Spanish Mackerel Survey
On the 6th April the Qld Government finally released it’s “Have Your Say” consultation survey on East Coast Spanish Mackerel with a closing date of 5th May. The survey & discussion paper are available to read here.
AFTA questions the very nature & structure of this survey, given the limited selection of multiple choice answers, answers which would be critical to our industry.
These concerns were raised by AFTA with the Director Qld Fisheries on the survey and its inadequacy given several questions are skewed towards the answers the Queensland DAF Group want to hear to support their pre-determined position and not those of genuine industry participants. Further, the survey cannot be “submitted” online with only Question 16 “ Are there any other issues, opportunities or solutions that you would like to raise?” being answered.
The survey questions are also available at the end of “Consultation on Management Discussion Paper” available on the link and AFTA recommends this as the preferred method to be submitted if you don’t wish to be forced into the multiple choice answers that you do not agree with. (Please note only questions 1 through to 5 are compulsory).
AFTA recommends that you print out the survey, complete and post your submission to:
Spanish Mackerel Fishery Discussion Paper
Department of Agriculture and Fisheries
GPO Box 46
Brisbane Qld 4001
or email to:
Questions 1 to 4 are self-evident questions to which AFTA have no issues, however, Q5 through to Q16 are fundamentally flawed and detrimental to our industry position. The AFTA response is as follows, please use it as a guide.
Your say matters and we want to hear from you about which management measures you prefer. The questions with an asterisk (*) are mandatory.
Question 1. Tell us who you are:
Question 2. What sector of the Spanish mackerel fishery are you part of?*
☐ Commercial fisher
☐ Recreational fisher
☐ Charter fishing operator
☐ Traditional fisher / Traditional Owner
☐ Seafood wholesaler/marketer
☐ Hospitality (restaurant, café, fish and chip shop) owner/worker
☐ Fishing tackle retailer
☐ Environmental group, industry peak body or other non-government organisation
☐ Interested community member
How many times per year do you go fishing for Spanish mackerel?
How many Spanish mackerel on average do you catch each trip?
Q.5 Which rebuilding timeframes should be considered?*
- 7 years
- 9 years
- 11 years
- 14 years
The AFTA position is that this is a trick question as we believe that more work needs to be done to the stock assessment before we can quantify any timeline that has a negative economic impact on our members or a negative social impact on anglers.
Q.6 The total allowable commercial catch (TACC) should be set at:
- 53 tonnes
- 107 tonnes
- 160 tonnes
- 214 tonnes
The AFTA position is we do not advocate for the commercial industry, nor do we support any changes to commercial TACC and yet again this question only allows for a drop in catch.
Q.7 The recreational in possession and boat limit should be set at:
- 1 per person, 2 per boat
- 1 per person, 3 per boat
- 1 per person, 6 per boat
- 2 per person, 2 per boat
- 2 per person, 4 per boat
The AFTA position is 2 per person (reduction of 1) and NO boat limit. As QDAF states in its consultation paper: “Boat ramp and recreational survey data indicate that, of those recreational fishers who landed Spanish mackerel in Queensland, approximately 70% only landed one Spanish mackerel per trip” therefore supporting the AFTA argument that there should be no per boat limit.
To address the stated “Black-marketing” perhaps QDAF should increase its compliance officer base.
Q.8 The minimum size limit for Spanish mackerel should be set at:
The AFTA position is 85cm, despite QDAF stating the survival rate after capture and release is almost zero due to sharks and/or hook removal and should remain with the original 75cm limit.
Q.9 Do you support a whole east coast seasonal closure?
The AFTA position is NO as QDAF have called it a “seasonal closure” which means it has nothing to do with the actual spawning period and the only relation is where the Spanish Mackerel aggregate. If DAF proceeds with the whole east coast closure everyone will lose out as north and south have different seasons. We would only consider a spawning closure which would have to be scientifically documented and well-proven.
Q.10 How long should a whole east coast seasonal closure be?
- 16 weeks
- 12 weeks
- 8 weeks
- 4 weeks
The AFTA position is there needs to be a scientific study into what triggers the spawning aggregation, how long the spawning aggregation period actually is and exactly where the spawning aggregation areas are located? Yet again the words” seasonal closure” do not mean spawning closure and this can only be interpreted as merely a no fishing clause. DAF has concluded there are spawning areas north of Cairns and around Townsville, both in Green Zones with no fishing at any time so AFTA questions why have limits in other areas outside of the Green Zones if the Spanish Mackerel are not spawning?
Q.11 Do you support a split north/south seasonal closure?
The AFTA position is once the accurate identification of spawning areas is known and when spawning takes place, then protective measures can be put into place. In short, we support well documented and timed spawning closures, not seasonal closures these are nothing more than no fishing clauses.
Q.12 How long should a split north/south seasonal closure be?
- 8 weeks each north and south
- 6 weeks each north and south
- 4 weeks each north and south
- 2 weeks each north and south
The AFTA position is once the spawning trigger, duration and locations are known this closure period can be addressed without a broad blanket approach based on inadequacies and not science. This is just another trick question to provide the statistical answer DAF need to justify the pre-determined result that they want.
Q.13 Would you support different recreational and commercial seasonal closures?
The AFTA position is we will not be drawn into a “them or us” division with the commercial sector on this issue. There should be no seasonal closure for recreational anglers and subject to quality research AFTA would only support short sharp 100% proven spawning period closures.
Q.14 Which recreational combination would you prefer?
- Higher recreational in-possession limit and a longer recreational seasonal closure
- Lower recreational in-possession limit and a shorter recreational seasonal closure
The AFTA position is neither as an option as the whole premise is not based on any true or accurate scientific assessment. If QDAF truly addresses the understanding and accuracy of spawning periods, location and aggregation triggers then a meaningful answer/solution can be provided.
Q.15 Would you support better recreational catch reporting?
The AFTA position is AFTA always supports a sustainable approach to any fishery management and will help with promoting realistic and user-friendly reporting measures
Q.16 Are there any other issues, opportunities, or solutions that you would like to raise?
The AFTA position is as stated in each of the questions above and further, in looking at the above questions and points raised we also note disappointingly that the QDAF Spanish Mackerel working group summarily dismissed Dr Neil Klaer’s Independent Peer Review. AFTA agrees with the concerns raised in Dr Klaer’s Executive Summary statement where he states of the modelling assessment :
“ The assessment report included a fairly comprehensive section on recommendations separated as they apply to data, monitoring and research, management and the stock assessment. I agree with those recommendations and particularly encourage any efforts to make use of earlier composition data that may enable extension of recruitment deviation estimation to earlier years, and exploration of the development of fishery- independent abundance indices such as from close-kin genetic analysis.
I am unable to support the conclusions regarding future harvest levels for the east coast Spanish mackerel stock until reservations regarding the most appropriate central value for steepness for the base-case are resolved. “
In addition, AFTA agrees with his finding:
It has long been recognised that steepness is a highly influential but uncertain parameter for fisheries stock assessments. Spanish mackerel do not fit the profile of a species likely to allow robust steepness estimation. …. that low central value for steepness for Spanish mackerel is inconsistent with previous accepted practice, and comparable existing DAF Spanish mackerel assessments. As such, it requires a much-expanded justification within the current assessment document.
In summary, the survey method used in this data collection is as flawed as the modelling and data input into the East Coast Spanish Mackerel Stock Assessment.
AFTA consider the only way forward is to conduct quality scientific research to determine the aggregation locations, spawning periods and aggregation triggers and then use a stock assessment model with quality data input that stands up to the rigour of an independent peer review.
If this is done QDAF will reduce the triple bottom line impact on the Environmental, Social and Economic contributory aspects of the fishery.