AFTA – Submission on NSW Rebuilding Programs for Depleted and Recovering Fish Stocks

The Australian Fishing Trade Association (AFTA) appreciates the opportunity to provide feedback on the proposed NSW Rebuilding Programs for depleted and recovering fish stocks. As the peak national body representing the fishing tackle industry—including wholesalers, importers, manufacturers, retailers, and associated media—we are deeply committed to the long‑term sustainability of Australia’s recreational and commercial fisheries.

Healthy fish populations are essential to sustaining participation in fishing, supporting thousands of jobs, and underpinning economic activity across retail, wholesale, import, manufacturing, tourism, and service sectors.

AFTA strongly supports the overarching intent of the NSW Rebuilding Programs. Rebuilding depleted stocks is essential to safeguard fisheries resources for future generations, protect ecosystem integrity, and ensure that both recreational and commercial fishing remain viable, sustainable, and accessible.

The framework’s emphasis on strong action, best available science, and adaptive management aligns with contemporary fisheries best practice and is welcomed by AFTA.

Recognition of the Triple Bottom Line

AFTA welcomes the program’s commitment to rebuilding biomass to sustainable levels (above B20 within biologically realistic timeframes). This approach reflects the triple bottom line of fisheries management:

• Environmental: stock recovery, resilience, and ecosystem health
• Economic: long‑term viability of dependent industries and supply chains
• Social: ongoing recreational access, community wellbeing, and cultural values

Successful rebuilding delivers the greatest long‑term value per kilogram of fish harvested by:

• Maximising future sustainable yields and economic returns
• Reducing the risk of severe future restrictions or closures
• Supporting social outcomes including angler participation, satisfaction, and regional tourism

AFTA encourages DPI to integrate triple bottom line assessments explicitly into decision rules, ensuring economic and social impacts are evaluated alongside biological metrics.

Key Feedback and Suggestions for Program Improvement

1. Proportional, Evidence‑Based Management Focused on Net Value per Kilogram

While precautionary actions are necessary for severely depleted species such as Grey Morwong (~11% biomass), AFTA encourages:

• Greater emphasis on gear selectivity improvements
• Use of targeted spatial/temporal closures where biologically effective
• Economic evaluation of harvest‑reduction scenarios to determine which options
  maximise the net benefit per kilogram of reduced catch

Management should deliver the highest conservation return with the lowest unnecessary social and economic disruption.

Economic and Employment Contribution – NSW (Recreational vs Commercial)

Table 1. Contribution to NSW economy and jobs

Sector	GSP Contribution (A$ billion)	FTE Jobs
Recreational	3.9	32,493
Commercial	0.6	4,440
Total	4.5	36,933

Table 2. Shares and Relative Scale

Metric	Recreational	Commercial	Recreational vs Commercial
Share of combined GSP	86.7%	13.3%	6.5× larger
Share of combined FTE employment	88.0%	12.0%	7.3× larger

Key insight (one sentence):
Recreational fishing generates ~6.5× more GSP and ~7.3× more jobs than the commercial sector in NSW, accounting for ~87% of total sectoral GSP and ~88% of jobs.

Why it matters (brief):
Given the outsized economic and employment contribution of recreational fishing, rebuilding measures should preserve reasonable recreational access and ensure proportional, evidence‑based reductions across sectors to avoid unnecessary impacts on regional jobs, retailers, distributors, and service businesses.

2. Strengthened Monitoring, Data, and Adaptive Triggers

AFTA strongly supports investment in:

• Fishery‑independent surveys
• Improved recreational catch estimation
• More frequent stock assessments

Clear adaptive triggers—e.g., review points every 3–5 years or earlier when new data emerge—would strengthen transparency and responsiveness.

3. Sectoral Equity and Shared Responsibility

Species such as Grey Morwong (~66% NSW harvest share) and Silver Trevally (~37%) require coordinated cross‑sectoral action.
AFTA emphasises:

• Allocations must reflect each sector’s actual harvest and impact
• All sectors must contribute proportionally
• Transparency is essential to maintain trust and compliance

4. Support for Affected Communities and Businesses

The rebuilding process will create unavoidable short‑term disruptions.
AFTA recommends:

• Transitional business‑support programs
• Educational communications to maintain angler participation
• Promotion of alternative sustainable species

This ensures ongoing consumer engagement and reduces shock to coastal economies.

5. Cross‑Jurisdictional Coordination

For species such as School Shark, Gemfish, and others managed nationally, AFTA supports NSW’s continued participation in collaborative frameworks.

SPECIES-SPECIFIC RESPONSES

AFTA Submission – Grey Morwong Rebuilding Program

Summary Position

AFTA acknowledges the rebuilding objective: biomass to reach 20% of unfished levels within 3 generations (11 years) and to progress toward a long‑term 40% target. We also recognise the need for a significant reduction in total harvest (~50%).

Disproportionate Impact on the Recreational Sector

The DPI proposes:

• Option 1: 2 fish per person + size increase to 35 cm
  • 80% reduction (not the stated 18%)
• Option 2: 1 fish per person, 30 cm size
  • 90% reduction (not the stated 33%)

These figures far exceed the required 50% cross‑sector reduction and are inconsistent with the recreational sector’s modest contribution to total harvest.

Such measures would effectively eliminate meaningful recreational access without proportional conservation benefit.

AFTA’s Preferred Option

Bag limit: 5 fish per person
Minimum size: retain 30 cm

This delivers:

• 50% reduction in recreational harvest
• Fair contribution in line with the program’s objectives
• Reasonable access for recreational anglers
• Lower social and economic disruption

Conclusion

AFTA urges DPI to adopt a proportional, equitable approach consistent with actual recreational harvest impacts.

AFTA Submission – Silver Trevally Rebuilding Program

Summary Position

AFTA supports the objective of achieving B20 within 15 years and recognises the required 20% reduction in fishing mortality.

Disproportionate Recreational Reductions

DPI options:

• Option 1: 1 per person (90% reduction)
• Option 2: 5 per person + 33 cm size (50% reduction)
• Option 3: 2 per person (80% reduction)

These measures exceed the required 20% reduction and disproportionately target recreational fishers.

AFTA’s Preferred Option

Bag limit: 5 fish
Minimum size: retain 30 cm

Benefits:

• Aligns with a realistic ~50% recreational contribution
• Maintains reasonable access
• Reduces unnecessary social and economic harm

AFTA Submission – Pearl Perch Rebuilding Program

Issue With Proposed Size Increase

DPI proposes reducing the bag limit from 5 fish to 4 fish—a 20% reduction, compared with the stated 17% target.

Raising the minimum size from 30 cm to 38 cm:

• Dramatically increases release numbers
• Significantly increases barotrauma mortality (deep‑water species)
• May increase total fishing mortality

This contradicts the rebuilding intent.

AFTA’s Preferred Option

Bag limit: 4 fish
Minimum size: retain 30 cm

This option:

• Achieves ~20% reduction in bag limit
• Minimises barotrauma mortality
• Preserves reasonable access

AFTA Submission – Redfish Rebuilding Program

Disproportionate Recreational Impact

DPI proposes reducing the bag limit from 20 fish to 1 fish—a 95% reduction, compared with the stated 14% target.

This is an extreme and inequitable restriction that essentially removes recreational access.

AFTA’s Preferred Option

Bag limit: 10 fish
Minimum size: retain 25 cm

Benefits:

• Provides a 50% reduction in recreational catch
• Far exceeds the stated 14% requirement
• Maintains access
• Supports compliance and stewardship

FINAL STATEMENT

AFTA strongly supports the sustainable rebuilding of NSW fish stocks base on sound scientific data and equitable outcomes.
However, several proposed recreational measures are disproportionate, inequitable, and inconsistent with DPI’s stated reduction targets.

AFTA advocates for:

• Proportionate sectoral contributions
• Measures grounded in biological reality
• Triple bottom line alignment
• Fair access for recreational fishers
• Practical, socially sustainable, economically sensible solutions

We welcome ongoing engagement with DPI as these programs are refined and implemented.

Please contact AFTA at any time for further discussion or clarification.

The Hon. Bob Baldwin

Independent Chair

Australian Fishing Trade Association