Ecofishers B&S Submission

Ecofishers “The Voice of the Recreational Fishers” represents fishing interests of over 6000 financial members and countless followers.

The feeling of our members is the Review of NSW Recreational Fishing Rules is at best a very sloppy attempt at fisheries management and at worst an attempt to introduce Marine Parks by stealth.

The complete lack of scientific detail is extremely disappointing coming from a Minister and a Government that has repeatedly stated that all future decisions regarding fishing will be based on scientific evidence.

The first paragraph of Section 1.1 says it all “The latest scientific surveys indicate that the bag limits for these commonly caught species are rarely reached by most recreational fishers (less than 1% of fishing trips.” If the limit is only reached on 1% of trips, then why the reduction – it makes no practical difference to the number of fish actually caught, but effectively penalises the odd lucky group who do catch more – this is nonsense science!

This item alone would indicate that recreational fishing under the current bag limits is having zero impact on fish stocks.

“Community concerns” that current bag limits are excessive has been quoted as the reason these reductions should be considered.

It is our assertion that many of these community concerns are not bona fide concerns of the general public or of recreational fishers but a well-orchestrated campaign by some green groups determined to stop all fishing.

ECOfishers would like to take this opportunity to propose that “ALL” recreational fishers be licenced including pensioners and indigenous whether they are required to pay licence fees or not as happens with drivers licences.

The bona fides of a correspondent can be verified by having to quote their licence number.

Additionally, identification needs such as marking gear like crab traps etc. would be simplified by only having to mark them with a licence number.  

The lack of science is patently obvious by the fact that coincidently the proposed bag limit of every species is exactly half the current figures and when that results in a fraction the number is rounded down.

We who are completing this submission paper are required to consider and comment on each species individually, something which the authors did not do themselves. There seems to be no account taken for the natural ebb and flow of the population of species, seasonal peaks and troughs or the accidental by-catch of juvenile fish due to some unsustainable commercial fishing practices such as estuary netting and beach hauling.

DPI Fisheries have proven to be very poor communicators. New rules and other initiatives come and go and aside from a press release that may or may not be broadcast the average fisher is unaware there has been any change.

This review of bag and size limits is the most important proposal of change that will affect every fisher for years to come and yet the majority of rec fishers don’t even know it is on. Surely this is one occasion when a direct mailing to every licence holder would have been appropriate.

Another example of poor communication is there are very few rec fishers who are aware that daily bag limits in NSW for saltwater fish are also “possession“ limits. This means that catching 20 flathead a day technically is not allowed under current regulations.

 

In the context of managing fish stocks we believe the netting of estuaries and beaches needs to be looked at as a matter of urgency.

While it may be true that 30 Recreational Fishing Havens have been created through the buy out of commercial fishers using rec fishing licence fees, the reality is that many of the commercial operators have simply moved their operations to other areas causing much greater fishing pressure on those areas where this type of activity is still allowed.

It is of concern to us that when species such as Bream, Blackfish and Mullet are on their spawning runs these commercial fishers move along the coast to keep up with the travelling schools of fish.

In addition to this we have commercial fishers from Queensland come down to cash in creating a situation that by the time these schools of fish reach the Mid North Coast of NSW we have seemingly dozens of separate commercial operations netting everything in sight. This practice of border hopping by the Queenslanders is not reciprocal in that NSW fishers are not permitted to work north of the border.

Not only does river netting and beach hauling decimate the target species locally, the horrendous bycatch of undersize and fingerlings that are dumped also restricts the numbers of future generations.

The fact that these species come back year after year is testament to the ability of these popular species to recover but other species such as juvenile Mulloway are made to suffer.

We offer these suggestions:

1. A buy out is exactly that. There should be no provision for a fisher who has sold his business to Fisheries for that operator to be able to take over a redundant licence and start operations all over again.

2. A commercial operation licenced in one area should be confined to fishing in that area only. No other form of farming allows for moving to another area in times of drought or flood.

3. If it is deemed that a certain amount of undersize bycatch is inevitable and needs to be disposed of, there should be systems in place whereby this resource can be used either as pet food or even food for the disadvantaged people. This also should apply to the vast quantities of mullet that are dumped because their roe is the only thing these fishers are after.

COMMENTS RE INDIVIDUAL SPECIES.

To be read in association with details under subtitles in the discussion paper.

Section 1.1

So called community concerns are unverifiable, unwarranted, uninformed and quite possibly made by people unfriendly to rec fishing.

Section 1.2

Dusky flathead

Most of the damage done to this species is by commercial netting. Restricting black marketing is a compliance issue not a stock management issue.

Snapper

There is no evidence of a decline in Snapper numbers in NSW so there is no need to blindly follow QLDs example.

Mahi Mahi

A fairer sharing of the catch of this species is nonsense. Anyone who wants to catch Dolphin Fish can. DPI’s own scientific research shows that the Mahi Mahi is the fastest growing fish in the ocean “growing at a rate of 1 cm in length daily” and also that they are one of the most prolific species, but then your discussion paper goes off and states that “CURRENTLY THERE IS LITTLE OR NO SCIENTIFIC JUSTIFICATION FOR THEIR SIZE LIMIT REDUCTION”.  It’s a contradiction in your own words. Your only justification is to “simplify the fishing rules”. Well, if it’s not broke then don’t fix it, that’s what’s called “simplifying things”. If Fisheries were truly concerned about stocks of this species then why are they putting FADs out there to attract them? Yet another contradiction.

Section 1.3 Yellowtail Kingfish

Black market is a compliance issue. What happens in QLD is irrelevant. Since commercial trapping was stopped in NSW this species continues to increase in numbers.

Cobia

Again QLD is irrelevant. On a charter boat containing 10 people or more 2 cobia for each person may seem adequate but not for a rec fishing boat.

Deep sea species

There is no evidence of a decline in numbers of these species even accounting for improvements in fishing gear and methods. Illegal trade is a compliance issue.

Spanish Mackerel

There is no evidence of a decline in numbers of these species. These species are seasonal visitors to NSW waters and as such nature restricts available catches. Very few people in NSW have ever caught anywhere near the stated maximum size and weight. Wahoo.

Quoting the maximum possible size and weight does not offer any reason to reduce bag limits.

Mangrove Jack

If as stated these are a popular catch and release species then why would there be a need for a bag reduction when there is no evidence of a decline in numbers.

Teraglin

Not long ago you were lucky to find a trag now they are almost a pest. The recreational catch may be greater than commercial catch but only because of lack of market value.

Section 1.4

Tunas

Making paperwork simpler for Fisheries is not a valid reason for reducing bag limits.

Billfish

The socio economic effect on local communities could be profound if these billfish options were brought in. The few people who fish for these species tend to spend a lot of money doing it.

Sharks and Rays

The precautionary principle is a valid argument for commercial fishers who actively target these species. Recreational fishers don’t tend to target shark and rays and when they do accidently catch them they are released.

Section 1.5 Miscellaneous bag limit options

The daily bag limit for saltwater species is also the possession limit therefore it is ridiculous to suggest a total bag limit of 20 across all species.

4. Recreational fishing gear and methods

Marking of set fishing gear

All recreational fishers should be licenced including pensioners and indigenous and simply display licence number. The current proposal to force rec-fishers to publically demonstrate their ‘Name’, ‘Post Code’ and their ‘Date of Birth’ on floats is a violation of privacy and in the wrong hands could easily lead to un-limited forms of identity fraud and/or even home related crime. This is an outrageous proposal quite clearly suggested without the slightest degree of thought or common sense.

Transhipping of fish

The black marketing of fish is a compliance/criminal law issue not a rec-fishing issue. It is stated this will affect very few rec-fishers so why bother with it.

In conclusion, it is the firm opinion of ECOfishers and its members that the paper should be shredded and started all over again, if indeed it’s necessary to introduce reduced bag limits in the first place, and if so, it should be conducted in a transparent manner involving acceptable independent research with the addition of ‘OPEN’ community consultation.

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