Department o f Pr imary Industr ies , Parks , Water and

Env i ronment

Wi ld F i sher ies Management Branch

Report to the Minister on the proposed alterations to the Rock Lobster Management Plans

September 2015

This report on the public consultation process and representations received under section 54 of the Living Marine Resources Management Act 1995 contributing to alterations to the Rock Lobster Fishery Management Plan (the Fisheries (Rock Lobster) Rules 2011 has been prepared by the Department of Primary Industries, Parks, Water and Environment in accordance with section 55 (1) of the Act . Robert Gott Director (Marine Resources) (Delegated authority under section 20 (2) of the Act) September 2015

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Introduction Tasmania’s marine fisheries are managed under the Living Marine Resources Management Act 1995 (the Act). The Act allows for management plans to be made for fisheries and requires that they are reviewed periodically. This review is for the current management plan for the Tasmanian rock lobster fishery, namely the Fisheries (Rock Lobster) Rules 2011. The Act specifies a number of steps to be followed when altering a management plan. After the Minister approves an alteration to a management plan recommended by the Secretary, the Secretary by public notice must notify that the management plan is to be altered and that written representations may be submitted in relation to any proposed alteration. The period during which representations may be made is at least 30 days from the date on which the notice is first published. The Secretary must forward to the Minister a report containing a summary of the consultation process and each representation received. Finally, the Secretary must make a recommendation as to whether the management plan should be altered. These amendments relate primarily to the management of the Eastern Region Non-Commercial (Recreational and Aboriginal) Rock Lobster Fishery to support the East Coast stock rebuilding strategy. In addition, amendment is proposed to the boat limit for non-commercial fishers in the Western Region. The Department submitted the proposed changes to the rock lobster management plan for assessment by the Department of Treasury and Finance’s Economic Reform Unit (ERU). The proposed rule changes to the Rock Lobster Fishery Management Plan were assessed by the ERU and it was determined that the changes were not a significant cost or burden on any sector of the public. The draft amendments to the Rock Lobster Fishery Management Plan and a review information paper were released for public comment on 5 August 2015. Public notices notifying the public of the review and the submission process were published in the Tasmanian Government Gazette and in major Tasmanian newspapers on Wednesday 5 August 2015. Information about the Review was disseminated through social media including an email newsletter and the DPIPWE Wild Fisheries facebook page. Copies of the draft amendment rules, review information paper and an on-line response form were made available on the Department’s web page and the licensing counter on the first floor of the Marine Board Building. Responses to the proposed amendments closed on 3 September 2015, which complied with the statutory requirement that alteration to management plans be publicly exhibited for at least one month. A total of 271 representations were received during the public comment period. Submissions were received from the relevant peak bodies, namely the Tasmanian Rock Lobster Fishermen’s Association (TRLFA) and Tasmanian Association for Recreational Fishing (TARFish). The Tasmanian Conservation Trust (TCT) was the only other organisation that made a submission. Copies of these submissions can be found at the back of this document. Submissions were received from 262 recreational fishers and four who

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stated they were commercial fishers. The majority of respondents used the Department’s online response form to indicate support or disagreement and to provide comment. The submissions were considered by the Department, the Recreational Fishery Advisory Committee (RecFAC) and the Crustacean Fishery Advisory Committee (CFAC). For each of the proposed amendments, the position of the Department in light of the submissions and the views of the Fishery Advisory Committees (FAC’s) were determined. The Department’s and the FAC recommendations and the outcome of the consultation process are detailed in the first section of the report. The responses and key comments to each of the management proposals are shown in the appendix. The consultation process is not considered a ‘vote’ or ‘poll’, however, the strength and diversity of views are considered - as is the rationale for the proposal and representations made. Information and data is provided for this purpose providing the basic level of support/opposition together with written comments. The purpose of this document is to provide a summary of the views detailing an analysis of the responses and the major themes and the FAC recommendations. The Department provides a discussion and outline of the issues and a final recommendation.

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Proposed changes to the Rock Lobster Management Plan following consideration of representations INTENT The intent is to implement a package of management actions that assist to constrain the recreational catch on the East Coast by limiting fishing activity in order to maintain the integrity of the East Coast Stock Rebuilding Strategy, and specifically, the integrity of the 200 tonne annual catch limit. In addition, as the fishery management plan was being amended, it was proposed to also address the issue of the extended boat limit for non-commercial fishers on the West Coast.

Amendments to Catch Limits and Season for the Eastern Region

A package of management actions were proposed for the non-commercial fishery (recreational and Aboriginal) in the Eastern Region (the Eastern Region is waters and islands east of Port Sorell to Whale Head). The management proposals and number of respondents and level of support are as follows:

1. Reduce the daily bag limit from 3 to 2 rock lobsters in the Eastern Region.

123 (45.4%) respondents support, 129 (47.6%) do not support.

2. Reduce the Eastern Region possession limit from 6 to 4 lobsters (this possession limit applies ‘on-water’ and also applies on land for all islands within the Eastern region. It does not apply on land to mainland Tasmania).

119 (43.9%) respondents support, 131 (48.3%) do not support.

3. Reduce the maximum boat catch limit in the Eastern Region from 15 to 8 rock lobsters irrespective of the number of days fished. This will also remove the extended boat limit trip provision.

131 (48.3%) respondents support, 110 (40.6%) do not support.

4. Close the Eastern Region season from 1 May to the November opening. The current season for male rock lobster closes on 1 September.

183 (67.5%) respondents support, 55 (20.3%) do not support.

OUTCOME OF PUBLIC CONSULTATION Comments from respondents supporting the catch limit reductions indicated that if stocks are low, then action is warranted to ensure the fishery is sustainable in the future. Several submissions indicated the bag limit will not affect them as they did not reach the limits anyway. The TCT submission supported the proposal but contended the reduction in catch will be minimal as few recreational fishers catch more than 2 lobsters per day. Some suggested the bag limit and “on water” possession limit should be the same.

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Most of the comments from respondents not supporting a catch limit reduction fell into three broad themes, that is:

concerns around equity issues between the recreational and commercial sector (catch and spatial overlap);

economic issues for individual fishers (cost – time and money spent balanced against decreased potential reward) and broader regional economic impacts; and,

alternative management suggestions to constrain non-commercial catch, such as tags. Several submissions mentioned that the commercial catch should be decreased. The TARFish submission proposed the “first access principle” (where the non-commercial sector gets the first allocation rights – with corresponding decreases in the commercial total allowable catch (TAC)). Others indicated that the commercial fishery should be excluded from certain inshore areas. Removing the “personal” take home take provisions from the commercial sector was also mentioned. Respondents not supporting a reduction in the Eastern Region bag, possession limit or boat limits mentioned concerns that it removes the incentive to travel long distances and may concentrate fishing to near main population areas. Impacts were highlighted by fishers who travelled distances, who stayed away fishing for multiple days (e.g. campers) and fishers that fish only occasionally. It was implied that the removal of the extended trip provision and reducing the boat limit to 8 rock lobster impacted greatly on some fishers. The TCT submission supported the proposals but suggested the boat limit reduction will have a minimal impact on catch as few recreational vessels would be catching more than 8 rock lobster in a day. Some submissions indicated that reducing possession limits may have little impact on reducing catch, as fishers could give fish away to others or consume the catch quicker to remain within the possession limit. Several submissions mentioned that the proposals will tend to impact on divers - as divers tend to have a higher daily catch rate and are more likely to achieve the bag limit than potters. Some submissions, including TARFish, mentioned that they do not support boat limits, and that individual bag and possession limits only should apply. Many submissions proposed alternative management options, particularly support for an individual seasonal limit and tag system. There was also mention that the reductions should be temporary until the stock recovers. The closure of the winter season received the most support of all the management proposals. Comments from respondents indicated that whilst most recreational fishing happens in the summer, it will make policing easier and would assist stock rebuilding. The concept of having a period when the rock lobster won’t be disturbed was also highlighted. Comments from respondents not supporting a season closure included concerns that the measure will not achieve the objective as very few people fish during this period. There were suggestions to close at the end of June or delay opening of season until later instead.

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The TARFish submission does not agree that using the proposed bag/possession/boat limits will limit recreational catch to the required level and believes that the proposals will potentially increase recreational catch, as fisher behaviour is likely to change. TARFish does not support boat limits or the winter closure and puts forward alternative options to be explored. TARFish suggests that there will be a negative economic impact on the east coast and much community concern. The TRLFA submission supported all the proposed amendments, noting that the current regulations had failed to effectively constrain recreational catch to the required levels in the first year of the east coast harvest strategy. The TRLFA commented that all extractive users of the resource must demonstrate a genuine commitment and willingness to reduce catches, in order to achieve the stock rebuilding goal of having the fishery at a level of 20% of virgin biomass within 10 years.

RECFAC RECOMMENDATIONS The RecFAC do not have consensus support for the catch limit proposals. The members supporting the proposed bag, possession and boat limits support them as an interim measure while a package of long term management measures are developed. Other RecFAC members indicated they do not support the proposals as they believe they will not achieve the desired results of constraining the recreational rock lobster catch on the east coast. Most RecFAC members do not support a winter closure for the entire East Coast recreational fishery, as the impact on stock levels for the recreational catch would be minimal. They noted this would impact only on a small number of recreational rock lobster fishers. There is consensus that a package of arrangements needs to be developed after a decision on an East Coast resource sharing arrangement is made. RecFAC supports an alternative proposal from the Department to exclude the major residential islands, such as Bruny Island, Flinders Island and Cape Barren Island from the definition of the Eastern Region for the purpose of possession limits. The ‘onwater’ possession limit also applies on land for all islands within the Eastern Region. This proposal addresses concerns that a possession limit of 4 rock lobster would have an adverse impact on residents and visitors (including campers) on those islands.

CFAC RECOMMENDATIONS The CFAC supported all the proposed amendments, whilst acknowledging that there are limited actions that can be taken by November 2015. Industry members and the conservation member expressed concern that the measures, of themselves, are insufficient to adequately control the catch of the recreational sector and ensure stock rebuilding to the required level.

DISCUSSION It was expected that the proposed package of measures - to constrain recreational catch to its notional catch share of 42 tonnes in order to maintain the integrity of the east coast stock rebuilding strategy and specifically the integrity of the 200 tonne annual limit - would elicit polarised views from the recreational sector.

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The major themes in the comments provided by respondents centred around perceptions of equity (or inequity) with the commercial sector, or between recreational potters and divers, as well as perceptions around the costs/benefits of fishing with the reduced catch limits. Comments include “with these reductions it’s hardly worthwhile to go fishing if you have to travel any distance or if I have a large boat/want to undertake extended fishing trips”. Such comments were to be expected given the proposed reductions. The TARFish and TCT submissions conclude that the proposed measures will have little impact on stocks. They argue that the assumption in the IMAS modelling that fisher behaviour will remain unchanged is flawed and that alternative management options should be explored instead. Suggested options included the east coast non-commercial catch being regulated by an individual season limit and tagging system, local area closures and total closure of the east coast for at least one year to allow the stock to rebuild. As detailed in the Information Paper, preliminary results from the IMAS survey for the 2014/15 recreational season indicated that the east coast recreational catch was about 52 tonnes, well above the notional catch share of 42 tonnes. To maintain the integrity of the 200 tonne catch limit, and to keep the east coast stock rebuilding strategy on track, to do nothing to constrain recreational catch for the new fishing season in November 2015 is not a considered a defendable option by the Department. IMAS has re-analysed the survey data by simulating the proposed daily bag limit of 2 lobsters to the previous season fishing patterns. IMAS estimated that if the bag limit had been 2 lobsters per day, the recreational catch would have been constrained by about 13% to 43 tonnes for the November 2014 – April 2015 period (NB this assumes there would be no change in fisher behaviour – such as increasing the number of days fished etc.). It is not possible for IMAS to predict future fisher behavior or changes in that behavior, and what impact changed behavior will have on the overall recreational catch. Similar to the previous recreational bag limit reduction in 2011, this change is likely to have a greater impact on divers than pot fishers, as divers tend to have a higher average catch rate than pot fishers. The IMAS simulation also indicates that the notional catch share of 42 tonnes would have been triggered at the end of April in 2015. Although the “catch savings” under current fishing patterns are likely to be small from the proposed winter closure, in future as stocks improve, the catch trigger may be reached earlier, so a reduced bag limit in combination with a winter closure from 1 May will assist in constraining the recreational catch. The IMAS survey does not collect the necessary data to provide an estimate on the impact of boat limits on the total catch. A reduction in boat limits is likely to affect the larger types of fishing groups. There are anecdotal reports from dive groups that boat limits have constrained such group fishing activities. Future surveys could seek further information about the efficacy of boat limits. Boat limits are intended to limit the overall recreational fishing catch and prevent the circumvention of personal daily bag limits, by fishers who take in excess of their own bag then gifting lobsters to other licenced fishers who have not taken their bag or indeed not fished at all. Boat limits are a cost effective catch limit as compliance officers do not need to prove who has taken the fish.

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The submissions make a case that the catch limit and boat limit reductions will remove the incentive (or benefit) of fishers to travel away from population areas. In response to these concerns and balancing the need to maintain the integrity and objectives of the management package, the Department recommends the boat limit be increased to 10 rock lobster (a limit of 8 had been proposed). The removal of the extended trip provision should still proceed to assist compliance, that is an East Region Boat limit of 10 should apply irrespective of the days fished. An increased boat limit also decreases the rationale for multiple day trip limits. The Department also considers that the proposed Eastern Region possession limit of 4 rock lobster, which applies to residents living on islands within the eastern region, is unintentionally disadvantaging these island communities. Under the current management plan, the on water possession limit applies to on-land on any island within the eastern region. To address this issue, the Department proposes that the 3 main residential islands (Flinders Island, Cape Barren Island and Bruny Island) be excluded from the definition of the eastern region for the purposes of possession limits. This will allow an on-land possession limit of 10 rock lobster for these island residents instead of being restricted to the proposed on water possession limit of 4 rock lobster. The RecFAC supported this option, and noted that a person will still need to comply with the Eastern Region possession limit and boat limit when they move off the island on to State Waters (e.g. after a camping trip). People travelling on the Bruny Island ferry or by plane when travelling from Flinders or Cape Barren Islands will not be affected. On balance, the Department believes that the rationale behind adjusting the existing recreational catch controls as a package of measures that can be implemented for the new fishing season is a reasonable and very necessary step to keep the East Coast rock lobster stock building strategy on track, acknowledging the imprecise and indirect nature of the current recreational management levers. Annual stock assessments and modelling by IMAS will continue to report on total biomass (stocks) for each stock assessment area (along with other stock information). This will allow an annual assessment as to whether the rebuilding strategy is on track to meet the 20% of unfished biomass goal by 2023. DPIPWE is now commissioning IMAS to undertake annual statistically based surveys to monitor the recreational catch. If stock assessments indicate that the mechanisms to limit total east coast catch are not appropriately supporting the objectives and performance measures of the strategy, then management measures will need to be assessed and potentially new proposals will need to be developed or existing arrangements fine-tuned. This will be done in consultation with the fishery advisory committees and peak bodies. The advice from the TARFish submission, RecFAC and CFAC stating that the management actions proposed will not explicitly limit the total catch in the long term is noted. Many individual submissions also made suggestions for alternative management measures. These suggestions can be viewed in submissions from organisations and the summary of key comments in the Attachment at the end of this document.

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The Department acknowledges that the effectiveness of these catch control levers is likely to be eroded as stocks rebuild. The Minister has clearly indicated these catch control adjustments are an interim step while alternative management options are explored and their cost/benefits assessed in consultation with the peak bodies. DEPARTMENT’S FINAL RECOMMENDATION:

In the Eastern Region:

1. Reduce the daily bag limit from 3 to 2 rock lobsters.

2. Reduce the possession limit from 6 to 4 rock lobsters.

3. Reduce the boat limit from 15 to 10 rock lobsters irrespective of the number of days fished thus removing extended trip provisions for boat limits.

4. Close the Eastern Region season from 1 May to the November opening, instead of closing from 1 September.

5. Redefine the Eastern Region to exclude Flinders Island, Cape Barren Island and Bruny Island for the purposes of administering East Coast Region possession limits.

Western Region Boat Limits The Western Region is west of Port Sorell around the west and south coast to Whale Head. The proposal in the draft management plan amendment was to remove the extended trip provisions that currently allow a maximum boat catch limit of 50 rock lobster for fishing trips longer than a day. The current maximum boat catch limit of 25 rock lobster for a day’s fishing remains unchanged. The aim is to limit fishing activity in the Western Region to reflect a fair and reasonable recreational catch and on a scale that reflects a non-commercial fishing operation and reduce opportunities for illegal fishing and marketing.

OUTCOME OF PUBLIC CONSULTATION From the submissions, 148 (54.6%) respondents indicated support, while 40 (14.8%) do not support the measure. Comments from respondents indicated that boat limits were seen as an effective compliance tool which would reduce opportunities for illegal trade. Some respondents felt that the boat limit of 25 should also be reduced, some saying it should be aligned with the eastern regional boat limit. Conversely, comments from respondents argued that the isolation and weather on the West Coast adequately protects stocks by limiting opportunities to fish and that recreational fishers only take a small proportion of total West Coast catch. The TRLFA supported this proposal. The TCT submission supported the proposal for improved enforcement but noted it would have little impact on stocks.

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The TARFish submission did not specifically comment on the proposal. The TARFish submission made a statement relating to boat limits that: “TARFish does not support boat limits as they supersede the individual’s bag/ possession rights.”

RECFAC RECOMMENDATION: RecFAC support this proposal as a boat limit of 25 represents a reasonable quantity of fish and will assist with compliance.

CFAC RECOMMENDATION: CFAC supported this proposal.

DISCUSSION Boat limits aim to confine non-commercial fishing activities within the spirit and intent of recreational fishing. The current boat limit in the Western Region is 25. The limit for extended trips (fishing trip over multiple days) is 50. This extended limit is considered excessive and is not considered a “reasonable” amount for recreational fishing. Recreational boats carrying rock lobster levels approaching the current levels allowed are considered more of a “commercial” quantity, and provide significant opportunity for illegal marketing. If the new proposed eastern region boat limits are implemented there is an even greater disparity between the catch limits with a multi-day boat limit in the Western Region ( i.e. 50 as opposed to 10 in the Eastern Region). Therefore, associated compliance risks are likely to increase, particularly on the south coast. Retaining a boat limit of 25 rock lobster, but removing the extended trip limit of 50, is proposed as a balance between providing a reasonable maximum catch for recreational fishing operations over multiple days - in keeping with the spirit of recreational fishing. The boat limit of 25 provides for up to 5 individual recreational fishers on a trip to take their full bag limit. It is suggested that 25 rock lobster is a reasonable boat limit for non-commercial fishing activities within the spirit and intentions of recreational fishing. It is noted that some have a view that 25 rock lobster is beyond a reasonable level for recreational fishing.

DEPARTMENT’S FINAL RECOMMENDATION FOR THE WESTERN REGION:

That Rule 34 is amended to remove the extended trip provisions for boat limits in the Western Region.

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ATTACHMENT 1 Rock Lobster Response Form Themes that came out of submissions. Total No. of submissions 271 received Break down of submissions by category.

Three submissions received from organisations:

TRLFA;

TARFish;

TCT. 2.1- Eastern Region Daily Bag Limits

Do Not Support- 129 (47.6%) Themes to come out of submissions:

The recreational catch is a very small percentage of the overall catch, in the region of 5-10%.

Why reduce the recreational bag limit when commercials take most of the fish.

Recreational catch/bag limits have been reduced by 66% when the previous reduction is included.

Will only support if there is an equivalent reduction for commercial fishers.

Commercial fisherman are over-fishing the fishery.

Recreational fishers spend thousands on boats, gear etc,

Need a buyback of commercials fishers/ quota/ gear.

Need recreational only areas, commercial fisherman bombard areas close to boat ramps and then move on.

Recreational fishers only get a limited opportunity to fish, reducing the bag limit to two does not make it worthwhile to head out. The cost of heading out on a fishing trip these days is getting higher.

Will impact regional communities, people won’t travel to the coast as frequently.

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Increase minimum size of males and females.

Introduce a maximum size limit.

Acknowledge stocks are low.

Close fishery on the east coast for a year to all commercial and recreational fishing.

Close the inshore waters to commercial fishers, close areas close to boat ramps to commercial fishing.

Ban recreational divers, they keep diving until they get their bag limit.

Introduce tags and individual seasonal limits.

Will put lives at risk by forcing people to fish in the west.

Will impact the honest fisher, illegal fishing will continue.

The fish are there, there is no problem.

Will put more pressure on other areas such as the north coast.

Recreational pot fishers have a minimal impact on the fishery.

Reducing the bag limit from three to two does not make it worthwhile getting a license.

Will cost of the recreational fishing license be reduced as a result of the bag limit reduction?

Need better policing of the current rules.

If a pot fisher is lucky enough to get three crays in one day after many days of nothing he should be able to keep all crays caught.

The first access principle should apply to recreational fishers as it does in New Zealand.

Fisher will head out more often to catch their possession limit.

Will not impact on the total catch taken by recreational fishers, fishers will increase the number of days fished.

The economic impact of recreational fishers has not been considered.

Remove the professional take home provisions. Support- 123 (45.4%) Themes to come out of submissions:

Rare to exceed the proposed limits.

Good move for the future.

Stocks are low drastic action is needed.

A tag system with an individual seasonal limit would be preferable.

Maximum size limits are needed to prevent the spread of sea urchins.

How have rock lobster stock been allowed to get to such a low level?

Divers have done a lot of the damage.

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The fishery needs to be closed to recreational and commercial fishers to help stocks recover.

The fishery must be sustainable.

This reduction only needs to be temporary until the stock recovers.

Support is conditional on commercial catch being reduced.

Happy to support if supported by the scientific evidence.

Support is conditional on commercial fishers having a similar reduction in catch.

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2.2- Eastern Region On Water Possession Limit

Do Not Support-131 (48.3%) Themes to come out of submissions :

Won’t be worthwhile doing multi day trips on the east coast if the possession limit is only four.

Will be hard to police and penalizes those who go on extend trips only once or twice a year.

The possession limit needs to take into account the numbers of people on board.

Limiting the overall possession limits is unlikely to do anything for the long term sustainability of the fisher, maximum possession limits are very rarely enforced or checked.

The possession limit has very little influence on what people take when they are fishing, and are easily overcome by giving fish away to family or friends, or eating your catch sooner.

The current possession limits are about right for the honest fisher, it is those doing the wrong thing and abusing the system that is the problem.

Reducing the possession limit will cause problems for those camping for long periods.

A possession limit of 6 is fair and adequate.

Possession limit restrictions would not be needed with a tag system.

Commercial fishers should not have a bag limit for personal use.

This measure unfairly targets infrequent fishers who need to travel long distances.

An on water possession limit of four is not enough for a feed and give a couple away to family and friends.

This measure is prejudice against people with large boats who can’t take their catch back to a shack.

Support-119 (43.9%) Themes to come out of submissions:

A reduction in possession limit will reduce waste.

4 lobsters is plenty.

Will need more police on the water to ensure compliance.

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Keep the possession limit and bag limit the same.

Nobody needs so many lobsters in their possession.

Reducing the possession limit will improve the equality of catch across the fishery.

Needs to apply equally to commercial and recreational fishers.

Will restrict local residents from over fishing.

Will restrict divers, they have a greater opportunity to catch lobsters.

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2.3- Eastern Region Boat Limits

Do Not Support-110 (40.6%) Themes to come out of submissions:

Won’t be worth having more than four people on a boat.

Discriminates against those who have large boats and head away on long trips, for example if I have 8 people on a boat each person can only take 1 cray, or 4 people can only take two each.

Will be prohibitive to travel long distances for a trip.

Will concentrate fishing effort close to the main population areas.

Impossible to police and will encourage illegal behavior.

Unfair on people who can only get out a few times per year.

Counteracts the daily bag limit.

Boat limit should equal the bag limit of the number of licensed fishers onboard.

Will encourage boat trips with less people on board or more boats in the party.

The limit is fine for day trips but not extended trips. Support-131 (48.3%) Themes to come out of submissions:

Will help increase rock lobster numbers.

Will restrict extended trips where a lot of cray fish can be taken.

Could be reduced further, to 6 or 4.

Will encourage less people on boats which is safer.

Will restrict divers, who have a greater opportunity to catch crays.

Won’t impact on potters.

Will reduce the opportunity for illegal activity.

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2.4- Eastern Region winter fishing

Do Not Support-55 (20.3%) Themes to come out of submissions:

Changes will make little difference as very little fishing done at this time of year.

Just not needed, will not achieve the objective.

Weather is more stable in the winter months.

Very few people fish at this time of year especially potters.

Closing at the end of May is a little early, end of June suggested.

Only close during the breeding season and when females are in berry.

Will force fishers to head to the west coast where it more dangerous especially in winter.

Commercials need to be closed at the same time.

Close the whole area for a year or two.

Would be better to delay the opening of the season, when females are still in berry. Support- 183 (67.5%) Themes to come out of submissions:

A sensible strategy, should have been done a long time ago.

The winter should be closed to all rock lobster fishing.

Only makes sense if closed to both recreational and commercials.

Will give a period of time where crays won’t be disturbed.

Stop winter diving which disturbs females in berry.

Only supported if bag limits are left unaltered.

Will protect molting females.

Little rock lobster fishing occurs in the winter.

Most rock lobster fishing happens in the summer anyway.

Would assist stock rebuilding.

Will make policing easier.

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2.5- Western Region Boat Limits

Do Not Support- 40 (14.8%) Themes to come out of submissions:

The weather will always protect the west coast, it limits the opportunities to fish.

Will put many lives at risk encouraging people to head west.

The isolation of the area protects it.

The logic of this proposal is not clear.

Recreational fishers only take 6-8% of the total catch. Support- 148 (54.6%) Themes to come out of submissions:

Will stop poachers from selling their fish, reduce opportunities for illegal trade.

Needs to be reduced further, a limit of 25 is too high.

Align with the eastern region to reduce confusion.

The commercial fishery also needs to take a cut.

Will assist with policing of the fishery.

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Rock Lobster submissions – Summary of themes and comments under the “Other Comment” category in the response form (Comments recorded verbatim) Fishing Area closures Around a dozen submissions mentioned interaction issues with the commercial fishery or suggested commercial fishing needs to be reduced or prohibited in inshore key recreational or populated areas:

Including exclude commercial fishers outside 500 metres of mouth to Fortescue/Stewarts/Pirates bay, others mentioned Mercury Passage, St Helens Island to just past Sloop Rock, from Cape Lodi to just past Diamond Island.

Numerous comments about commercial pots around Tasman Peninsula e.g. Pirates Bay. Essentially recreational fishers can't access a lot of deeper or west coast the commercially fished areas, yet commercial fishers can access the recreational areas.

More inshore commercial effort, as the deeper white fish has less price.

Permanent and temporary reserves in bays and areas are required period to allow the populations to grow. This should be applied to commercial and recreational. Or a depth or shore meter limit for pots to preserve the more vulnerable areas.

Bombing of areas such as Triabunna.

Recreational fishing only zones say from and see how the crays recover.

Couple of suggestions about closing fishing zones for a whole year, rotating the zones.

Other suggestions included:

Close the whole eastern region down for recreational and commercial fishers for a significant amount of time.

One suggested restricting commercial fishing to the West Coast for 1-2 seasons.

Zones for commercial fishing only, combined commercial and recreational fishing zones, & recreational only fishing zones, interspersed with no take zones for all fishers.

Close the commercial fishing on the east coast for 12 months. Don't close rec - if you close the whole Eastern region, 1000's of people will be heading West not knowing what they are in for.

Closed areas to be introduced, pot only areas introduced, dive only areas introduced.

More smaller no take zones in inshore areas, dotted along the coastline, to act as safe havens where the lobsters can breed un interrupted.

Size limits ~ Ten submissions suggested to increase minimum size. Some saying increase females to 110 mm or apply an increase in Eastern Region.

~ Dozen suggested maximum size limit to encourage increased predation on Centrostephanus; protect big breeders.

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Season limit or tags Over a dozen mentioned a season limit or tags being fairer. Comments included:

Happy with boat limit if extended trip privileges were allowed. Tags are fairer - happy to pay for tags.

The catch limits unfair for camping trips. Only go on several trips. Those fish every day get a lot of crays for the summer.

Go back to a tag/book system where you have to account for crayfish before you bring them ashore. This is a fairer system so people like us who get very limited time to fish have a chance get a few crayfish if lucky enough. This would stop local people who go out every day (whether permitting) and over fishing. I know of people over the years who fish most of the season and there is no way they can be eating that amount of crayfish themselves. Also put greater restrictions on divers.

There are quite a number of recreational fishers who live near good fishing areas and often have their pots in the water many days in each week of the open season and even with at a catch limit of two per day can take hundreds in the season. For others much travelling effort is often needed and they can only fish for a limited number of days each season. The fair way is for tags to issued to recreational fishers. The recreational fisher is not getting a fair share of the resource down from 10% to 6%.

May be 30 tags per licence with existing possession and boat limits and closed winter.

Tags are the only just and fair way to police the quota.

Diving

Ban diving –mentioned of effect of diving - breaking limbs, localised effort etc.

Snorkellers should not have to pay a licence.

Several suggested, a lower bag limit for Divers different limits for potters (3) and divers (2), or noted that the boat limit is effective in limiting dive catch.

Reported that divers that use pots multi-trip. Get crays from pot and then dive later that day exceeding their limits.

Diving for crays should be banned. These guys just don't miss out on getting theirs and their mate's allowance.

Pot fishers are sick of divers entering the next to where their pots are set, and, diving in between pots set within 15 m of one another. Ban within 100m of pot buoys.

It is easy for pot fishers to share their haul there needs to be some provision to allow divers to share similarly.

Hauling pots

The pulling of pots in the night time should be made illegal in the amateurs and the commercial sectors. By removing night pot lifts you would reduce the effort placed on the fishery.

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Maximum recreational boat limits of three pots pulled in any 24 hour period could reduce what appears to be me obvious over fishing pressures. Restrict lifting a pot to only once per day and only during the period of daylight.

General Comments

Fisher reported in Area 4 average size and number aught has dropped off around 30% since 2009/10.

The season opens too early for commercial and recreational - fishers disturb berried females 2- it should not open till at least the first week of December and that should be for everyone not just recreational.

In general these proposals represent a disproportionate load on the recreational fisher compared to the commercial.

Will the licence fees be reduced in line with quota drop?

I strongly believe that Tasmania should adopt the New Zealand example of allocating more fish to the recreational sector.

Some balance to the Eastern region recreational restrictions needs to be considered. IMAS data shows that 50% of Eastern caught rock lobster is taken in Area 1, with the balance caught in the other 3 Areas. I urge consideration that given the little uptake in Area 8, a line is drawn across the south of the state at the top of Areas 1 & 8 to create a third (Southern) region with a limit of 2. Bag limits of 3 in Eastern Area’s 2,3 & 4 and a limit of 5 in Western Area’s 5,6, & 7 could then exist.

Lower the commerial quota by 50%, gov buyback of 5% of licence holders each season for 10 years.

Increase bag limit for the white crays - encourage deepwater fishing.

Discussion about localised effort transfer due to biotoxin closures.

Make commercial fishers have a recreational rock lobster licence to take "personal use" fish home.

A couple submissions mentioned more education is needed on the lifecycles etc so fishers understand the problem.

Several mentioned enforcement needed – “more police patrolling and checks (day and night) as there is a lot of pots and nets being pulled by other fishers.”

Several submissions queried the use of old data or why an up to date fisheries assessment was not presented.

“Good to see both commercial and rec fishers are expected to help make the stock sustainable. Disappointing the info provided did not provide 2015 data on unfished stocks/virgin biomass. That data was three years old. Surely there have been things put in place (e.g. commercial caps) to help address that that may have changed/influenced the stock levels.”

“why a consultation in August 2015 is using data from November 2012 to justify that stocks/mass of the species is still critically low. Is there not more up to date information on which to make an assessment of stock levels, and if not why not?”

21

Western Region

Close season 1st May to opening November on West Coast as proposed for East Coast.

The population of crays along the whole North coat of Tasmania needs to be better managed. Fishers can hardly even catch a cray in a pot, divers struggle to even see crays in some areas.

Reduce the catch from Robbins Island to Devonport [Port Sorel] from five to 3.

Reduce the catch to 2 all the way to Boat Harbour.