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RECFISHWEST SUBMISSION TO THE SOUTH WEST COMMONWEALTH MARINE NETWORK PROPOSAL
Submission by:
Mr Frank Prokop, Executive Director, Recfishwest.
PO Box 34 North Beach, Western Australia, 6920
Primary Interest
Recfishwest is the peak body representing the interests of over 600,000 recreational fishers in Western
Australia. We are formally recognised and funded by the Western Australia government to perform that
role which includes undertaking extensive consultation with the recreational fishing community on
issues relating to marine and freshwater ecosystem management.
The aquatic habitat in which fishing is carried out and access to those areas are particularly important to
Recfishwest and we place the highest priority on preserving the future of recreational fishing and the
resources on which it depends. Recfishwest has developed this submission after considering the values
and future management challenges of recreational fishing in areas affected by the South West
Commonwealth marine network reserve proposal.
Recfishwest has provided specific comments following the format of the official feedback template.
Consent is given for this submission to be made public.
Question 1.
Please describe your views on the Commonwealth marine reserve network proposal for the South-west
Marine Region noting, where relevant, the name of the specific reserve to which your feedback relates.
In providing your feedback you may wish to consider:
 any aspects of the proposed marine reserve boundaries and/or zones that you would like to
see amended,
 the impacts of the proposed marine reserves on you/your sector/organisation/community,
 the benefits of the proposed marine reserves for you/your sector/organisation/community.
Proposed Abrolhos marine reserve:
Recfishwest is pleased that the federal government has recognised recreational fishing as a key activity
around the Abrolhos Islands. The Abrolhos Islands is an iconic destination visited by recreational fishers
for both day trips and short stays. The islands themselves provide sheltered anchorage for launches and
larger trailer vessels accessing fishing grounds both within and beyond the archipelago. Recreational
fishers target both demersal and pelagic species in both state and commonwealth waters surrounding
the islands.
Recfishwest believes that the proposed zoning within this reserve is appropriate for protecting the
major conservation values identified within this reserve. We have no objection to the proposed reserve
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and zoning boundaries. We support the zoning of the area surrounding the islands as a Special Purpose
Zone (IUCN VI).
Recfishwest has no objection to the Marine National Park (IUCN Category II) as indicated in the
proposed Abrolhos Commonwealth Marine Reserve. It is worth noting that the area in which this zone
is proposed is not accessed by recreational fishers. However, we recommend that ecosystem based risk
appropriate recreational fishing is allowed to occur within all Marine National Park (IUCN Category II)
Zones of the proposed network consistent with the current management arrangements in place in other
IUCN Category II Commonwealth Marine Reserves (see rationale in General Comments section).
Proposed Jurien marine reserve:
Again, Recfishwest is pleased that the federal government has recognised that recreational fishing,
charter fishing and tourism are important activities within this area. Recreational fishing is highly
important to the town of Jurien Bay. Many recreational fishers visit the tourist town to access the high
quality fishing in the region. Recreational fishing provides important social and economic benefits to the
town and surrounding areas.
Recfishwest believes that the proposed zoning within this reserve is appropriate for protecting the
major conservation values identified within this reserve. We have no objection to the proposed reserve
and zoning boundaries. We support the zoning of this area as a Special Purpose Zone (IUCN VI).
The recreational fishing sector has recently deployed a number of Fish Aggregation Devices (FADs) off
the coast of the Jurien Bay town site in waters of 200m deep. The locations of these FADs are within the
proposed reserve. The deployment of devices deemed to attract fish has caused a large amount of
misunderstanding and confusion in the Ningaloo Commonwealth Marine Reserve. Recfishwest believes
it is important that the government explicitly recognises the important role that FADs and similar
devices play in providing high quality recreational fishing experiences. We urge the government to
develop a clear and specific policy for the deployment and use of these and similar devices within the
South-west Marine Reserves Network.
Recommendation: The government, in partnership with the recreational sector, develop a policy which
recognises the high social value of FADs and similar devices to the recreational sector (see General
Comments Section for critical policy elements).
Proposed Perth Canyon marine reserve:
The proposed Perth Canyon Commonwealth Marine Reserve situated offshore from the Perth
metropolitan region covers an area commonly accessed by recreational fishers. Recfishwest is pleased
the government has recognises this area as “one of the most important recreational fishing destinations
off the west coast”.
Recfishwest strongly supports the proposed ‘Multiple Use Zone’ (IUCN VI) as indicated in the proposed
Perth Canyon Commonwealth marine reserve. This zoning recognizes the importance of recreational
fishing in this area. We have no objection to the proposed reserve and zoning boundaries. We believe
that the proposed zoning within this reserve is appropriate for protecting the major conservation values
identified and will benefit the recreational fishing sector by affording increased protection to the
environment on which our pastime depends.
Recreational fishers target both demersal and pelagic fish species in this area. The proposed Perth
Canyon Commonwealth Marine Reserve lies within an area currently controlled by extensive fisheries
management arrangements. The area is currently closed to commercial fishing and recreational fishers
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face strict arrangements over the take of demersal species including a two month closure of the
demersal fishery.
This area has been used over the last century as a government dumping ground for decommissioned
vessels and barges, and these structures now form a system of functioning fish attracting devices for key
angling species including samson fish, amberjack, skipjack trevally, pink snapper and dhufish. In
addition, the federal government sunk the HMAS Derwent in this proposed reserve at a depth of 200m
in December 2004 as a fish attraction device. This has become a highly valued fishing area for Perth
anglers as it aggregates tuna and billfish as well as demersal species.
The area within this proposed reserve is vitally important to Perth and Fremantle based game fishers as
it provides readily accessible access to large pelagic species. The vast majority of the tuna and billfish
species caught by game fishers is this area are tagged and released as part of a national tagging project
supported by the NSW Government and the Game Fishing Association of Australia.
The boundaries of the proposed Perth Canyon Marine Reserve also encompass numerous FAD locations.
Since the late seventies Perth Game Fishing Club and Fremantle Sailing Club, in conjunction with the
Challenger Institute of Technology, have deployed up to six FADs in waters up to 200m in depth. The
FADs area is designated for this use by the WA Department of Transport. These FADs also carry
research equipment for the Department of Fisheries and the Commonwealth Scientific and Industrial
Research Organisation (CSIRO).
In recognition of the high importance of the Perth Canyon to the recreational fishing sector, Recfishwest
recommends that the eastern portion of the reserve <200m depth be zoned as “Recreational Use Zone”
(IUCN II).
Proposed South West Corner marine reserve:
Recfishwest acknowledges that the government has endeavoured to assess and account for the effects
of the reserve network on recreational boating and fishing interests. While Recfishwest does not object
to the overall boundary of the South-west Corner Marine Reserve, we raise objection to some of the
proposed boundaries of the highly protected Marine National Park Zones in their current form.
Recfishwest does not object to these highly protected zones out of principle, rather we believe that the
location and design of these zones should be reconsidered to minimise impacts on the recreational
sector. We have put forward alternative boundaries in an effort to deliver the desired conservation
objectives while considering the social values.
Recfishwest acknowledges that a key element of the federal government’s approach to developing the
regional marine reserve networks is the objective, embedded in the Goals and Principles, of establishing
the reserve network in a way that minimises social and economic costs. For that reason, the design of
the reserves network must seek to avoid restrictions on access to areas of significance to recreational
interests.
Recfishwest has sought the views of local communities likely to be affected by the Marine National Park
Zones proposed for shelf habitats. The changes proposed following this consultation closely follow the
Government’s “Goals and Principles for the establishment of the NRSMPA in Commonwealth waters”.
Recfishwest has proposed changes here which are particularly considerate of:
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Principle 9 - Socio‐economic costs should be minimised;
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Principle 14 - Boundary lines should be simple, as much as possible following straight
latitudinal/longitudinal lines;
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Principle 16 - The size and shape of each area should be set to minimise socio‐economic costs;
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Principle 19 - Zoning will be based on the consideration of the risk that specific activities pose to
the conservation objectives of each MPA; and
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Principle 20 - Zoning of MPAs will seek to ensure that the conservation objectives of the area
are protected, taking into account a precautionary approach to threats as well as the relative
costs and benefits (economic, social and environmental) of different zoning arrangements.
Recreational fishing is an important activity throughout the South-west region of WA. In many areas of
this region, particularly along the south coast, recreational fishing in commonwealth waters is often
limited by the inhospitable prevailing weather conditions. Strong winds and a large swell are common
in all of the commonwealth waters south and east of Cape Naturaliste. When weather conditions are
suitable recreational fishers do not generally venture more than 40 km from boat launching locations.
Proposed changes to the Marine National Park Zone near Margaret River (34˚S – 34˚ 12’S):
This zone is located in close proximity to recreational access points near Margaret River and Hamelin
Bay. This zone will unnecessarily restrict local and visiting recreational fishers.
Recfishwest believes that the eastern portion of this zone should be zoned as a Recreational Use Zone
(IUCN II) which allows recreational fishing consistent with the state-based rules (see rationale in General
Feedback section).
Recommendation: The portion of this zone east of 114° 45’E to be designated as a “Recreational Use
Zone” (IUCN II) to allow recreational fishing to continue consistent with the current state-based rules.
The portion of this zone west of 114° 45’E to be designated as a Marine National Park Zone (IUCN II) (see
Map 1).
Proposed changes to the Marine National Park Zone near Walpole (115˚ 42’E-115˚54’E):
Windy Harbour represents the only recreational boat launching location within the approximately 200
km of coastline between Augusta and Walpole. Windy Harbour is the major recreational fishing access
point for the adjacent inland areas which includes the towns of Manjimup, Bridgetown, Northcliffe and
Pemberton. In addition, Windy Harbour is an increasingly popular holiday destination for the greater
South-west region.
The majority of recreational fishing which takes place in this area occurs to the west of Windy Harbour.
Local fishers estimate that the proposed highly protected zone covers approximately 70% of the
grounds fished by recreational fishers on a regular basis.
Local recreational fishers and members of Windy Harbour Sea Rescue have raised concerns that this
zone will pose an extreme safety risk as fishers will be tempted to venture across it to areas open to
fishing on the western side. Zoning which will likely cause boaters to venture further from the boat
ramp is of particular concern in a region well known for rapid changes in sea conditions.
Recfishwest believes that the location of this proposed zone poses an unacceptability high socioeconomic cost and safety risk. As a result, Recfishwest recommends that this zone is moved further to
the west of Windy Harbour (see attached map). We believe that the desired conservation objective of
providing a high level of protection for shelf ecosystems in the Southwest Shelf Province can be achieve
with less impact on the community by placing such a zone between 115° 30’E and 115° 40’E. Indeed, a
zone of high protection here would cover the area known as “Donnelly Banks” which is believed to
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contain important spawning sites for the high value demersal scalefish species pink snapper and
dhufish.
Our recommendation here is also consistent with planning Principle 15 “Boundary lines should be easily
identifiable, where possible coinciding with existing regulatory boundaries” as 115° 30’E represents the
boundary between the West and South Coast Bioregion recognised by the WA Department of Fisheries.
Recfishwest has considered alternative locations for a zone of high protection to the east of Windy
Harbour and does not believe that a suitable location can be found which encompass shelf habitats
while minimising social impacts. Commonwealth waters adjacent to Walpole are regularly accessed by
recreational fishers.
Recommendation: The Marine National Park Zones located near windy Harbour be moved west to
between the longitudes 115° 30”E and 115° 40”E. (see Map 2)
Proposed changes to the Marine National Park Zone west of Esperance (120˚ 42’E - 121˚ 03’E):
Waiting for input from Esperance fishers. Some changes will be recommended.
Proposed Eastern Recherche marine reserve:
Recfishwest believes that the proposed zoning within this reserve is appropriate for protecting the
major conservation values identified. We have no objection to the proposed reserve and zoning
boundaries.
Question 2.
Please describe any general feedback you have on the South-west Commonwealth marine reserve
network proposal.
Recfishwest strongly supports appropriate management of marine areas in order to provide adequate
protection of biodiversity and marine ecosystems. Recfishwest believes this management should also
provide for sustainability of any resource use. Recfishwest recognises that a marine reserve is a
resource for the entire community.
Recreational anglers are not opposed to the creation of marine reserves. In fact history would show
that conservation minded anglers have advocated for improved management and protection of marine
biodiversity. Establishing marine reserves has the potential to conserve Australia’s rich marine
biodiversity and ensure a more sustainable future for recreational fishers and the regional economies
that depend on recreational fishing. For this reason, the recreational fishing sector can contribute
positively to the marine reserves planning process.
Recfishwest supports no-take areas where evidence can be supplied and quantified that recreational
fishing is having an adverse impact on habitat, biodiversity values or sustainability. Indeed recreational
fishers have historically been the main drivers of no-fishing areas to protect fish stocks from overexploitation where clear management objectives can be identified and met.
If we are to remain credible with the international community and meet our various international and
national marine biodiversity agreements and management objectives, we should develop our marine
reserves network following agreed ANZECC and IUCN methodology and using appropriate nomenclature
for specific zonings.
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The proposed network contains three different zone types in which different activities are allowed
within each zone. These zones are defined as either IUCN category II which exclude all commercial
activities and extractive recreational activities or IUCN VI which allows multiple extractive uses to occur.
Recfishwest is concerned about the inconsistent application of these categories throughout state and
commonwealth waters.
While Recfishwest believes that IUCN II affords the level of protection appropriate for Marine National
Park Zones, we believe that the definition used within this network is inconsistent with Australian IUCN
Reserve Management Principles for Commonwealth MPAs (Schedule 8 of the Environment Protection
and Biodiversity Conservation (EPBC) Regulation 2000). The definition use of IUCN category II within
this reserves network is inconsistent with other IUCN II zones in other parts of Australia. For example,
the commonwealth portion of Ningaloo Marine Park is zoned IUCN II and in called a “Recreational Use
Zone” which permits recreational fishing activities consistent with current the state based rules.
The Environment Protection and Biodiversity Conservation Act 1999 provides that “the reserve or zone
should be managed in accordance with the Australian IUCN Reserve Management Principles.” These
principles carry an IUCN 1994 description of Category II as “National Park: Protected Area managed
mainly for ecosystem conservation and recreation.” It is a:
“Natural area of land and/or sea, designated to (a) protect the ecological integrity of one or more
ecosystems for this and future generations, (b) exclude exploitation or occupation inimical to the
purposes of designation of the area, and (c) provide a foundation for spiritual, scientific, educational,
recreational and visitor opportunities, all of which must be environmentally and culturally compatible.”
Based on the above definition, we can find no reason why ecological based risk appropriate recreational
fishing practices are not consistent with the management principles for IUCN Category II. Indeed, it
could be argued that recreational fishing experiences are complimentary with the other objectives of
Category II in that it is a recreational purpose at a level which will not cause significant biological or
ecological degradation to the natural resources it does not adversely affect the primary management
objective and it contributes to local economies through tourism.
Recfishwest believes that catch-and-release fishing, where regulation prevents the removal of fish from
the area, is an ecological based risk appropriate recreational practice which is compatible with IUCN II
Marine National Park Zoning. Catch-and release fishing within commonwealth waters generally targets
high migratory pelagic species and has no impact on the benthic habitat or the long‐term ecological
viability of marine systems.
Australian IUCN Reserve Management Principles for IUCN category II as set out in the Schedule 8 of the
EPBC Regulations 2000 are detailed below. Recfishwest believes that ecological based risk appropriate
recreational fishing is a compatible activity under these principles and should therefore be allowed to
occur within the Marine National Park Zones.
Australian IUCN Reserve Management Principles (Schedule 8 of the EPBC Regulations 2000).

3.01 The reserve or zone should be protected and managed to preserve its natural condition
according to the following principles.

3.02 Natural and scenic areas of national and international significance should be protected for
spiritual, scientific, educational, recreational or tourist purposes. Ecological based risk
appropriate recreational fishing such as catch and release has high recreational, spiritual and
tourist value.

3.03 Representative examples of physiographic regions, biotic communities, genetic resources,
and native species should be perpetuated in as natural a state as possible to provide ecological
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stability and diversity. Ecological risk appropriate recreational fishing such as catch and release
will not impact on ecological stability and diversity.

3.04 Visitor use should be managed for inspirational, educational, cultural and recreational
purposes at a level that will maintain the reserve or zone in a natural or near natural state.
Recreational fishing is a very important cultural and recreational activity. Implementation of
management practices which allow ecological risk appropriate recreational fishing such as those
described above, will ensure a high level of protection such that the zone will be maintained at a
natural or near natural state.

3.05 Management should seek to ensure that exploitation or occupation inconsistent with these
principles does not occur. Ecological risk appropriate recreational fishing is not inconsistent with
these principles.

3.06 Respect should be maintained for the ecological, geomorphologic, sacred and aesthetic
attributes for which the reserve or zone was assigned to this category.
The management of recreational fishing towards ecological risk appropriate arrangements
ensures no impact on the attributes for which the zones were assigned.

3.07 The needs of indigenous people should be taken into account, including subsistence
resource use, to the extent that they do not conflict with these principles.

3.08 The aspirations of traditional owners of land within the reserve or zone, their continuing
land management practices, the protection and maintenance of cultural heritage and the
benefit the traditional owners derive from enterprises, established in the reserve or zone,
consistent with these principles should be recognised and taken into account.
Recommendation: Ecological based risk appropriate recreational fishing practices such as catch-andrelease fishing be a permitted activity within IUCN category II Marine National Park Zones.
Recfishwest is concerned that the government has not been consulting closely enough with state-based
agencies during the drafting of this network. We believe that the commonwealth process must consider
complimentary state based planning which is likely to follow closely. With state-based marine parks
soon to be implemented within the south-west of the state, it is critical that the commonwealth process
has linkages so that the Western Australian community does not end up with a patchwork of
inconsistent marine zoning. It is equally important the commonwealth process considers the potential
impact complementary state marine parks on the displacement of the recreational fishing community.
Recfishwest appreciates the level of consultation and communication we have had with the federal
government in the development of this draft plan. We believe that the government has taken a realistic
and balanced approach in this marine planning process.
We look forward to having further input into the marine planning process and hope that the views
provided here are given the due recognition of the 600 000 recreational fishers in Western Australia.
Yours sincerely
Frank Prokop
Executive Director
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APPENDIX
Map 1: Recfishwest’s recommendation for the proposed South-west corner commonwealth marine
reserve near Margaret River.
Map 2: Recfishwest’s recommendation for the proposed South-west corner commonwealth marine
reserve near Walpole
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