On behalf of the Commercial Access Commission, I am pleased to forward to you the Commission's report 'Proposed Access and Allocation Arrangements for Commercial Wet Line Fishing'. The Panel recognizes that these findings are eagerly awaited by many operators in the commercial fishing industry.
The main focus should be the long-term sustainable management of towelfish stocks and the provision of high quality fish to consumers through the commercial industry. However, it should be made clear that the "wet line review" is not a sectoral resource allocation exercise.
SUMMARY OF PROPOSALS
The average should be determined based on the three highest annual catches recorded against the FBL during the financial years from 1 July 1999 to 30 June 2003. Operators who have caught a minimum of 1000 kg of demersal shellfish per year by handline or dropline in the Gascoyne region in at least three of the four fiscal years during the period from July 1, 1999 to June 30, 2003.
- T ERMS OF R EFERENCE
- M EMBERSHIP
- C ONSULTATION PROCESS
- M AKING A S UBMISSION
The Department of Fisheries made a presentation to WA vessel brokers on 19 September 2003 to inform them of the scope and nature of the review. CAP members (and MPPs) received copies of all initial applications they received.
W HAT IS ‘W ETLINING ’?
Therefore, wetland activity, in terms of target species and gear that can be used, may vary between regions depending on the existing managed fisheries that may be present in that region. Since there are no easily identifiable rules (rules), it can be difficult for commercial fishermen to identify what activities can be undertaken under the auspices of an unrestricted FBL.
W ETLINE MANAGEMENT TO DATE
The media release noted that "no history of fishing in the league after this date will be considered in developing any new management agreement for the fishery." A letter was also sent to all FBL holders which stated that. The state's coastal fish resources are to be managed on the basis of four main marine regions - Kimberley/Pilbara, Gascoyne, West Coast and South Coast.
W HY USE BENCHMARK DATES ?
The long delay in the case of fishing in the league has undoubtedly made this review process more complex. The long delay between the announcement of the standard date and the establishment of this review has clearly exacerbated such issues in relation to league fishing.
KEY MATTERS FOR CONSIDERING ACCESS AND
- A UTHORITY TO WETLINE
- E XTENT OF INVOLVEMENT IN WETLINING
- R ELEVANCE OF CATCH HISTORY
- A WARENESS OF BENCHMARK DATE
- I MPACT OF MANAGEMENT ON THE ‘ VALUE ’ OF FBL S
- S UMMARY OF THE RELEVANT GENERAL PRINCIPLES OF LAW
- S UMMARY OF RELEVANT FACTS
CAP does not believe there is any legitimate basis to expect that existing. In this regard, the MPP report listed one of the objectives of in-water fisheries management as “Management arrangements should be consistent with encouraging the provision of a high-quality towelfish product to markets and maximizing returns through processes such as value addition". Some fishermen advised CAP that the announcement of the standard influenced their decision about which FBL to purchase.
CAP also noted that the original promulgation date of the 1997 standard did not include the concept of regional management. CAP understands that following the announcement of the standard date, pre-1997 "wetline" history licenses attracted a market premium of some over a "no history" FBL. However, the CAP noted that fishing history is a question of fact, not a property right [Adams v Executive Director .
OPTIONS FOR ACCESS AND ALLOCATION
T YPES OF OPTIONS
- Options based around the premise that all operators have an equal
- Options based on a level of involvement in, or dependency on, wetlining
- Options based in part on both the premise that all operators have an equal
However, given the relatively low sustainable harvest levels and the value of the wet line fishery, the CAP did not support this option. The CAP believes that catch history can provide an indication of the degree of involvement and dependence that an operator may have on wet-line fisheries in different regions. The CAP noted that a large number of boats have recorded some level of wet line catches.
The CAP looked at precedents that have been used in WA to consider appropriate periods within which catch history should be taken into account. The CAP believes that four years provides a reasonable time to assess an operator's level of involvement in the fishery. The CAP noted that the potential attractiveness of such an option is again severely limited by both the relatively small sustainable catch and the value of the wet line fishery.
PROPOSED CRITERIA FOR ACCESS AND ALLOCATION
- A CCESS CRITERIA
- A LLOCATION CRITERIA
- R ECOMMENDED CRITERIA FOR ACCESS AND ALLOCATION
- A LTERNATIVE O PTION
Operators that have caught a minimum of 1000 kg of demersal shellfish per year using a wetlining method in at least three of the four financial years during the period from 1 July 1993 to 31 October 1997*. Operators that have caught by hand or dropline a minimum of 1000 kg of demersal shellfish per year in at least three of the four financial years during the period 1 July 1999 in the West Coast region (as defined in the report of the Management Planning Panel) through June 30, 2003. The average should be determined on the basis of the three highest annual catches recorded in the FBL for the financial years July 1, 1999 through June 30, 2003.
If the combined allocation to these operators exceeds the "surplus" of the sustainable commercial catch, the entitlement of each eligible operator must be reduced by an equal proportion to reach the "surplus" of the sustainable commercial catch. If the combined allocation to these operators exceeds the "surplus" of sustainable commercial catch, each eligible operator's entitlement must be reduced by an equal proportion to reach the remaining available commercial catch. The impact of this option on operators will vary depending on the size of the commercial catch (as identified in the MPP report) and the number of operators eligible for access in each management zone.
WORKING EXAMPLES OF THE APPLICATION OF THE
W EST C OAST AND G ASCOYNE REGIONS
- West Coast Demersal Scalefish Fishery
- Gascoyne Demersal Scalefish Fishery
- West Coast and Gascoyne Inshore Net Fisheries
In the Midwest area, 'long-term wet-liners' will receive an allocation equal to their current fishing level. When long-term wet bottom vessels are subtracted from the sustainable catch, a 'surplus' of 68 tonnes is available for allocation to the 'recent wet bottom vessel' category. This means that each of the 'recent wet-liners' will still be allocated around 60% of their current catch level even though they are not meeting the performance criteria.
That is, each of these 'recent wetliners' will receive an allocation of approximately 29% of their average recent catch. In the Kalbarri zone, the average recent catch of 'long-term natliners' is marginally above the sustainable commercial catch. That is, each of the 'recent wetliners' will still receive an allocation of approximately 58% of their current catch level.
A NALYSIS OF ALTERNATIVE OPTION
- Gascoyne Demersal Scalefish Fishery
There are a number of options for dealing with this 9.5 tonnes: it can be divided equally among the boats that qualify (so that each vessel gets an additional 2.4 t); or alternatively it can be allocated to other boats that may be operating in this fishery but do not meet the criteria in recommendation 2. The CAP proposes that this surplus should be distributed equally among the boats that gain access. The CAP is also of the opinion that the proposed criteria can be reasonably applied to the coastal seine fisheries in both the West Coast and Gascoyne bioregions.
Although there is currently no sustainability issue, it is important to set a cap on the number of operators to prevent further growth in effort (especially after the implementation of demersal fishery management in each region). No allocation to recent wet lines (surplus not available). of their average recent catch). of their average recent catch) Metro No reduction 27 No reduction as surplus.
ADDITIONAL MATTERS FOR CONSIDERATION
- C ATCH VERIFICATION
- M INIMUM UNIT HOLDING
- L ICENSING SYSTEM
- I MPACT OF INTRODUCING ACCESS CRITERIA FOR W EST C OAST AND
Many managers have expressed concern that they will lose a valuable asset if FBLs are no longer required, but it appears that any value currently attributed to FBL will be included in the value of the fishing right (i.e. MFLs or units of eligibility). CAP therefore considers it essential that the introduction of wet line management in the West Coast and Gascoyne regions does not result in a 'spillover' of effort into other fisheries such as wet line fishing in the Pilbara or South Coast regions. In the case of future or emerging fisheries, access through the New Fisheries Development process could be considered to avoid repeating similar problems of unregulated increases in catch and effort.
On this basis, the outcome of the current wet line review could be the introduction of management plans for the west coast and Gascoyne fisheries and the introduction of limited access fisheries on the north and south coasts. It may then be possible to "speed up" management in the northern and southern coastal regions by making these fisheries limited access to begin with (thereby avoiding problems with possible transfers of effort) and then developing more specific management schemes for these fisheries (presumably along lines of those proposed by the MPP for the West Coast and Gascoyne fisheries). The generic entry criteria recommended for the West Coast and Gascoyne fisheries are being introduced for all other 'wetline' fisheries in WA, particularly the demersal wetline fisheries in the South Coast and Pilbara regions, to avoid the potential for any unregulated transfer of effort between fishing and fisheries. to ensure that commercial fishing is maintained at a sustainable level.
S UMMARY OF ISSUES RAISED IN INITIAL SUBMISSIONS RELATING TO ACCESS
Should be 'knife edge' entry criteria leading to the smallest number of commercial operators that will be financially viable. Landlords should be encouraged to dispose of their FBL through buyback scheme or other incentive. The wetland managed fishery must be protected from other operators, just like other managed fisheries.
Section 143 of the Fish Resources Management Act 1994 should be used to remove the latent permits. 50% of the wet line access given to the rock lobster fleet should be distributed evenly among the entire fleet, with the remaining 50% weighted to those with a history. Special consideration should be given to accommodate small-scale commercial fisheries operating from a home port that supplies visitor demand for fresh local seafood.
S UMMARY OF LICENCE TYPES
12 Report of the Rock Lobster Industry Advisory Committee to the Honorable Minister of Fisheries September 24, 1987. 4 vols.) Assessment of Management Options Volume 1. 68 Long-term Management Strategies for the Western Lobster Fishery. 103 Future management of the water charter industry in Western Australia by the Tourist Fishing Operators Working Group (September 1997).
123 Future Directions for the Rock Lobster Industry Advisory Committee and the Managed Western Rock Lobster Fishery. Discussion paper prepared by Kevin Donohue on behalf of the Lobster Industry Advisory Committee.