Wild Fisheries Management Branch,
NRE Tas,
PO Box 44,
Hobart, Tas 7001.
FISHERIES (SCALEFISH) AMENDMENT RULES 2023 REVIEW
The Australian Fishing Trade Association (AFTA) make this submission as the national body that represents all manufacturers, wholesale distributors, agents, retailers, and recreational charter operators engaged in the recreational fishing trade and through the conduct of their business operations AFTA have direct connection with all recreational fishers in pursuit of their recreational fishing activities.
Tasmania is home to 59 dedicated fishing tackle stores, including the 4 BCF and 4 Anaconda outlets, 2 wholesalers, 6 agencies and is home to one of Australia’s oldest and iconic lure manufacturers, the Tassie Devil. There are 37 identified fishing charter/guide operators across Tasmania. The recreational fishing industry is further supported through dedicated fishing sections in the 8 BigW/Kmart stores and incidental across the counter sales at Fuel Stops and General Stores throughout the state.
The financial impact of recreational fishers in pursuit of their pastime is not just measured in sales at just those stores, but through the broader economic contribution brought about by the flow on effect into tourism industry.
The recently published National Recreational Fishing Survey Results[i] showed that Tasmania has a 26% participation rate in recreational fishing, supporting over 2700 FTE jobs and contributing $300m to the Gross Domestic Product (GDP) representing 2.7% of the National GDP figure of $11b.
AFTA commence this submission by stating our strong support for the work of TARFISH in their submission to this Scalefish Fishery Rules Review, AFTA do not seek to replicate their arguments, but to support and add to them. AFTA will not be completing the online submission “Have Your Say”, please accept this as our submission.
With a view towards increasing sustainability AFTA support the interim size limit increase on Sandy Flathead to 35cm and the bag limit of 10 fish as an acceptable and manageable outcome, however AFTA does not support the proposed further reduction of the current flathead bag limit from 10 to 2 in the south and 5 elsewhere or the proposed narrow slot limit of 35-38cm as proposed in the current Scalefish review proposals.
The government is quite correct in identifying the need for a sustainable fishery, but only when those decisions are based on sound science and solid qualified data. AFTA submits that the government’s assessment of the contribution and therefore impact of the “115,000” Tasmanian recreational fishers[ii] is not based on sound qualified data. That is our primary concern and is the focus of this submission.
Further, AFTA do not support the proposed rules for the commercial sector across all species as outlined as it does not address the commercial total allowable catch (TAC) for the listed species, only individual daily trip limits for those species and this disproportionally shifts the burden for sustainability to recreational sector.
AFTA support species seasonal spawning closures across all species and all sectors without exception as long as the closure is based on sound scientific analysis as a means to increase stock level biomass, but only for the pre-spawn period and immediately after the spawn.
The Tasmanian method modelling of recreational fishing data collection and assessment is fundamentally flawed as was highlighted in the Productivity Commission Inquiry Report, Marine Fisheries & Aquaculture (No 81 2016)[iii]
The report in Licensing and samples frame for surveys[iv] clearly identifies flaws in the very recreational fishing data collection methods used by the Tasmanian government. It states:
… The scale and diversity of recreational fishers makes it difficult to identify and target a representative sample the recreational fishing population for survey. Where recreational fishing licences have been introduced, benefits have included a reduction in the cost of screening surveys, an increase in the speed with which surveys are completed, and greater confidence in the outcomes (Griffiths et al. 2014).
In the absence of a licensing system, a survey sampling frame is generally established through telephone screening. This involves randomly phoning households in order to obtain information on those fishing, or intending to fish, and to recruit a selection of fishers to a longitudinal diary survey to obtain trip-specific catch and effort data.
Telephone screening can be costly and time consuming. Further, the efficiency and effectiveness of telephone surveys has been decreasing over time because of a rising rate of non-response due to the increasing prevalence of telephone marketing, and lower usage of traditional landlines (Griffiths et al. 2014).
The CSIRO has found that:
The required large-scale surveys involve estimating participation from general population telephone surveys … are becoming increasingly inefficient. This is due to incomplete sampling frames, non-response and non-contact issues associated with increasing use of mobile phones and unlisted numbers. The result is highly uncertain participation and effort estimates that are required by scientists to estimate the total catch of particular species by the recreational fishery.
Benefits of sampling from a list of licence holders include reduced cost for the initial screening survey, high response rate, a reduction in non-response bias and improved precision in estimates.
It needs to be further considered that 6 years on from this PC report that fewer people now have landline phones installed or mobile phones listed in directories, this the very basis of data to be mined to establish the quantum of participation and catch rates in Tasmania.
The report further states[v]:
” Estimating catch and effort to incorporate recreational fishing into stock and marine management is significantly more difficult than for the commercial sector because of the number and diversity of participants… existing information — often based on sporadic surveys undertaken by State .. provides a limited, unreliable and out‑of‑date picture of recreational fishing effort, catch and value across Australia.
Whilst Tasmania has a freshwater fishing licence and species-specific licenses, it does not have a broader saltwater fishing licence/compulsory registration as recommended in the Productivity Commission Report.[vi] and therefore the quantum of fishers and resultant saltwater fishing effort is fundamentally flawed as it is based largely on wildly extrapolated assumptions.
The benefit of such complete licence/compulsory registration system as recommended would provide a qualified count of recreational fishers which then enables the creation of a database that can be used to improve the efficiency of surveys which then improves knowledge about recreational fishing activity. As stated in the PC Report, “Better information contributes to better management decisions, including how access to fisheries should be shared and what additional services or facilities should be provided for recreational fishers”[vii].
The Scalefish Fishery Rules Review also recommends the introduction of a Recreational Fishing Boat Charter Licence, again this was recommended in the 2016 PC Report [viii].
AFTA supports the introduction of a Recreational Fishing Boat Charter Licence, not as a revenue raising measure but as a means of obtaining qualified participation and catch rate data collection through logbooks, contributing to better overall fisheries management.
Overall, once a qualified and quantified recreational fishing effort is ascertained, better management processes and outcomes can be achieved, until then apportionment of the recreational fishing effort is largely guesswork and that is a failing of both science and public policy. AFTA agrees with the PC Report that:
… licensing will support the gathering of essential information and is a logical and proportionate response to improving the management of Australia’s fisheries resources for the benefit of the wider community, including recreational fishers, now and for the future. …. The management of recreational fishing should be based more on evidence about its extent, nature, impact and value to the community. This would contribute to improved management of catch-constrained stocks, and more generally support the development of fishing controls that are proportionate to environmental risks (that is, neither too stringent or lax) as well as predictable, transparent decision making.
… The purpose of licensing is not to restrict participation in recreational fishing, but to get a more comprehensive picture of activity … Government and its agency managers need to better understand how many people are fishing when and where, and what they are catching. Understanding existing activity is essential to managing Australia’s fisheries resources for future generations of fishers, as well as providing well-targeted regulatory services.
Information gaps may not be crucial when stocks are healthy, but when the threat of over-fishing arises, good catch and participation information leads to better responses and outcomes.
In making sound and informed fishery policy decisions on the sustainability of fish stocks, governments must address the “Triple Bottom Line”, that is the economic, the social and the environment impacts of any such decisions, this review only addresses the environmental aspect and that is not acceptable.
Due and equal consideration needs to be given to the social impact – the wellness outcomes in any decision. Already the participation rate of recreational fishing in Tasmania is declining, down to 26% from 29% and the resultant downstream impacts both on the industry and the individual have been significant.
Often an unrecognised benefit of recreational fishing is that of the mental health benefits – the wellbeing outcome. It is well documented and proven that participation in recreational fishing has many personal health benefits, in particular Mental Health.
From the 2011 report to the Commonwealth Fisheries Research & Development Corporation (FRDC) “Identifying the health and well-being benefits of recreational fishing” 2 Professor Alexandra McManus[ix] identified:
“The main reason Australian anglers go fishing, apart from catching dinner, is to relax and unwind. And while it seems logical that there are health benefits associated with recreational fishing, it seems incredible that we do not fully understand the scale and range of the benefits……. Participants (in the study) indicated that there were several social, physical, mental health and well-being benefits to be gained from recreational fishing, with a particular emphasis on relaxation and stress release. When asked what health and well-being benefits families can gain from recreational fishing there was a significant focus on familial bonding.[x]
This study found that considerable health and well-being benefits can be gained through involvement in recreational fishing. Encouraging young children, youth, adults and families to fish offers healthful outdoor recreational activity that can be enjoyed throughout life. Benefits were evident for both individuals and groups.
Recreational fishing also provides significantly benefits to youth with behavioural and mental health issues. The major benefits identified were: youth development; social support; good mental health outcomes, behavioural management, rehabilitation of upper body musculoskeletal injury and reductions in stress and anxiety.
This too must be considered as a part of any rule changes.
In conclusion, this Scalefish Fishery Rules Review represent the largest range of cuts and restrictions to recreational fishers at a single point in time without a realistically proportionate impact on the commercial sector. The economic and social impacts of these proposed changes will be devastating for the recreational fishing & boating businesses and the community well-being reliant on a sustainable recreational fishing future.
Further consideration of these rule reviews is required, should you wish input from AFTA, please email admin@afta.net.au.
Yours sincerely,
The Hon. Bob Baldwin
Chair – AFTA
[i] National Social and Economic Survey of Recreational Fishers 2018-2021 – Executive Summary
[ii] National Social and Economic Survey of Recreational Fishers 2018-2021: Table 4.2: Estimated number of adult recreational fishers by State and Territory, 2018 (Stage 1 data), p. 40
[iii] Productivity Commission, 2016, Marine Fisheries and Aquaculture, Final Report Chapter 4: Recreational Fishing. P. 123
[iv] ibid: p.129
[v] ibid: Improving the information base: Chapter 4.5, p.151
[vi] ibid: Recommendation 4.1, p. 137
[vii] ibid: The benefits of licensing p.132
[viii] ibid: Recommendation 4.1, p.137
[ix] Professor Alexandra McManus PhD, MPH, PGDipPH, BSc HP (H.Biol), GAICD, MAIFST, is the Director, Centre of Excellence Science Seafood & Health (CESSH), Faculty of Health Sciences, Professor and Executive, Curtin Health Innovation Research Institute (CHIRI)
[x] FRDC Report “Identifying the health and well-being benefits of recreational fishing” Prof A. McManus, Dr W. Hunt, J. Storey, J. White at 7.4.3 “Health and well-being” p.37