As a commercial fisher person for all of my working life I find it difficult to understand just how this “potential draft allocation” of quota actually works so I have coined the phrase “Ghost Quota” to address some of the confusion and concerns that not only I have but also a big percentage of fishers have as well. I will use the mud crab fishery as an example but more importantly, this also pertains to every fishery that is being forced into individual transferable quota (ITQ) by Fisheries Queensland (FQ).
We have been told that the total quota (ITQ) pool for the Mud Crab fishery is around 770 tonnes. To qualify to be able to claim the catch history share (on your primary licence) of this quota pool that we must have a C1 crab endorsement attached to the primary fishing licence by the 22 April. Most of us know, as do FQ, that there are nowhere near enough C1 endorsements to allow every primary licence with history to be able to claim their “potential allocation”, put simply, a percentage of licences will miss out on ITQ crab allocation.
An example of this is…
The total ITQ pool sits at 770 tonnes for Mud Crab. If there is 170 tonne potential quota allocation sitting on primary licence’s that will not have a C1 endorsement on them by the 22April, then the “Ghost Quota” is 170 tonnes that can not be claimed thus making the “real time” ITQ pool only 600 tonnes.
We (QSIA) posed the following questions to a principal fisheries manager (name withheld) on the 22 March 2021, these were the questions:
- From the total mud crab quota allocation pool of 770 tonnes as of today, how much of that pool can be claimed by primaries with a C1 attached?
- How many primary licenses as of today that have crab history attached but are not paired with C1 endorsement are able to claim that history?
- How much of the 770 tonnes to be allocated is actually unclaimable?
My reading of your correspondence to commercial mud crab and net fishers is that as of 22 April 2021 if you do not have a C1 or N endorsement on a licence with history it is deemed not claimable for quota. So, does unclaimed quota go back into the pool?
We (QSIA) never got an answer to any of these very real questions that are going to affect many fishing businesses. The only answer we got was this: ‘There are a number of factors that will determine the allocation of quota across the net and crab fisheries. It would be best perhaps to arrange a briefing session to explain the process. Let me know if you would like to do that’.
Well, isn’t that just magical. Here we are, approximately 4 years into this reform/quota process and the best FQ can do to answer business and life changing questions is to “meet for a briefing session”. If they have to meet to explain this to us now, then where has been the consultation with industry? Virtually non-existent and where has been the education for industry as to what is about to change some of our businesses and lives for ever?
Something worth noting, we offered the principal fisheries manager (name withheld) that sent the reply email the opportunity to speak with us on a podcast (in a safe space) to address these question and other questions regarding this reform/quota, an excellent opportunity to speak to our members as well as the wider industry, to date this offer has not been accepted. Many questions remain unanswered by FQ.
Symbol Trading and Tracking Catch History
Going back to when FQ started symbol trading within industry the assurance was given to licence owners by a well-known senior fisheries manager (name withheld), that the history would always be tracked on the symbol, some operators still have that in writing from FQ and there was never any investment warning on the symbol trading.
Years later when it was brought to the attention of the then fisheries minister, all of a sudden, we had an investment warning come out about symbol trading. It has become blatantly clear that FQ have done a backflip on their own policy, changing the goal posts to suit their own agenda which will cost licence owners millions of dollars, how does this stack up in a legal case? Time will tell.
Another glaring example is in the fact of offshore boats working numerous C1 endorsements on the one primary licence to be able to work up to 150 crab pots in the sand crab fishery under a general fisheries permit. I have absolutely no issue with those boats working extra pots, what I do have an issue with is how FQ went about the process.
The original deal with FQ to allow this to happen was that 3 primary licences were used (all of which had to have sand crab history on them), 2 of which went into limbo or “no boat” status and the 3 X C1 symbols went onto the one primary. The catch history was to be shared equally between the 3 primary licences, but it seems now that FQ have done yet another backflip there as well and left all the history/quota allocation on the one primary licence that was being used thus making the other 2 primaries that went into “no boat” status worthless with zero history allocation, is this fair or even legal in a court of law? Time will tell.
Another glaring example of fisheries mismanagement is the extending of the vessel size in certain quota managed fisheries. Boats that can and now do work any weather, never giving grounds a spell whereas when it was capped to a lot smaller size vessel the resource got a chance to have a break when the weather was too rough to work. This quota managed fishery is now down below 1/3 of the original quota holdings issued. Rough weather in essence was a form of “natural closure”. It begs the question, is FQ genuinely wanting to preserve and enhance our resource or are they pandering to the whims of a few of the bigger players? You be the judge.
Logbook Catch History
An even more concerning scenario is the fact that FQ have made the claim publicly that lies have been told in logbook reporting of catch history which equates to an increase in potential quota allocation. FQ know this is a problem through their own admission yet they have decided to “cap” each licence’s maximum quota allocation to combat this problem. Where did this advice come from? The crab working group? If so, then, what is the actual expertise of people on that working group?
Hard working crab fishers have been penalised for the catch effort they have put into their business’s, a simple example is this, in the logbooks for the crab fishery it asks, how many pots or dillies are used daily and how many lifts per day? When crabs are on the move or feeding more frequently some crabbers will work the morning tides and also the afternoon tides, working twice a day. The catch rate obviously increases, so these crabbers are being penalised in the form of maximum “catch caps” on their logbook history simply because they have worked twice as hard as some others, is this fair or even legal? Being penalised for working hard.
I have talked to numerous crab fishers (as well as being a crabber myself) and some years with the right wet seasons the catch rates are at least double what the caps have been set at. So, the caps in place do nothing to reflect the true catch history of good years in the fishery.
As an example, with my crab catch history I worked on the Queensland east coast for several years crabbing and then started working in the Gulf of Carpentaria crabbing. My catch history has therefore been spread over 6 years east coast and 6 years in the Gulf of Carpentaria, thus calculating my total allocation over 12 years and not 6 because you can’t possibly crab 2 places at once, again, is this fair or even legal? Time will tell.
Fisheries Working Groups
Around 2012 and the formation of a crab working group the entry criteria was that you had to be a working commercial fisher, own a primary licence and had to been fishing for a minimum of 7 years. Not all applicants qualified for the entry criteria. There were applicants that never qualified who did, however, get accepted as an observer. Now as the crab working group meetings advanced, FQ needed to develop a framework that would validate catch history which involved the volunteering of an observer. A grave concern I have is, did this volunteering observer have access to private and confidential logbook history? Information supplied by a long-term industry member who was on the crab working group.
Currently, governments and departments talk about equality and balance in the workplace. Why then is there only a couple of women on the working groups? I know it’s not because of lack of applicants.
I know several women with long-term histories in industry that applied for the working groups and never succeeded, FQ please explain.
Why is the seafood consumer being ignored, after all, without the seafood consumer none of us have a market for our product? The consumer has a right to have representatives on those working groups, but no provision has been made for this, FQ why not?
I know of numerous crab fishers with far more generational expertise that applied for the first round and also the latest round of crab working groups and were never successful, FQ, why were these people never accepted?
I still have many unanswered questions on behalf of industry for FQ, here are just a few.
- Does the unclaimable quota allocation get dived equally among the remaining quota holders?
- Why is there a reluctance by FQ to answer formally by email the simple questions posed to them?
- Does this “Ghost Quota” pertain to all fisheries that are being forced to ITQ (my guess is yes)?
- If the ITQ is not caught in any given year, does this affect or how will this affect the current quota holdings of fishers?
- Will fishers ITQ be “dialed down” over time, as we have seen with every other ITQ fisheries? Case in point, none have ever been lifted above the original ITQ holdings, gradually eroding the fisher’s ability to catch and making their business less profitable over time due to lost revenue.
- What happens to the catch history of licenses that do not have the relevant endorsement attached by the 22April? Does this history get wiped out, this potential quota holding being lost to the license owner forever?
As my personal point of view, many of us have seen and experienced dismal failures in quota fisheries both here and worldwide. I have studied quota fisheries worldwide, (far too many to count), and I can’t see this roll out being any different to anywhere else, many of the problems that exist in this framework are the same problems worldwide. FQ has been warned by industry repeatedly about the glaring flaws in ITQ but as usual our concerns are not noted. To go to quota on Mud Crab is beyond belief when a huge range of issues and questions from industry seem to have been ignored by the department. Why are our concerns being ignored?
The harvest of a single sex species, a large part of the biomass is in undersize male and female Mud Crab, which is not being considered, the enormous fecundity (breeding rate) of Mud Crabs, the amount of Mud Crab photos placed on social media by recreational fishers is staggering. The catch rates of recreational fishers are increasing rapidly despite what flawed boat ramp surveys. The enormous impact that good wet seasons have on Mud Crab populations, environmental influences etc.
All these factors, and there are many more, confirm the question ‘why the need to force us to ITQ?’ This is our last chance to stand up to this absurd and ridiculous so-called fisheries management. How many of you fishermen out there have been subjected to any or all of this BS coming from FQ? Stand up now people or be happy with whatever crumbs FQ decide to throw at you.
I have my own theories, and some might say I’m paranoid about so-called fisheries management, but I’ll let you be the judge. And as I have said before, in a court of law, time will tell.
Footnote: This article has used the mud crab fishery as an example only. QSIA has not forgotten about all the other fisheries and commercial fishers that we have which are under the same pressures from FQ. Most of us are only too familiar with the quota management in the Reef line fishery and the failure of quota management in the Spanner Crab fishery.
We are looking forward to pursuing FQ legally in a court of law and would urge anyone with any information that could help, any fishers that have been treated unfairly in the past or present or any comments on any of this to contact our CEO, Eric Perez.
Author: Shane Snow, QSIA Vice President
Image: Shane Snow
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