Surf Casting and Angling Club of W.A. (Inc.) Submission on:- "A Quality Future for Recreational Fishing on the West Coast Review."

Surf Casting and Angling Club of W.A. (Inc.) PO Box 2032, Marmion W.A. 6020 Submission on:- "A Quality Future for Recreational Fishing on the West Coast Review." Prepared for:- Executive Officer West Coast Working Group CONTENTS

The Club owns an air conditioned holiday house at Kalbarri which is available for rent to the public and club members at competitive rates

• West Coast Review Submission.

• General.

• Comments on Proposals.

• General.

• Proposal 1 Key Principles for Management.
• Proposal 2 Major Catch Survey.
• Proposal 3 Volunteer Angler Log Book Program.
• Proposal 4 Priority Species for Research
• Proposal 5 Fishing Quality Indicators.
• Proposal 6 (a) - Bag Limits for Trophy Fish.
• Proposal 6(b) Bag Limits for Prize Fish.
• Proposal 6 (c) Bag Limits for Table Fish.
• Proposal 6 (d) Bag Limits for Crustaceans
• Proposal 6 (e) Bag Limits for Cephalopods.
• Proposal 6 (f) Bag Limits for Shellfish'
• Proposal 7 Proposed Changes to Minimum Legal Size Limits.
• Proposal 8. Filleting at Sea.
• Proposal 9. Accumulation of Fish at Sea.
• Proposal 10. Recreational Boat Limits.
• Proposal 11. Charter Boat Limits.
• Proposal 12. Possession Limits.
• Proposal 13. Closure to Fishing.
• Proposal 14. Set and Haul Net Fishing.
• Proposal 15. Prawn Drag Nets.
• Proposal 16. Changes to Legal Fishing Gear.
• Proposal 17. Fishing Competitions.
• Proposal 18. Position Statement on Recreational Fishing by Indigenous People.
• Proposal 19. Code for Recreational Fishing at Rottnest.
• Proposal 20. Restocking as a Stock Enhancement Strategy.
• Proposal 21. Resource Sharing.
• Proposal 22. Low Impact Wilderness Fishing Experiences.
• Proposal 23. Protection of sensitive habitat areas and fish stocks around new marina developments.
• Proposal 24. West Coast Region Community Education Plan.
• Proposal 25. Additional Patrol Capacity.
• Proposal 26. Education.
• Proposal 27. Recreational Fish Management Officer.
• Proposal 28. Regional Recreational Fishing Council.
• Proposal 29. State Government Funding.

• Questions and Statements on the Discussion Paper.

West Coast Review Submission.

General.

In June 2000 the West Coast Working Group (WCWG) published a document for public discussion and comment. The document outlined the working group's suggestions for management of the recreation fishery in an area designated by them as The West Coast. This area extends from Black Point east of Augusta to a point roughly mid way between Kalbarri and Denham.

The working group called for public submissions on the content of that document and the members of the Surf Casting and Angling Club of W.A. (Inc.) (SCAC) convened a sub committee to carry out that review and prepare a submission based on their findings.

This document is a result of that decision.

Comments on Proposals.

General.

This section describes the SCAC response to the WCWG's proposals.

Proposal 1 Key Principles for Management.

Generally agree to all ten principles however SCAC believe that item 7 which states that "fishing rules should kept simple and, where practical, made uniform across the region." should be changed to read "Fishing rules should be kept simple and made uniform across the State".

Our reasoning is that dividing the State into regions is a separatist attitude and will only lead to confusion for both recreational anglers and the authorities when crossing boundaries. For many years we have had confusion in our road traffic laws when they are applied, in particular to transport operators, when travelling interstate. And look at the ridiculous situation that prevailed with the rail system. Why risk frayed tempers when an angler has to attempt to prove that fish in his/her possession was not caught 100 yards away in another zone.

Imagine the scenario where an angler has fished at Steep Point and then leaves that location to continue at Kalbarri. The bag and possession limits between the two locations may be completely different. Does that mean that the angler has to return home to dispose of the catch prior to returning to Kalbarri. We think not! We can see a confrontation should an inspector approach the angler for an explanation.

Proposal 2 Major Catch Survey.

SCAC agrees to this proposal. Contrary to the belief of some, clubs are concerned at the lack of detailed information on our fish stocks. We therefore welcome any attempt to improve our knowledge or this resource. However it also our belief that a major nationwide survey has been initiated by national bodies. Is this proposal merely duplicating monetary and physical resources? If so then this proposal should be reviewed.

SCAC also believe that club records can and should be used in compiling any survey. They are a more consistent indication of recreational fish catches than catches by the occasional angler.

Proposal 3 Volunteer Angler Log Book Program.

SCAC agrees in principle however care should be taken with interpretation of the results. Invariably these results will be inaccurate and misleading.

Proposal 4 Priority Species for Research

SCAC agrees but would like to see Australian Salmon included in the Inshore beach group.

Proposal 5 Fishing Quality Indicators.

SCAC agrees but would like to see King George Whiting shifted from the Inshore Beach group to the estuarine group.

Proposal 6 (a) - Bag Limits for Trophy Fish.

SCAC agrees with the following principals as described on page 46 of the review document.

• "Limits should be set at a level that will ensure long term sustainability".
• "Limits should reflect a precautionary approach to recreational fish management".
• "They should be set around what is a fair and reasonable feed for a family". We interpret this to mean what are socially acceptable number and /or quantity of fish to keep.

The club believes that the bag limits set out in proposal 6 do not follow these principals for some species. Thus the club must disagree with the proposed mixed bag limit of four (4) fish, because this may allow an angler to retain four (4) fish of a particular species that, in some cases, would exceed the actual bag limit.

SCAC has prepared the following table as a suggested alternative. This alternative will allow a total mixed bag limit of six (6) fish and limits the number of some species to a lower limit than that proposed by the WCWG.

Table 3.1 Trophy fish Mixed bag limit 6.

Proposal 6(b) Bag Limits for Prize Fish.

The club disagrees with "only two (2) over the 50cm" slot limit for Tailor. This proposal should be removed.

Proposal 6 (c) Bag Limits for Table Fish.

SCAC recommend adopting option A with the following alterations.

• Omit Sea Mullet. This fish is rarely caught.
• Change "only 4 King George Whiting over 35 cm" to "only four King George whiting over 40 cm".

Proposal 6 (d) Bag Limits for Crustaceans

SCAC recommend adopting option A

Proposal 6 (e) Bag Limits for Cephalopods.

SCAC agrees

Proposal 6 (f) Bag Limits for Shellfish'

SCAC agrees.

Proposal 7 Proposed Changes to Minimum Legal Size Limits.

SCAC has prepared the following table describing its recommended minimum sizes. These recommendations come from experience and size limits imposed by the club on all its activities. They reflect what is considered a balance between the need for conservation and the need to ensure that encouraging our children to keep fishing perpetuates the recreational fishing industry. Fish such as School Whiting, Swan river Tailor and Skippy rarely exceed the current size limits therefore any increase in these minimum sizes will see our children discouraged and leave the sport.

Proposal 8. Filleting at Sea.

SCAC agrees.

Proposal 9. Accumulation of Fish at Sea.

SCAC disagrees. Assuming that possession limits are implemented then these limits should apply to all anglers. This is a matter of simplicity and equality.

Proposal 10. Recreational Boat Limits.

SCAC disagrees. This proposal discriminates against those anglers who choose to fish from boats. It is a ridiculous situation where a boat with 3 or 4 anglers on board may be limited to a small number of red snapper only for a day's fishing. Not only is it discrimination but it will discourage anglers to purchase boats thereby destroying that industry.

Proposal 11. Charter Boat Limits.

SCAC agrees.

Proposal 12. Possession Limits.

SCAC disagrees. Recently the club submitted a proposed possession limit to the Gascoyne group. To be consistent across the State we recommend the following possession limit:-

20Kg of fillets or

15 kg of fillets plus one day's bag limit of whole fish or

Two day's bag limits of whole fish.

The individual recreational angler should be free to chose one of these options to meet his wishes on the day or trip - that is all three options are available to him.

Proposal 13. Closure to Fishing.

a) Fishing for Baldchin Groper at the Abrolhos Islands prohibited within the Habitat Protection Zone prohibited between December and March SCAC agrees

b) Fishing for Pink Snapper should be prohibited from September 15 to October 31 between Cape Bouvard and Ocean reef marina. SCAC agrees, but extend the boundary to Two Rocks in the north. The prohibited zone should extend from the shore to a line that is to be defined.

Proposal 14. Set and Haul Net Fishing.

a) SCAC agrees that set and haul netting should be prohibited for recreational anglers in the West Coast region but disagrees that attended set nets should be allowed in the Peel/Harvey estuary and the Hardy inlet.

b) SCAC disagrees with allowing attended set nets.

c) SCAC agrees that throw nets should be allowed except in "no fishing" zones.

Proposal 15. Prawn Drag Nets.

a) SCAC disagrees with the total prohibition of prawn drag nets in the Peel/Harvey estuary and Leschenault Estuary. Prohibited areas within those regions can be applied.

b) "Hand trawl nets shall be prohibited for recreational anglers in the waters adjoining nature reserves on the Swan River". It is assumed that these are already prohibited in nature reserves. The Winter 2000 edition of the Landscope magazine published by the Dept of Conservation and Land Management contains an article on the Swan River. This article states that "the management plan also highlights the need to fully explore the impact that recreational prawning may have on the reserve values. The plan proposes a research or monitoring program to fully investigate the possibility that prawning disturbs the main food source for wading birds". The WCWG seem to have pre-empted the outcome of that research.

SCAC agrees in principal with prohibiting hand trawl nets but without an explanation of the term "adjoining" we cannot fully agree.

Proposal 16. Changes to Legal Fishing Gear.

SCAC agrees that unattended setlines should be prohibited and agrees that one (1) attended bait trap per person should be allowed.

Proposal 17. Fishing Competitions.

a) SCAC Strongly disagrees. This document provides no detail on the administration of the proposal.

b) This is an impossible proposal. The results of the records coming from a regulation such as this will be totally inaccurate and misleading. An organiser has NO control over the results offered from the public. Any survey conducted from these records will be inaccurate, invalid and totally misleading.

c) SCAC agrees that a formal "Code of Conduct" for recreational anglers be developed, however this Code cannot be developed without input from clubs and associations who in most cases already have stringent codes for all members. It is a fact that all competitions organised by clubs and associations are conducted under those stringent codes and have been for many years. SCAC does not agree that these codes should make reference to "The Animal Welfare Bill". Whatever this bill has to offer is already more than covered in the current codes and by laws of the clubs.

Proposal 18. Position Statement on Recreational Fishing by Indigenous People.

SCAC agrees with the statement with an emphasis on the last paragraph.

Proposal 19. Code for Recreational Fishing at Rottnest.

It is noted that this proposal is for a voluntary code and therefore the term VOLUNTARY must be clearly stated. People should be educated and encouraged to comply with the code but must be able to exercise their rights to take quantities of fish, up to the maximum bag limits as prescribed for the West Coast region. They should be allowed to do so without fear or prejudice of their actions being interpreted to be in breach of regulations.

The real issue with the Rottnest code is the preservation of fish stocks and this message should not be obscured by codes, which might be interpreted as being local, but should apply to everywhere. Many sections of the proposed code should apply universally and are applicable not only to Rottnest. The following are taken from the proposed code and it is our belief that they should be applied universally:

• Take the time to release all undersized or unwanted fish
• When keeping fish for the table dispatch them quickly and keep them in a cool place, preferably on ice.
• Clean your catch as soon as possible. Fillets should be kept in sealed plastic bags and kept on ice to reduce the possibility of spoiling and to seal the flavour in.
• Respect all sanctuary areas and stay on marked trails to protect the fragile environment.
• Aim to fish safely and treat the ocean with respect.

The Rottnest code of conduct should be rewritten around mandatory issues that are specific to Rottnest alone.

Proposal 20. Restocking as a Stock Enhancement Strategy.

The use of the term "Significantly depleted" implies that there is some baseline level that is acceptable. It is clear from general hearsay that many fish stocks have been significantly depleted from what they once were. So the position statement contained in this proposal may justify stock enhancement in some cases.

The critical factor is to provide the knowledge and technology to quickly, safely and economically implement stock enhancement where and when it is needed. Research is critical and costly and is an area that requires immediate funding.

This proposal should not be seen or used as an instrument for the authorities to approve commercial fish farming as has been suggested in the Esperance and other areas in the state.

Proposal 21. Resource Sharing.

a) SCAC agrees with the proposal to limit commercial fishing but believe that the limit should be five (5) nautical miles from shore in the region from Cape Bouvard to Two Rocks. The club agrees that the proposed three- (3) nautical mile limit should be extended to five (5) nautical miles in areas of high recreational use such as Bunbury Mandurah, Busselton etc.

b) SCAC agrees with the proposal to reduce commercial catches of Herring on the West Coast. In particular, reduce or eliminate catches of Herring to be used for Rock Lobster bait or other uses deemed "not for human consumption"

c) SCAC agrees

d) SCAC agrees

e) SCAC agrees

f) SCAC agrees

g) SCAC agrees

h) SCAC considers that NO commercial purse seine, wetline, demersal gill netting or long line operations shall be allowed within three (3) nautical miles of Rottnest, not two (2) nautical miles as proposed.

i) SCAC agrees

j) In addition SCAC propose that low value use of Australian Salmon should be phased out. Salmon is an important recreational fishery and the commercial use of this species for Rock lobster bait has the potential to impact severely on the West Coast recreational fishery.

Proposal 22. Low Impact Wilderness Fishing Experiences.

SCAC does not agree with the proposal for "low take". Normal bag limits should apply but a limit set on the number of tour operators allowed to operate in these areas.

Proposal 23. Protection of sensitive habitat areas and fish stocks around new marina developments.

a) SCAC agrees.

b) SCAC agrees.

Proposal 24. West Coast Region Community Education Plan.

a) SCAC agrees.

b) SCAC agrees.

c) The campaign should be entitled " Educate recreational fishers on fishing ethics in the West Coast Region. The questions are;

• Who pays for the campaign?
• What is it about?
• How effective will it be?

Proposal 25. Additional Patrol Capacity.

SCAC agrees.

Proposal 26. Education.

a) VFLO Program.

Education of the community should not be the limited to VFLO's. Angling clubs and associations should be recruited and funded to assist this valuable resource program.

b) Junior VFLO Program.

This program should also be extended to include the clubs and associations.

It should not be forgotten that the clubs and associations are a valuable resource when education of the public is concerned. It is estimated that some 6500 anglers are members of various clubs and associations in Western Australia and are genuinely concerned with our environment. Past differences should be forgotten in the fight to save the environment for all our children.

Proposal 27. Recreational Fish Management Officer.

The club agrees in principal, however it is our belief that this position is already held be a responsible person.

Proposal 28. Regional Recreational Fishing Council.

SCAC cannot comment on this proposal until more information has come to light.

Proposal 29. State Government Funding.

a) This is SCAC's preferred option.

b) Recreational fishing licenses should be a last resort. The fishing public will need to be reassured that the State Governments will not decrease current funding if a license is implemented. Any license should cover the entire state and not on a region by region basis. It is ridiculous to assume that a traveler has to take out four (4) licenses to fish the coast. As stated previously this is a separatist attitude and one that should not be considered by sane people.

c) SCAC understand the basis for the introduction of a recreational fishing license but it is essential to publicise how the money raised is to be used and as importantly how it is actually used.

Questions and Statements on the Discussion Paper.

General.

This section has been included because the sub committee believes that some clarification of specific statements is needed.

Page 12. Management for the Future.

It is stated here that between 1989 and 1991 a comprehensive review of recreation management was undertaken by the inaugural working group. SCAC question the validity of this statement as we have little knowledge of any attempt to gather information from our organisation. It would seem that the review might have been conducted "in camera". If this is so then the result of that review might be questionable notwithstanding the good intentions of the reviewers.

Page 16.

The SCAC would like to know who was on the selection panel for the West Coast Working Group and what is or was the selection criterion? It would seem that a greater cross section of the fishing community should have been selected for this most important committee.

Page 18. Talks of "extensive public consultation". Who are the key stakeholders? To enable a fair and just result one would assume that all recreational and industry groups would be consulted. Groups such as ANSA, AAA and independent clubs should have been included in the consultative process. It would seem that they have been excluded for whatever reason.

Page 22 The document seem to have lots of extrapolation from the figures 2.2.3. Was this data gained simply from boat ramp surveys? And if so over what length of time? To our knowledge only one member of a club has been approached for data.

Page 32. SCAC agrees with the need for an integrated framework that includes consultation with all interested groups and parties.

Page 33 Section 3.6.3 mentions that commercial premises and places of residence may be excluded from the possession limits. This statement needs clarification, as it is a grey statement.

Section 2.6.4. Commercial size limits need to be consistent with recreational size limits. It is understood that professionals are currently allowed 10% of their catch to be undersized.

Section 2.6.5 SCAC agrees with the statement that it is important to have closed seasons for particular species.

Section 2.6.6. SCAC do not condone the use of treble hooks for Tailor fishing but considers these hooks should be allowed when ballooning or lure fishing.

Section 2.6.7. This section claims that licenses do many things such as "Licenses track participation rates accurately and provide a basis for estimates of fishing effort, individual and average fishing success and total catch rate for a given fishery". This would only be true if a significant sample of licensed recreational fishers provided accurate detailed information on their efforts for the period of the license. The mere existence of a license will not guarantee this. Licenses will only provide funds for research and education. One cannot liken a recreational fishing license to a commercial venture.

Page 36. We wonder at the effectiveness of a "Structured process of peer education". It would seem that those who want to know would know. The VLFO program has been successful in the past but need to be resourced further. We are suggesting that the clubs and associations be approached to assist.

Page 41 mentions a comprehensive data collection system established for fishing clubs. We support this but would like to see a consultation process to develop a structure that does not throw additional work onto already overworked volunteers.

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