Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere)

Draft POSITION PAPER ON POSSESSION LIMITS BACKGROUND In recent years and particularly since 2011, there has been an increasing groundswell of concerns being raised in South Australia in relation to the, at the very least anecdotal, issue of fishers visiting regional SA and catching well in excess of what could be deemed a reasonable amount of fish for purely personal consumption. This Position Paper outlines the considered stance of the MFA on the matter and suggests what will hopefully be viewed by all legitimate parties involved as an appropriate solution to the matter. It is to be noted that the MFA conceptually supports government initiatives in this area, with the caveat that the final regulatory outcome does not impinge excessively on legitimate recreational fishing activities particularly where there are protracted trips involved. BASELINE OVERVIEW The current approaches to Possession Limit management in the geographically contiguous states of Victoria and Western Australia were considered and rejected as not being relevant to SA in terms of simplistically being used as templates for a local outcome. The reasoning was as follows; - The Victorian approach of ...while in, on or next to Victorian waters. does not address the very issues raised in SA with respect to stockpiling and transporting a large amount of fish. Nor does the effective interchangeability of the terms bag and possession limits. - The Western Australian regime was considered to be overly complicated (albeit understandably so given their particular circumstances) and was not considered an appropriate local carbon-copy solution. A weight limit per person approach was also discounted as an option for numerous reasons; - The requirement to provide for a weighing device. - The consideration that it would be conceivable to easily exceed a total per-person weight limit through catching only a few larger specimens of a particular species. - Given that the main area of concern appears to be fishing for excessive quantities of King George Whiting and Abalone, this of itself mitigates towards a quantity rather than weight limit approach. - The possibility that species/specimens specifically intended for use as bait during subsequent fishing trips would be included in any total weight-based limit. The suggestion of labelling any packs or containers of fish with the name of the owner is considered to be an unnecessary impost; the number of persons involved would have, by definition, a corresponding amount of maximum total quantity of fish in mutual possession at the time.

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere)
Draft MFA POSITION (Explanatory comments in italics) The permitted individual possession limit of any listed species within the State of South Australia (to which a Commercial Quantity limitation currently applies) shall be not more than twice the relevant boat limit for that species. This is not an unreasonable amount given that it represents six days of full bag or twelve days of half bag outcomes on a protracted (and in all likelihood once-a-year) recreational fishing trip to regional SA, with subsequent personal/family consumption over an extended period of time. The most pertinent example using current limits would be King George Whiting; daily bag limit 12 boat limit 36 possession limit 72 whole fish or 144 fillets Arguably not an excessive amount given ongoing subsequent family consumption over a period of months. Current specifications of what constitutes Commercial Quantity to be aligned via regulatory change with the Personal Possession Limit Quantity. Provides for a logical consistency of approach. Possession Limits will apply throughout the whole of SA, including the principal residence. This addresses the main concern regarding catching, storing and transporting excessive quantities of fish. Note that labelling will not prevent rorting in storage within a principal residence environment, and is thus an unnecessary impost. Principal residence included for enforcement action purposes in the, most likely, rare instances of an information received situation. Any accommodation or travel in company will be acknowledged as a legitimate circumstance for storing or transporting any number of fish not greater than the sum of the individual possession limits. Addresses the issue of several fishers having one storage facility. Persons travelling in vehicles which are in convoy, or essentially in convoy, will be deemed to have complied with the preceding requirement. Example four people in two cars but only one freezer. Any whole fish or fillets shall be packaged on an individual species basis, and in such a manner that the number of whole fish or fillets can be readily ascertained by visual inspection. Self-explanatory, for ease of enforcement. Any sections of fillets of larger specimens, which have to be reduced in size for the purposes of storage or transport, will be deemed to be individual fillets. Apart from simplifying enforcement, this provides for a de facto additional catch-reducing effect. Any one cutlet or section of fillet will be deemed to be a fillet for possession limit purposes. The MFA acknowledges this is a potential issue of equity and fairness in the case of larger specimens, however it is to be noted that effectively the only other alternative then becomes a weight-based limit.

Metropolitan Fishers Alliance

(Live Metro - Fish Everywhere)
Where there is any region-specific difference in permissible boat limits (for instance the varying snapper quantities in the gulfs versus elsewhere) the lower boat limit shall be the one utilised as the basis for determining the possession limit. Simplification of enforcement and potentially provides for a de facto catch-reducing effort whilst still facilitating an acceptable take-home outcome. The Snapper Possession Limit would thus be derived on the basis of 2x 6 large snapper plus 2x 15 small snapper ie 42 fish in total or 84 fillet sections There shall be no mincing permitted prior to returning to the principal residence, in order to facilitate enforcement. Self-explanatory and once again raises the issue of a weight-based limit as the only other option. Skin shall be left on all fillets for transporting to the principal residence, in order to facilitate enforcement. Self-explanatory. Possession Limits will apply to any person age 16 or over. This will acknowledge a holiday fishing demographic (ie slightly older friends with cars) whilst preventing potential rorting of the system whereby, for instance, a couple with two pre-teen children would otherwise be entitled to four full possession limits. The Possession Limit for a person under 16 years of age shall be the relevant daily bag limit. Follows on from the previous item and is a logical solution to fishers under 16 years of age being able, for instance, to walk from jetty to home whilst in possession of fish in the new regulatory regime To conclude, the MFA acknowledges the PIRSA 2011 Possession Limits Options Paper as having been well-considered and a good starting point for discussion.