14 November 2003
The Manager,
Eastern Tuna and Billfish Fishery,
Australian Fisheries Management Authority,
P O Box 7051,
Canberra BC,
ACT 2610
Fax 02 6272 4614
Dear Sir
Draft Eastern Tuna and Billfish Fishery Management Plan
We wish to lodge this response to the draft plan.
Earlier this year we commented on the management plan and with minor amendments our views are still very relevant.
Our main concern is that Tasmanian based fishermen and specifically F, G and H permit holders were most unfairly penalised by the AAP recommendations in being allocated only 4.35 hookdays out of a possible 145 hookdays, or just 3% for historical permits.
This 3% recommendation contrasts remarkably with the 1999 AAP recommendations which would have allowed a 40% allocation. It is to us unbelievable and very suspicious that two independent panels could come up with such a wide difference in opinion.
With the total fishery hooks at 12 million the F, G and H hookdays are probably around 3 days only which of course is ridiculous given that all 44 F, G and H permit holders currently pay around $4,627 in permit fees per annum. I understand these fees for 3 days equivalent work will now cost around $6,727 pa, which will have the effect of definitely shutting these fishermen out of the fishery.
This miniscule hookdays allocation would make it impossible to profitably activate F, G and H permits or to access known or possible unquoted pelagic resources in southern Australian waters and with the increased fees the whole proposal is unviable and unrealistic.
In her media release dated 2 June 2003 the AFMA Board Chair Wendy Craik is quoted as saying "An example of an under-utilised resource could be albacore tuna off Tasmania. If scientific advice indicates that there would be no impacts on the sustainability of other species, only a fraction of the actual number of hooks used would be deducted from their allocation when longlining off Tasmania."
This statement does not appear to have been taken seriously in the latest version of the draft management plan.
Tasmanian has historically been most unfairly treated in both the SBT and SENT fisheries and the discrimination as proposed in the recommendations is in every way an insult to responsible local operators in this fishery.
We therefore strongly urge the AFMA Board to adopt a sensible and responsible approach to F, G and H permit holders and to allocate a fair and reasonable opportunity for these fishermen to utilise their permits and to access available resources off southern Australia.
Yours sincerely,
R.K. LISTER
Chief Executive