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||Surf Casting and Angling Club of W.A. (Inc.)
Club Comments on West Coast and Gascoyne Recreational Fishing Reviews.
PO Box 2032
Marmion, W.A. 6020
4th December 2001
The Honourable Kim Chance, MLC,
Minister for Agriculture, Forestry and Fisheries
Recreational Fishing Regional Reviews
Locked Bag 39, Cloisters Square Post Office.
Perth WA 6850
Comments on West Coast and Gascoyne Recreational Fishing Reviews.
These comments have been prepared on behalf of the members of the Surf Casting and Angling Club of W.A. by the club Secretary. The club has been in existence since 1952, and currently has 74 adult and 13 junior members. The Club's main activities are dry casting and shore based recreational line fishing from Esperance to Exmouth, with members going further north and east on individual trips.
The Club congratulates you for your initiative in publishing these reports and your initial responses at this time, and the opportunity for further public comments before changes are actually introduced. The comments in this letter are based on the details in the "Minister's Initial Responses", unless otherwise indicated.
The club remains concerned that proposed changes to Recreational bag and possession limits are not matched by any effective controls on professional catches. Although professional boat and license numbers are controlled, there is no effective control on how much fish is actually caught by professional fishers, for the great majority of species of interest to recreational fishers.
The club is concerned that increased abundance of fish if recreational catches are reduced, could simply result in increased professional catches. This would not meet Key Principle 1 which is that benefits from management of total recreational catch should flow back to the recreational sector. Recent reports of large (legal) professional catches of Dhufish and Pink snapper from metro waters and large Tailor (catch location not known) reinforce our concerns that controls on total catch are essential.
Our preference is for an integrated fisheries management strategy which includes the immediate introduction of effective controls on the professional catches at the same time as changes to recreational limits, to ensure that fish stocks are sustainable. If effective controls on the professional catches can not be introduced yet because the Justice Toohey committee inquiry has not reported, then we believe that any changes to recreational limits should be limited to the introduction of the proposed possession limits, with the changes to categories and bag limits to be introduced later, at the same time as effective controls on professional catches. All fish stocks identified as being at risk already have effective catch controls for recreational fishing, so there is no urgency for changes.
The club urges that consideration be given to nominating certain specific species of fish for recreational angling only. Species included in this "recreational only" category should include species such as tailor, herring, mulloway and salmon. All of these species have a minimal or low commercial value.
The club supports the majority of the principles and recommendations. This support is given conditionally on the assumption that effective controls on professional catches will be introduced. If not, then the club submits that the limits for recreational catches should be publicly reviewed before implementation, when the details of professional limits are known to the public.
We do not, however, agree with some of the details in the current recommendations, as listed below.
The club supports uniformity of rules across the State, and also recognises the need for special limits where specific situations occur. But a comparison, species by species, and category by category of the proposed limits for Gascoyne and West Coast shows some significant differences between the two regions in minimum and maximum sizes, bag limits and slot limits, and placement of fish in categories. These are not logical and cannot be supported, and will make understanding of and compliance with the proposed rules much more difficult.
A specific example is:-
||Proposed 2 over 500 mm
Strategy W1. The club notes the proposed reduction in the daily bag limit for cobbler to four fish. The club is concerned at the reported decline in the number of cobbler and proposes that a study should be undertaken into the sustainability of cobbler.
Strategy W2. The club strongly disagrees with the proposal to increase the minimum size for tailor to 300mm for the Swan and other estuaries. This species rarely grows larger than 250mm in river systems and estuaries, and fish of this size are already hard to catch in the Swan river during the summer. Raising the limit to 300 mm will seriously affect the quality of recreational fishing by people such as children, families and disabled people who can use the jetties and shorelines in the river, where they could not cope with ocean conditions where they might catch tailor above this size. As such, this change is inequitable and unfair.
No data is given which shows that this change is needed, or that it will improve the stocks of tailor. The article by Andrew Cribb in the Oct/Nov 2001 Western Angler, page 20, says "the fishery is both healthy and sustainable at the current level of fishing" and "the need to improve protection for the adult spawning stock..." The club submits that proposed slot limits, and making tailor a recreational only fishery south of Shark Bay (rec 19c) would be sufficient, without taking away an important recreational fishery for those of our community who can only fish in protected waters.
The club further submits that if it is still proposed to increase the tailor size limit for the Swan River and other estuaries, this should occur only after surveys are undertaken during this 2001/2002 summer estuary fishing season to get data on tailor catches and sizes from jetties and shoreline of the Swan and other estuaries, and only if that data shows that the quality of recreational fishing for this part of our community would not be greatly affected by the change. If it is claimed that restraint for one year will result in better catches of fish above 300 mm in later years, then surveys should be undertaken to prove this, and if not proven, then the size for estuaries should be reduced back to 250 mm in later years.
The club also considers that the slot limits for tailor are unsuitable, as tailor often school in common sizes in any one area, meaning that if two fish are caught over the maximum size, it is most likely that any others may be similar in size, effectively reducing the bag limit to two.
Strategy W2. Black Bream. The club strongly disagrees with the proposed reduction of the bag limit to 4 in the West Coast Region. Currently this is 8 in the Swan and Canning Rivers and 20 elsewhere, and the reduction from 20 to 4 is much too severe. The black bream fishery is in excellent health in the Swan and Canning River and no evidence was presented which showed that the fish stocks are at risk at present, so the reduction from 8 to 4 in the Swan and Canning Rivers is not supported. The club proposes that the limit should be made 8 State wide. Breeding stock would have a considerable degree of protection, compared to the current limits, with the introduction of the slot limit of only two fish over 40cm. Black bream is a species which can easily be bred from local fish and restocked if ever required.
Strategies W2/W3. Pike and Snook in West Coast. The proposal to increase the size limit to 300 mm for both these species is not supported by the club. Snook is a large species and the current limit of 330 mm is appropriate, if not actually too small. Pike is a small species and the current limit of 280 mm is appropriate. Indeed, during the summer, small pike are common and many are below the current limit of 280 mm, yet carry roe, showing that they have already reached breeding age at that size. Increasing this size limit to 300 mm will make it difficult to catch legal sized pike. One reason given for these proposed changes is that the public has difficulty distinguishing between pike and snook, so it is easier to have a common size limit. But pike is a category 3 fish with no individual bag limit within the forty allowed, and snook is a category 2 fish with an individual bag limit of 8. So the public needs to be able to distinguish between them, and publicity and education may be needed, and this cannot be used as justification for having the same size limit.
Strategy W4. Mud Crabs in West Coast. Mud crabs have appeared in several estuaries in the West Coast region in the past year, but there are no size or bag limits proposed. This naturally occurring and potentially valuable recreational fishery should be closely managed in early years to ensure that it is not wiped out by uncontrolled catches.
Strategy W9. Possession limits. The club supports possession limits, but these need to be defined in more detail. It is not at all clear what is meant by "possession limits". While a person is on the beach and water, and travelling on the road, these are clear enough. But is it intended to apply to places of residence, etc?.
These also need some commonsense latitude in their definition and application. The limits allow options which include 1 or 2 day's bag limit of "whole" fish, but many people remove the heads and tails from their fish where this is allowed by Strategy W7, and these should still be classed as "whole" fish. Similarly, not many people have an icebox which can hold a legal sized (900mm) or bigger spanish mackeral in one piece, so may cut it in half. It would be unfair and inequitable if a spanish mackeral or other large fish suddenly became "fillets" if cut in half, and yet these pieces could still clearly be identified as coming from one fish, and that definition then put the owner over the possession limits.
Strategy W12. Set and Haul Netting. The club does not support recreational set netting. Small throw nets should be permitted for the gathering of small quantities of bait for immediate use in suitable places in estuaries even if these are closed to other forms of netting. To cover any concerns about compliance, please see our later comments on education and compliance.
Strategy W13. Prawn Drag Nets. The term "adjoining" in "adjoining nature reserves" needs to be defined before the impact can be assessed. Does this mean 10 metres, 50 metres or 500 metres ?
Strategy W14(a). Unattended set lines. The club fully supports the proposals for heavy set lines. However again some sensible latitude is needed. Shore fishers often place their rod in a rod holder in the sand or rocks and move away in the interests of their personal safety, to talk, get some food or a drink, etc. The 10 metre limit should be increased to 30 metres or should not be enforced in these circumstances.
Strategy W15. Fishing Competitions. The organisers of fishing competitions simply cannot comply with some of these requirements. An organiser can record the numbers who register, and the fish actually presented for weigh in, but has NO control over the results offered from the public about fish caught and released, or caught and not presented, and cannot compel a competitor to accurately record catch and effort. Any survey conducted from these records may be inaccurate, invalid and totally misleading. The club considers these rules should only be applied to commercial organisations using recreational fishing as an advertising or promotional venture.
While the club supports most of the proposals, and supports the precautionary approach where there is some data to justify that, the club is concerned at the apparent misuse of statistics to support and justify some of the proposed actions. The surveys have been extrapolated to 600,000 odd recreational anglers and 10 million odd angler days. In the past, it was said and generally accepted that 10% of the anglers caught 90% of the fish. That didn't necessarily mean they were greedy, just a statement of fact that most recreational anglers aren't very good at, or committed to putting in the effort needed to catch fish. A more recent figure suggested that now 96% of the fish are caught by 4% of the anglers. This statement wasn't supported by hard data, but may well be true, from observations of the great many occasional anglers and their spectacular lack of success.
This concern is supported by the calculations on page 32 of West Coast where the calculated potential herring catch is an impossibly large 21,600 tonnes, yet the estimated catch was only 100 tonnes. All the proposals seem to be based on the premise that all anglers are equal and the result from any one fishing trip is the same as any other. Both of these premises are clearly wrong. An indication that a person has fished on a day does not equal a full day's fishing and does not result in a day's bag limit of fish or anything remotely approaching that.
We question the 10 million fishing days per 365 day year. This comes to 27,400 recreational fishers fishing on every day of the year on average. This would be an absolute boom industry, but one would have to doubt that figure when one can travel a fair bit of the metro area and not see more than a few thousand people fishing (if that) even on busy days, and very few fishing on many days. And look around coastal holiday resorts even during holiday periods and find similar numbers.
Recommendations 22 to 24. Education and Monitoring. Changes to possession and bag limits will not mean anything unless the public is educated and the limits are enforced sensibly. Non compliance is a social problem wherever people do not respect the rules, and there is a limit to what individuals can do when they see breaches. A reporting system is of little value unless it has effective follow up. The club believes a combination of education and enforcement should be used so that those who blatantly don't comply will face a high chance of being caught, and will pay a price which is high enough that it makes them and others do the right thing in future. The fact that there will always be some people who will not comply, despite all the publicity and education, should never be used as an excuse to limit catches by the majority of people who will do the right thing.
I can be contacted on for any queries about these comments.
Surf Casting and Angling Club of WA (Inc.)
Copyright © 2002 Surf Casting and Angling Club of W.A. (Inc.) Permission may be obtained to use extracts from this document by applying to the Club. Please check the copyright notice.
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