Re: South Australian Snapper Closure
As Chair of the Australian Fishing Trade Association (AFTA), I write on behalf of our members to express extreme disappointment and concern with the recently announced Snapper closures by the SA Government.
AFTA represents all the fishing tackle industry at a wholesale, import, manufacturing, media and retail level with members throughout Australia and as such this decision directly effects our South Australian members as well as other significant sectors of the tourism industry.
We recognise and support the urgent need to develop sustainable snapper stock levels, however we don’t agree with the government’s Option B, that is why after much consultation, AFTA offered an Option C (attached), a sustainable alternative that minimised the economic impact on both the recreational & tourism industry.
As can be seen in our submission we believe our solutions are paramount to the success and sustainability of recreational fishing across South Australia, indeed Australia.
Please Note: AFTA takes a non-partisan approach to engaging with all politicians, across all levels of government, our only goal is to build an open relationship that benefits not just our members, but everyone that participates in recreational fishing. We see our industry as a part of the solution going forward on so many fronts and not as a part of the problem. I would encourage you, should you have questions or concerns, to reach out to us for assistance at any time.
I am personally contactable anytime at by phone: 0419 694620,
The Hon. Bob Baldwin
Chair – Australian Fishing Trade Association
Management Options for Snapper in South Australia
The Australian Fishing Trade Association is the national peak body representing the Wholesale, Retail and Media fishing industry in Australia. It is the recreational fishing body with direct contact and influence with recfishers across the nation.
This submission follows on from a meeting with Hon Tim Whetstone, Minister for Primary Industries & Regional Development on 23 August in Adelaide. It is based on the information gathered in consultation with our South Australian AFTA members, the very people that will be affected by the decisions of the Government.
AFTA appreciate that Minister Whetstone acknowledged that the recreational fishing economy was more than just fishing tackle stores, it is an integral part of the overall State tourism economy and that there would be impacts, particularly in regional areas resulting from adoption of any of the Options.
The recent Fisheries Research & Development Corporation report identified that snapper fisheries in the Spencer Gulf/West Coast are depleted, whilst the snapper stocks in Gulf St Vincent and Victoria are sustainable at this point in time. AFTA members acknowledge that immediate action needs to be taken to ensure the sustainability of snapper (Chrysophrys Auratus) fish stocks, not only in South Australia but indeed throughout Australia.
To increase snapper sustainability AFTA support any reduction in commercial marine scalefish fishing sector effort, in particular long lining. AFTA recommend progressing with the $20m commercial license by-back and a more stringent approach applied to commercial fisheries management.
AFTA consider a whole of state commercial fishery management – “species/quota/area” program be undertaken to minimise the effect on other species due to reduction in snapper total allowable catch across the state.
AFTA consider that its suggested “Option C” outlined below would help achieve the government’s snapper sustainability objective across the whole of South Australian waters in relation to the total recreational fishing catch whilst minimising the impact on the recreational fishing industry directly, and the tourism industry indirectly.
AFTA recognise the need for urgent action on the snapper fishery to provide long term sustainability, AFTA believe its members are a part of the solution going forward, not part of the problem in both an economic and educational sense.
The AFTA “Option C” is based on information gathered from AFTA members in South Australia, the very people affected from any change.
The Key Points of AFTA Option “C”:
- Reduced Bag Limit.
- Tag & Release Program
- SA Fishing License,
- Fisheries Research Funding
- Snapper Fisheries Management Committee,
- Fish Hatcheries
- Fishery Compliance.
- Trawling in aggregation/spawning areas
- Artificial Reefs
- Extend seasonal closures
Reduced Bag Limit.
The current bag limits for Snapper are:
Daily boat limit when 3 or more people on board:
- Snapper 38 to 60cm 15,
- Snapper over 60cm: 6
- Personal daily bag limit:
- Snapper 38 to 60cm: 5
- Snapper over 60cm: 2
- Charter Boat Fishery:
Personal daily limit:
- Snapper 38 to 60cm: 3
- Snapper over 60cm: 1
From the outset it is critical to understand that an “Option A”, state-wide or “Option B”, partial state closure will not stop people catching Snapper, it will only effect those caught with fish in possession.
Whilst targeting other species, Recfishers will still catch Snapper as a bycatch. What is important in how those fish are handled and released. AFTA supports the education and use of return weights as a means of increasing survival rates of released snapper.
To ensure sustainability of both fish stocks and the industry, AFTA recommends a reduced recreational bag limit to 1 snapper per person, per day, with a size limit of 40cm to 60cm. across the whole of the State with NO area closures. This is to apply to all recreational and charter boat fishing. The bag limit is to be reassessed after 4 seasons.
SA Recreational Fishing License and Tag & Release Program
AFTA supports the government plan to invest in new research to strengthen the recreational fishing data as indicated in the consultation paper. The snapper fishery needs to be based on sound scientific data. As such AFTA recommends the introduction of a South Australia Recreational Fishing License as a means of providing an accurate analysis of the number of Recfishers in South Australia. The license system, when combined with a Tag & Release program would provide an accurate assessment of the actual catch rate by recreational fishers.
AFTA recommends that the licence and T&R program be implemented and managed through a mobile phone application. All T&R info could be managed by this mobile app including photos, rather than hard paperwork as it is in other states.
AFTA members support a Recfishing license with a suggested $30 price point. However, this is on the understanding that all funds collected from license fees be hypothecated towards a direct recfishing benefit, not put into Government consolidated revenue. This fund should be matched by Govt funding on an agreed matching $ for $ basis and overseen by the recently elected South Australian Minister’s Recreational Fishing Advisory Council.
Transparency in fishing license fee collection and expenditure is critical to ensure AFTA support and community acceptance.
Introduction and promotion of a Tag & Release program to build an accurate scientific database on all mainstream scalefish, not just snapper helps satisfy, in part, the objectives of the consultation paper.
A mobile app, similar to the NSW Model, in conjunction with a licensing scheme, would allow fish to be photographed with the tag inserted and data instantly recorded and uploaded. This provides a more accurate system than the NSW card-based system. A measured length marker on the tag could be used to scale measure the actual fish in the photo would benefit scientific accuracy. Recapture could also be loaded up in real-time with the photographic evidence supporting growth rates and fish stock movement.
An “App” based system would reduce the amount of hard copy paperwork and postage costs to government.
Fisheries Research Funding
AFTA recognises that the current Government inherited this problem due to past budget reductions into fisheries science. We note this has affected the ability to ascertain the snapper biomass and the ability to monitor the status and recovery of stocks.
AFTA agree with the need to invest in new research to establish a reliable cost-effective method for monitoring the annual strength of juvenile fish numbers entering our snapper stocks
AFTA recommend that the SA Government immediately restore funding for fisheries management to PIRSA and so as to ensure the quality science is being acted upon, restore funding to SARDI for fisheries research over the forward estimates to better assess fish stocks to avoid this situation occurring again.
Whilst the snapper fishery is the basis of this review, the government must be mindful of the increased fishing pressure that will occur on other species, in particular Whiting, Nannygai and squid by the commercial sector.
Snapper Fisheries Management Committee
The issue of sustainability of snapper stocks is not limited to South Australian waters. These are migratory species, with 2 separate DNA travelling into SA from Victoria in the east and from Western Australia the west. South Australian coastal waters extend to 3 nm from shore, beyond that they are Commonwealth waters.
AFTA consider that a whole of governmental approach, overseen by Commonwealth, including South Australia, Victoria, Queensland, New South Wales, Western Australia and Tasmania governments be established to examine and share the science and develop an overall action plan for sustainability of snapper stocks and in particular management of by-catch. AFTA recommend that the recently elected South Australian Minister’s Recreational Fishing Advisory Council be involved in the Management Advisory Committee on the fishery to reflect recfishers views.
AFTA support the proposed “national snapper workshop in Adelaide in 2019 to bring together fisheries management, science and industry experts from around Australia and New Zealand to discuss the most effective ways to conduct scientific stock assessment and manage snapper stocks.” as outlined in the consultation paper.
To assist in restocking depleted fish stocks, AFTA recommends increased financial support for existing SARDI hatcheries at West Beach & Lincoln.
AFTA recommends investigation to increase the number of fish hatcheries, not only to help restock snapper, but other species. It is suggested funding be considered for the Clean Seas Hatchery at Arno Bay, Eyre Peninsula specifically to produce snapper,
AFTA believe for effective compliance management under either Option A or B, there will need to be an increase number of fisheries compliance officers to enforce new limits/laws and that this will be required regardless of which option is chosen. For the government to effectively enforce any reductions/no take rules it will need to increase the budget allocation to provide stronger enforcement presence.
It is logical that there would be no increased compliance cost with enforcing a bag limit reduction as suggested in AFTA’s “Option C”. In fact, with a state-wide bag limit there would be cost savings over “Option B”, partial closure, in enforcement management and education on where closure boundaries apply.
Trawling in aggregation/spawning area
AFTA members have raised serious concerns over trawling (prawn) in the aggregation/spawning areas causing disruption of the natural seabed and possible detrimental effect on fish spawning. AFTA recommends the government undertake an immediate scientific assesment to determine the impact of trawling on these grounds and if the science shows an impact, then trawling in spawning/aggregation areas be banned.
AFTA recommends a program of increasing the number of Artificial Reefs, with suggested locations at Port Broughton, Wallaroo, Whyalla & Ardrossan. This would assist in fishing pressure reduction on the natural spawning grounds
Extend seasonal closures
AFTA support a scientific analysis and possible implementation of an extension of seasonal closures to October 1 to January 1, as this will include two full moon phases to promote spawning.
AFTA accepts that a responsible management approach must be undertaken to affect a sustainable snapper fishery, but that management approach must recognise the importance of the economic and social impact it will place on the recreational fishing sector.
AFTA believes “Option C” is a “Win-Win-Win” outcome for government.
It is a Win for the environment through fish stock sustainability, a Win for recreational fishers, and as a result, a Win for the government for taking a responsible pro-active management role. AFTA is committed to working with the government should “Option C” be adopted in providing communication, education and implementation assistance to benefit recfishers in this period of change.
The Hon Bob Baldwin
Australian Fishing Trade Association (AFTA)