13.03.01Com Policy Review  

13 March 2001

Ms Tracey Reed,
Commonwealth Fisheries Policy Review,
Fisheries and Aquaculture Branch,
Department of Agriculture, Fisheries and Forestry-Australia,
G.P.O. Box 858,
Canberra, A.C.T. 2601.

Dear Ms Reed,


Commonwealth Fisheries Policy Review

Thank you for the opportunity to contribute to this important review. Your Issues Paper was discussed with our TFIC Directors at a recent meeting in Hobart and we wish to make the following brief comments on behalf of our commercial fishing industry members in Tasmania.

We ask that the following issues be considered by the Review Steering Group

• The roles and responsibilities of AFMA, AFFA, Environment Australia, the National Oceans Office and FRDC need to be clearly defined so that each authority is aware of their responsibilities, obligations and the relationship to each other. In our view AFMA should be the lead authority responsible for Commonwealth Fisheries Policy and Management and the other agencies should recognise and comply with AFMA's needs so that we have one effective and efficient management agency providing all the sustainability and management needs of Commonwealth species.
• The current AFMA structure as a statutory authority should be reviewed to determine if there are advantages in having a more flexible and practical structure enabling the most cost effective and efficient management of our fisheries.
• There needs to be consistency between Commonwealth and State fisheries legislative objectives as the current inconsistency causes difficulties with MOU and OCS arrangements.
• The Commonwealth fisheries agency in AFMA must have the ability to respond to and support the needs of other jurisdictions and to take into account corresponding laws.
• We believe a working group as a sub-committee of the Review Steering Group should be established to investigate financial and other support for the Australian Seafood Industry Council with perhaps a compulsory levy on all Commonwealth permit holders and/or quota holders similar to the funding currently provided for the FRDC. ASIC is structured to provide considerable and valuable assistance on fisheries and related issues but can only be effective if is appropriately resourced.
• There should be provision made for the national generic promotion and development of Australian seafood given that our fisheries management has matured to a level where emphasis can now be placed on maximising the economic return on those fisheries.
• This policy review should also include a reassessment of the role of the Standing Committee on Fisheries and Aquaculture to include industry representation (possibly through ASIC) and to ensure that issues are effectively managed and resolved in a timely manner.
• As the current Government policy and that of the Opposition is that no resource rent tax should apply this policy position must be clearly spelt out in legislation.
• There should be a clear and consistent definition of ESD in all State and Commonwealth legislation closely aligned to a definition of the precautionary principle.
• This review of Commonwealth fisheries policy should be used to address the social impacts on fisheries decisions through structural adjustment programs. Social issues are explicitly addressed through ESD objectives in current legislation.
• In our view the management of recreational and charter fishing are issues that can best be dealt with at State level and responsibility should be given to the States under fisheries legislation.
• The costs of developing, establishing and managing marine protected areas outside of 3nm should be a Commonwealth responsibility particularly as the government has community obligations.
• The auction, tender and ballot method of allocating fishing rights should be removed from Commonwealth legislation and replaced with new standards which place a greater recognition on pioneering rights.
• The FRDC roles and responsibilities and relationships with other agencies should be clearly defined as being a service advisory/research and development structure working on behalf of AFMA and industry.
• More funding should be provided to AFMA to enable them to initiate better stock assessments and to meet their fisheries management needs. They are currently on a reducing budget and FRDC do not consider stock assessments to be within their key responsibilities.
• Industry restructuring schemes such as those recently introduced for the South East Non Trawl and Southern Shark fisheries which are currently handled by AFFA should be the responsibility of AFMA as a part of their fisheries management role.
• Currently AFFA enters into International fisheries agreements with other countries however we believe this should be a responsibility of AFMA who in our view are better placed to consider all issues and to negotiate the best outcomes.
• The current provision in fisheries legislation for fishing permits to be cancelled even for minor infringements should be replaced with financial penalties thereby ensuring that fishermen's rights and entitlements are protected.
• AFMA should have no role in managing detention centres that house apprehended foreign fishermen. They have no expertise in this role and the responsibility should be given to the most appropriate government agency that can manage this issue in the most effective manner.
• The management of Commonwealth fisheries is a complex task and it requires a clear set of rules and adequate funding to enable the achievement of objectives.

We trust that the above comments are of assistance to enable your Review Steering Group to recommend constructive changes to Commonwealth Fisheries Policy that can last at least for the next ten years.
R. K. LISTER
Chief Executive
Tasmanian Fishing Industry Council