Welcome back, more questions and concerns raised here.
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).
This post provides the remaining issues raised in the PIA.
Quote in PIA – Paragraph 3, Page 6 – Part 1
Reforms such as the move to output controls (i.e. commercial fishing quotas) to manage Queensland’s commercial fisheries will be a change from current management approaches that will impact upon commercial fishing businesses in particular.
Interesting use of language – “i.e. commercial fishing quotas” not “e.g. commercial fishing quotas”. This is an indication of the predetermined outcome that the industry was going to be forced to take quotas even though industry majority gave a very clear response that they did not believe quotas were the way to go and not in industry’s best interests. The department kept denying that there was anything predetermined in the reform process but the fact that this is included in this document with the note “i.e.” suggests that it was predetermined.
Quote in PIA – Paragraph 3, Page 6 – Part 2
It is anticipated that some there will be some changes made to the current rules governing recreational fishing although not to the extent of the commercial aspects of fisheries.
Why, after 20 years of continual changes and closures of fishing grounds should industry once again shoulder the majority of change? It is evident that the government has committed to doing very little to restrict recreational angling in any way, thereby leaving the stocks predominantly in the hands of the unmonitored, mostly unregulated, and some illegal fishers who have no requirement to report anything. So much trust given to them while no trust afforded those who have gone to the trouble of paying licence fees and doing all the requirements to be law-abiding commercial fishers.
Quote in PIA – Paragraph 4, Page 6
It is important to note that a failure to implement the necessary reforms to how Queensland’s fisheries are managed could potentially jeopardise the long-term sustainability of these resources, would contradict community expectations and run contrary to the Government’s position on fisheries management outlined in the Strategy.
So why no real controls over recreational angling? Commercial fishers are managed to the hilt and restricted to a large extent. With elements of the PIA redacted we will never know the real objectives of government.
Quote in PIA – Paragraph 5, Page 6
Key stakeholder groups relevant to the management of Queensland’s fisheries are; commercial, recreational, charter and indigenous fishers, conservation groups, seafood consumers, fishing related businesses (tackle suppliers etc.) and Government.
When were seafood consumers consulted? Fisheries Queensland will argue that they represent the public interest. Their interest in having a share is not a high priority given the continual reduction and restriction of commercial supply of domestic wild-caught seafood in the state.
It is more than a little interesting that the post-harvest sector has been excluded. Again, we will never know the impact on the supply chain as no regulatory impact statement (RIS) has not been undertaken.
Quote in PIA – Paragraph 6, Page 6
Queensland’s fisheries resources are important to all Queenslanders – culturally, socially, environmentally and economically. The commercial fishing industry comprises 2,368 licensed fishers operating from Karumba to the Gold Coast, with an annual gross value of production of about $200 million. An estimated 642,000 Queenslanders regularly participate in recreational fishing throughout the State (although trends in participation are declining). The Government has previously estimated the economic contribution from recreational fishers to be at least $400 million annually.
There is no accurate data underpinning the $400 million figure quoted by the State government. Only estimates of expenditure of disposable income on mostly goods that are imported and taxes added into the retail prices. This is not indicative of a net economic benefit to the State because of the amount that pays for imported tackle and because of the GST added to the price. It is also not indicative of actual expenditure by most recreational anglers and the most affluent inflate the average expenditure. Quoting expenditure as an economic contribution without additionally including the retail value of the commercial caught seafood sets up a comparison of apples and oranges so cannot be compared like this, as GVP for commercial seafood is only the wholesale value – not retail value as fishing tackle is.
Quote in PIA – Paragraph 8, Page 6
There was significant public consultation following the release of the Green Paper in 2016, with more than 11,000 submissions and 230 face to face meetings. There is an expectation that there will be changes to the system of managing Queensland’s fisheries.
How many were seafood consumers and food service industry who understood the ramifications of the proposals? At the time of the consultation they were saying that nothing was determined but that they were open to suggestions. Industry indicated their preferred option when it was finally put to them but the seafood consuming public had no say over whether they supported losing more of their access to wild catch seafood according to what is being rolled out to industry.
Quote in PIA – Paragraph 1, Page 7
The proposed changes to the Fisheries Act should not be contentious as none of the changes proposed will directly impact upon individual stakeholders economically or restrict access to fisheries resources.
This is a blatant misrepresentation of the facts to try to justify not doing a full RIS. The government always knew that fishers would be required to “buy back” their jobs by having to buy back a percentage of their earning capacity to keep their businesses viable. Every percentage of quota they remove from each species and in each fishery increases the amount each fishing business must reinvest just to remain doing what they’ve been doing before.
Author: Eric Perez, QSIA CEO
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