Submission on the Draft Management Plan for Recreational Fishing in South Australia
The Australian Fishing Trade Association (AFTA) is the peak Recreational Fishing Industry body representing the Manufacturing, Wholesale, Retail & Media businesses of the Australian recreational fishing industry and therefore through the face to face engagement, the RecFishers across South Australia.
Our industry receives feedback daily from RecFishers, this is what shapes our industry and our policies. This Draft Management Plan for Recreational Fishing (DMP) submission builds on the recent AFTA submission to the FRDC Commonwealth Fisheries Resource Sharing Network and the AFTA submission Management Options for Snapper in South Australia”.
AFTA has fought long and hard for responsible fisheries management plans and importantly an equitable share of the fish resource across our nation. Our contribution to the South Australian economy and importantly to the social fabric is unique and not forgetting the health benefits, both physical & mental, from people engaging and simply getting outdoors.
Nationally the recreational fishing industry is made up of approximately 60 Australian Manufacturers (300 employees), 60 Wholesalers (600 employees) and 2000 Retailers (100000 employees)  servicing the needs of approximately 3,362,990 RecFishers. This does not take into account the downstream employment numbers through the flow on effect spreading to the whole of the community, not just the tourism sector.
The 2017 Productivity Commission Report into Marine Fisheries and Aquaculture (PCRMFA) reported an estimate of 3.4m RecFishers in Australia and somewhere between 328,227 (24% of population) and 277,027 (18% of population)  in South Australia. Whilst this represents somewhere between 8.2% – 9.75% of the nation’s recreational fishers, the AFTA industry averaged sales figures show that South Australia represents approximately 6% of sales. This could be in part due to participation rate, low species stock levels (e.g. SBT, snapper, whiting), species season closures and weather conditions.
Following on from the 2019 Snapper closures there is unquestionably the need for this timely review of the needs and requirements for recreational fishers in South Australia. However, in that, getting the balance right between Recfishing and Commercial fishing, AFTA questions whether the data upon which determinations are made is correct.
The PCRMFA correctly asserts that: “A small number of fishers account for the majority of the recreational fishing effort” and further asserts that “Surveys are undertaken on an ad-hoc basis and there is therefore little information on shifts in fishing activity and catch.”
It is impossible to see how the total catch of any species apportioned to the recreational fishing industry to date can be accurately determined when there are no accurate South Australian figures on the actual number of RecFishers, the participation rate at which they fish, and the species targeted and resultant catch rate.
Currently, recreational fishing licenses are not required in South Australia other than permits for 5 of the 8 reservoirs and the registration of personal use rock southern lobster pots. There are 4261 southern rock lobster registration holders with 7,533 registered pots.
AFTA believes that the South Australian Government should take guidance from the PCRMFA Report and implement licensing or compulsory registration for all RecFishers.
To quote the PCRMFA Report:
“For maximum efficiency, licensing systems should have high coverage rates…… Governments may exempt certain groups from the payment of fees for welfare reasons, but there should be few, if any, exemptions from being ‘counted’ and contributing data.
“The scale and diversity of recreational fishers makes it difficult to identify and target a representative sample of 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)…
As outlined in the DMP, the South Australian method of surveying is ….
“a telephone interview screening survey of randomly chosen households, to ascertain participation and demographics of recreational fishers in the 12- months prior to the survey. Then some fishing households are randomly selected to participate in the 12-month diary survey where household 
The PCRMFA report reflected the SA Telephone survey method as both inefficient and inaccurate.….
“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 reliance of PIRSA on random telephone surveys for recreational fishing data is out of date and substantially flawed. The CSIRO has found :
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. 
If the SA Government introduced mandatory licencing/registration, only then can meaningful appraisals of the recreational fishing effort be determined. Whilst it is for the government to determine a cost, that cost could be borne by government with a no-cost to RecFishers mandatory registration thus avoiding any deemed political fall-out.
AFTA members support a Recfishing license with a suggested $30 price point, however, this is with a caveat that allfunds collected from license fees be hypothecated towards a direct recfishing benefit, not put into Government consolidated revenue. These funds to be matched by Government funding on an agreed matching $ for $ basis and overseen by the recently elected South Australian Minister’s Recreational Fishing Advisory Council. AFAT also recommend an exemption for licence holders from other states (NSW & Vic) so as to not affect the interstate recreational fishing tourism into SA.
With the introduction of a compulsory registration/licensing regime the South Australian Government would have a direct means of communication with RecFishers, improve the quality of survey outcomes and more importantly providing ongoing targeted education/information to RecFishers on the State requirements and at the same time reducing costs to Government of surveying RecFishers.
As the PCRMFA Report summarised the argument in support of a license system:
A licensing system in South Australian would provide a better basis for monitoring effort, enforcing controls and developing services for recreational fishers and coverage of all recreational fishers (including independent fishers, charter fishing operators and sports fishers) to provide an accurate picture of participation and generate the information used to help manage stocks.
Licensing systems are not intended to restrict participation in recreational fishing and, rather, primarily be used to gather information. The experience of domestic systems shows that the costs for government and compliance burden on fishers can be relatively low. The experience of other countries, such as the United States indicates that well-designed licensing systems can provide an effective means of collecting data and improving management.
Overall, licensing provides a practical and proportional way of better incorporating recreational fishing into harvest and other management strategies. All jurisdictions should therefore require recreational fishers to obtain licences (or permits) to fish. 
To this end the fisheries management practices that determine the resource sharing and restrictive conditions applied need to be based on a foundation of accurate data to reflect that RecFishers have equitable access to all fish stocks. Small scale surveys when combined with inaccurate extrapolation methods through estimated catch rates and bag limits do not provide accurate figures for quantification of the RecFisher catch.
Participation rates and ability between commercial and recreational fishers need to be taken into consideration in evaluating catch rates. Whilst commercial fishers may very well be fishing at least 15 days per month on average, with much higher skill sets and catch rates, recreational fishers would be lucky to fish 15 days per year with a great diversity on personal ability and catch rates.
Even if there were compulsory licensing in South Australia, that does not necessarily equate to an accurate assessment of fish take as frequency, ability and regions are all determining factors, but it does allow for an accurate estimation of the number of RecFishers and therefore increases the accuracy of any baseline assessment of the economic and social benefit from recreational fishing.
Participation in fishing surveys by all levels of government to date have not been well supported due to 2 primary reasons, trust and a lack of awareness and engagement.
The trust issue came to the fore with the introduction of Marine Parks at both state & commonwealth levels where RecFishers participating in surveys and identified areas of prime fish grounds and then watched as those areas were targeted as Marine Park – “No Recreational Fishing” Zones.
The awareness and engagement issue can easily be addressed by introduction of “Compulsory Registration” whether a licence fee is applied by the South Australian government or not. By utilising the contact details the majority of RecFishers can be communicated with directly.
As a means of measuring catch effort, as stated in the AFTA submission on snapper closures, AFTA does not support the principle of “Harvest Tags” for RecFishers across all species as a means of controlling catch but do support the concept of “Tag & Release” program.
AFTA recommends that a 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 copy as it is in other states as a means of building greater scientific research across a range of species. A mobile app in conjunction with a licensing/registration scheme, would allow fish to be photographed with the tag inserted and data instantly recorded and uploaded providing a more accurate system than the current card-based system employed in other states.
A measured length marker on the tag could be used to scale measure the actual fish in the photo benefiting 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.
As stated by AFTA in the “Management Options for Snapper in South Australia” submission, the recent FRDC report identified that snapper fisheries in the Spencer Gulf/West Coast were depleted, whilst the snapper stocks in Gulf St Vincent and Victoria were sustainable at this point in time. AFTA did not agree with the Snapper Management Plan undertaken by the Government but acknowledge that immediate action needed to be taken to ensure the sustainability of snapper (Chrysophrys Auratus) fish stocks in South Australia.
AFTA is critical of the South Australian government “PIRSA” allocation program of 3030 Recreational Fishing Snapper Harvest Tags as a means of controlling the capture rate of the decimated snapper stocks. Whilst the estimated number of RecFishers in SA is 277,000 only 3,624 RecFishers applied for the 3030 tags with just 606 RecFishers being issued 5 tags each. AFTA questions the Snapper allocation of only 6000kg to RecFishers, 7,500kg (3788 tags) to Charter Boats whilst an allocation of 60,750kg went to commercial fishers as a fair distribution of the snapper fishery resource given the depletion was arguably brought about through overfishing by the commercial sector. This is just another example that without a complete licensing/registration system in SA, no accurate data upon which to base the distribution of the resource is available.
It was also disappointing to see a harvest tag system introduced without addressing bag limits for long term sustainability for Snapper. AFTA recommended, to ensure longer term sustainability of both fish stocks and the industry 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 was to apply to all recreational and charter boat fishing with the bag limit being reassessed toward the original level after 4 seasons.
AFTA also recommend that to increase snapper sustainability in South Australia a reduction in commercial marine scalefish fishing sector effort, in particular long lining be implemented immediately by progressing the $20m commercial license by-back scheme and a more stringent approach applied to commercial fisheries management.
AFTA suggested “Option C” in the “Management Options for Snapper” as a plan that would have helped 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.
Clearly there is a need to determine a fair and equitable share of the each of the fishery stock for the RecFishers, Customary fishing by Indigenous Australians & Commercial fishing sectors and that once determined, isolate that quota independent of whether the commercial sector reach their portion of the TAC.
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.
RecFishers can no longer be the scapegoat for poor fisheries management practices!
Transparency is critical in gaining trust, as such AFTA wants a published list from both AFMA & PIRSA of each species allocation including the past 10 years allocation history, species by species, state by state. AFTA want a year on year incremental allocation increase to RecFishers from the current allocation. The increase should be stepped year by year with a 1% increase per annum to bring about an equitable distribution of allocation.
It is critical that the South Australian government address the fact that a shared resource is not a first in best dressed solution just because the commercial sector has caught their species TAC quota. AFTA question how is that an equitable distribution of the fishing effort? The same needs to be taken into consideration across the whole of the range of fish species and not discounting the larger scale commercial incidental by-catch, particularly with long lining.
In relation to the Southern Bluefin Tuna (SBT) the equitable sharing of the resource is absolutely critical to the Recfishers of South Australia in particular where the income derived from Recfishers spend in pursuing these fish as targets is of high economic impact throughout the community in what is a relatively short season. Any attempt at banning of RecFishers from capture of SBT, whilst at the same time maintaining quota’s for collection of relatively juvenile size stock for fish farming will not sit well across the recreational fishing sector. The depletion of the tuna biomass across all species, in particular SBT and Yellowfin, has been due to commercial pressure, poor past management practices and not that of recreational fishing effort.
AFTA also note that there are many species not targeted, nor caught as bycatch by RecFishers due to the location of the waters in which they habitat. Fisheries stock management and resource sharing allocation in this area needs to be addressed in an entirely different manner to that where RecFishers compete with commercial fishery for the same species.
Finally, AFTA recommends a program of increasing the number of “Artificial Reefs”, with immediate locations at Port Broughton, Wallaroo, Whyalla & Ardrossan and further sites by engagement with stakeholders. This would assist in fishing pressure reduction on the natural snapper spawning grounds whilst boosting the broad economic benefit achieved from recfishing.
AFTA considers that whilst there has been considerable progress and a genuine desire by government for improved fisheries management plans which will result in fair and equitable resource allocations across all sectors, without the intended resource allocations being quantified for each species & sector, it is difficult to appraise the result against the intent.
AFTA is committed to working with the South Australian government at all levels to ensure the guiding principles of the Management Plan & resource sharing are not only observed, but more importantly committed to and achieved.
3 May 2020
The Hon Bob Baldwin
Australian Fishing Trade Association (AFTA)
 These are conservative estimates based on AFTA industry feedback.
 Productivity Commission report into Marine Fisheries and Aquaculture, Chapter 4, Table 4.1 Estimates of State-wide participations on recreational fishing
 Ibid, 2000-01 National Survey (Henry & Lyle 2003)
 Ibid, 2013 – 14 Survey (Giri & Hall 2015)
 Ibid, Page 124,
 Ibid, Page 125,
 Ibid, Page 127, Table 4.2, Recreational Fishing Licenses – Independent Fishers
 Ibid, Page 9
 Ibid, Page 129, Box 4.3 Licensing and sample frames for surveys
 PIRSA Draft Management Plan, page 25
 Productivity Commission report into Marine Fisheries and Aquaculture, Chapter 4, Table 4.1 Estimates of State-wide participations on recreational fishing, Page 129, Box 4.3 Licensing and sample frames for surveys
 Ibid, Page 129,
 Ibid, Page 130