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Tasmanian Seafood Industry Council 
Tasmanian Seafood Industry Council


 

16.10.02 Bull Kelp  


Tasmanian Fishing Industry Council

Submission on:

Marrawah Kelp Pty. Ltd.

Environmental Impact Statement for:

Collecting Of Cast Bull Kelp - Bluff Hill Point, North-West Tasmania


Author: Ralph Mitchell
Executive Officer
Tasmanian Fishing Industry Council

16 October 2002

To: Mr Allen Carmen-Brown
Acting District Manager
Parks and Wildlife Service
GPO Box 809
Ulverstone
Tasmania 7315

Tasmanian Fishing Industry Council:
The Tasmanian Fishing Industry Council (TFIC) is the peak representative body for the commercial fishing industry in Tasmania. This submission is made in representation of those fishing industry interests.

TFIC respectfully requests that the issues raised hereunder are seriously considered when assessing the recommendations in the Marrawah Kelp Pty. Ltd. Environmental Impact Statement (EIS).

Commercial Fishermen: Coastal Use
Over the past decades abalone divers, net fishermen and rock lobster fishermen have traditionally utilised northwest Tasmanian coastal access points for launching/retrieving vessels, safely landing their catch for timely transport to processors, rock lobster pot bait collection, beach netting and fishing gear retrieval from the beaches.

Bluff Hill Point is of significant importance for this part of the commercial fishing industry and is also a vital access point for any search and rescue operations that members of the commercial fishing industry and authorities participate in.

Coastal access restrictions within the Arthur Pieman Conservation Area (APCA) have already had significant detrimental effects upon those licensed commercial fishermen who have historically used these various coastal access points.

The reduction in coastal access points available to commercial fishermen along the northwest Tasmanian coastline has placed severe constraints upon the commercial fishing industry’s ability to fish the entire coast in a safe, responsible and sustainable way.

TFIC recognises the importance of preservation of any endangered species, as well as the presence of Aboriginal sites in the region. TFIC supports the conservation of existing substantiated sites of significance.

Comments made in the EIS:

            • The EIS identifies "Access to the sites is the principal issue that needs to be addressed by this EIS" .
            • It recognises the need for fishermen to have alternative landing points as negotiated with Parks and Wildlife Services (PWS).
            • Comment is made about discarded fishing gear on the shoreline.
            • It recommends closure of "…Some or all of the tracks into Bluff Hill Point" by blocking or fencing with gates, with vehicular access being gained by "acquiring a key from nominated custodians…" .

          Access Issues:

          While accepting that access is the principle issue, this and other issues should be put into perspective.

          During the "Inquiry into the finalisation of the Draft Arthur-Pieman Conservation Area Management Plan 2000" and at the subsequent protest rally at Arthur River on 19th August 2001, TFIC made it very clear that the issue of access restriction has the potential to seriously impinge upon safety at sea, as well as any search and rescue operation that may need to take place in the region.

          With regard to the safety issues, it is appropriate to quote from the TFIC submission:

          "Any reduction in accessibility at Bluff Hill Point seriously compromises maritime safety in its present form:

          One significant consequence of access closures within the Bluff Hill Point region strikes at the very heart of the current initiative from Marine and Safety Tasmania (MAST) for increased water safety awareness. The reduction of coastal access points quite obviously elevates the potential for lives to be lost at sea. This point is relevant for all boat users.

          With conditions on the West Coast being unpredictable and fickle (as has been amply documented elsewhere) it is often vitally important to have a secondary vessel landing/retrieval point when coming ashore. This is pertinent both during normal fishing operations and also when fishermen voluntarily assume a crucial role in emergency search and rescue operations that have to be undertaken in the region from time to time.

          For a fisherman to have to travel to an access point miles away from the launching area because the safe bay within a few hundred metres is closed is patently ludicrous and highly likely to cause even more loss of life on the west coast. Locked gates and fences will create extra problems."

          Bluff Hill Point Access:
          Bluff Hill Point is now the most northern coastal access point to a rugged and remote coastline that is subject to rapid extremes of weather and sea conditions.

          TFIC recognises that Marrawah Kelp Pty. Ltd. is an important developing industry on the Northwest coast. However, access should not be restricted to any of our commercial fishing members who use Bluff Hill Point unless it impinges negatively on Aboriginal sites of significance or endangered species habitat.

          The Bluff Hill Point ocean access can become impassable if weather conditions change whilst vessels are at sea, forcing fishermen to seek another landing point (often on the southern or lee side of the headland). On the southern side of the Bluff Hill Point headland are Crosseys Bay and Tummers (Harry’s) Bay. These bays have been areas that have historically provided safe coastal access points vital to commercial fishermen for both launching or landing (especially with boats loaded with catch) when the Bluff Hill Point access has become too dangerous and as such foolhardy to attempt.

          Abalone divers may be forced (by changing weather and sea conditions) to land on the southern side of the headland at Bluff Hill Point after a fishing operation.

          For them to have to find a custodian with a key for them to access the region to retrieve their boat and high value catch is an imposition, especially if there is no one actually there to provide the key at the time.

          In a case where there is a safety issue or emergency that arises, any access that is deliberately impeded by locked gates and fences will give rise to questions about 'Duty of Care' and legal liability.

          Mandatory vessel survey stipulations:
          There are other issues that may have serious ramifications to abalone divers who are forced by a combination of blocked access and weather/sea conditions to land elsewhere when having launched at Bluff Hill Point.

          Again the TFIC submission to the "Inquiry into the finalisation of the Draft Arthur-Pieman Conservation Area Management Plan 2000" covers these points eloquently:

          "Vessel Survey Requirements:

          The issue of travelling extended distances at sea from the launching area has further ramifications for fishermen who have stringent (limited) survey conditions to comply with as well as post-fishing reports to make within a specific time-frame. These regulations are not a matter of choice for the fishermen but licence conditions that are imposed by MAST and strenuously enforced by the Marine Police.

          The vessel survey requirements that fishermen must comply with have gained authorities attention at MAST due to the access closures being likely to cause fishermen to operate outside the area that the boats are surveyed to operate in. Causes for this would be being caught in adverse weather after launching or being forced to launch substantial distances from the fishing ground due to a lack of suitable access.

          These survey regulations include the ‘3 x 30’ and ‘2 x 20’ surveys. The former restriction means that the licensed fishing vessels are surveyed to go 3 nautical miles out to sea and can range a maximum of 30 nautical miles along the coast from the launching site. Those boats not equipped with marine radio are further limited to the latter ‘2 x 20’ restriction. Most of the aluminium dinghies used by abalone divers fall into the latter group.

          This is an issue that could realistically create serious difficulties for the fishermen and divers should they be required to launch away from the fishing ground or land and retrieve their boats at other points on the coastline. A good example would be if an abalone diver could not launch at Bluff Hill Point due to weather conditions and had to travel by sea from either Sundown Point or Montagu on the north coast to access the abalone northern zone that commences at Arthur River. Apart from the survey restrictions, there are other issues to be recognised in relation to these zones.


          Abalone Zones:

          Bluff Hill Point is the only vessel launching point on the west coast in the Northern Zone of the abalone fishery. Abalone fishermen must by law launch and retrieve their boats in that zone. It is illegal for them to access the water from Sundown Point, fish in the Northern Zone and land back at Sundown.

          Historically if conditions prevented them using Bluff Hill Point they could launch their boats from the southern side of the headland at Crosseys Bay or Tummers Bay. The option to access the water on the south side of the Bluff Hill Point headland is currently no longer open to them with this being a significant and expensive constraint to those abalone divers who have traveled across the state to work in the Northern Zone.


          ‘Prior’ and ‘Post’ Fishing Report Requirements:

          When rock lobster and abalone fishermen commence fishing activities they are required to make a ‘prior’ and ‘post’ fishing report to the authorities. These stringently enforced reporting requirements could easily be compromised by instances of landing away from the launching point (with possible unnecessary penalties).

          The remaining access points on the northwest coast are obviously poor and costly options for commercial fishermen with a valuable catch on board, specific survey stipulations to adhere to and stringently enforced time constraints to comply with due to post-catch reporting requirements."

          The above speaks for itself. Access should not be restricted by placing a requirement for custodial keys that may or may not be available when required.

          Discarded fishing gear:
          Historically, storm events have damaged and washed fishing gear to the beach, a fact of life accepted as part of the fishing operations on the west coast.

          Rock lobster fishermen need to be able to retrieve rock lobster pots and gear that can be strewn over miles of beaches after these storms. To leave expensive ropes, pots and buoys scattered on the beaches is not only another unnecessary expense for the fishermen, but is environmentally irresponsible as it can pose an unnecessary threat to other species.

          Significant costs in relation to lost gear will be borne unnecessarily by the rock lobster fishermen if coastal access is unavailable or significantly restricted.

          Aboriginal Sites:
          It is accepted that continued usage of existing tracks within the Bluff Hill Point region has the potential to have a deleterious effect upon Aboriginal sites.

          TFIC considers that the recommendations for rerouting of tracks, stabilisation of banks and/or concealment with 'soil-saver' as per the EIS should be investigated and initiated where practicable. This is an issue that is best dealt with by the Off-Road Vehicle Consultative Group that was set up by Circular Head Council in September 2001 to attend to this type of concern.

          Conclusion:
          Marrawah Kelp Pty. Ltd. is to be commended for presenting a thorough EIS. Considering the issues to be addressed at Bluff Hill Point for their operation, the EIS is a valuable document, well researched and appropriate.


          However, TFIC vigorously opposes any access restrictions to licenced commercial fishermen in the Bluff Hill Point area.

          Blocked and fenced tracks (along with locked gates) have the potential to seriously affect our members who work in the region, some of whom have done so for many years.

          These measures recommended in the EIS also have the potential to create an unnecessary risk to lives if an emergency situation develops and a 'key custodian' is unavailable. Currently, mobile phone service in the area is lacking and there is no public telephone at Bluff Hill Point. Lives potentially at risk include both public marine users and the commercial fishermen who are the backbone of search and rescue efforts in the region.




© Tasmanian Seafood Industry Council (TSIC) - 2010