Submission Questions — Draft NSW Snapper Harvest Strategy and Draft NSW Yellowtail Kingfish Harvest Strategy

Before next week’s meeting with NSW DPI, AFTA sent a series of questions raising recreational fishers’ concerns so a structured, meaningful response to the Kingfish & Snapper reviews can be prepared.

Ms Tara Black
Deputy Secretary, Fisheries and Forestry
NSW Department of Primary Industries and Regional Development

Dear Ms Black

Submission Questions — Draft NSW Snapper Harvest Strategy and Draft NSW Yellowtail Kingfish Harvest Strategy

The Australian Fishing Trade Association (AFTA) is the peak body for Australia’s recreational fishing tackle and boating trade. Our members manufacture, import, wholesale and retail the equipment used by recreational fishers across New South Wales, and they employ people in every coastal community in the state. We write in response to the two draft harvest strategies released for public comment on 1 September 2026.^1,3

AFTA supports the sustainable management of NSW fish stocks and does not oppose rebuilding where the evidence establishes that rebuilding is required. Our members’ businesses depend on abundant fish stocks; we have no interest in overfishing. Our concern with these two drafts is not the objective but the evidence base, the distribution of the burden, and the absence of any published pathway back to normal access once a stock recovers.

We want to be clear at the outset about the spirit in which this submission is made. AFTA wants to work with the New South Wales Government to develop a pathway forward — one that benefits the fish stocks, the marine environment, the fishing community, and the businesses, families and coastal towns that depend on both. Those interests are not in competition. Healthy Snapper and Yellowtail Kingfish stocks are the foundation of our members’ livelihoods, and no one in the recreational fishing trade has anything to gain from a depleted fishery. What we are seeking is not weaker management. It is management built on evidence that can be examined, a burden shared fairly between the sectors, and a process in which the people affected are genuinely part of the solution. The questions in this submission are asked in order to get to that outcome, not to obstruct it. Where the Department can show us the analysis, AFTA will back the measures it supports — publicly, and to our members.

Whom AFTA speaks for

AFTA makes this submission on behalf of the recreational fishing industry and the recreational fishers our members serve. We represent tackle manufacturers, importers, wholesalers and retailers, and we work alongside the charter, boating, marine and fishing tourism businesses whose trade depends on recreational access to these two species. Our interest in these drafts is the interest of that sector: the 1.29 million people who fish recreationally in New South Wales, and the businesses, employees and coastal communities that depend on them continuing to do so.

This submission is made with the support of the Boating Industry Association (BIA). The BIA is the peak body for the marine industry in New South Wales, representing boat builders, dealers, marinas, brokers, chandlery and service businesses. Its members and ours serve the same customers, and the measures proposed in these drafts fall on both our sectors together. AFTA and the BIA are jointly of the view that the concerns set out in this letter — the unpublished evidence base, the unexplained change in stock assessment method, the absence of any economic impact assessment, and the want of a genuine engagement process — must be addressed before these strategies are finalised.

We want to be equally clear about what this submission is not. AFTA does not represent the commercial fishing sector and makes no submission on its behalf. Commercial licence holders have their own representative bodies and will make their own case, and it is not for AFTA to speak for them. Where this letter refers to commercial arrangements — the sector shares, the transition to quota, catch validation, or the structural adjustment proposal set out below — it does so for one reason only: those arrangements determine what is left for recreational fishers, and they set the standard of accountability against which recreational fishers are being measured. We raise them as matters of fairness to our own sector, not as advocacy for another. Where we say that commercial fishers should be treated fairly and compensated properly, we say it because AFTA does not seek advantage through unfairness to anyone, and because a settlement that is unjust to one sector will not endure.

The sector these measures apply to

The FRDC-funded National Social and Economic Survey of Recreational Fishers 2018–2021 (Moore, Schirmer, Magnusson et al., FRDC / ABARES / University of Canberra, February 2023) and its New South Wales and ACT state report (July 2023) record the following.^13,14

1,293,700 adults in NSW and the ACT went fishing at least once in the survey year — a participation rate of 19.6 per cent of adults, close to one in five.¹⁴

Those fishers spend an estimated 10 million days fishing each year.¹⁴

Recreational fishing by residents and visitors contributed an estimated $4.07 billion to the NSW/ACT economy in 2019–20.¹⁴

It supported 33,995 full-time equivalent jobs — 12,378 directly, with a further 21,617 generated through flow-on activity.¹⁴

The contribution is not concentrated in Sydney: $2.41 billion and 18,428 jobs in Greater Sydney, $1.47 billion and 14,065 jobs in regional NSW, and $190 million and 1,502 jobs in the ACT.¹⁴

Nationally, 4.2 million Australians — one in five adults — fish recreationally each year, contributing over $11 billion and more than 100,000 jobs to the Australian economy.¹³

That sector does not fish from the shore alone, which is why the Boating Industry Association joins this submission. Transport for NSW records 586,599 licensed boaters in New South Wales, including personal watercraft riders, and 250,405 boat and personal watercraft registration holders.¹⁶ The NSW Recreational Boater Survey 2023, a survey of 3,000 NSW households conducted for Transport for NSW, found that between 1.70 million and 1.85 million NSW residents had spent time in a recreational boat or other watercraft over the survey period, representing 22 per cent of residents.¹⁷

The same survey establishes why these two drafts matter so much to the marine industry. It found that “fishing was by far the most popular main purpose of a boating trip cited by boaters, being more than twice as popular as the next most popular purpose: cruising/sightseeing”, and that 58 per cent of boaters had fished on their most recent trip.¹⁷ Fishing is not one boating activity among many in New South Wales. It is the principal reason people own, register, licence, fuel, berth, insure and maintain a recreational vessel. A measure that reduces the reason to go fishing reduces the reason to own a boat, and the consequences are borne by every business in that supply chain.

The proposed Yellowtail Kingfish boat limit of one fish per vessel is felt most sharply here. A family of four, or four mates sharing fuel on a trailer boat, would be entitled to a single fish between them regardless of how far offshore they travelled or what the trip cost them. Neither draft assesses what that does to boat usage, to trailer boat sales, to charter bookings, or to the marine businesses in coastal towns that depend on them.

Snapper and Yellowtail Kingfish are two of the principal target species driving that offshore and estuarine effort in New South Wales, and two of the largest single drivers of specialist tackle, boating, charter and travel expenditure in the state. Neither draft strategy contains any assessment of the effect of the proposed measures on the participation, expenditure, employment or regional economic activity described above.

The value of a kilogram of Snapper and Kingfish

The Department’s own Economic Indicators for the NSW Commercial Fisheries in 2023/24 records the following.¹⁸

Commercially landed Snapper: 156,354 kg at an average beach price of $12.00 per kilogram, generating $1.9 million in gross value of production.¹⁸

Commercially landed Yellowtail Kingfish: 120,760 kg at an average beach price of $14.20 per kilogram, generating $1.7 million in gross value of production.¹⁸

The entire NSW commercial fishing sector: 9,837 tonnes landed, $88.2 million gross value of production at beach price, a total contribution to gross state product of $267.4 million ($117.0 million directly), and 2,393 full-time equivalent jobs (1,425 directly).¹⁸

Read against the FRDC figures above, the two datasets — both held or commissioned by government — invite a straightforward comparison. Recreational fishing in NSW and the ACT contributes an estimated $4.07 billion and 33,995 full-time equivalent jobs. The whole of the NSW commercial fishing sector contributes $267.4 million and 2,393 full-time equivalent jobs. On the Department’s own figures the commercial sector generates approximately $27,000 in contribution to gross state product per tonne landed, and approximately one full-time equivalent job for every four tonnes landed.

Combined, the two species at the centre of these consultations account for roughly $3.6 million in commercial gross value of production — about four per cent of the state’s total commercial gross value of production. That is the value being protected on one side of the ledger. On the other side, more than 1.29 million recreational fishers are asked to accept a Snapper bag limit cut by 70 per cent and a Kingfish bag limit cut by 80 per cent, with a three-month catch-and-release period.

AFTA does not put these figures forward as a claim to reallocation, and we note that the FRDC report cautions against using contribution estimates as the basis for access decisions between sectors. We put them forward for a narrower and, we think, unanswerable proposition: where a public resource is being rebuilt and access must be constrained, the Department should be able to demonstrate that each kilogram of that resource is directed to the use that returns the greatest economic, social and environmental value to the people of New South Wales. Nothing in either draft strategy attempts that demonstration.

Six matters we ask the Department to address

1. The recreational catch model has not been published.

Every recreational measure in both strategies rests on a modelled relationship between a bag limit and a tonnage. The Kingfish draft acknowledges that this relationship is not linear — that “a 50% change in bag limits does not achieve a 50% change in catch”⁴ — but neither draft publishes the model, its inputs, or its validation. Critically, a bag limit reduction only removes catch from those fishers who actually reach the limit. Without the frequency distribution of daily retained catch per angler, neither we nor any other party can assess whether reducing the Kingfish bag limit from five to one, or the Snapper bag limit from ten to three, delivers the catch reduction attributed to it. Nor does either draft state how many of the 1.29 million recreational fishers in NSW and the ACT are assumed to catch either species in a year, at what rate they are assumed to catch them, or how those catch rates were measured. This is the single most important omission in the consultation package.

2. The peer reviews of the stock assessments have not been published.

The Snapper draft states that the assessment “was completed and peer reviewed in 2025”; the Yellowtail Kingfish draft states the same of 2026.^2,4 Neither names the reviewer, publishes the review, or sets out its terms of reference. Both drafts then add that peer review “recommendations will be incorporated in current and future assessments” — wording which indicates that the reviewers made recommendations that have not yet been applied to the very assessments on which these measures rest. Fishers are being asked to accept an 80 per cent reduction in access on the strength of a review they cannot read, by a reviewer they cannot identify, whose recommendations are acknowledged to be outstanding. Publishing the reviews, and stating which recommendations remain unimplemented and what difference they would make, is the minimum that a process of this consequence requires.

3. No socio-economic analysis, options paper or regulatory impact statement has been released.

The Mulloway process released a draft strategy together with a management options paper.²⁴ That step has been omitted here. There is no published analysis of the alternatives considered and rejected, and no assessment of economic or regional impact against the baseline set out above. Where two measures would deliver an equivalent catch reduction — for example a change in minimum legal length or a slot limit as against a bag limit reduction — there is nothing on the record to show that the least-cost option was chosen.

4. The case for the Snapper reduction has not been made.

The draft states that the NSW portion of the stock is classified “Sustainable” under the Status of Australian Fish Stocks framework^2,9and that biomass “has been increasing slowly since the 1990s”. A 70 per cent reduction in the recreational bag limit on a stock in that condition requires justification that the draft does not provide. In particular, the draft does not show what the model projects for 2035 under status quo management — the counterfactual against which the proposed cut must be judged. The draft also states no total harvest limit in tonnes, which makes a 45 per cent recreational share difficult to interpret.

5. For Kingfish, there is no published pathway back.

The Snapper strategy sets out a schedule at Table 4 under which recreational limits rise as the sector’s catch share recovers. The Kingfish strategy contains no equivalent. It states only that recreational catch will be adjusted “in proportion to changes to the RBC”.⁴ Fishers being asked to accept a one-fish bag limit and a three-month catch-and-release period are entitled to know, in advance and in writing, what recovery buys back and at what biomass level.

6. No triple bottom line test has been applied to the resource.

Both strategies fix sector shares on a decade of catch history and then distribute the reduction across those shares. Neither asks the prior question: on a full triple bottom line assessment — economic contribution, employment, regional distribution, social and health benefit, and ecological footprint per kilogram landed — which use of a kilogram of Snapper or Yellowtail Kingfish returns the greatest value to New South Wales? The Department holds both the commercial economic indicators and the recreational survey data required to answer that question. We ask that it be answered before the shares are locked in.

The Department’s own assessments, three years ago

Before turning to what AFTA can and cannot advise on, we ask the Department to address a matter that in our view goes to the foundation of both drafts.

Yellowtail Kingfish. The NSW Stock Status Summary for 2021–22, published by the Department in 2023, states: “Yellowtail Kingfish are currently assessed as sustainable for the NSW component of the stock.”¹⁰ It reached that conclusion on six findings. Standardised handlining catch per unit effort had increased by approximately 13 per cent between 1997–98 and 2021–22. The production model estimated biomass at 26 per cent of carrying capacity, above the 20 per cent limit. The spawning potential ratio model returned 22 per cent of unfished levels. Fishing mortality was estimated at F/F20 of 0.61, well below the limit of 1.0. Harvest of 183 tonnes sat well below an estimated maximum sustainable yield of 416 tonnes. And catch curve analysis indicated fishing mortality below natural mortality. Commercial landings had fallen from 264 tonnes in 2009–10 to 67 tonnes in 2021–22, and commercial effort stood at a historic low of 2,109 days.¹⁰

The draft now before us states that the same stock is at approximately 5.5 per cent of unfished biomass.^3,4

AFTA does not suggest that the earlier assessment was necessarily right and the current one wrong. Our difficulty is that the two cannot both be right, and the Department has not explained the difference. Yellowtail Kingfish is a long-lived, slow-maturing species. Spawning biomass does not fall from 26 per cent of carrying capacity to 5.5 per cent of unfished in three or four years while commercial landings and effort are at historic lows and standardised catch rates are rising. What appears to have changed is not the stock but the method: the 2021–22 assessment was a weight-of-evidence approach combining standardised CPUE, a CMSY++ surplus production model, spawning potential ratio modelling, catch curve analysis and length composition; the current assessment is an integrated age-structured Stock Synthesis model. A new model may well be better. But if the entire case for an 80 per cent reduction in recreational access rests on a change in assessment method rather than a change in the fishery, that must be stated openly, quantified, and put to public scrutiny. It has not been.

The earlier summaries also carried cautions that bear directly on the current estimate. They recorded that “much of the spawning stock may be distributed offshore where it is not vulnerable to the NSW coastal fishery”; that “the data underpinning the analyses presented in this summary were collected from NSW waters only but relate to the assessment of the entire ‘Eastern Australia’ biological stock” — a stock also fished by Queensland, Victoria, Tasmania, South Australia, the Commonwealth SESSF, the SPRFMO Convention Area and New Zealand; and that where the size composition of commercial landings is unrepresentative, “mortality estimates (Z & F) will be inflated, and SPR models may produce pessimistic SPR estimates”, a condition the Department considered likely for NSW Yellowtail Kingfish.^10,12 AFTA asks whether those cautions have been resolved in the new model, or simply not carried forward.

Snapper. The position is similar. The NSW Stock Status Summary for 2021–22 states: “Snapper is currently assessed as Sustainable for the NSW component of the stock.”¹¹ It recorded biomass between 0.2 and 0.45 of unfished levels, standardised catch rates stable with a slightly increasing trend since 2014–15, declining commercial effort, and increasing proportions of older fish in the landings — which the Department described as suggesting “an increasing biomass in recent times”. Three years later, the recreational bag limit is proposed to fall from ten to three.²

That same summary records recreational Snapper harvest of approximately 160 tonnes in 2019–20.¹¹ Under Table 4 of the draft strategy, a recreational catch share of 160 tonnes or more corresponds to a bag and possession limit of six. The draft proposes three — two full bands lower on the Department’s own ladder. AFTA cannot identify, from the material released, which recreational catch estimate places the sector in the 114 to under 140 tonne band that yields a limit of three. We ask the Department to identify it, together with the survey and the year from which it is drawn, and to explain why the most recently published estimate does not govern.

The Department published sustainable classifications for both species as recently as 2023. Fishers, charter operators and the tackle trade made investment and business decisions on the strength of them. AFTA is not asking the Department to defend the earlier assessments. We are asking it to reconcile them with the current ones, publicly and in quantified terms, before measures of this severity are imposed on that basis.

Why this submission does not propose alternative limits

The Department will note that AFTA has not put forward alternative bag limits, boat limits or seasonal closure arrangements for either species. That is deliberate, and it follows directly from the material that has not been released.

To propose a bag limit responsibly, a submitter needs to know how many fishers take the species, at what rate, what proportion of them reach the current limit, how catch actually responds to a change in that limit, and what tonnage each option would deliver with what margin of error. To propose a boat limit, add the distribution of anglers per vessel and per trip. To propose a seasonal closure, add the spawning aggregation data, the distribution of effort through the year, and the post-release mortality that a catch-and-release season itself generates. None of that is in the consultation package, and much of it — the recreational catch model, the peer reviews, the economic analysis — has not been published at all.

On the information provided, AFTA is not in a position to make a qualified or reasonable suggestion as to what the bag limit, the boat limit, or any seasonal species closure should be for Snapper or for Yellowtail Kingfish. We will not offer a number we cannot support. A figure advanced on this evidence base would be no better founded than the figures now proposed, and putting one forward would not assist the Department, the fishery, or our members.

We make this point explicitly because consultation summaries often record that stakeholders raised concerns without proposing alternatives. If that is to be recorded here, we ask that it be recorded accurately. AFTA has not declined to engage. AFTA has not been given what it needs in order to engage. Release the recreational catch model, the peer reviews and the economic analysis, extend the period as requested above, and AFTA will provide considered, specific positions on every measure in both strategies — including, where the evidence supports them, reductions. We would rather do that than argue about numbers neither party can presently justify.

A better use of recreational fishing licence revenue

The Department’s own material records that the Recreational Fishing Trusts fund “nine coastal, three coastal mobile squads and six inland Fisheries Officers” in order to “enhance DPI’s capacity to enforce fisheries rules and regulations”.^19,20 AFTA asks the Department to explain why recreational fishers are paying for this at all.

Enforcing the fisheries law of New South Wales is a core function of government. It is exercised against commercial operators, recreational fishers and unlicensed offenders alike, and it exists to protect a public resource on behalf of the whole community. It is not a service delivered to licence holders, and it is not obviously distinguishable in principle from policing, which no one suggests should be funded by a levy on the law-abiding. The recreational fishing fee is paid for access and for investment in the fishery. Charging the state’s own enforcement obligation to that fee means that every dollar spent on compliance officers is a dollar not spent on the stock assessments, onsite recreational surveys and habitat programs that both of these draft strategies concede are needed — and whose absence the drafts then rely on as a reason to restrict recreational access further.

There is a demonstrably better use for that money, and Victoria has already shown what it looks like. Under the Target One Million program the Victorian Government committed up to $27 million to compensate commercial licence holders to exit the Port Phillip Bay net fishery.²² The Victorian Fisheries Authority records the outcome: “33 of 43 licence holders have accepted the compensation package to exit the Port Phillip Bay commercial net fishery in April 2016”, and “these 33 licence holders have caught 87 per cent of the commercial catch of fish targeted by recreational fishers”.²¹ First-year payments ranged from $350,000 to $1.6 million depending on catch history.²² The VFA describes the purpose plainly: “Removing commercial netting from the bay is a key commitment of the State Government’s Target One Million plan for recreational fishing, which aims to get more people fishing, more often.”²¹ Netting was phased out in Western Port in 2009, the Gippsland Lakes in 2020 and Port Phillip Bay in 2022.²³ Notably, the small non-net fishery that remained in Port Phillip Bay is described by the VFA as “using mainly longlines for snapper” — the same species, and the same method, at issue here. The Victorian Government’s stated rationale is equally direct: “the removal of netting will increase catch rates and the size of fish for recreational anglers”.²²

AFTA asks the NSW Government to consider the equivalent: a voluntary program to acquire commercial Snapper and Yellowtail Kingfish entitlement on fair and just terms, and to reallocate that catch to the recreational sector. We stress the words fair and just. AFTA does not seek the confiscation of anybody’s livelihood, and we would not support a program that failed to compensate commercial licence holders properly for what they give up. Victoria did not confiscate; it paid, and it paid well.

The scale in New South Wales is modest. The combined commercial gross value of production for these two species is approximately $3.6 million a year. A program acquiring that entitlement on fair and just terms would cost a fraction of Victoria’s $27 million commitment, and it would be a one-off investment rather than a permanent restriction imposed on 1.29 million people. Measured against the Department’s own figures, it would also return far more per kilogram to the New South Wales economy, to regional employment, and to the community. That is precisely the proposition set out earlier in this letter: where a public resource must be constrained, direct each kilogram to the use that returns the greatest value. A structural adjustment program on the Victorian model is the mechanism by which that is actually achieved, rather than merely asserted.

What we ask

Publish the recreational catch model — its structure, the catch-rate distribution, the proportion of anglers reaching the current bag limit, the effort-response assumption, and its validation against any previous bag limit change — before these measures are finalised.

Publish a quantified, side-by-side reconciliation of the 2021–22 stock status summaries — which classified both species as sustainable — with the current assessments, identifying every change in method, data and assumption and the effect of each on the estimated stock status.

Publish the peer reviews of both stock assessments in full, name the reviewers, and state which of their recommendations have been incorporated into the assessments relied on here and which remain outstanding.

Publish the remaining analysis: model projections under status quo and alternative packages, a socio-economic impact assessment against the FRDC baseline, and the management options considered and rejected.

Assess lower-cost alternatives — size and slot limits, spatial measures and boat limits — against bag limit reductions on a least-cost-to-the-community basis, and publish that assessment.

Publish, for Yellowtail Kingfish, an automatic schedule of recreational limits at each biomass level equivalent to Snapper’s Table 4, with a guaranteed review even if the stock assessment is delayed.

Fund onsite recreational surveys of adequate precision before survey estimates are used to move the recreational sector down a management band.

Publish a triple bottom line assessment of the value returned per kilogram of Snapper and Yellowtail Kingfish by each sector, using the Department’s own commercial economic indicators and the FRDC recreational survey, before the sector shares are finalised.

Fund fisheries compliance from consolidated revenue rather than from the Recreational Fishing Trusts, and redirect the Trust expenditure so freed to the stock assessment, onsite recreational survey and habitat programs that both strategies depend on.

Cost and publicly consider a voluntary structural adjustment program to acquire commercial Snapper and Yellowtail Kingfish entitlement on fair and just terms, and reallocate that catch to the recreational sector, on the model of the Victorian Government’s Port Phillip Bay program.

Extend the closing date for submissions on both draft strategies from 18 October 2026 to 30 March 2027, so that meaningful consultation and engagement with recreational fishers and the recreational fishing industry can actually be undertaken, and so that the Department can report back publicly on what it heard and what it changed.

On that last request, the point is not simply more time to write. The material we ask to be published above does not yet exist in the public domain, and no submitter can respond properly to measures of this magnitude without it. Seven weeks spanning September and October also falls across the start of the peak season, when the fishers, charter operators and retailers most affected are least able to prepare a considered response. The Department extended the consultation period for the Draft Mulloway Harvest Strategy on narrower grounds than these.²⁵

An extension to 30 March 2027 would allow a genuine engagement process rather than a submissions window. AFTA asks that the extended period be used to: release the peer reviews, the recreational catch model and the economic analysis; hold face-to-face sessions in the regions these measures affect most — Port Stephens, the Central Coast, Sydney, the Illawarra and South Coast, and the Mid North and Far North Coast — with recreational fishers, charter operators, tackle retailers and boating businesses; brief the peak bodies on the assessment and the modelling directly, so that the technical basis can be tested rather than merely asserted; and co-design the engagement program with those bodies rather than presenting it to them. AFTA is willing to help convene and host those sessions and to bring our members to them.

We further ask that the Department report back publicly at the end of that process: publishing the submissions, a summary of what was heard at each engagement session, and a statement of which management measures changed, which did not, and why. Consultation that cannot be shown to have changed anything is not consultation, and recreational fishers in New South Wales have learned to read it that way. A visible report back is what would distinguish this process from that expectation.

Working together on a pathway forward

AFTA is not writing to the Department as an opponent of these strategies. We are writing as the recreational fishing industry — an industry that wants a durable settlement for these two fisheries and is prepared to help build it.

We are ready to contribute in practical ways. AFTA can make our members’ retail, charter and boating data available to support a proper economic assessment — data the Department does not hold and cannot readily obtain elsewhere. We can convene and host engagement sessions in the affected regions and bring fishers, charter operators and retailers to them. We can help the Department communicate whatever measures are ultimately adopted, through the tackle trade and through our members’ direct relationships with fishers, which is the channel through which most anglers actually learn the rules. We can assist in designing recreational data collection that fishers will genuinely participate in, rather than a reporting obligation imposed on them. And where the evidence supports a restriction, we will say so publicly and explain it to our members.

What we are asking for in return is straightforward: show us the analysis, share the burden fairly across the sectors, give recreational fishers a published pathway back as the stocks recover, and give us the time and the forum to work through it properly. On that basis AFTA is confident that a management framework can be settled which rebuilds these stocks, protects the marine environment, treats commercial fishers fairly, and sustains the 1.29 million recreational fishers and the thousands of businesses and jobs that depend on them. Those outcomes are not in conflict, and we do not accept that they need to be traded against one another.

Attachment A sets out the questions on which AFTA seeks a response from the Department. Attachment B provides full endnotes and sources for every figure and quotation relied on in this submission; superscript numerals throughout this letter and Attachment A refer to those endnotes. We would welcome the opportunity to meet with you and your harvest strategy team before the strategies are finalised, and we are ready to begin that work immediately.

Yours sincerely

The Hon. Bob Baldwin

Chair

Australian Fishing Trade Association

Attachment A — Questions on notice

Draft NSW Snapper Harvest Strategy and Draft NSW Yellowtail Kingfish Harvest Strategy. AFTA seeks a written response to each of the following.

 

1. Process and the supporting documents

Q1.  Will the Department publish a regulatory impact statement or cost-benefit analysis for each draft strategy, and if not, on what basis was it decided that one is not required for measures of this magnitude?

Q2.  Neither consultation released a management options paper setting out the alternatives considered and rejected, unlike the Mulloway process. Why was that step omitted, and will the options analysis be released before submissions close?

Q3.  Will the Department extend the closing date for submissions on both draft strategies from 18 October 2026 to 30 March 2027, so that meaningful consultation and engagement with recreational fishers and the recreational fishing industry can be undertaken and reported on? Seven weeks spanning September and October covers the start of the peak season, gives affected businesses limited time to quantify impacts, and is insufficient for any submitter to respond to material — the peer reviews, the recreational catch model, the economic analysis — that has not yet been released. The Department extended the consultation period for the Draft Mulloway Harvest Strategy on narrower grounds.

Q4.  Will the Department commit to a program of face-to-face engagement during any extended period, in the regions most affected — Port Stephens, the Central Coast, Sydney, the Illawarra and South Coast, and the Mid North and Far North Coast — with recreational fishers, charter operators, tackle retailers and boating businesses? Will that program be co-designed with the peak recreational and industry bodies rather than presented to them?

Q5.  Will the Department brief the peak recreational fishing and industry bodies directly on the stock assessments and the recreational catch modelling, with the responsible scientists present, so that the technical basis for these measures can be tested rather than asserted?

Q6.  At the conclusion of the process, will the Department publish a report back setting out the submissions received, a summary of what was heard at each engagement session, and a statement of which management measures changed, which did not, and the reasons in each case?

Q7.  What measure of success will the Department apply to this consultation? How will it demonstrate, at the end of the process, that engagement with recreational fishers and the recreational fishing industry was meaningful rather than procedural?

Q8.  Does the Department accept that, without the recreational catch model, the peer reviews and the economic analysis, no external party is in a position to propose alternative bag limits, boat limits or seasonal closure arrangements on an informed basis? If the Department considers that a submitter could do so on the material released, please identify which document supplies the necessary information.

Q9.  Will the consultation summary record accurately that AFTA and other parties were unable to propose alternative limits because the underlying analysis was not released, rather than recording simply that no alternatives were proposed?

Q10.  Will the working group minutes, the Consultative Working Group membership, and any dissenting positions recorded by recreational or industry representatives be published alongside the submissions summary?

2. The stock assessments

Q11.  The Kingfish consultation page states the stock is at approximately 5.5 per cent of unfished biomass at the start of 2025, but the draft strategy itself states no current depletion estimate. What is the point estimate, and what are the confidence intervals around it?

Q12.  For both species, what is the uncertainty range around the depletion estimate, and how sensitive is it to the steepness assumption, natural mortality, and the unfished biomass reference period used in the Stock Synthesis model?

Q13.  Both strategies use standardised commercial CPUE as the secondary indicator. Given long-term changes in fleet structure, effort, targeting behaviour and market conditions, how has the Department satisfied itself that CPUE remains a reliable abundance index, and has a fishery-independent index been evaluated as an alternative?

Q14.  Neither draft addresses post-release or discard mortality. What mortality rate is assumed for released fish in each fishery and sector, is that mortality included in the modelled catch, and if not, why not?

Q15.  What proportion of the estimated decline in each stock is attributed to fishing mortality as against environmental drivers — East Australian Current variability, warming, recruitment failure — and what would the modelled biomass trajectory look like under a recruitment-driven rather than fishing-driven hypothesis?

Q16.  Will the Department publish the model projections showing biomass trajectories under (i) status quo management, (ii) the proposed package, and (iii) at least one alternative package, so that the marginal benefit of each proposed measure can be assessed?

3. Peer review of the stock assessments

Q17.  The Snapper draft states that “the assessment was completed and peer reviewed in 2025” and the Yellowtail Kingfish draft states that “the assessment was completed and peer reviewed in 2026”. Who conducted each peer review? Please name the reviewer or panel members and their institutional affiliations.

Q18.  What were the terms of reference for each peer review, what material was provided to the reviewers, and how much time were they given?

Q19.  Was each peer review independent of the Department? How was that independence assured, were the reviewers engaged and remunerated by the Department, and were any of them involved in developing the assessment they reviewed?

Q20.  Will the peer review reports be published in full? If not, why not, and will they at least be made available to the Consultative Working Group and to peak bodies during this consultation?

Q21.  Both drafts state that peer review “recommendations will be incorporated in current and future assessments”. What recommendations did each reviewer make? Which have been incorporated into the assessment relied upon in these draft strategies, and which have not?

Q22.  For any peer review recommendation not yet incorporated, what is its expected effect on the depletion estimate, the recommended biological catch and the rebuilding timeframe? If the reviewers identified deficiencies that remain unaddressed, why is it appropriate to impose these measures before the assessment is revised?

Q23.  Was the harvest strategy itself — as distinct from the stock assessment — subject to independent review, including the reference points, the harvest control rules, the resource-sharing arrangements and the model converting recreational bag limits into catch? If so, by whom, and will that review be published? If not, will the Department commission one?

Q24.  The NSW Snapper stock assessment is authored by Stewart, J., Fowler, A.M. and Liggins, G. of NSW DPIRD Fisheries (2025). Who authored the NSW Yellowtail Kingfish stock assessment, and were both assessments reviewed by the same reviewer or panel?

Q25.  Both drafts state that the harvest strategy was developed by “a sub-committee of the NSW Commercial Fisheries and Recreational Fishing Advisory Councils, including fishing sector representatives, independent experts, and DPIRD officers”. Who were the members of each sub-committee, which sector did each represent, who were the independent experts, how were they selected, and were the sub-committee’s recommendations unanimous?

4. Reconciling the 2021–22 stock status summaries with these drafts

Q26.  The NSW Stock Status Summary 2021–22 for Yellowtail Kingfish states that “Yellowtail Kingfish are currently assessed as sustainable for the NSW component of the stock”, with a production model estimate of biomass at 26 per cent of carrying capacity, a spawning potential ratio of 22 per cent of unfished, fishing mortality at F/F20 of 0.61, and harvest of 183 tonnes against an estimated maximum sustainable yield of 416 tonnes. The current draft states the stock is at approximately 5.5 per cent of unfished biomass. Please reconcile those two assessments.

Q27.  How much of the difference between 26 per cent and 5.5 per cent is attributable to an actual decline in the stock between 2021–22 and 2025, and how much to the change in assessment method from a weight-of-evidence approach to an integrated age-structured Stock Synthesis model? Please quantify the contribution of each.

Q28.  Yellowtail Kingfish is a long-lived, slow-maturing species. What biological mechanism would allow spawning biomass to fall from 26 per cent of carrying capacity to 5.5 per cent of unfished in three to four years, in a period during which commercial landings fell to 67 tonnes and commercial effort reached a historic low of 2,109 days?

Q29.  If the current Stock Synthesis model were applied retrospectively to data available in 2021–22, what depletion estimate would it produce for that year? If materially below 26 per cent, on what basis was the sustainable classification published in 2023, and has that classification now been formally withdrawn or corrected?

Q30.  The 2021–22 summary records that standardised handlining CPUE increased by approximately 13 per cent between 1997–98 and 2021–22. The draft strategy adopts standardised CPUE as its secondary indicator. How is a rising CPUE series reconciled with a depletion estimate of 5.5 per cent, and what does the standardised CPUE series show through to 2025?

Q31.  The 2021–22 summary cautions that “if the size composition of commercial landings is not representative of size composition of the stock, then mortality estimates (Z & F) will be inflated, and SPR models may produce pessimistic SPR estimates”, and that large fish being less catchable is likely occurring for NSW Yellowtail Kingfish. Does that concern apply equally to the length and age composition data used in the current integrated model, and if so how has it been addressed?

Q32.  The 2021–22 summary states that “much of the spawning stock may be distributed offshore where it is not vulnerable to the NSW coastal fishery”. If that remains the Department’s view, how can a depletion estimate derived largely from NSW coastal fishery data represent the spawning biomass of the Eastern Australia stock, and what proportion of that spawning stock does the NSW assessment actually observe?

Q33.  The 2021–22 summary states that “the data underpinning the analyses presented in this summary were collected from NSW waters only but relate to the assessment of the entire ‘Eastern Australia’ biological stock” — a stock also fished by Queensland, Victoria, Tasmania, South Australia, the Commonwealth Southern and Eastern Scalefish and Shark Fishery, the SPRFMO Convention Area and New Zealand. Does the current assessment rely on NSW-only data for that same multi-jurisdictional stock, and if so why is that appropriate as the basis for NSW-only reductions?

Q34.  Recreational Yellowtail Kingfish harvest is recorded at approximately 219 tonnes in 2000–01, 129 tonnes in 2017–18 and 114 tonnes in 2019–20 — a declining series. The proposed recreational share is 60 tonnes, roughly half the most recent published estimate. Why is a sector whose harvest has been falling for two decades being required to halve it again?

Q35.  The NSW Stock Status Summary 2021–22 for Snapper states that “Snapper is currently assessed as Sustainable for the NSW component of the stock”, with biomass between 0.2 and 0.45 of unfished levels, standardised catch rates stable with a slightly increasing trend since 2014–15, declining commercial effort, and increasing proportions of older fish suggesting “an increasing biomass in recent times”. What has changed since that assessment to justify a 70 per cent reduction in the recreational bag limit?

Q36.  The same summary records recreational Snapper harvest of approximately 160 tonnes in 2019–20. Under Table 4, a recreational catch share of 160 tonnes or more corresponds to a bag and possession limit of six. The draft proposes three, two bands lower. Which recreational catch estimate places the sector in the 114 to under 140 tonne band, from which survey and which year, and why does the most recently published estimate not govern?

Q37.  Will the Department publish a side-by-side reconciliation of the 2021–22 stock status summaries and the current assessments for both species, identifying every change in method, data, model structure and assumption, and quantifying the effect of each on the estimated stock status?

Q38.  The Department published sustainable classifications for both species as recently as 2023, and fishers, charter operators and the tackle trade made investment and business decisions on the strength of them. What assurance can the Department give that the current estimates will not be similarly revised, and what has changed in its assessment governance and peer review arrangements to prevent it?

5. The basis of the recreational catch modelling

Q39.  What is the model that converts a change in the recreational bag limit into a change in recreational catch? Please describe its structure, assumptions and inputs, and publish it.

Q40.  Of the 1,293,700 recreational fishers recorded in NSW and the ACT, what percentage is assumed to fish for, or to catch, Snapper in a given year? What percentage for Yellowtail Kingfish? Please state the number of participating anglers assumed for each species, and the source of that figure.

Q41.  Of those anglers, what is the assumed catch rate per angler for each species — expressed as fish retained per angler per trip, fish released per angler per trip, and fish retained per angler per year? Please state the assumed mean, the median, and the upper percentiles of the distribution, not the mean alone.

Q42.  How has the Department measured recreational catch rates for these species? Please specify the survey instrument and method used — on-site creel or boat-ramp survey, off-site telephone or diary panel, licence-frame recall survey, or app-based reporting — together with the recall period, the sample size, the response rate, how avidity bias and recall bias were corrected, and how catch was raised from the sample to the statewide estimate.

Q43.  What is the confidence interval around the estimated number of Snapper and of Yellowtail Kingfish caught and retained by recreational fishers in NSW? How does the width of that interval compare with the size of the catch reduction the proposed measures are intended to achieve? If the interval is wider than the reduction sought, how will the Department determine whether the measures have worked?

Q44.  The Kingfish draft states that the relationship between bag limits and total catch is non-linear — “a 50% change in bag limits does not achieve a 50% change in catch”. What functional form is used in place of a linear relationship, and what is it fitted to?

Q45.  What is the underlying recreational catch-rate distribution used — fish retained per angler per day, or per boat per trip — and from what data is it derived? Specifically: which survey, which years, what sample size, and does it distinguish targeted from incidental capture?

Q46.  What proportion of NSW recreational anglers currently reach the existing bag limit for each species on a given trip? A bag limit reduction only removes catch from the fishers who reach the limit. Please publish the frequency distribution of daily retained catch per angler for each species.

Q47.  Does the model account for effort response — fishers making more trips, fishing longer, or shifting effort to other species or areas in response to a reduced bag limit? If so, what elasticity is assumed and on what evidence? If not, how can the projected catch reduction be relied upon?

Q48.  Does the model account for the release mortality generated by a lower bag limit? A one-fish limit converts retained fish into released fish. What proportion of those released fish are assumed to survive, and is the resulting mortality added back into the recreational catch share?

Q49.  How was the catch-rate model validated? Has the Department compared its predicted catch reduction against the observed outcome of any previous recreational bag limit change in NSW or another jurisdiction? Please publish that comparison.

Q50.  What is the modelled catch reduction, in tonnes and with uncertainty bounds, attributable separately to each proposed measure: the bag limit change, the boat limit, the charter boat limit, the November to January Kingfish closure, and any size limit change?

Q51.  Is the same modelling standard applied to the commercial sector? Commercial catch will be constrained by quota — a hard, verifiable number. Recreational catch is constrained by a bag limit whose effect is modelled and uncertain. How does the Department ensure that modelling uncertainty on the recreational side does not systematically transfer risk onto recreational fishers?

6. Yellowtail Kingfish

Q52.  The draft states the eastern biological stock spans south-eastern Australia with mixing into the New Zealand stock. On what basis is a NSW-only depletion estimate and a NSW-only harvest limit an appropriate management unit for a stock of that range, and what proportion of the biological stock does the NSW assessment cover?

Q53.  If the stock is at 5.5 per cent of unfished biomass across its range, what fraction of total mortality on that stock is NSW recreational fishing, and what rebuilding benefit is attributable to NSW recreational cuts alone?

Q54.  How was the 120 tonne total harvest limit derived, against recent total catches of around 250 tonnes? What was the objective — a target rebuild date, a probability of reaching Bsp30, or a fixed proportional cut?

Q55.  The consultation page states rebuilding to Bsp20 in around nine years and Bsp30 in around twelve, but the draft strategy states no timeframe. What is the probability of achieving Bsp30 within twelve years under the proposed package, and at what probability threshold would the Department consider the strategy to have failed?

Q56.  What is the modelled catch reduction attributable to the November to January catch-and-release period, and how does that reduction compare to the post-release mortality generated by the same period, given that a catch-and-release season concentrates effort rather than removing it?

Q57.  Was an increase in minimum legal length above 65 cm, or a maximum size or slot limit protecting large spawners, modelled as an alternative to a bag limit of one? If so, what catch reduction did each deliver, and why was the bag limit preferred?

Q58.  What is the modelled effect of the charter boat limit of one on charter trip demand, and was any alternative — a per-person limit on charter vessels, or a charter-specific quota — evaluated?

Q59.  Commercial take is to be zero outside the Line West and Line East sectors, but the recreational sector loses 80 per cent of its bag limit and gains a three-month closure. What analysis demonstrates that this division of the burden is proportionate to each sector’s contribution to fishing mortality?

Q60.  NSW has an established Yellowtail Kingfish aquaculture industry. To what extent does farmed production substitute for wild-caught product in the domestic market, and was a larger reduction in wild commercial take, with correspondingly less restriction on recreational access, modelled on that basis?

Q61.  The draft states that under phase 2 recreational catch will be adjusted “in proportion to changes to the RBC” but provides no equivalent of the Snapper strategy’s Table 4. Will the Department publish a transparent, pre-agreed schedule of recreational limits at each biomass level for Kingfish?

7. Snapper

Q62.  The draft states the NSW portion of the stock is classified “Sustainable” and that biomass has been increasing slowly since the 1990s. What is the justification for a 70 per cent reduction in the recreational bag limit on a stock in that condition?

Q63.  What does the model project for NSW Snapper biomass in 2035 under status quo management? If the stock reaches or approaches Bsp30 by 2035 without the proposed recreational cuts, what is the marginal benefit of those cuts?

Q64.  The Snapper draft states no total harvest limit in tonnes. What is the total harvest limit, and how is a 45 per cent recreational share meaningful without a stated total against which to apply it?

Q65.  Table 4 sets the commencing bag limit at three, corresponding to the 114 to under 140 tonne recreational catch share band. What recreational catch estimate places the sector in that band, from which survey, and what is the coefficient of variation on that estimate?

Q66.  The meta rule treats recreational harvest as compliant within plus or minus 10 per cent of the catch share. If the coefficient of variation on the biennial recreational survey estimate exceeds 10 per cent, the sector can be moved down a management band by survey noise alone. How will the Department prevent survey uncertainty from triggering restrictions?

Q67.  Table 4 steps from a bag limit of three straight to a bag limit of one between the 114 tonne and 85 tonne bands. What is the rationale for a step of that size, and will the Department consider an intermediate step of two?

Q68.  The minimum legal length remains at 30 cm while the bag limit falls by 70 per cent. What length at maturity is assumed for NSW Snapper, and was an increase in minimum legal length modelled as an alternative delivering equivalent or greater spawning biomass benefit at lower cost to participation?

Q69.  Please define “soft slot limit” precisely, including how a fisher and a compliance officer determine whether a second fish over 70 cm has been taken, and how the rule interacts with the boat limit.

Q70.  Interim commercial arrangements permit Snapper retention in Ocean Trawl (15 kg daily), Southern Fish Trawl (30 kg), Estuary General meshing (15 kg) and Lobster (10 kg). What is the estimated discard and discard mortality of undersize Snapper in these methods, is it counted against the commercial share, and how is retaining Snapper as trawl bycatch consistent with rebuilding?

8. Resource sharing and allocation

Q71.  Both strategies lock in sector shares based on commercial data from 2013/14 to 2022/23 and recreational survey data from 2013/14 to 2021/22. Why was catch history over that particular decade, which includes the COVID period and a period of declining commercial effort, chosen as the basis for a durable allocation?

Q72.  For Kingfish, the draft states that historical catches were approximately equal but that recent estimates suggest recreational catch dominates. Does a 50/50 share therefore impose a disproportionate reduction on the recreational sector relative to its recent catch? What percentage reduction is required of each sector to meet its share?

Q73.  Why is allocation based on historical catch volume rather than on value to the NSW community — economic contribution, participation, employment and regional expenditure — as the optimum community benefit objectives of the Fisheries Management Act 1994 would arguably require?²⁶

Q74.  Is the sector share reviewable, and if so on what trigger, on what cycle, and by what process? Is there any mechanism by which the recreational share can increase over time?

Q75.  Will unused catch in one sector be available to the other within a season, or carried forward? If not, why is a share that is not fully taken not reallocated?

9. Value per kilogram and the commercial sector’s contribution

Q76.  What is the Department’s estimate of the total value generated per kilogram of Snapper, and per kilogram of Yellowtail Kingfish, by (a) the commercial sector and (b) the recreational sector — measured as contribution to gross state product, full-time equivalent employment, and regional distribution of that activity?

Q77.  Economic Indicators for the NSW Commercial Fisheries in 2023/24 records commercially landed Snapper at an average beach price of $12.00 per kilogram (156,354 kg, $1.9 million gross value of production) and Yellowtail Kingfish at $14.20 per kilogram (120,760 kg, $1.7 million). Are those the figures the Department relies on for these strategies, and what is the equivalent recreational value per kilogram?

Q78.  The same report records total NSW commercial fisheries gross value of production of $88.2 million, a contribution to gross state product of $267.4 million ($117.0 million direct) and 2,393 full-time equivalent jobs (1,425 direct), on 9,837 tonnes landed. Does the Department accept the derived figures of approximately $27,000 in contribution to gross state product per tonne landed, and approximately one full-time equivalent job for every four tonnes landed? If not, what are the correct figures?

Q79.  What proportion of the commercial sector’s $267.4 million contribution to gross state product, and of its 2,393 full-time equivalent jobs, is attributable to Snapper and Yellowtail Kingfish specifically? Their combined gross value of production of approximately $3.6 million is about four per cent of the state total — is the employment and gross state product share of a similar order?

Q80.  How many commercial fishing businesses, and how many full-time equivalent jobs, depend on Snapper or Yellowtail Kingfish for a material share of their income, and how is that dependence distributed across the 858 active commercial fishing businesses in NSW?

Q81.  Commercial Yellowtail Kingfish landings were 120,760 kg in 2023/24, against a proposed commercial share of 60 tonnes. Has the Department modelled the effect of that reduction on commercial gross value of production, employment and business viability? AFTA asks not out of concern for the commercial sector, which will make its own case, but because if such an analysis exists for a sector worth $1.7 million a year, the absence of any equivalent analysis for a recreational sector worth billions requires explanation.

Q82.  On a full triple bottom line basis — economic contribution, employment, regional distribution, social and health benefit, and ecological footprint per kilogram landed including bycatch, discard mortality and habitat impact — which allocation of a kilogram of Snapper or Yellowtail Kingfish returns the greatest net benefit to New South Wales? If the Department has not undertaken that assessment, on what basis were the 55/45 and 50/50 shares determined to deliver optimum community benefit?

Q83.  Does the Department’s assessment of commercial value account for the proportion of NSW-landed Snapper and Yellowtail Kingfish that is exported or sold outside New South Wales, as against the wholly domestic and largely regional expenditure generated by recreational fishing for the same species?

Q84.  What is the ecological cost per kilogram landed of each sector’s methods — bycatch, discard mortality, and habitat impact — and how does that cost enter the allocation decision?

10. Use of recreational licence revenue, and structural adjustment

Q85.  The Department records that the Recreational Fishing Trusts fund “nine coastal, three coastal mobile squads and six inland Fisheries Officers” to “enhance DPI’s capacity to enforce fisheries rules and regulations”. On what basis is the enforcement of NSW fisheries law — a core function of the state, exercised against commercial operators and unlicensed offenders as well as licence holders — charged to recreational fishers rather than funded from consolidated revenue?

Q86.  What is the annual cost to the Recreational Fishing Trusts of funding Fisheries Officers, and what proportion of total Trust expenditure does it represent?

Q87.  Were the Recreational Fishing Trust expenditure committees asked whether they would prefer that expenditure directed instead to stock assessment, onsite recreational surveys and habitat restoration — the very programs both draft strategies identify as necessary and currently lacking?

Q88.  If compliance were funded from consolidated revenue, what additional recreational data and habitat work could the Trusts fund, and would that materially improve the evidence base for these harvest strategies?

Q89.  Has the Department considered a voluntary structural adjustment program to acquire commercial Snapper and Yellowtail Kingfish entitlement on fair and just terms, and to reallocate that catch to the recreational sector? If so, what was the outcome of that consideration and will the analysis be published? If not, why has it not been considered?

Q90.  The Victorian Government committed up to $27 million under Target One Million to compensate commercial licence holders to exit the Port Phillip Bay net fishery. The Victorian Fisheries Authority records that “33 of 43 licence holders have accepted the compensation package to exit the Port Phillip Bay commercial net fishery in April 2016” and that “these 33 licence holders have caught 87 per cent of the commercial catch of fish targeted by recreational fishers”. Has the Department examined the Victorian program, and what conclusions did it draw about its applicability to NSW?

Q91.  The combined commercial gross value of production for Snapper and Yellowtail Kingfish in NSW is approximately $3.6 million a year. What would a voluntary acquisition of that entitlement on fair and just terms cost, and how does that one-off cost compare with the recurring economic cost to the recreational sector of the restrictions now proposed?

Q92.  Does the Department accept that acquiring commercial entitlement on fair and just terms, with proper compensation rather than confiscation, and reallocating that catch to recreational fishing, is a mechanism capable of maximising the value returned per kilogram of these species to New South Wales? If not, on what analysis is that view based?

Q93.  What legal, policy or share-management impediments exist under the Fisheries Management Act 1994 to a voluntary structural adjustment and reallocation program, and what would be required to implement one?

Q94.  If structural adjustment is not contemplated, what alternative mechanism does the Department propose by which the recreational share can increase over time, given that both strategies fix sector shares on a decade of historical catch?

11. Recreational data, reporting and cost

Q95.  Both strategies rely on biennial recreational surveys for the primary recreational catch estimate. What is the survey design, sample size, coefficient of variation, and the date of the most recent estimate used to set the commencing arrangements?

Q96.  Both strategies foreshadow mandatory near real-time catch reporting for recreational fishers. Is that a policy commitment? What is the proposed mechanism, what compliance rate is assumed, and how will estimates be corrected for non-reporting?

Q97.  What is the estimated cost of building and operating a recreational reporting system, who pays for it, and will it be funded from the Recreational Fishing Trust? If so, was the Trust’s expenditure committee consulted?

Q98.  What proportion of the stock assessment, monitoring and survey work underpinning these strategies has been funded from recreational fishing licence revenue, and how is that investment reflected in the allocation outcome?

Q99.  Will the Department commit to funding onsite recreational surveys at a frequency and precision sufficient to support the Table 4 mechanism before that mechanism is used to further reduce recreational limits?

12. Commercial accountability, so far as it affects the recreational share

Q100.  AFTA raises the following not on behalf of the commercial sector, which has its own representatives, but because commercial catch control determines what remains available to recreational fishers and sets the accountability standard against which recreational fishers are being judged.

Q101.  What is the timeline for ITQ implementation in each fishery, and what management applies in the interim? How will the Department ensure interim monthly and daily catch limits do not result in the commercial share being exceeded before quota commences?

Q102.  Will commercial catch be subject to independent validation — observer coverage, catch documentation, landing verification — proportionate to the near real-time reporting being asked of recreational fishers?

Q103.  What are the consequences, and for whom, if the commercial sector exceeds its share by more than 10 per cent? Is there an overcatch deduction from the following year’s share?

Q104.  Will quota be issued free to existing shareholders? If so, what is the public value transferred, and what return does the NSW community receive for granting exclusive access to a rebuilding public resource?

13. Aboriginal cultural fishing

Q105.  Both strategies state that cultural harvest is accounted for within the total but define no specific share or arrangements. How is cultural harvest estimated, against which sector’s share is it counted, and will it be quantified before the strategies commence?

Q106.  What consultation has occurred with the Aboriginal Fishing Advisory Council on these drafts, and will the outcome be published?

14. Cross-jurisdictional management

Q107.  For Snapper, the objective is to support improved cross-jurisdictional management with Queensland. What specific commitments, timeframes or agreements exist, and what happens to the NSW rebuilding trajectory if Queensland does not reduce catch on the shared stock?

Q108.  For Kingfish, given mixing with the New Zealand stock and a range across south-eastern Australia, what engagement has occurred with Victoria, Queensland, the Commonwealth and New Zealand, and when will an eastern-stock assessment be delivered?

Q109.  If NSW fishers bear substantial reductions and other jurisdictions do not, will the Department revisit the NSW arrangements, and at what point?

15. Economic and social impact

Q110.  The FRDC National Social and Economic Survey of Recreational Fishers records 1,293,700 adult recreational fishers in NSW and the ACT, 10 million fishing days a year, a $4.07 billion contribution to the NSW/ACT economy in 2019–20, and 33,995 full-time equivalent jobs, 14,065 of them in regional NSW. What is the Department’s estimate of the effect of the proposed measures on those figures?

Q111.  Has the Department used the FRDC survey, or any equivalent dataset, in developing these strategies? If not, why not, and will it do so before finalising?

Q112.  Was the tackle and boating retail sector, or the charter sector, consulted or surveyed in developing these measures? If not, will the Department undertake that analysis before finalising?

Q113.  What analysis has been done of the effect of a one-fish Kingfish bag limit on trip motivation, participation and licence uptake, and therefore on the Recreational Fishing Fee revenue that funds the science these strategies depend on?

Q114.  Where two measures deliver an equivalent catch reduction, has the Department applied a least-cost-to-the-community test in choosing between them? If so, please publish that analysis; if not, will the Department commit to applying one?

Q115.  What is the estimated impact on charter operators of a one-fish-per-vessel Kingfish limit, and what transitional or adjustment support is contemplated?

Q116.  Transport for NSW records 586,599 licensed boaters and 250,405 registered recreational vessels in New South Wales, and its NSW Recreational Boater Survey 2023 found that “fishing was by far the most popular main purpose of a boating trip cited by boaters, being more than twice as popular as the next most popular purpose”, with 58 per cent of boaters fishing on their most recent trip. What assessment has the Department made of the effect of these measures on recreational boating participation, vessel registrations, licence renewals and the marine industry that depends on them?

Q117.  Was Transport for NSW, or NSW Maritime, consulted in the development of these drafts, given that fishing is the principal purpose of recreational boating in this State and that boating fees and registrations are a material revenue stream to government?

Q118.  What is the modelled effect of a Yellowtail Kingfish boat limit of one fish per vessel on boat usage, trailer boat sales, charter bookings and marine service businesses? A vessel carrying four anglers would be entitled to a single fish for the trip regardless of distance travelled or cost incurred. Was that outcome intended, and was it assessed?

Q119.  Given that 14,065 of the jobs supported by recreational fishing are in regional NSW, has any regional impact analysis been undertaken for coastal communities where Snapper and Kingfish drive visitation — Port Stephens, the Central Coast, Sydney offshore, Jervis Bay, Batemans Bay and Coffs Harbour?

16. Review, triggers and restoration of access

Q120.  For Kingfish, what specific biomass level, measured how and verified when, restores a recreational bag limit above one, and by how much? Will that schedule be published as a table equivalent to Snapper’s Table 4?

Q121.  The stock assessment runs at least every three years. If it is delayed, the previous RBC rolls over. What guarantees that recreational restrictions are reviewed on schedule rather than persisting by default through assessment delay?

Q122.  Table 4 for Snapper is symmetric on paper, with the bag limit rising to five and six at higher catch shares. What is the process for moving up a band, who decides, and has the Department ever moved a recreational limit upward under an existing harvest strategy?

Q123.  The strategies are subject to consultative review within five years. Will recreational and recreational-industry representation on the review group be guaranteed, and in what proportion?

Q124.  If, after five years, the rebuild is on track and the recreational sector is under its share, will limits be relaxed automatically or only by ministerial decision?

17. Implementation and transition

Q125.  When will the final rules commence, and what notice period will be given? The tackle trade orders stock and charter operators take bookings months in advance. What transition period is contemplated?

Q126.  What compliance and enforcement resourcing accompanies these measures, particularly for a slot limit and a seasonal catch-and-release period that are materially harder to enforce than a simple bag limit?

Q127.  What education and communication program will accompany the changes, and will the Department partner with the tackle trade and charter sector to deliver it?

Attachment B — Endnotes and sources

Every figure and quotation in this submission is drawn from the following publicly available sources. Superscript numerals in the letter and in Attachment A refer to the numbered endnotes below. All sources were accessed on 2 September 2026.

1. The consultation documents
2.  NSW Department of Primary Industries and Regional Development, “Have your say — Draft NSW Snapper Harvest Strategy”, consultation open 1 September 2026, closing 18 October 2026.

https://www.haveyoursay.nsw.gov.au/snapper

Cited for: consultation dates; proposed recreational bag limit of 3 with one over 70 cm; 30 cm minimum legal length; commercial quota and reporting proposals.

2.  NSW DPIRD, Draft NSW Snapper Harvest Strategy (PDF), 2026.

https://www.dpird.nsw.gov.au/__data/assets/pdf_file/0003/1677234/Draft-NSW-Snapper-Harvest-Strategy.pdf

Cited for: SAFS classification of the NSW portion as “Sustainable”; biomass “increasing slowly since the 1990s”; 55/45 commercial/recreational resource share and the 2013/14–2022/23 and 2013/14–2021/22 basis periods; Table 4 recreational catch-share bands and corresponding limits; the ±10 per cent meta rule; the soft slot limit; interim commercial retention limits for Ocean Trawl, Southern Fish Trawl, Estuary General meshing and Lobster; the statement that the assessment “was completed and peer reviewed in 2025”; the description of the developing sub-committee; the cross-jurisdictional objective with Queensland.

3.  NSW DPIRD, “Have your say — Draft NSW Yellowtail Kingfish Harvest Strategy”, consultation open 1 September 2026, closing 18 October 2026.

https://www.haveyoursay.nsw.gov.au/yellowtail-kingfish

Cited for: the statement that the stock is at approximately 5.5 per cent of unfished biomass at the start of 2025; rebuilding to 20 per cent in around 9 years and 30 per cent in around 12 years.

4.  NSW DPIRD, Draft NSW Yellowtail Kingfish Harvest Strategy (PDF), 2026.

https://www.dpird.nsw.gov.au/__data/assets/pdf_file/0011/1677233/Draft-NSW-Yellowtail-Kingfish-Harvest-Strategy.pdf

Cited for: the 120 tonne total harvest limit and 50/50 sector share; reference points Bsp20, Bsp25, Bsp30 and Bsp50; phase 1 and phase 2 decision rules; the one-fish bag, boat and charter boat limits; the November–January catch-and-release period; the 65 cm minimum legal length; the eastern biological stock range and mixing with the New Zealand stock; the statement that “a 50% change in bag limits does not achieve a 50% change in catch”; the statement that the assessment “was completed and peer reviewed in 2026”; the description of the developing sub-committee.

5.  NSW DPIRD, “Open for Comment”, commercial fisheries consultation index.

https://www.dpird.nsw.gov.au/fishing/commercial/open-for-comment

Cited for: confirmation that both consultations close on 18 October 2026.

6.  NSW DPIRD, “Harvest strategy development”, NSW Marine Estate / harvest strategies index.

https://www.dpird.nsw.gov.au/fishing/harvest-strategies

Cited for: the harvest strategy framework and programme context.

1. The stock assessments
2.  Stewart, J., Fowler, A.M. and Liggins, G. (2025), Stock assessment of Snapper (Chrysophrys auratus) in the New South Wales (NSW) region, Australia, NSW DPIRD Fisheries.

Released with the Snapper consultation at haveyoursay.nsw.gov.au/snapper

Cited for: authorship of the Snapper assessment; the Stock Synthesis modelling framework.

8.  NSW DPIRD Fisheries, NSW Yellowtail Kingfish Stock Assessment (PDF), released with the Yellowtail Kingfish consultation.

https://www.haveyoursay.nsw.gov.au/yellowtail-kingfish

Cited for: the integrated age-structured assessment, catch fleets, CPUE indices and length and age composition data.

9.  NSW DPIRD, “Status of Australian Fish Stocks — NSW stock status summary reports”.

https://www.dpird.nsw.gov.au/fishing/fisheries-research/fisheries-resource-assessment/stock-assessment/status-of-australian-fish-stocks-2024

Cited for: the SAFS classification framework referred to in the Snapper draft.

10.  NSW DPI, Stock Status Summary 2021–22 — Yellowtail Kingfish (Seriola lalandi) (PDF), published 2023.

https://www.dpird.nsw.gov.au/__data/assets/pdf_file/0005/1553594/Stock-Status-Summary-2021-22-Yellowtail-Kingfish.pdf

Cited for: the classification that “Yellowtail Kingfish are currently assessed as sustainable for the NSW component of the stock”; the weight-of-evidence method comprising standardised commercial linefishing CPUE, CMSY++ surplus production modelling, spawning potential ratio modelling, catch curve analysis and length composition; biomass at 26 per cent of carrying capacity; SPR at 22 per cent of unfished; F/F20 of 0.61; harvest of 183 tonnes against an estimated MSY of 416 tonnes; standardised handlining CPUE up approximately 13 per cent between 1997–98 and 2021–22; commercial landings falling from 264 tonnes in 2009–10 to 67 tonnes in 2021–22; commercial effort at a historic low of 2,109 days; recreational harvest of approximately 114 tonnes in 2019–20, 129 tonnes in 2017–18 and 219 tonnes in 2000–01; the caution regarding unrepresentative size composition inflating mortality estimates; the statement that “much of the spawning stock may be distributed offshore where it is not vulnerable to the NSW coastal fishery”; and the statement that NSW-only data are used to assess the entire “Eastern Australia” biological stock.

11.  NSW DPI, Stock Status Summary 2021–22 — Snapper (Chrysophrys auratus) (PDF), published 2023.

https://www.dpird.nsw.gov.au/__data/assets/pdf_file/0003/1553034/Stock-Status-Summary-2021-22-Snapper.pdf

Cited for: the classification that “Snapper is currently assessed as Sustainable for the NSW component of the stock”; biomass between 0.2 and 0.45 of unfished levels (Wortmann et al., 2018); standardised catch rates stable with a slightly increasing trend since 2014–15; declining commercial effort from approximately 5,000 to fewer than 3,000 fish trapping days annually between 2009–10 and 2021–22; increasing proportions of older fish suggesting “an increasing biomass in recent times”; commercial catch of approximately 180 tonnes; charter catch of approximately 18 tonnes; and recreational harvest of approximately 160 tonnes in 2019–20.

12.  Hughes, J.M. and Stewart, J. (2020), NSW Stock Status Summary — Yellowtail Kingfish (Seriola lalandi), NSW Department of Primary Industries (2018/19 assessment year).

https://www.dpi.nsw.gov.au/__data/assets/pdf_file/0010/1329571/stock-status-summary-2021-yellowtail-kingfish.pdf

Cited for: the earlier “Sustainable” classification for the NSW component of the stock; the weight-of-evidence method including CMSY with Bayesian state-space Schaefer surplus production modelling; the 20 per cent limit reference level; commercial landings of 76 tonnes in 2018/19 and recreational harvest of approximately 129 tonnes in 2017/18; the statement that the approach “reveals considerable uncertainty due largely to the lack of data on size composition from historical landings, the recreational harvest, and the population dynamics of the stock”; and the Eastern Australia stock structure and cross-jurisdictional movements.

1. The recreational sector: participation and economic contribution
2.  Moore, A., Schirmer, J., Magnusson, A., Keller, K., Hinten, G., Cameron, S., Wright, D., Sahlqvist, P., Ruello, N., Vieira, S. and Hone, P. (2023), National Social and Economic Survey of Recreational Fishers 2018–2021, Fisheries Research and Development Corporation Project 2018-161, ABARES / University of Canberra, February 2023.

https://www.frdc.com.au/project/2018-161

Cited for: the national figures: 4.2 million Australian recreational fishers, one in five adults, over $11 billion contributed and more than 100,000 jobs supported.

14.  Fisheries Research and Development Corporation, Social and Economic Survey of Recreational Fishers 2018–2021: New South Wales and ACT (PDF), July 2023.

https://www.frdc.com.au/sites/default/files/2023-07/nsw_act_rec_fishing_survey_-_web.pdf

Cited for: the NSW/ACT figures: 1,293,700 adult recreational fishers; 19.6 per cent participation; 10 million fishing days a year; $4.07 billion contributed to the NSW/ACT economy in 2019–20; 33,995 full-time equivalent jobs (12,378 direct, 21,617 flow-on); and the regional distribution of $2.41 billion and 18,428 jobs in Greater Sydney, $1.47 billion and 14,065 jobs in regional NSW, and $190 million and 1,502 jobs in the ACT.

15.  FRDC, National Recreational Fishing Survey programme page and state report index.

https://www.frdc.com.au/about-recreational-fishing/nrfs

Cited for: the survey programme and the state and territory report series.

16.  Transport for NSW, “Boating fees at work”, NSW Maritime.

https://www.transport.nsw.gov.au/operations/roads-and-waterways/waterways/commercial-vessels/boating-fees-at-work

Cited for: the figures of 586,599 licensed boaters in NSW (including personal watercraft riders) and 250,405 boat and personal watercraft registration holders, over the 2019–2021 period.

17.  Transport for NSW, NSW Recreational Boater Survey 2023 (Ref 6612, August 2023), prepared by Taverner Research Group; Boater Participation Survey of 3,000 NSW households, fieldwork February–May 2023.

https://www.transport.nsw.gov.au/system/files/media/documents/2023/NSW-Recreational-Boater-Survey_2023.pdf

Cited for: the finding that “fishing was by far the most popular main purpose of a boating trip cited by boaters, being more than twice as popular as the next most popular purpose: cruising/sightseeing”; that 58 per cent of most recent boating trips involved fishing; that 22 per cent of NSW residents reported that they or a household member had spent time in a recreational boat or watercraft on NSW waterways over the survey period; and the estimate that between 1.70 million and 1.85 million NSW residents spent time in recreational boats or other watercraft during that period.

1. The commercial sector: value, employment and contribution
2.  NSW DPIRD, Economic Indicators for the NSW Commercial Fisheries in 2023/24 (PDF).

https://www.dpird.nsw.gov.au/__data/assets/pdf_file/0005/1660730/NSW-Economic-Indicators-FY24.pdf

Cited for: total commercial catch of 9,837 tonnes and $88.2 million gross value of production at beach price; total contribution to gross state product of $267.4 million, $117.0 million of it direct; 2,393 full-time equivalent jobs, 1,425 of them direct; 858 active commercial fishing businesses; commercially landed Snapper of 156,354 kg at $12.00 per kilogram generating $1.9 million; and commercially landed Yellowtail Kingfish of 120,760 kg at $14.20 per kilogram generating $1.7 million. The derived figures of approximately $27,000 in contribution to gross state product per tonne landed, and approximately one full-time equivalent job per four tonnes landed, are AFTA calculations from this source.

1. Recreational licence revenue and its uses
2.  NSW DPIRD, “Fisheries Officers”, Recreational Fishing Trust annual report — priority access.

https://www.dpi.nsw.gov.au/fishing/recreational/recreational-fishing-fee/rft-annual-report/priority-access/fisheries-officers

Cited for: the statement that the Recreational Fishing Trusts fund “nine coastal, three coastal mobile squads and six inland Fisheries Officers” in order to “enhance DPI’s capacity to enforce fisheries rules and regulations”.

20.  NSW DPIRD, “Recreational fishing fee” and “Licence fees at work”; Recreational Fishing Saltwater and Freshwater Trust Expenditure Committees.

https://www.dpird.nsw.gov.au/fishing/recreational/recreational-fishing-fee

Cited for: the structure and governance of the Recreational Fishing Trusts and their expenditure committees.

1. The Victorian precedent
2.  Victorian Fisheries Authority, “The nets are coming out of the bay”, Target One Million.

https://vfa.vic.gov.au/recreational-fishing/go-fishing-victoria/target-one-million/pulling-nets-out-of-the-bay

Cited for: the quotations that “33 of 43 licence holders have accepted the compensation package to exit the Port Phillip Bay commercial net fishery in April 2016”; that “these 33 licence holders have caught 87 per cent of the commercial catch of fish targeted by recreational fishers”; that “removing commercial netting from the bay is a key commitment of the State Government’s Target One Million plan for recreational fishing, which aims to get more people fishing, more often”; the phase-out timeline; and the description of the remaining non-net fishery as “using mainly longlines for snapper”.

22.  Premier of Victoria, “Labor Government To End Netting In Port Phillip Bay”, media release, 22 October 2015 (the Hon. Jaala Pulford MP, Minister for Agriculture).

https://www.premier.vic.gov.au/labor-government-end-netting-port-phillip-bay

Cited for: the commitment of up to $27 million in compensation; first-year payments ranging from “$350,000 up to $1.6 million, depending on catch histories”; 43 commercial licence holders; the seven-year phase-out to 2022 and the Corio Bay closure by 1 April 2018; and the statement that “the removal of netting will increase catch rates and the size of fish for recreational anglers”.

23.  Victorian Fisheries Authority, “Bays and inlet fisheries”.

https://vfa.vic.gov.au/commercial-fishing/commercial-fisheries/bays-and-inlet-fisheries

Cited for: the phase-out of commercial netting in Western Port in 2009, the Gippsland Lakes in 2020 and Port Phillip Bay in 2022.

1. Consultation precedent
2.  NSW DPIRD, “Have your say — Draft NSW Mulloway Harvest Strategy and management options”.

https://www.dpi.nsw.gov.au/fishing/harvest-strategies/have-your-say-draft-nsw-mulloway-harvest-strategy-and-management-options

Cited for: the precedent of releasing a draft harvest strategy together with a management options paper.

25.  NSW DPIRD, “Fishers encouraged to have their say on Draft Mulloway Harvest Strategy as consultation period extended”, media release, 2025.

https://www.dpi.nsw.gov.au/about-us/media-centre/releases/2025/general/fishers-encouraged-to-have-their-say-on-draft-mulloway-harvest-strategy-as-consultation-period-extended

Cited for: the precedent of extending a harvest strategy consultation period.

1. Legislation
2.  Fisheries Management Act 1994 (NSW), in particular the objects of the Act relating to the sharing of fisheries resources and optimum community benefit.

https://legislation.nsw.gov.au/view/html/inforce/current/act-1994-038

Cited for: the statutory basis for AFTA’s submissions on resource sharing, allocation and community benefit.

 

AFTA is happy to supply copies of any of the above on request. Where this submission derives a figure by calculation rather than quoting it directly — principally the per-tonne contribution to gross state product and the per-tonne employment figures at endnote 18 — the derivation is stated in the text and the underlying figures are the Department’s own.