14 November 2003
The Manager,
Licensing and Administration Branch,
DPIWE,
GPO Box 44,
HOBART, Tas 7001
Dear Sir,
RIS – proposed fees for renewal of fishing licences (automatic squid jig)
We certainly agree with the statement in the RIS to the effect that the arrow squid fishery is variable in nature and there is no guarantee that there will be a fishery in Tasmanian waters each year and that the quantities taken in various years vary considerably.
From the TAFI Scalefish Fishery Assessment Report 2002 we have confirmed that catches of arrow squid by all methods in State waters for the last eleven years to 2001-02 have averaged 19 tonne pa (with most years less than 10 tonne pa) except for the financial year 1999-00 when 480.5 tonne were taken in an incredible 36 different fishing blocks around the state. Approximately 360 tonne of the 480.5 tonne in 1999-00 was taken by automatic jig or an average of just 19 tonne each per FLASJ vessel.
Significantly in 2001-02 only 2 tonne of arrow squid were reported which is the lowest catch since 1989-90.
The above catch results for this oceanic species with one isolated exception indicate that this is at best a very marginal fishery with minimal returns to fishermen.
The reality of this fishery is in stark contrast to the emotive words used in the RIS including "windfall gains" to FLASJ licence holders.
Whilst there are nineteen automatic licences they were originally created to restrict uncontrolled expansion in the fishery. Anecdotal information suggests that no licence has been traded since they were issued and of course there is no realistic demand given the recorded catch levels in recent years. The licences therefore have no historic or present day value and as a consequence there is no basis to argue that windfall gains have been created.
The RIS also refers to "super profits" and that they should in some way be recovered to provide a return to the State. As can been seen by the catch figures above only one year in the last twelve years has seen any reasonable sort of catch return for the effort so there are very definitely no super profits historically.
The 360 tonne of arrow squid taken by automatic jig in 1999-00 were difficult to sell and prices just above $1 per kilo were the norm. Given all the costs of operating a vessel etc at best most fishermen would have been only slightly ahead financially. In other years most would have lost money because of the costly and time consuming exploratory nature of the fishery.
The overall effect is that there are no windfall gains or super profits in this fishery and any statement to the contrary is very incorrect.
Other issues also need to be taken into account -
- Arrow squid is not an exclusive species for FLASJ holders. Most scalefish fishermen can also take this species so no exclusivity of access applies to one fisherman over another.
- FLASJ can only be traded as part of a licence package and not normally as a stand alone licence.
- There is no criteria established for Ministerial discretion on the application of fees in the likely event of a poor season or for that matter a minimal fishery.
- The suggestion that an acceptable proportion of operating overhead costs attributable to industry is 80% with 20% being of a public good nature is not correct. The true position is closer to 50% to each component when benefits to the community are realistically considered.
Management Costs
The estimated management costs appear excessive and unrealistic particularly with regard to the no fishing and full fishery comparison.
A tripling of management and licensing/monitoring costs over one year compared to another is very hard to understand or justify.
Compliance would also be minimal with no quotas and very visual fish attraction lamps in operation for fishing reasons.
The research budget of $10,000 pa is also probably not warranted in years when no fishing occurs.
Return to the State
The catch for the period 1995-96 to 1999-00 was 586.6 tonne (480.5t in one year) which using the RIS basis of calculation represents 117 tonne per year average or 6.1 tonne if divided by 19 FLASJ.
A 5% return at $1.25 per kilo on 6.1 tonne equals $381 but the above catch figures include catches by all methods and fishermen not just FLASJ. Obviously this calculation in the RIS needs reworking as the recorded basis for establishing an annual access fee is flawed.
Impact on Competition
The statement to the effect that the level of proposed fees is not considered to be such that it represents a cost that is so great that fishers will decide not to fish is wrong. The proposed costs against the potential gross value of the fishery are exceptionally high and can not be justified under any reasonable assessment. The approximately and proposed $2,800 cost plus yearly adjustments to target a total State catch of perhaps 19 tonne in an average year is a big disincentive and would definitely discourage costly exploration activity and participation in the fishery.
Summary
In our view the RIS is fatally flawed.
Of the four options the most suitable and appropriate is option one which provides for no renewal fee. This would actively encourage fishery exploration and development of any available resource and may enable a positive return to the community to be achieved with significant flow on benefits in any year that the fishery achieves substantial catches.
Yours faithfully,
R.K.LISTER
Chief Executive