro or do we totally stop the amatuer from fishing for demersals all together to preserve stocks.  The amatuer has so many industries behind us to survive, if you take into account, tackle shops, boat builders/accesseries/caravan parks, tourism, licenses (all), registration of boats/trailers/cars. On average who takes the most us the amatuer or the pro?  Thats the biggest burning question that will never be truthfully answered, it all boils down to us or them. Its the fish, all species that will suffer one way or the other, regardless of costs or livehoods, just my honest thoughts on this.

____________________________________________________________________________

Ginger Tablets Rock

 

Tony Halliday's picture

Posts: 2500

Date Joined: 14/06/07

Roberta, I have long been an

Mon, 2010-09-06 11:06

Roberta, I have long been an advocate of "Rec Only" for some species, Yes it's selfish for those that don't fish to not get access, but then again, if they want Dhuie, they can go catch a dhuie, not just BUY BUY BUY!

The Red Book approach is now well documented in South Africa and kept many sport fish endagered still on the menu but only for " own catch" and took them away from the resturants and fish markets that where slaughtering them by the hundreds for money!

Tradional fishermen make their money from catching fish and selling at the harbor to people that want to have fresh fish. Commercial fishermen are part of big business and take for profit in huge volumes and trade the fish like stocks in a market.
My view is Dhuie should come off the comercial list. They can have Pink Snapper, Sweet Lip & Breaksea Cod from the metro area, supplemented with line fish from cat2 & 3. Nothing wrong with well prepared cat3 fish in a resturant. You can't always have Ribeye at the dinner now can you! Sometimes it has to be mince, sauce and pasat... same goes for fish on the menu in my books.

Meals on Reels, that my stand. You want to eat it, you catch it!

____________________________________________________________________________

Tony Halliday: ~Meals on Reels ~

 It takes a strong fish to swim against the current. Even a dead one can float with it

"It is always in season for old men to learn." Aeschylus (525-456 BC)

"In a mad world only the mad are sane." Akira Kurosawa (1910-1998)

meersy's picture

Posts: 278

Date Joined: 20/04/10

Recfishwest with us or against us

Mon, 2010-09-06 18:54

Who knows. Ive been to a couple of the meetings held regarding the new fishing rules. They ask you to come along and express your veiws and give feed back.To me they dont give a rats backside what the amature fisho thinks because when you comment on an issue at these meetings all they do is try and justify there decisions. They dont take into account how the reel world works.Counting the amount of boat trailers at the boat ramp and cauculate bag limits on that is a tru reflection of the people/commitee we are dealing with. A bunch of pen pushers that make educated guesses on fish stocks.Im all for fish for the future but the way its going it will be no fishing in the future.Come on rectfishwest, do what you preach and look after recriational fishing. THE CREEL SURVEY.What a bloody joke.How can these departments pin all there hopes on a guess.If every person that has a fishing from boat licience caught there bag limit of dhuie every wk end then i could see that there would be cause for concern.My estimate would be more like only 10% if your lucky would go fishing all at the one time due to various factors(whether,work,etc) out of those people only half of them would catch a dhuie or even go chasing them. And what about the licience holders that dont even live in ground where dhuies are caught, north of shark bay.How can u put those licience holders into the equation when you need a licience to go barra fishing in the fitzroy river from a boat.I am only using dhu fish as an example by the way, just like the way the creel survey does as an indicator spieces.Basically i think untill there is a more logical way getting a tru indcation of fish stocks just leave things the way they are. Fishrectwest you have done enough!!!!Frown

Toby Roe's picture

Posts: 118

Date Joined: 01/02/10

Agree mostly except for this

Wed, 2010-09-08 12:06

Agree mostly except for this comment "I still think we need to get more fish on a take only by line bases for recs only".

 

All methods of recreational fishing should be protected.  It is the number taken and not how they are taken that matters.

 

Cheers

Toby

Tony Halliday's picture

Posts: 2500

Date Joined: 14/06/07

toby it's about gill nets

Wed, 2010-09-08 12:10

toby it's about gill nets and commercial whole sale rape of the oceans. You go behind a big factory / processing boat and see what gets dumped out and tossed away.
Same goes for by-catch from netters on the shore, prawn & scallop boys etc.

The "take only by line" basis is a control means it stops the hunting of big prize fish by spear fishermen as well. We all know how many close to tame gropers and big cod have been bagged etc.
JMO

____________________________________________________________________________

Tony Halliday: ~Meals on Reels ~

 It takes a strong fish to swim against the current. Even a dead one can float with it

"It is always in season for old men to learn." Aeschylus (525-456 BC)

"In a mad world only the mad are sane." Akira Kurosawa (1910-1998)

ody's picture

Posts: 581

Date Joined: 30/12/06

  Hi Ya, And may be more

Wed, 2010-09-08 14:16

 

Hi Ya,

And may be more radically, ban all forms of trawling.  It destroys the floor of the ocean, it catches and destroys everythng in its path, it contributes significantly to species elimination.

JMO.

 

Cheers.

 

Toby Roe's picture

Posts: 118

Date Joined: 01/02/10

Non-Issue

Wed, 2010-09-08 14:27

Commercial by-catch is a different issue to recreational quota allocation. 

 

If a quota is allocated to recs and bag limits apply to individual fisherman then I don’t see how you can suggest any legal form of recreational fishing be excluded from the resource (P.S. coming from the Territory I don’t see how the words “recreational” and “Gill Net” can ever be used in the same sentence but that is a different matter). 

 

“it stops the hunting of big prize fish by spear fishermen as well”, don’t line fisherman target big fish?  Seriously though; spear fishing has zero by catch, has no issues with barotrauma/release survival rates leaves fish in water deeper than 20m untouched by all but the best and to top it all off is bloody hard work.