The Department of Primary Industries (DPI) Victoria seems to have nearly gotten away with very limited consultation before undertaking the most extensive reform of fisheries in Australia’s history.

It’s about capping catches and enabling trade between 270,000-700,000 people in recreational fishing, 400-800 in commercial fishing and the entire Aboriginal community. All with just one month’s consultation planned and a report on the web that still has the wrong closing date for submissions, and that has been extended from November to March.

The document Future Fisheries Strategies — Proposals to Reform was released in October. There are no descriptions of any fisheries — and no economic data on the income and jobs they generate for regional economies, tourism or Aboriginal people. There is no clear argument made for the need to reform. The environment and habitat, relied on by fish, is mentioned but its protection and legislative change to manage it, is ruled out.

It’s not just what it tells you that is worrying — it is what it leaves out — the management costs and red tape implied and possible — all sounding much like management that’s done elsewhere.

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It was likely drafted with an ex-manager from New Zealand Fisheries where almost all fisheries, except recreational fishing, is under tradable quota mostly owned by a handful of companies.

The language used, such as “best available science” is American and the international group, the Worldwide Fund for Nature is said to have replaced Victorian National Parks Association in representing marine conservation. The membership of the Stakeholder Reference Group, which appears to have overseen the development of this reform, has not been revealed.

The “strategy” cites the Canadian halibut fishery as an ideal example:

“This case study highlights the potential for market based resource allocation mechanisms as an alternative way to manage the competition between commercial and recreational fishing when the resource is fully utilised and it is unacceptable to allow recreational catches to continue to grow in an unconstrained way.”

Quota management applies in Canada and many Commonwealth fisheries. It is about capping the catches and enabling the most efficient operators to buy and trade quota from the least efficient with fish “ownership” often shifting to the corporate sector.

The practice in Victoria outlined in this proposal involves regulating every catch in every fishery. This kind of management assumes that only the catch of fish set their population. This is plausible in the public mind for commercial fisheries — but not for people catching fish with hooks. This is especially so when tagging shows many commercial fish and recreational species fished, range through Bass Strait to Tasmania and even across to New Zealand. It goes on to say:

“It has the potential to provide a way to enable recreational fishing to grow, whilst providing a choice about either cutting bag limits or buying commercial quota. However, the trading system can only work well if the governance structures are well developed — it needs to be clear what entity will be able to buy, hold and trade shares on behalf of the recreational sector. Information about the level of take from each sector is also critical to make this system work.”

In consultation, Fisheries said that this was just an example — not a model — but it sounds like a plan.

The Department of Primary Industries’ Future Fisheries Strategies — Proposals to Reform would need the largest government department in Victoria to tax and manage the catches and trade in units of the catch landed by everyone who catches a fish.

On TV now is the New Zealand-made series Coastwatch on Channel Seven at 7.30pm Sundays.  It shows New Zealand enforcement officers at massive roadblocks prosecuting families for catching too many pippies, fish and their abalone-poa, etc. Is this what this reform means for Victoria’s or indeed Australia’s future?

This “strategy” is vague, badly written and yet proposes irreversible effective privatisation of all fish, formerly “common property”, to be enshrined in “yet to be revealed” legislation. Under this strategy, all commercial, recreational and Aboriginal fishfolk will be directly impacted and will pay for it under “full cost recovery”. The public will pay through the high price of fish, loss of jobs and tourism.The economic impact on regional Victoria is also potentially huge — especially when combined with massive hikes in costs and fines for recreational boating. Despite this, there has been no effort from the Department of Primary Industries to gauge the likely economic and social impact of this “strategy” on  regional communities or fish consumers.

For commercial fisheries — all 800 commercial licences — on its website, DPI states:

“… quotas or other fishing rules would be used to manage commercial catches. These ‘management tools’ would be adjusted up or down over time based on the best available scientific and fishing expertise.”

With quotas come quota levies, taxes often paid direct to Treasury, and in the “strategy”  there is also a proposal for a “resource tax” — treating fish like minerals — and the auctioning of licences.

Bay and inlet fisheries are the only substantial source of many of Victoria’s fresh fish species such as whiting, rock flathead, bream, etc. They are suffering from “reform fatigue” after 15 years of closures and buyouts that have more than halved the fleet and catch of key species. Fleet cuts have doubled or tripled fresh fish prices for Victorian consumers and the price of bait to recreational fishfolk, with imported fish, also taking the “price advantage”.

Still Victorian consumers have no legal guarantees of where their fish was caught or even what species it is.

Set catches will end more than 100 years of variable catch data used to manage fisheries by changing who fishes and how.  The Commonwealth “attempted” to solve this problem in the southern shark fishery by conducting “fisheries independent surveys” for each species for stock assessments, all costing tens of thousands of dollars annually for each species. When fleets were regulated by boat numbers, seasons, gear restrictions, etc, this data was free, more comprehensive and more accurate.

These set catches will not necessarily be based on fisheries’ independent surveys and stock assessments but could also use “the best available science”. This could be the opinion of a committee of scientists and WWF, for instance, or as a result of major expensive research. None of this is specified or defined in this “strategy” document.

Fish will be dumped dead in bay and inlet fisheries under quota. There is no way of keeping a  fish species entering the net when there are often a dozen of more caught at once.  If fish, for which no quota is available, are caught and dead, they will have to be dumped.  Fisherman are fined for landing them and cannot even give them away.  This is happening right now in the southern shark fishery, which has been heavily regulated. When supposedly rare sharks are common and widespread, like now, they are caught unavoidably and dumped dead more than a tonne at a time in Bass Strait — as recently as last week, according to industry sources.

Indeed this “strategy” does not mention habitat management for fish nursery grounds or address fish kills or algal blooms that are occurring now in Lakes Entrance and toxic blue green algae at Eildon Weir and Lake Eppalock — stopping all recreational fishing.

There is no proposal to reform legislation to protect fish nursery habitat from land reclamation, pollution or guarantee adequate streamflow for fish nursery grounds when water is traded.  It is now a management nightmare crossing jurisdictions of many local and state government departments, their agencies and corporatised bodies. The cause of fish kills are never really identified and usually addressed by myriad inconclusive reports and meetings.  A recreational fisherman who asked about habitat management in consultation was accused by DPI staff of being a “greenie”.

In 1992, Russell Blamey, from the Queensland DPI Fisheries Division, wrote a paper Economics and the evaluation of coastal wetlands.  It made clear that as the numbers of fish decline because of the loss of wetlands, the economic losses are more than compensated for by the overall increase in the price of the catch.  So, under quota management, mangrove swamps, saltmarsh and clean estuaries can be described as an “economic burden”.  This may explain why DPI Victoria only considers landed catch value for commercial fisheries and not any management of fish habitat. It might also explain lack of DPI Fisheries concern the Wonthaggi Desalination Plant and channel deepening in Port Phillip Bay.

The sadly obvious flaw in this economic modelling is that fish are worth far more than their landed catch value to regional communities. For recreational fisheries, they come with spending on fuel, bait, accommodation, etc. For commercial fisheries, building, equipping and crewing boats and the additional value of selling the fish locally, is worth 3-6 times the landed value of commercially caught fish. Compare the $9.50-$10.50 per kilo price commercial fishermen are paid at the market for flake to the $6.50-$8.50 charged at the fish’n’chip shop for a 50-gram piece at $130-$170 per kilo.  This pays for transport, processing, wholesalers and retailers — and means jobs. But there is a limit to what the public can pay.

The increases in the price of fish that this “strategy” will generate are not dealt with but it could make locally caught fish as unaffordable as crayfish and abalone are already under quota to Victorians.  This is just when the Victorian government is promoting the health benefits of eating fish.

The impact on recreational and Aboriginal fishing will be even greater, as will be the flow-on affects on the Victorian economy.  Surely these costs must be calculated for regional Victoria and provided for consultation. Hundreds of jobs have likely already been lost to quota and catch management under the Australian Fisheries Management Authority in Victoria — and thousands across Australia. All for no discernible benefit.  This collapse in employment was “masked” by maintaining the “total landed catch value” but not the affordability or reliability of the supply of Australian-caught fish.

The Victorians who fish and the public clearly need a lot more information and analysis to work out the impact of  “non-partisan” sources and a lot more time to read and understand a far more comprehensive version of Future Fisheries Strategies — Proposals to Reform before they can comment. So too do Victorian politicians and regional Victorians. It’s all about the price of fish.