14 May 2004
Scalefish Review,
Attn Peter Trott (Scalefish),
DPIWE Marine Resources,
GPO Box 44,
HOBART, Tas 7001
Dear Sir,
Review of the Scalefish Fishery Management Plan
Thank you for the opportunity to comment on the Review Information Paper circulated in March 2004.
Latent Effort
We share the DPIWE view that potential effort in the State commercial sector is of concern and if activated could adversely impact on the future sustainability of scalefish resources.
By our calculations there are 70 Scalefish A licences including 13 licences that have no catch history from July 1998 to 28 February 2003, 163 Scalefish B including 48 with no catch history, 198 Scalefish C including 110 with no catch history and 314 rock lobster scalefish entitlement of which 136 have no catch history during the above period.
We have considered all the options put forward by DPIWE and TFIC members we have been in contact with both at the public meetings and in person. Naturally the views are many and varied and the TFIC Board has recently decided on two important criteria which should be adopted
- We do support the non transferability and owner operation of Scalefish C licences which have no catch history, and
- we do not support the compulsory non renewal of Scalefish licences by the Government.
There is another important issue which also has full TFIC Board support and that is the fair and reasonable treatment of Scalefish C licence holders under this review. In our opinion as the issue is latent effort all Scalefish C licence holders should be offered some form of structural adjustment assistance by the State Government to surrender their licences should they choose to do so and on a voluntary basis.
This approach would permanently remove the surrendered licences from the fishery and would be treating licence holders who have in good faith and for their own reasons renewed their licences for the last 5 + years both morally and fairly.
Scalefish C licence holders who do not accept the financial assistance should continue to be non transferable and owner operated. This approach would enable Scalefish C operators to voluntarily exit the fishery with a level of dignity and would enable the Government to achieve permanent structural change at very little cost.
The level of adjustment assistance would be small and as the current Scalefish C renewal fee is $158.57 pa an offer to voluntary surrender licences should be by reimbursement of the last three years licence fees i.e approximately $465. This would not suit fishermen who may have paid up to $5,000 to purchase a Scalefish C licence several years ago before non transferability came into effect but it does manage this issue fairly for all concerned.
To be consistent and with the full support of the TFIC Board this structural adjustment assistance should also be offered to Scalefish A and B licence holders with no catch history based on reimbursement of the last three years of their licence fees (approximately $1,120 for a Scalefish A and $680 for a Scalefish B) as these licences are also proposed to be non transferable.
In summary we support the following positions –
- For Scalefish C with no catch history between 1 July 1998 and 28 February 2003 these licences should be permanently non transferable and owner operated. Structural adjustment assistance should be offered on a voluntary acceptance basis and the surrendered licences cancelled. We do not support the proposed non renewal of these licences.
- For Scalefish C licences with catch history the licences should be permanently non transferable with three exceptions and structural adjustment assistance should be offered as above.
- An exception to this non transferability should allow Scalefish C licences with (say) three tonne of catch over the period to be transferable. This would recognise the level of commitment of these fishermen and over time would allow an entry point for new participation in the scalefish fishery the need for which was identified by the Matt Bradshaw Socio Economic Profile of the Scalefish Fishery.
- For the seven Scalefish C licence holders with wrasse entitlements these operators should be allowed to transfer their whole package.
- Scalefish C licences with catch history should be available for transfer or nomination to a direct family member and we would be pleased to participate in a examination of how this could be undertaken.
- Scalefish A and B with no catch history in the criteria period should become non transferable with a one off opportunity to nominate a supervisor to undertake scalefishing on behalf of the licence holder. Structural adjustment assistance should also be offered on a voluntary acceptance basis and the surrendered licences cancelled.
- Scalefish A and B with catch history – no change.
- We believe the Tasmanian Rock Lobster Fishermen’s Association will put forward a submission on rock lobster scalefish entitlements.
Netting Practices
The major issues here are –
- Recreational net setting practices have been of concern for many years with some fishermen leaving nets for considerable periods and overnight resulting in wastage of fish and unnecessary mortality of bycatch species and wildlife.
- Commercial fishermen on the other hand have a different approach in so much as the quality of the catch has a significant bearing on the prices achieved and for economic reasons nets are attended generally on a regular basis.
The difficulties with the DPIWE recommendations are defining and enforcing "attended", weather/sea conditions are a defensible reason for non compliance and the issue of extreme tides particularly in the northwest. There are also significant safety concerns about inexperienced recreational fishermen attending nets after dark and this aspect alone makes the DPIWE recommendation inappropriate.
On balance we believe that both recreational and commercial fishermen should continue to be allowed to have nets set at night without being in attendance.
Species of High Value to the Recreational Fishery
We agree that a trigger point on the overall commercial catch of Australian salmon available to holders of a fishing licence (Australian salmon) be set at a level 20% higher than the ten year average. This would not affect the bycatch fishery and will take into account the special circumstances of the Australian salmon licences.
Bag and Possession Limits
We oppose boarfish being declared a protective species. They are generally taken in nets and would mostly be dead if returned to the water and are not viewed by industry as being in any danger. Commercial catches have consistently averaged 7-8 tpa for the last 10 years.
For the other recommendations relating to recreational fishermen there is a need to address the fillets and filleting at sea issues and penalties for non compliance as we are particularly concerned about preventing the unlicensed sale of fish. It also needs to be made clear that possession limits do apply to fish at home as I understand this is the case.
Shark Bycatch Possession and Trip Limits
Many commercial fishermen supplement their diversified income with catches of shark other than school and gummy shark, i.e. saw, mako, blue, thresher and 7 gill sharks.
We accept the current commercial combined bycatch limit of five school and gummy sharks but do not support a boat limit of 5 shark carcasses for state licensed scalefish fishermen. We therefore recommend no change to the current arrangements.
Norfolk Bay and Eaglehawk Bay
The proposal to prohibit gillnetting in Eaglehawk Bay is supported provided that this does not impact on the octopus fishery. This scalefish plan is not about managing octopus and barrier nets with no interaction with scalefish species should continue to be permitted in this area.
Danish Seine
The proposal to prohibit fishing in the waters identified on weekends is apparently acceptable to the main non transferable licensed operators and is their normal practice anyway.
Size Limits
We do not support the proposed upper size limit for wrasse – refer to a separate submissions from Dale Jacobson and Michael Hardy. There are markets available for larger fish in Victoria.
Seals
We agree with the recommendation to provide flexibility for banded morwong fishermen although view this as only a short term benefit.
Species specific commercial licences
We agree that no new species specific licences are needed at this time and that southern calamari issues need to be addressed separately with stakeholders.
Yours faithfully,
R.K. LISTER
Chief Executive