The Association sought information regarding the reform process through a right to information (RTI) request in late 2018. The document is hosted on the Disclose Log of the Queensland Productivity Commission website. The Association has been advised to direct you to the document using the following link: Preliminary Impact Assessment (PIA)
Each statement is referenced to the PIA via a quote and what follows is an analysis and/or questions raised from the document (noted in blue).
Quote in PIA – Paragraph 1, Page 3
To this end, the Strategy defines the future role of the Minister as providing “Strategic direction for fisheries management on behalf of the community”. It is proposed as part of the legislative amendments that more of the day to day decisions (e.g. quota changes, size and bag limits, closures etc.) be expressly the responsibility of the Chief Executive where it is consistent with a harvest strategy for the fishery.
The Minister’s role should be to ensure fisheries habitats are healthy to support abundant fish stocks and to ensure fair access to public resources for all as part of a food security policy. This does not mean developing fisheries management systems that will minimise catch in what are sustainable fisheries and exclude commercial fishers is unacceptable.
Quote in PIA – Paragraph 3, Dot Points 2 and 3, Page 4
Dot Point 2 – Provide the ability to charge for general deficiencies in information requirements provided to the chief executive e.g. where it has been proven a fisher sold more/less fish over a period of time than reported in logbooks.
This is data entry issue, what has it to do with black marketing?
Dot Point 3 – Increased penalties for failing to comply with vessel tracking requirements to support the roll out of vessel tracking across all commercial and charter fishing boats by 2020.
When most black marketing involves criminals why is the vessel management systems (VMS) not applicable to both the recreational and commercial fisheries? Inclusion of this indicates that they are assuming that commercial fishers are the main offenders yet they are licenced to sell their catches – therefore not black marketing.
Quote in PIA – Paragraph 7, Page 5
Some questions should be noted:
- Why does anything need to be redacted here amongst the objectives of the government action?
- What objective did they have that was so necessary to keep from us that it was redacted?
- Being non-transparent about the very “Objectives of government action” raises great concerns. Was it indicative of a predetermined outcome or was it indicating a prior commitment to one or another of the minority groups committed to eliminating commercial fishing in the state?
Quote in PIA – Paragraphs 1 to 4, Page 6
Paragraph 1, Page 6
The proposed amendments to the Fisheries Act are not expected to result in material impacts upon external stakeholders or limit access to Queensland’s fisheries resources.
This is going to have enormous impacts upon many commercial fishers and government are not even acknowledging any impacts at all.
Quote in PIA – Paragraph 2, Page 6
The proposed changes to compliance powers and penalties are intended to provide a strong deterrent to individuals involved in the illegal trafficking and black marketing of fisheries resources, and persons who have repeatedly convicted of offences against the Fisheries Act. Compliance with Queensland’s fisheries legislation is very high (currently a 93% compliance rate for all sectors) and as such, the proposed changes are unlikely to impact upon the majority of Queenslander’s.
The department would not have a clue about the level of compliance in the recreational sector due to the high level of participation in areas all along the coast and in all waterways with so few Queensland boating and fisheries patrol (QBFP) officers to cover such a large area and no VMS on recreational vessels.
After having just explained the need for much more enforcement powers to deal with growing black market that is “increasingly organised”. The department has no requirement for recreational fishers to report their catches so there is no strategy in place to have any idea of a 93% compliance rate. This would mean QBFP officers to check every recreational angler and 93% of the time. This is simply not true.
Please keep reading on in Part 2 of this post.
Author: Eric Perez, QSIA CEO
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