Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere)

The Metropolitan Fishers Alliance (Draft) Position Paper on PIRSA's Draft Snapper Management Arrangements "From a Recreational Fishing Perspective" 24th August 2012

Overview
In July 2012, the Department of Primary Industries and Regions South Australia proposals for changes to the management of the Snapper fishery started circulating on the Internet in a document called "Draft Snapper Management Arrangements Proposal" which is separately attached to this Position Paper for ease of reference. The stated purpose in that document is to put in place Management arrangements that effectively control the level of commercial fishing effort on Snapper stocks, optimise Snapper spawning and recruitment, and support a sustainable Snapper fishery. There have been several initiatives by PIRSA to achieve this result over time, but the outcome has actually been a steadily increasing commercial extraction amount over the last 8 years, resulting in an approximate doubling of the commercial take during that period. The Metropolitan Fishers Alliance feels that the two measures affecting recreational fishers currently proposed by PIRSA (seasonal closures and spatial closures) may notionally reduce the recreational snapper take but this will cause an associated negative impact on tourism and local business and the reduction may be negligible to the result in terms of a planned reduction on the overall Snapper effort and the biomass itself. We feel that blanket closures for recreational fishers (seasonal or spatial) will not result in a significant reduction in the overall snapper catch rate and will therefore not assist in achieving the goal of this plan. NOTE In PIRSA documents, there are references to an 8% Recreational Sector Allocation. This is based in part on data from 2007, since which time the commercial take has increased significantly (refer bar graph in Attachment I). It is to be noted that, of the other four documents utilised in the Draft Commercial Marine Scalefish Management Plan to determine Sector Allocations (ie for the Commercial, Charter, Traditional and Recreational sectors), the most recent report pertains to the period 2008/09. There has been a significant yearon-year increase in commercial snapper take both prior to and since that time. The Metropolitan Fishers Alliance acknowledges that PIRSAs recreational catch data combines both Recreational and Charter as one group, but this perhaps this should be re-visited to show each portion. This paper is focussed explicitly on the non-Charter recreational catch, and the impact that PIRSAs proposed Management Arrangements would have on this recreational sub-group, on local communities and on the snapper themselves.

Page 1 of 6

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere) Seasonal Closures
The Metropolitan Fishers Alliance supports the general concept of increasing the protection of spawning snapper stock by an increase in the closed period, but we question the reasoning behind including recreational fishers. The PIRSA draft proposal will not achieve a significant benefit to the snapper themselves if it does not provide protective measures for spawning schools at the end of the closure period. Given this, the extent to which the Recreational Sector could adversely affect the total catch effort is seriously questioned. It would seem sensible to mandate additional daily catch and Total Allowable Commercial Catch (TACC) restrictions for the commercial sector during this period particularly on the use of long-lines. In addition, we query the effectiveness and reasoning behind increased seasonal closures for recreational fishers that can only affect an 8% recreational sector allocation of snapper stock, and also the closures being proposed for periods that will likely have a considerable consequential impact on Recreational Fishers and local communities during the build-up to the traditional holiday periods (ie the month of December pre-Christmas). Put simply, there would be a negative socio-economic impact on recreational fishers and local communities related to the proposed seasonal closures, and the Metropolitan Fishers Alliance requests that this be fully investigated and understood prior to the implementation of any seasonal ban on recreational fishers during the build-up to the December-January holiday period. We also feel that PIRSA has lumped recreational and commercial fishing together when seeking a solution to a problem generated for the most part by sectorspecific issues. The approach proposed by PIRSA does not appear to acknowledge the significant disparity in the Sector Allocations themselves - 81% Commercial, 10% Charter, 8% Recreational and 1% Indigenous. It is worth highlighting that the November 2011 Snapper Management Options Background Paper arose primarily from concerns regarding snapper take by the commercial sector and this was explicitly stated in that documentation. The Metropolitan Fishers Alliance requests a more considered proposal from PIRSA that is more targeted to the actual problem rather than to drawing in the recreational sector under a broad brush that may appear to be equitable to all but have a serious negative impact more so on one group than another. Specifically, we request a seasonal opening date for all sectors (including recreational) on the 11th of December, not just for commercial and charter operators.

Spatial Closures
Lines on maps do not protect fish, enforcement does. The Metropolitan Fishers Alliance does not agree with the concept of placing unenforceable restrictions on recreational fishers, and feels that there are potentially unforeseen and unresolvable issues associated with this concept. 1. 2. 3. Where were the fish on your vessel caught? How to prove it? Further complexity about closed area mapping, eg. Overlap with Franklin Harbour and upper Gulf St Vincent sanctuary zones At the most, this measure can only result in some reduction of the already proportionally small rec fishing snapper catch - excluding the charter portion.

In addition we feel, apart from the potential adverse socio-economic considerations accruing due to the extended seasonal closure (referred to above), that the areas identified for spatial closure will unfairly penalise the economy of some coastal towns due to tourist displacement, this impact being amplified to the worst case due to the gulf spatial closures occurring during the peak holiday period.

Page 2 of 6

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere) Summary
The Metropolitan Fishers Alliance does not support implementation of the proposed seasonal and spatial closures for Recreational Fishers, and we request that PIRSA consider the overall impact of this measure on both local communities and the snapper themselves as the basis for not applying these closures to Recreational Fishers. We feel that the small impact of recreational fishing on snapper stock is not the major cause of problems, and we request that PIRSA addresses the already acknowledged issue of excessive commercial extraction without adding to the continual increase in restrictions on recreational fishing. We ask that PIRSA makes a realistic estimate of current catch percentages between the Commercial, Charter and Recreational Fishing sectors rather than utilise figures captured 4 to 5 years ago, thus focussing on the rapid increase in the commercial take largely due to increased long lining. In particular, the Metropolitan Fishers Alliance urges PIRSA to reconsider its Proposed Draft Management Arrangements regarding the gulf spatial closures to exclude recreational fishing from all gulf spatial restrictions (currently proposed to be applicable through to the 10th of January annually). The Metropolitan Fishers Alliance is supportive of any measure to protect all fish stocks in SA provided those measures will actually achieve the stated outcome. For instance, mandated additional daily catch and Total Allowable Commercial Catch restrictions for the commercial sector during December after the snapper opening (the weeks colloquially referred to as the Pro Snapper Slaughter period) in conjunction with a snapper closure period extension for all sectors from 30th Nov to 10th December. This would be considered an appropriate starting point, to be subsequently reassessed, and would have the distinct advantage of simplicity and common equity across sectors. The Metropolitan Fishers Alliance would like to draw attention again to the opening paragraph of PIRSAs own draft document ("Management arrangements that effectively control the level of commercial fishing effort on Snapper stocks, optimise Snapper spawning and recruitment, and support a sustainable Snapper fishery.") and to express its dismay and opposition to any proposal that would extend these measures to include non-charter recreational fishing.

Page 3 of 6

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere) Attachment I
South Australian Wild Fisheries Information and Statistics Report 2010/2011 Page 29. SARDI Publication No. F2008/000808-4

http://www.sardi.sa.gov.au/__data/assets/pdf_file/0008/171377/South_Australian_Wild_Fis heries_Information_and_Statistics_Report_2010-11.pdf

Page 4 of 6

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere) Attachment 2
PIRSA Snapper Options Background paper November 2011 page 3

From Attachment 2 of the Snapper Options Background Paper (History of Snapper Management in SA) 2003 - November closure extended to be for the whole month - November was selected as this was historically a time of increased effort and low market prices - December was also considered but not deemed suitable due to potential impacts on recreation and tourism A local (Arno Bay) recreational fishers perspective:Our state markets are reaching saturation point for snapper and as a result large volumes are now heading interstate to try and fetch a better price. Is our state government so short sighted it cannot see the long-term revenue recreational fishing brings to regional SA? In our little seaside community, all accommodation is booked and we have an influx of interstate fishos visiting for the opening of the snapper season, bringing substantial economic spin-off to our town during an otherwise quiet time of year.

http://www.fishingworld.com.au/news/opening-of-snapper-season-exposes-flaws-infishery-management

Page 5 of 6

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere) Attachment 3

The following references were consulted in the development of this paper. Their availability in the Public space is appreciated.
http://www.sardi.sa.gov.au/__data/assets/pdf_file/0020/73208/f2007_000523_1_snapper.pdf
2007 Snapper Stock fishery assessment report to PIRSA from SARDI showing the estimated Snapper stocks for the time, history and performance of the fishery and management protocols recommended.

http://www.sardi.sa.gov.au/__data/assets/pdf_file/0004/140863/No_473_Snapper_Fishery_Fishery_A ssessment_Report_to_PIRSA.pdf
2010 Snapper Stock report that includes comprehensive Commercial catch and effort data for the 20-plus years up to 2008/09.

http://www.pir.sa.gov.au/__data/assets/pdf_file/0016/167110/Economic_indicators_for_the_South_A ustralian_marine_scalefish_fishery_2009-2010.pdf
Economic indicators for the SA MSF that show catch and gross value data as well as an indication of economic returns from the MSF.

http://www.pir.sa.gov.au/fisheries/commercial_fishing/marine_scalefish_fishery/interim_snapper_co mmercial_daily_trip_limits
Explanation of the current interim Snapper commercial daily trip limits by PIRSA Fisheries.

http://www.misa.net.au/__data/assets/pdf_file/0009/173763/Draft_Commercial_Marine_Scalefish_Fis hery_Management_Plan_-_June_2012.pdf
Draft Management Plan for the Commercial MSF 2012.

http://155.187.2.69/coasts/fisheries/sa/marine-scalefish/pubs/marine-scalefish-management.pdf
Existing Management plan for Commercial MSF 2006.

http://www.pir.sa.gov.au/__data/assets/pdf_file/0018/163026/Background_Paper_for_Snapper_Manag ement_Options.pdf
Background paper for Management Options for Snapper in SA. PIRSA Fisheries Nov. 2011.

http://www.sardi.sa.gov.au/__data/assets/pdf_file/0008/171377/South_Australian_Wild_Fisheries_Inf ormation_and_Statistics_Report_2010-11.pdf
South Australian Wild Fisheries Information and Information report giving more data on volume and value of Commercial catch.

Page 6 of 6