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||Surf Casting and Angling Club of W.A. (Inc.)
Submission on Jurien Bay Marine Park Indicative Management Plan.
2 January 2001
To:- Plan Coordinator
Jurien Bay Marine Park Indicative Management Plan
Marine Conservation Branch
Department of Conservation and Land Management
47 Henry St.
Fremantle, W.A. 6160
- General Comments.
- Section 2.1, Vision Statement.
- Section 2.2, Strategic Objectives.
- Section 7.1.1, Geomorphology.
- Section 7.1.2, Intertidal Reef Platforms.
- Section 7.1.3, Water Quality.
- Section 7.1.4, Seagrass Meadows.
- Section 7.1.5, Macroalgal Communities.
- Section 7.1.6, Seabirds.
- Section 7.1.7, Invertebrate Communities.
- Section 7.1.8, Finfish.
- Section 7.1.9, Sea Lions.
- Section 7.1.10, Cetaceans and Turtles.
- Section 7.2.3, Commercial Fishing.
- Section 7.2.4, Aquaculture.
- Section 7.2.5, Coastal Use.
- Section 7.2.6, Seascapes.
- Section 7.2.7, Recreational Fishing.
- Section 7.2.8, Water Sports.
- Section 7.2.9, Marine Nature Based Tourism.
- Section 7.2.10, Petroleum Drilling and Mineral Development.
- Section 7.2.11, Scientific Research.
- Section 7.2.12, Education.
- Table 2. Uses Permitted in the Zones.
- Comments on Proposed Zones.
This submission has been prepared on behalf of the members of the Surf Casting and Angling Club of W.A. by the Secretary, Terry Fuller. The Club's postal address is PO Box 2032, Marmion W.A. 6020, and the secretary can be contacted by telephone on
The Surf Casting and Angling Club of W.A. (Inc). is based in the Perth metropolitan area and has 77 adult members and 13 junior or mini junior members. The club has been in existence since 1952 and has members who have fished in the proposed Park many times over more than thirty five years. The Club's main activities are shore based recreational line fishing and dry casting.
As such, the Club's main interests and activities in the proposed Jurien Bay Marine Park are shore based recreational line fishing. Individual Club members and their families are also interested in other tourism and recreational activities in the area.
1. The Club wants to make a clear distinction between shore based recreational line fishing, and other shore based recreational fishing such as collecting shellfish, etc. from the shore. Shore based recreational line fishing targets mobile fish such as tailor, herring, garfish, whiting, mulloway, skipjack trevally, sharks and other similar pelagic species. These fish have seasonal migrations along the West Coast and have seasons when they are present and seasons when they are not present. They also regularly move significant distances along the beaches over a short period.
Shore based catches of other fish species are not very common and would have little if any impact on fish populations, particularly compared to recreational boat fishing and professional fishing which are far more mobile and which can cover the entire area and not just a few tens of metres from the shoreline.
We believe that there would be little impact on the effectiveness of Sanctuary zones if shore based line fishing to 100 metres was allowed throughout.
Thus the Club proposes that there should be another zone type called Special Purpose (Shore Based Recreational Line Fishing) Zone.
2. The proposed marine park covers many kilometres of coastline. Unfortunately not all of the coastline is suitable for recreational line fishing from the shore for the types of fish most people want to catch. Some of the coast is shallow, some is rocky, some is invariably weedy, and when these are combined within the regular strong sea breezes, shore based line fishing in these areas is difficult at best and often unrewarding. Successful shore based fishing requires access to the areas where the fish will come through, or come past.
So the equity of the proposals cannot be measured merely by quoting the percentage of coastline still available for shore based line fishing. Even though this percentage may be very high, the areas lost to anglers appear to include some of the most suitable parts of the coast. We believe that far too many of the good areas for shore based line fishing would be lost through being included in the proposed Sanctuary areas.
3. The size and shapes of many of the proposed zones appear to reflect major compromises. Many do not appear to have enough area or width to be effective as sanctuary zones. The proposal relies heavily on the presence of large areas of Special Purpose (Scientific Reference) zones to back up the sanctuary zones, but as covered elsewhere in this submission, the application of these Special Purpose (Scientific Reference) zones is badly flawed.
4. The Special Purpose (Scientific Reference) Zones as proposed remove 17 percent of the marine park from recreational line fishing from boats. A further 4 percent of the marine park is closed to recreational line fishing from boats in the sanctuary areas. This total of 21 percent area loss to recreational line fishing from boats is excessive and inequitable. The Club wonders how the proposers expected to get community support for such a major loss of access, when it is clear that commercial rock lobster fishing would hardly be affected by the loss of access to only 4% of area in the sanctuary zones.
Section 2.1, Vision Statement.
The Club fully supports the Vision Statement for the proposed Marine Park, but notes the sentence "will be considered an important asset by the local community". Due to it's proximity to the Perth metropolitan area and to mid west rural farming areas, it is important that the proposed Park also meets the needs of the residents of these areas, without compromising the main purposes of the Park.
Section 2.2, Strategic Objectives.
The Club fully supports the Strategic Objectives as stated in Section 2.2, but does not believe that the details in later sections of the plan actually follow or will achieve these objectives. More details will be provided later in this submission.
Section 7.1.1, Geomorphology.
Management Objective number 2 under this section is "to ensure that coastal landforms within the park are not degraded by recreational access and use". This objective is fully supported by the Club. However, the Club cannot support this objective being used to completely exclude access to specific areas, as listed as one possibility in the "Background" section, unless this exclusion is the ONLY possible way this protection can be achieved, AND if it is critical that such protection be provided. The alternative of providing made access tracks, boardwalks or roads, as appropriate, is far preferable. Where provided, it is important that the layout of these does meet the legitimate needs of users.
Section 7.1.2, Intertidal Reef Platforms.
The Management Objective is to ensure the species diversity and abundance of marine flora and fauna on intertidal reef platforms of the park are not significantly impacted by fishing and reef walking activities. The important words are "significantly impacted" and these need to be better defined. Without such a definition, the concern is that any visible impact may be considered significant, and lead to more unnecessary restrictions.
The Club supports this objective in principle, but considers that the objective should not be applied where it would result in a significant loss in access for reasonable and sustainable recreational activities. As indicated, intertidal reef platforms around the offshore islands are barely used because of access difficulties, and these should be used as the reference baseline, rather than restrict access to mainland intertidal platforms. Collection of animals from the reef surface should be controlled by bag limits and closed seasons as for metropolitan recreational abalone collection, and this would control the effect on the population and would go some way towards reducing human activity on the reef surfaces.
This suggestion is consistent with the long-term target No 3, which is "that the abundance of targeted flora and fauna species on intertidal reef platforms is maintained at sustainable levels" - words which appear to allow some impact provided the populations are sustainable.
Section 7.1.3, Water Quality.
The Club fully supports this Management Objective to maintain an important feature of the park.
Section 7.1.4, Seagrass Meadows.
The Club fully supports this Management Objective to maintain the seagrass meadows as important habitat.
Section 7.1.5, Macroalgal Communities.
The Club fully supports this Management Objective to maintain the food chain.
Section 7.1.6, Seabirds.
The Club agrees with the strategy to educate Park users about the Park's seabird population.
Section 7.1.7, Invertebrate Communities.
The Club fully supports this Management Objective to maintain the food chain and population of invertebrate species.
Section 7.1.8, Finfish.
The Management Objective is to ensure the species diversity and abundance of non target finfish species are not significantly impacted by human activities in the Park. However the background also talks about control of targeted species, e.g. Baldchin Groper - which should be included under sections 7.2.3 and 7.2.7.
The Club fully supports and endorses proposals to reduce, and if possible eliminate, commercial fishing by-catch as soon as possible. While the Club realises that commercial fishing is an important industry, we believe the by-catch in the past has been completely unacceptable.
The Club actively endorses and supports ethical methods and restraint in recreational fishing, to the extent that many of our members voluntarily limit their catches to less than the quantity of fish allowed under Fisheries WA recreational fishing regulations. Fishing methods and catch care principles are used which allow all unwanted fish a high probability of successful release back into the ocean.
Recently, Fisheries WA produced a discussion paper covering Recreational Fishing on the West Coast, which obviously includes the Jurien Bay Marine Park. The Club submitted many comments on that document, and supported many of the proposals in it. However, the Club strongly believes that recreational fishing regulations should be uniform throughout the State.
The Club believes that Sanctuary Zones and/or closed seasons should be used to manage pressures on particular species of fish. The Club strongly disagrees with a total prohibition on catching particular species of fish from particular areas where recreational fishing is generally allowed, unless in exceptional circumstances such as dense spawning aggregations. Here short closed seasons covering the aggregation period are preferred.
Section 7.1.9, Sea Lions.
The Club supports this Management Objective.
Section 7.1.10, Cetaceans and Turtles.
The Club supports this Management Objective.
Section 7.2.3, Commercial Fishing.
The Club supports the three Management Objectives listed. In particular, the Club endorses objective number two which is "to ensure that commercial fishing activities in the park are managed in a manner that is consistent with maintaining the park's values." Objective number three which is "maintenance of a viable commercial fishing industry.." is of course important, but must not be used to allow activities which are not compatible with the requirements of the Park.
The Club is also concerned about the equity of access to areas of the park. The proposed size of Special Purpose (Scientific Reference) zones, combined with their use for rock lobster catches is an example where objective three appears to have been given far to much emphasis over objective two.
Section 7.2.4, Aquaculture.
Comments as for section 7.2.3 above.
Section 7.2.5, Coastal Use.
This section deals with litter, and with the use of Recreational Vehicles.
Litter is a social problem wherever people do not respect the environment and do not follow common courtesy. The fact that there will always be some people who will litter, despite all the publicity and education, should never be used as an excuse to limit access by the majority of people who will do the right thing, and who will treat the environment very well. The Club believes a combination of education and enforcement should be used so that those that do litter and get caught will pay a price, preferably high enough so that it makes them do the right thing in future.
Similarly, unsuitable Recreational Vehicle use is also a social problem, and once again must never be used as an excuse to limit access by the majority of people who will do the right thing. Recreational Vehicle use can be benign or can be very damaging. Recreational Vehicle use on sandy beaches has a very transient affect, which is often completely eliminated by the next strong sea breeze or high tide. People who value their access to and along such beaches would never do anything that might compromise that right. Unfortunately there is a small minority of socially irresponsible people who do things like damage vegetation or drive on sand dunes or drive dangerously near other beach users.
The Club believes a combination of education and enforcement should be used so that those who use RVs irresponsibly and get caught will pay a price, preferably high enough so that it makes them do the right thing in future.
Section 7.2.6, Seascapes.
The Club fully supports this Management Objective.
Section 7.2.7, Recreational Fishing.
The Club fully supports this Management Objective. However, see other comments under 7.1.8, Finfish, and comments on zoning, etc.
Section 7.2.8, Water Sports.
The Club supports this Management Objective, but not the use of powered water sportscraft in Sanctuary zones. See other comments on zoning, etc.
Section 7.2.9, Marine Nature Based Tourism.
The Club generally supports this Management Objective. See other comments on zoning, etc.
Section 7.2.10, Petroleum Drilling and Mineral Development.
The Club considers that the most stringent examination, precautions and penalties should be applied to all such proposals within the Park.
Section 7.2.11, Scientific Research.
The Club supports this Management Objective, however believes that the proposals have major flaws. See other comments on zoning, etc.
Section 7.2.12, Education.
The Club supports this Management Objective.
Table 2. Uses Permitted in the Zones.
Commercial Rock Lobster Fishing. The Club most strongly disagrees with allowing commercial rock lobster fishing within the Special Purpose (Shore Based Activities) zone and the Special Purpose (Scientific Reference) zones.
It particularly does not make sense to allow commercial rock lobster fishing within the Special Purpose (Scientific Reference) zones, since section 8.1.2 says "the primary purpose of these zones used to provide large areas where natural processes can be studied free of significant human influence". Commercial rock lobster fishing must be considered a significant human influence since it is removing what we believe is a significant part of the food chain, and is using pots which have a potential to cause damage to the seabed and environment.
It does not make sense to allow commercial rock lobster fishing within the Special Purpose (Shore Based Activities) zones adjacent to sanctuary areas such as Boullanger Island and North Head. Also, since these areas are only 100 metres wide from the shoreline, it is not known how much use commercial rock lobster fishers will be able to make use of this area, but there is a significant potential for conflict between rock lobster pots and ropes and recreational fishermen casting from the shore. There is also a considerable difficulty with checking compliance because the boats would need to transit the sanctuary zones to get to these Special Purpose (Shore Based Activities) zones.
Recreational Rock Lobster Fishing. The Club disagrees with allowing recreational rock lobster fishing within the Special Purpose (Scientific Reference) zones, for the same reasons as above, and since no other recreational collecting is allowed in these zones.
Surface Water Sports. The Club strongly disagrees with allowing surface water sports such as jet skis, water skiing and racing boats, particularly in sanctuary zones and to a lesser extent in Special Purpose (Scientific Reference) zones. It is considered that sports such as these represent a significant and avoidable disturbance to the environment through continuous and/or sustained high levels of engine noise. The Club has no objection to non disruptive surface water sports such as surfing, windsurfing, kite surfing, etc. or normal recreational boating in any area.
Comments on Proposed Zones.
Special Purpose (Shore Based Activities) Zones. The Club recognises that an effort has been made to make provision for shore based recreational fishing in all of the Special Purpose (Scientific Reference) zones and some parts of the Sanctuary zones. This has provided a significant length of coastline for shore based recreational fishing. As far as they go, we fully agree with all of the areas shown in the document. However, when we look at the location of the proposed Sanctuary zones which exclude shore based recreational line fishing, the most critical point is that these zones contain many of the best areas for recreational line fishing from the shore, and many of the areas in which shore based line fishing is allowed are not really suitable. Thus we do not think that there are enough of these Special Purpose (Shore Based Activities) zones in Sanctuary Zones.
Sanctuary Zones. The Club agrees with the concept of Sanctuary zones where these are essential to provide a reservoir of fish stocks, and where the proposed zones will be effective in doing this. However Sanctuary zones are only one means of preserving fish stocks. The Fisheries WA discussion paper covering Recreational Fishing on the West Coast proposes significant changes to recreational fishing, aimed among other things, at preserving fish stocks in the entire West Coast region. The paper and related papers promise that commercial fishing pressures are well controlled and managed. And the proposals in that paper are tightening recreational fishing controls at a time when stocks of many recreational fish targeted by shore based recreational line fishermen are at the best levels for many years.
As indicated in your section 7.2.7, research and monitoring of the target species and the effects of recreational fishing on the park's values need to be undertaken. This would indicate to us that there is no data yet which indicates an urgent need for Sanctuary zones for the purposes of stock preservation of the type of fish caught by shore based recreational line fishing. In fact, the good fish stocks in the 2000 season could be used to show that current controls and education are working well.
We accept that Sanctuary zones have other uses, in particular for tourism, and for preservation of reef fish and invertebrates, and we accept that these would be valid reasons to have some. However we believe that shore based recreational line fishing would not be incompatible with the primary aims of these areas. Thus the Club proposes that there should be another zone type called Special Purpose (Shore Based Recreational Line Fishing) Zone which should be used for the shoreline of Sanctuary Zones or any other zones where shore based recreational line fishing might otherwise be prohibited.
Target Rock Sanctuary Zone. This zone contains an important shore based fishing area at Target Rock. The Club does not support the restrictions on shore based recreational line fishing in this area. The shoreline should be zoned as either Special Purpose (Shore Based Activities) or Special Purpose (Shore Based Recreational Line Fishing).
Grey Sanctuary Zone. The shoreline should be zoned as either Special Purpose (Shore Based Activities) or Special Purpose (Shore Based Recreational Line Fishing).
Boullanger Island Sanctuary Zone. The Special Purpose (Shore Based Activities) zone should be extended to cover the entire shoreline of this sanctuary zone.
North Head Sanctuary Zone. The proposed loss of access to the beach area east and southeast of North Head is significant, because this is an important shore recreational line fishing area in an area with few other alternatives. The beach area within the proposed Pumpkin Hollow sanctuary zone is less suitable, and access to the beach area from that location south towards Jurien is understood to be difficult because of the mining lease.
The reef platforms at North Head are important recreational line fishing areas, because they are accessible from the shore. They can however, only be used under favourable conditions of tide, swell and wind.
Similarly, the beach and reef areas north of North Head are also important shore recreational line fishing areas.
Section 8.1.2 says that the purpose of sanctuary zones includes the opportunity to obtain comparative data with areas of the park where extractive activities are permitted and/or where environmental impacts may be occurring. However it seems that by including North Head in a sanctuary zone, there is no similar area which can be used as the comparative area where extractive activities are permitted and would actually occur.
The Special Purpose (Shore Based Activities) zone or Special Purpose (Shore Based Recreational Line Fishing) should be extended to cover the entire shoreline of this sanctuary zone.
Special Purpose (Scientific Reference) Zones. The Club has major objections to the way in which these are proposed to be applied. The application of Special Purpose (Scientific Reference) zones is flawed, and we wonder how the proposers possibly expect to get community support. The major problem is that they are de facto sanctuary areas for all purposes except rock lobster capture, and by this they exclude recreational line fishing from boats.
The Club is a shore based fishing club, and does not have experience with boating in these areas. Looking at the maps, we could expect comments that these areas are some distance from the major population and access points, and the loss to recreational line fishing from boats would be small. However if it is claimed that these areas are available to and would actually be used for recreational rock lobster fishing from boats, then the same claim could be made about line fishing from boats. No doubt, recreational boat fishing clubs will make their submissions.
It would appear that commercial rock lobster fishing industry has received a major concession through being allowed to continue captures in these areas. It would also appear that recreational rock lobster fishing has also been allowed in an attempt to demonstrate equity, but we wonder how much use can be made of this.
We realise that prohibiting rock lobster fishing within Special Purpose (Scientific Reference) zones will in effect make them Sanctuary zones. But it would be much better to have adequate sanctuary zones, because these could also be used as scientific reference zones.
If it is claimed that the scientific reference zones will enable the effect of rock lobster fishing to be assessed by comparing these zones with sanctuary zones where no activities are allowed, then surely such large areas (17% of the park) are not required, and the sanctuary zones (4%) are far too small and fragmented to be references.
If it is finally decided that rock lobster fishing will be permitted as proposed, then we submit that the proposals should not try to hide the real use of these zones. The name of these zones should be changed to something which truly represents their use, such as Special Purpose (Rock Lobster extraction) zone, so that the meaning and use of the zone is absolutely clear to everyone.
In summary, the Club supports proposals for conservation and controls, where there is data which shows that these are needed and will be effective, equitable and will share the effort and impact among all involved parties.
We hope that our comments will assist the Management Plan's Advisory Committee, and will show which areas of the proposal are not justified and which need changes to achieve community acceptance.
Surf Casting and Angling Club of W.A. (Inc)
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