Australian Anglers Association, (WA Division) Inc.

Comments on West Coast and Gascoyne Recreational Fishing Reviews

These commments were prepared using some input from beach clubs' and boat clubs' submissions, and existing AAA policies, in response to the West Coast and Gascoyne Recreational Fishing Reviews which were released for further public comments in late 2001.

27th November 2001
The Honourable Kim Chance, MLC,
Minister for Agriculture, Forestry and Fisheries
Recreational Fishing Regional Reviews
Locked Bag 39, Cloisters Square Post Office.
Perth WA 6850

Dear Minister,

SUBJECT: Response to Fishery Management Papers 153 & 154

Please find attached the submission from the Australian Anglers Association (WA Division) lncorporated in response to: "Recreational Fishing Management Strategy for the Gascoyne" (Paper No. 154) and Recreational Fishing Management Strategy for the West Coast" (Paper No. 153).

As you are aware the Australian Anglers Association represents 6,000 shore and boat recreational fishers. Whilst the Association agrees with the principles of the management plans, it is felt that it is of paramount importance to "Get the Balance Right".

We are in support of the main themes expressed in both papers (153 & 154) "the need to manage all impacts on fish resources" and "recreational fishing cannot be considered in isolation from commercial fishing, aquaculture, Aboriginal interests and the creation of marine reserves".

It is with this theme that we submit the following responses.

1. The Need for Integrated Fisheries Management

We are strongly opposed to any changes as described in papers 153 & 154, for Recreational Fishing, until a suitable Integrated Fishery Management strategy has been developed and presented for public review.


If Commercial fishing is not managed at the same time, fish not caught by Recreational Fishers may be caught by Commercial fishers and there will be no overall benefits or gains to be made to the preservation of fish stocks.

Putting management measures into place for only one sector of fishing can be construed as discriminatory and does not provide the holistic approach that is required.


Develop an Integrated Fisheries Management Strategy to find the correct balance to the issues.

Introduce a management plan on commercial fishing as soon as possible.

Introduce both recreational and commercial management plans at the same time.

2. Possession Limits (Strategy G8 Paper No.154)

Within the Association, there is some support for possession limits. However, the majority of members oppose the introduction of any possession limits until they are made fully aware of the management proposals for the professional sector.

Possession limits need to be defined and provide more specific detail. It is not at all clear what is meant by the term "possession limits". While a person is on the beach, or on the water, or travelling on the road, then these possession limits are clear. However what is not clear is whether these limits are intended also to apply to places of residence, for instance. There needs to be some commonsense latitude in the definition and application of the proposed requirement.

The limits allow options which include I or 2 day's bag limit of "whole" fish, but many people remove the heads and tails from their fish where this is allowed by Strategy W7, and these should still be classed as "whole" fish.

Similarly, not many people have an icebox which can hold a legal sized (900mm) or bigger spanish mackerel in one piece, and so, for the sake of storage and transport, may cut it in half. It would be most unfair and inequitable if a spanish mackerel or other large fish was then suddenly considered "fillets" if cut in half. These pieces could still clearly be identified as coming from one fish, and that definition then places the owner over the suggested possession limits.

These possession limits will then directly impact on those recreational anglers who go to great lengths in travel and expenses to enjoy one or two good trips per year and it is felt that they would be unjustly disadvantaged by the inclusion of this regulation.

3. Changes to Legal Fishing Gear (Strategy G12)

The Association is strongly opposed to the statement: "recreational fishers must be within 10 metres of any line which is being fished" for all situations. For shore based anglers, the Association feels that a limit of 30 metres would be a more realistic limit.

4. Facts and Statistics.

A number of facts and statistics have been stated in papers 153 and 154, which have not been clearly defined or substantiated for accuracy. The Association questions the 10 million fishing days per 365 days per year.

This equates to 27,400 recreational fishers fishing on every day of the year on average. One would have to doubt that figure when one can travel a fair bit of the metro area and not see more than a few thousand people fishing (if that) even on busy days, and very few fishing on many days.

What is the definition of "one angler day". How was this derived?

5. Further Recommendations

The following are further recommendations for consideration:

Management plans for commercial fishing, should include control of captures of juvenile and undersize fish.

Retain certain specific species of fish for recreational angling only. Species in included in this "recreational only" category would include, species such as tailor, herring, mulloway and salmon. All of these species have or hold a minimal or low commercial value.

Strategy WI. This category includes prized fish such as Dhufish, Baldchin Groper/Tuskfish and Pink Snapper. The Association does not agree with a mixed bag limit of 7 fish. It is felt that there should be a mixed bag limit of 10 fish.

The Association believes that the individual species limit should be 4 of any one of the above fish. The reasoning behind this proposal is that due to constraints such as cost, weather and other family commitments association and club anglers generally only fish on average, 12 times per annum.

Whilst we do not reach the current bag limits on many occasions we feel that the reduction of 50% for these prized fish in particular negates the ability to have that exceptional fishing day on the beach or in the boat

Species capture limitations in the form of Bag Limits are designed to be restrictors to sustain the species and not targets to be fished for.

Strategy W2. (King George Whiting)

The Association believes that there is no scientific justification for the slot limit for King George Whiting. It is felt that this should be removed.

Anecdotal evidence received from Association members fishing from boats offshore between Rottnest and Guilderton indicates that they rarely catch King George Whiting that are less than 350mm in length.

The Association believes that a bag limit of 8 King George Whiting with no slot limit would be more equitable for offshore boating anglers.

Strategy W2. (Alteration to regulations for tailor) The Association strongly disagrees with the proposal to increase the minimum size for tailor to 300mm. We feel that it should be left at 250 mm following the successful public education program relating to this species that appears to have been well received and implemented.

Again from our members anecdotal evidence it would seem that this species rarely grows larger than 250mm in river systems and estuaries. Fish of this size are already hard to catch in the Swan estuary during the summer. Raising the limit to 300 mm will seriously affect the quality of recreational fishing.

Consideration needs to be given to those members of the recreational angling community such as children, families and disabled people who can and do use the jetties and shorelines in the river when fishing for this species because they cannot cope with prevailing ocean conditions, hoping to catch a tailor above this size. As such, we see this change is inequitable and unfair.

The slot limits for Tailor are unsuitable, as Tailor often school in common sizes in any one area, meaning that if 2 fish are caught over 50cm it is most likely that any others may be similar in size.

Strategy W2 (Uniformity of size limits)

The Association supports uniformity of rules across the State. We also recognise the need for special limits where specific situations occur.

A comparison, species by species, and category by category of the proposed limits for Gascoyne and West Coast shows some significant differences between the two regions in minimum and maximum sizes, bag limits and slot limits, and placement of fish in categories.

These are not logical and cannot be supported, and will make understanding of and compliance with the proposed rules much more difficult.

Strategy W2. (Black Bream)

The Association strongly disagrees with the proposed reduction of the bag limit to 4 in the West Coast Region. Currently this is 8 in the Swan and Canning Rivers and 20 elsewhere. The Association feels that the reduction from 20 to 4 is much too severe.

The black bream fishery is in excellent health in the Swan and Canning River. Anecdotal evidence from association members and from the recreational fishing press indicate that the fishery is in good health. No evidence to the contrary has been presented to support the notion that the stocks of this popular angling species are at risk at present. The Association therefore feels that a reduction in bag limits from 8 to 4 in the Swan and Canning Rivers is not only unjust but also unsustainable.

The Association proposes that the limit should be made 8 State wide. When coupled with the introduction of the slot limit of only two fish over 40cm, breeding stock would have a considerable degree of protection, compared to the current limits, This will then enhance the fishery and ensure sustainability.

Black bream is a species which has had extensive aquaculture research conducted on it here in Western Australia and this research has shown that it can be easily bred and restocked into specific locations using breeding stocks obtained from those locations to retain the local genetic uniqueness of the species. This can be done on an 'as needs' basis for each locality and the association would support and assist in any such program as and when it was required.

Strategies W2/W3. (Pike and Snook in West Coast Review) The proposal to alter the size limit to 300 mm for both these species is not supported by the Association. Snook is a large species and the current limit of 330 mm is appropriate, if not actually too small.

Pike is a small species and it is felt that the current limit of 280 mm is appropriate. Indeed, during the summer, small pike are common and many are below the current limit of 280 mm, yet carry roe, showing that they have already reached breeding age at that size. Increasing this size limit to 300 mm will make it difficult to catch legal sized pike.

One further reason given for these proposed changes is that the general public has difficulty distinguishing between pike and snook, so it is easier to have a common size limit.

It should be noted however that pike is a category 3 fish with no individual bag limit within the forty allowed, and snook is a category 2 fish with an individual bag limit of 8.

Because of this the general public may need to be able to distinguish each species, therefore a publicity and education program should be implemented to ensure that fishers may distinguish them. This cannot be used as justification for having the same size limit.

Strategy W4. Mud Crabs in West Coast Region.

Mud crabs have appeared in several estuaries in the West Coast region during the past year. Since there are no size or bag limits proposed within either of the proposals, the Association is of the opinion that they should be standardised across the state and be included in the management plan for the region.

The Association feels that this naturally occurring and potentially valuable recreational fishery should be closely managed in early formative years to ensure that it is not wiped out by uncontrolled catches from either recreational or commercial fisheries.

Strategy W12. Set and Haul Netting.

The Association has in place a documented policy which does not support recreational set or haul netting in estuaries throughout WA, because it is felt that the estuaries are vital nursery and breeding areas which require protection.

The Association feels that small throw nets should be permitted for the gathering of small quantities of bait for immediate use in defined places in estuaries, even if these are closed to other forms of netting. (Please also refer to our later comments on compliance.)

Strategy W13. Prawn Drag Nets. The term "adjoining" in "adjoining nature reserves" needs to be defined before the impact can be assessed.

Does this mean 10 metres, 50 metres or 500 metres?

Strategy W15. Fishing Competitions. The organisers of fishing competitions simply cannot comply with some of these requirements. An organiser can record the numbers who register, and the fish actually presented for weigh in, but has NO control over the results offered from the public about fish caught and released, or caught and not presented, and cannot compel a competitor to accurately record catch and effort. Any survey conducted from these records may be inaccurate, invalid and totally misleading.

The Association considers these rules should only be applied to commercial organisations using recreational fishing as an advertising or promotional venture.

Recommendations 22 to 24. Education and Monitoring. Changes to possession and bag limits will not mean anything unless the public is educated on an ongoing basis, and the limits are enforced sensibly. Non-compliance is a social problem wherever people do not respect the rules, and there is a limit to what individuals can do when they see breaches occurring. A reporting system is of little value unless it has effective follow up.

The Association believes a combination of education and enforcement should be used so that those who blatantly don't comply will face a high chance of being caught, and will pay a price which is high enough that it makes them and others do the right thing in future. The fact that there will always be some people who will not comply, despite all the publicity and education, should never be used as an excuse to limit catches by the majority of people who will do the right thing.

6. Impacts

If these changes were introduced, have the following impacts been considered?

As recreational fishing has been highlighted as a significant community activity (claimed to be 600,000 recreational fishers or approximately 37% of WA Population, what are the social implication of the changes?

As recreational fishing is considered recreational and therapeutic for the participants, what are the "well being" implications?

What are the revenue implications for the flow-on effect of recreational fishing in the community? For example the fishing tackle supply chain, the tourism industry, bait suppliers, camping suppliers, boating and motor vehicle industries.

Thank you for the opportunity to respond to the recommendations. As discussed at our recent meeting with you, we are prepared to assist you in any way in establishing management of our fishing resources for a sustainable future for the benefit of all WA residents.

Yours faithfully,

Australian Angler's Association WA Division

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This page last updated 10 February 2003.