9 October 2003
The National Oceans Office,
G.P.O. Box 2139,
Hobart, Tas. 7001
Dear Sir,
Response to Draft South-east Regional Marine Plan
Thank you for the opportunity to respond to this draft plan.
The Tasmanian Fishing Industry Council (TFIC) is the peak industry body representing all commercial fishermen, marine farmers and fish processors licensed in this State we are therefore extremely concerned about any proposal that will adversely impact on our members future opportunities to access marine waters.
I must emphasise that our industry is generally opposed to the introduction of restrictive marine protected areas which will impact on traditional and current commercial fishing activities. Based on authoritative research information we see little or no benefit for fishermen, commercial fish species, coastal communities and the economy of Tasmania generally in locking up further areas of marine waters for what we view to be political rather than common sense reasons.
We have however responded below to the draft plan in good faith to provide you with our views but are clearly of the opinion that MPAs in Commonwealth managed waters are not only not necessary but also will have unnecessary impacts on our industry at a time when States need continuing small business growth and expansion within of course the constraints of sustainable fishery management plans.
Despite what may be the good intentions of this plan the whole process has not provided "increased long term security of access and certainty of process for existing and future marine-based industries" – Pages 14, 17 and 36.
The reverse is the true story. Any suggestion of restrictions on sustainable fishing activities by say the creation of marine protected areas has already caused more uncertainty and concern amongst our industry members than any other single issue in recent memory.
The threat of locking up more productive areas of marine waters puts at risk the very considerable investment in fishing businesses and also places in doubt the whole process of responsible and sustainable fishery management plans, including quotas and total allowable catches etc.
Commercial fishermen have statutory fishing rights developed under very detailed plans of management which includes consideration for protection of marine biodiversity and ensures the sustainable use and development of marine resources. These plans have evolved over time with changes in knowledge and information and are flexible to meet for instance changes in marine species stock assessments.
The draft plan and proposed actions appear to give scant regard to the considerable economic and employment benefits that result from commercial fishing activities both to regional communities and at State/Commonwealth level, and the considerable downside if existing arrangements are impacted by this SERMP. Commercial fishermen should not be expected to take the brunt and all the pain of the BAOI proposals with a loss of access rights and fishing grounds.
Whilst many of the Action Plan objectives are commendable there are several issues that we believe should be highlighted as principal objectives such as:
• a full commitment in every instance to minimise any impact on sustainable commercial fishing businesses and operations and to protect the service industries that rely so much on these activities;
• to provide certainty for the commercial fishing industry by providing structural adjustment support to meet any displaced fishing effort with agreed criteria and mechanisms and for full funding arrangements to be in place before MPA decisions are made (more positive than the vague proposition at 1.5.2);
• before final decisions are made fully assess the socio-economic impacts including a cost/benefit analysis and take account of these issues when decisions are being considered (refer 1.5.1), and
• only develop MPAs in any of the 11 BAOI where there is minimal impact on commercial fishing businesses and operations and where clear and positive benefits can be identified and measured.
It would also be most worthwhile at Action Plan 2.7, 2.8 and 2.10– and could provide tangible benefits to the whole marine environment – if the SERMP took into account State based impacts on the marine environment such as pollution, storm water runoffs and marine debris and developed plans to minimise such impacts along with a strategy to tackle introduced marine pests.
The general thrust of the Plan should be to identify threats to the marine environment and how to measure those threats and a positive plan of action to minimise any impacts.
It is very important that any SERMP changes emphasise the need to provide certainty and a clear direction for our industry with proposals that result in positive benefits rather than the apparently negative impacts and likely penalties on responsible businesses.
The other aspect of importance is the need for adequate time frames to enable industry to respond to specific proposals. The National Oceans Office/Environment Australia have had four years to put together this plan and we view recent requests on industry for candidate areas assessments as being in indecent haste and unrealistic.
The Final Plan now due for release in March 2004 should acknowledge the eleven BAOI and not attempt in the short time frame from now to rush the process by putting lines on maps for candidate MPAs.
In summary we need balanced and measurable environmental protection but with support for our industry and increased investment confidence and this plan should clearly and positively reflect that position.
Yours faithfully,
R.K. LISTER
Chief Executive