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Assessment of the NSW Sea Urchin and

Turban Shell Fishery

Assessment of the NSW Sea Urchin and Turban Shell Fishery

Published by the NSW Department of Primary Industries

Assessment of the NSW Sea Urchin and Turban Shell Fishery - Prepared for the Department of the

Environment for the purpose of assessment under Part 13 and 13(A) of the Environment Protection

and Biodiversity Conservation Act 1999

First published August 2018

More information

Fiona McKinnon, Fisheries NSW

www.dpi.nsw.gov.au

OUT18/11264

© State of New South Wales through the Department of Industry, 2018. You may copy, distribute and otherwise freely deal with this publication for any purpose, provided that you attribute the NSW Department of Primary Industries as the owner.

Disclaimer: The information contained in this publication is based on knowledge and understanding at the time of writing (August 2018). However, because of advances in knowledge, users are reminded of the need to ensure that information upon which they rely is up to date and to check currency of the information with the appropriate officer of the Department of Primary Industries or the user’s independent adviser.


2 | NSW Department of Primary Industries, August 2018

Contents

1 Introduction ....................................................................................................................................................... 4

2 Description of the fishery ............................................................................................................................. 5

2.1 Species ............................................................................................................................................................ 5

2.1.1 Sea Urchin ............................................................................................................................................ 5

2.1.2 Turban shell ......................................................................................................................................... 5

2.2 Method of harvesting................................................................................................................................ 5

2.3 Fishing area ................................................................................................................................................... 5

2.4 Management arrangements ................................................................................................................... 6

2.4.1 Input controls ...................................................................................................................................... 6

2.4.1.1 Limited Access ................................................................................................................................ 6

2.4.1.2 Area closures ................................................................................................................................... 6

2.4.2 Output controls .................................................................................................................................. 6

2.4.2.1 Quota management ..................................................................................................................... 6

2.4.2.2 Size limits ......................................................................................................................................... 6

2.5 Number of fishers ....................................................................................................................................... 6

2.6 Allocation between sectors ..................................................................................................................... 6

2.6.1 Recreational fishing .......................................................................................................................... 7

2.6.2 Aboriginal cultural fishing .............................................................................................................. 7

2.6.3 Policy for Fisheries Resource Sharing in NSW ........................................................................ 7

2.7 Governing legislation ................................................................................................................................ 7

3 Management ..................................................................................................................................................... 8

3.1 Licensing arrangements ........................................................................................................................... 8

3.1.1 Licensing conditions specific to SUTS endorsements .......................................................... 8

3.1.2 NSW Commercial Fisheries Administration Guide ................................................................ 9

3.2 Legislation...................................................................................................................................................... 9

3.2.1 Fisheries Management (General) Regulation 2010 ............................................................... 9

3.2.1.1 Real time quota reporting ....................................................................................................... 10

3.3 Fishing closures ......................................................................................................................................... 10

3.3.1 Intertidal Protected Areas ............................................................................................................. 12

3.4 Total allowable commercial catch ...................................................................................................... 13

3.5 Marine estate reforms ............................................................................................................................. 13

3.5.1 NSW Marine Estate Management Strategy ........................................................................... 13



3.5.2 Hawkesbury Shelf marine bioregion assessment ................................................................ 14

3.6 Compliance ................................................................................................................................................. 14

3.6.1 Compliance rates ............................................................................................................................. 15

3.7 Consultation processes ........................................................................................................................... 16

3.7.1 Ministerial Fisheries Advisory Committee .............................................................................. 16

3.7.2 Commercial Fishing NSW Advisory Council .......................................................................... 16

3.7.3 Working groups ............................................................................................................................... 16

3.7.4 Total Allowable Fishing Committee .......................................................................................... 17

3.8 Cross jurisdictional management arrangements .......................................................................... 17

3.9 Interaction with threatened or protected species ........................................................................ 17

3.9.1 Frequency and nature of interactions ...................................................................................... 17

3.9.2 Management actions taken to reduce interactions and results of such actions ..... 17

3.9.3 Compliance with TAPs, recovery plans, etc. and also relevant domestic and

international arrangements ............................................................................................................................ 17

4 Research and Monitoring ........................................................................................................................... 18

4.1 Research priorities .................................................................................................................................... 18

4.2 Results of any research completed relevant to the fishery ....................................................... 18

4.3 Monitoring programs .............................................................................................................................. 18

4.3.1 Resource Assessment Framework ............................................................................................. 18

4.3.2 Collection of catch and effort data ........................................................................................... 19

4.3.3 Port monitoring ................................................................................................................................ 19

5 Catch data ........................................................................................................................................................ 19

5.1 Total catch and value of the SUTS Fishery ...................................................................................... 19

5.2 Harvest by each sector............................................................................................................................ 20

5.2.1 Recreational fishing ........................................................................................................................ 20

5.2.2 Aboriginal cultural fishing ............................................................................................................ 20

5.2.3 Illegal fishing ..................................................................................................................................... 20

6 Status of target stock ................................................................................................................................... 21

7 Impacts of the fishery on the ecosystem.............................................................................................. 21

7.1 Results of any Ecological Risk Assessments ................................................................................... 21

7.2 Management actions taken to reduce the impacts ..................................................................... 22

8 Report against SUTS Fishery conditions and recommendations of WTO declaration ........ 23

9 References ........................................................................................................................................................ 25

Appendix 1 ................................................................................................................................................................ 26



1 Introduction This submission has been prepared by the NSW Department of Primary Industries (NSW

DPI) on behalf of endorsement holders in the NSW Sea Urchin and Turban Shell Restricted

Fishery (the SUTS Fishery) in order to assist industry to obtain export approval by leveraging

off the comprehensive legislative and policy framework for fisheries management in NSW.

The following provides a report of the SUTS Fishery for assessment under Part 13 and Part

13(A) of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

Information provided is based on the headings contained within Appendix B of the Guidelines

for the Ecologically Sustainable Development of Fisheries – 2nd Edition and, consistent with

these guidelines, this submission references sections of related documents.

Table 1: Summary of the SUTS Fishery

Area NSW waters

Management Controls Limited entry

Total allowable commercial catch applied to red sea urchins only

Minimum size limits

Regulated closed waters

Target species Purple sea urchin (Centrostephanus rodgersii)

Red sea urchin (Heliocidaris tuberculata)

Fishing units 37 fishing businesses

Catch (2017) Purple sea urchin – 79.7 tonnes (t)

Red sea urchin – 19 t

Military turban shell – 6.6 t

Sydney turban shell – 2 t

Other Turban shell – 5.2 t

Value (2017) $742,072

Stock Status Purple sea urchin – Moderately Fished

Green sea urchin – Uncertain

Red sea urchin – Uncertain

Turban shells – Undefined



2 Description of the fishery The commercial harvest of sea urchins and turban shells is managed as one fishery in NSW.

For the purposes of this submission, the fishery comprises the Sea Urchin and Turban Shell

Restricted Fishery as declared under Division 1 of Part 9 of the Fisheries Management

(General) Regulation 2010 (the FM(G) Regulation) and pursuant to section 111 of the Fisheries

Management Act 1994 (the FM Act).

2.1 Species

2.1.1 Sea Urchin

There are three main species of sea urchin found in NSW that are targeted by the SUTS

Fishery:

• Purple sea urchin Centrostephanus rodgersii

• Red sea urchin Heliocidaris tuberculata

• Green sea urchin H. erythrogramma

The main target species are C. rodgersii and H. tuberculata, with only small commercial

catches of H. erythrogramma recorded.

2.1.2 Turban shell

Two species provide the majority of the commercial harvest of turban shells in NSW, the

Sydney turban shell (Turbo torquatus) and the Military turban shell (T. militaris). A third

species, the green turban shell (T. undulatus), is less commonly taken.

2.2 Method of harvesting

Commercial fishers dive for sea urchins and turban shells using mainly surface supplied

compressed air (hookah). Because of their shallow habitat, turban shells are sometimes taken

by free diving. Sea urchins are removed using a hook, whilst turban shells are taken by hand.

Most fishing operations comprise a diver and deck-hand/compressor operator. Some fishers

operate alone, particularly free divers.

2.3 Fishing area

Sea urchins and turban shells may be taken commercially and recreationally in all NSW

waters except for those waters, as specified in the FM (G) Regulation, in which the taking of

sea urchins and turban shells are prohibited (refer to 3.3 Fishing closures below).

The SUTS Fishery is also subject to a range of spatial closures arising from the comprehensive

network of marine protected areas that include marine parks (pursuant to the NSW Marine

Parks Act 1979), aquatic reserves and intertidal protected areas (pursuant to the FM Act).



2.4 Management arrangements

The SUTS Fishery is managed under the FM Act and regulations made under this Act. NSW

DPI is the State Government agency responsible for the administration of the FM Act. The

SUTS Fishery is managed by a combination of input and output controls.

2.4.1 Input controls

2.4.1.1 Limited Access

Access to the SUTS Fishery is limited to fishing business owners that are eligible for an

endorsement (authorising the take sea urchin and/or turban shell) in the fishery, or their

nominated fisher. Only one person is eligible for an endorsement in respect of each fishing

business.

2.4.1.2 Area closures

A number of fishing sub-zones have been closed to the SUTS Fishery since 1994 to provide

reference points for stock assessment purposes and as refugia (refer to 3.3 Fishing closures

below). There are no seasonal closures.

2.4.2 Output controls

2.4.2.1 Quota management

The commercial harvest of red sea urchins is subject to an annual Total Allowable

Commercial Catch (TACC) of 60 tonnes. The TACC is set by the statutory and independent

Total Allowable Fishing Committee (the TAF Committee) established under the FM Act. The

TACC is divided equally between all endorsement holders in the SUTS Fishery and the

resulting individual quotas are allocated on an annual basis.

2.4.2.2 Size limits

There is currently no minimum or maximum size limit for the three species of sea urchins.

A minimum size limit of 75 mm (shell diameter) applies to Sydney and Military turban shells.

2.5 Number of fishers

There are currently 37 fishing businesses with endorsements to operate in the SUTS Fishery,

with 26 of those fishing businesses reporting catch in 2017.

2.6 Allocation between sectors

Sea urchin and turban shell are not permitted to be taken in any other NSW commercial

fishery.



2.6.1 Recreational fishing

Limitations on the capture of all sea urchin and turban shell species are employed to

minimise localised depletion caused by recreational harvesting. Recreational fishers are

subject to a bag limit of 10 sea urchins (all species combined), and bag and size limits exist

for all species of molluscs, to which the turban shell family relate, including a limit of 20 of

any species or a combination of any species and a minimum size limit of 75 mm shell

diameter (for Sydney and military turban shells). Intertidal Protected Areas (IPA) have also

been established in nine areas around Sydney to protect selected rocky habitats and

intertidal species.

2.6.2 Aboriginal cultural fishing

Aboriginal cultural fishing is defined in the Act as “fishing activities and practices carried out

by Aboriginal persons for the purpose of satisfying their personal, domestic or communal

needs, or for educational or ceremonial purposes or other traditional purposes, and which do

not have a commercial purpose”. Daily cultural fishing needs are currently provided for by the

Aboriginal Cultural Fishing Interim Access Arrangement which allows for extended bag and

possession limits, as well as other special arrangements, for cultural fishing activities. Special

provisions also exist under the Act to accommodate access to fisheries resources beyond

what the current cultural fishing rules provide for (for events such as for a large cultural

gathering or ceremonies).

Aboriginal cultural fishing activity and possession of fish and/or fishing gear must comply

with the current fisheries legislation i.e. size limits of fish as prescribed in the FM (G)

Regulation apply to Aboriginal cultural fishing activities. Further information can be found on

the NSW DPI website at www.dpi.nsw.gov.au/fishing/aboriginal-fishing

2.6.3 Policy for Fisheries Resource Sharing in NSW

The Ministerial Fisheries Advisory Council (MFAC) has developed the policy Fisheries

Resource Sharing in NSW to assist decision making on sharing the State's sustainably

exploitable fisheries resources between the various commercial, recreational, charter and

Aboriginal cultural fishing sectors in accordance with the objects of the Act. Further

information can be found on the NSW DPI website at

www.dpi.nsw.gov.au/fishing/consultation/fisheries-resource-re-allocation-proposals

2.7 Governing legislation

Relevant current legal instruments include the Fisheries Management Act 1994 and the

Fisheries Management (General) Regulation 2010.



3 Management

3.1 Licensing arrangements

3.1.1 Licensing conditions specific to SUTS endorsements

Licensing conditions are applied to a fishery where there is a need to further clarify aspects of

the management of the fishery to ensure sustainability and provide compliance-based

provisions. Table 2 describes the licensing conditions specific to the SUTS Fishery.

Table 2: Licensing conditions specific to the SUTS Fishery

(a) Not on any day undertake any fishing activity unless he/she has contacted the local fisheries office prior to leaving port and reported his/her intended fishing location that day and from which boat ramp the boat will be launched.

(b) Carry a suitable measuring device when in possession of, or when attempting to take turban shell, to facilitate compliance with the prescribed minimum size.

(c) Upon returning to port, contact the local fisheries office to inform them of the location and time of landing and approximate catch.

(d) The license holder shall not permit any abalone endorsement holder to operate from an LFB being used by the license holder, unless the license holder is also endorsed in the Abalone Fishery.

(e) Not use an unlicensed crew member in a boat being used by the endorsement holder for the taking of sea urchins or turban shell, except to operate the boat or other equipment on the boat.

Note: an unlicensed crew member is not authorised to take sea urchin or turban shell from the fishery on the endorsement holder’s behalf.

(f) Not, within the waters to which this Act applies, or on or in any waters adjacent thereto, transfer sea urchin or turban shell from one boat to another boat.

(g) Not on any day undertake any fishing activity unless a DPI Sea Urchin and Turban Shell Fishery Catch and Effort Report for that day is in his/her possession.

(h) On each day that fishing activity under the endorsement is conducted, complete and submit within 24 hours of the end of the day one or more DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Records as issued to the fishing business owner by NSW DPI for that activity according to these conditions and the instructions issued with the catch and effort record forms.

(i) Upon landing red urchin, Fishing Business identifying information and Part A of the DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Record must be completed for the red urchin catch before the catch leaves more than 50m from the point of landing at the shore.

(j) Not loan, give or make available in any fashion to any other person/s DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Records issued to his/her possession.

(k) At all times keep DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Records in a safe place.

(l) In the event of any DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Record books or used DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Records being stolen, lost,



destroyed or damaged, immediately notify the Director-General in writing.

(m) Ensure that completed daily DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Records are returned to DPI within 24 hours of the weight of the catch being validated.

(n) Not on any day be in possession of any sea urchin or turban shell after such sea urchin or turban shell have been landed in NSW unless these sea urchin or turban shell are accompanied by a DPI Sea Urchin and Turban Shell Fishery Daily Catch and Effort Record completed in the required form.

(o) Comply with DPI research requirements for daily recording of information for research purposes, as arranged with DPI Researchers.

(p) Not, while using any apparatus to facilitate breathing underwater, or while such equipment is on any vessel, take or attempt to take rock lobster by any method, nor have any rock lobster in his/her possession.

(q) Not, while using any apparatus to facilitate breathing underwater, or while such equipment is on any vessel, take or attempt to take abalone by any method, nor have abalone in his/her possession, unless endorsed in the Abalone Fishery.

(r) At all times comply with the requirements of the Act and the Regulations made under the Act and abide by any instruction relating to the operation of this endorsement, given by an officer of NSW DPI.

(s) Not exercise the right to take sea urchin or turban shell for commercial purposes until the conditions of the license have been read and understood.

3.1.2 NSW Commercial Fisheries Administration Guide

The NSW Commercial Fisheries Administration Guide summarises the administrative

arrangements for commercial fisheries in NSW and has been developed for people who

operate in the NSW commercial fishing industry and anyone else who has an interest in the

way it is managed. In particular, the guide aims to explain licensing requirements for

commercial fishing activities in NSW, and processes relevant to important administrative

transactions. The NSW Commercial Fisheries Administration Guide, January 2012, on the NSW

DPI website at www.dpi.nsw.gov.au/__data/assets/pdf_file/0009/370818/NSW-Commerical-

Fisheries-Administration-Guide.pdf

3.2 Legislation

3.2.1 Fisheries Management (General) Regulation 2010

Clauses 154 – 166 of the FM (G) Regulation provide the specific legislative arrangements

under which the SUTS Fishery is defined. In summary the provisions include:

• Definitions of endorsements, endorsement holders, entitlement holders, nominated

fishers and quota.

• Declaration of the SUTS fishery as a restricted fishery.

• The classes of endorsements in the restricted fishery (sea urchin or turban shell).

• Eligibility criteria for endorsement in the restricted fishery.

• Provisions for further entry into the fishery by way of public tender.



• Provision for the nomination of a person to act as a nominated fisher on behalf of an

entitlement holder.

• Provisions relating to the endorsement of commercial fishing licenses and grounds for

refusal of an endorsement (previous convictions, failure to pay fees etc).

• Duration of an endorsement in the restricted fishery.

• Provisions for the cancellation or suspension of an endorsement (previous convictions,

failure to pay fees etc).

• Provisions for the determination of a Total Allowable Catch (TAC) by the TAF Committee.

• Provision for the establishment of quotas in the SUTS Fishery for the equitable allocation

of TAC.

• Provisions and administrative procedures for the transfer of quota between entitlement

holders.

• Special licence conditions for licence holders who nominate fishers to ensure the

nominated fish acts within the management provisions of the restricted fishery.

• Waters closed to harvesting of sea urchins and turban shells.

• Pre-fish and post land reporting requirements (refer to 3.2.1.1 Real time quota reporting

below).

3.2.1.1 Real time quota reporting

As of 1 December 2017 fishers are required to report fishing activity and quota usage in real

time using the FisherMobile App on a mobile device. Fishers are required to use FisherMobile

to make a pre-fish report before leaving port or launching place and, if red sea urchins are

taken, the fisher must make a post-land report, reporting the validated weight (total weight

of red urchin to one decimal place).

The post-land report must be made:

1. within 30 minutes and 50m from the point of landing;

2. before transferring red sea urchin into another boat, vehicle, or premises; and

3. before any red sea urchin are moved from NSW.

3.3 Fishing closures

For management and stock assessment purposes, NSW has been divided into five fishing

regions as described in Table 3.

Table 3: Geographical areas of the SUTS Fishery management regions

Region Area

Region 1 Tweed Heads to Newcastle

Region 2 Newcastle to Currarong

Region 3 Currarong to Brush Island

Region 4 Brush Island to Narooma

Region 5 Narooma to Cape Howe



These regions are further divided into sub-zones for management purposes (See Appendix 1

for a schedule of sub-regions). A number of the fishing sub-regions have been closed to

commercial SUTS fishing since 1994 to provide reference points for stock assessment

purposes and as refugia. Coinciding with the introduction of a TACC for red sea urchins in

2002, changes were made to the system of fishing closures applied to the SUTS Fishery. New

fishing closures were introduced in areas previously subjected to intensive fishing and new

areas opened, particularly in Region 1 and 2, to spread effort along the coast.

Table 4: Waters closed to the taking of sea urchin and turban shells

Sub-zone Description

Sandon to Red Rock The whole of the waters between a line drawn east from the point 153°19′57.9648″ east, 29°40′25.8456″ south, and a line drawn east from the point 153°14′03.4764″ east, 29°58′52.014″ south.

Red Rock to Coffs Harbour The whole of the waters between a line drawn east from the point 153°14′03.4764″ east, 29°58′52.014″ south, and a line drawn east from the point 153°09′11.6064″ east, 30°18′31.8888″ south.

Seal Rocks to Broughton Island The whole of the waters between a line drawn east from the point 152°32′09.9384″ east, 32°26′02.3964″ south and a line drawn east from the point 152°17′16.75″ east, 32°35′25.0044″ south.

Ex-HMAS Adelaide Reserve The whole of the waters enclosed by the following coordinates: (a) 33°27.887′ S and 151°27.301′ E, (b) 33°27.767′ S and 151°27.374′ E, (c) 33°27.852′ S and 151°27.574′ E, (d) 33°27.973′ S and 151°27.502′ E.

Broken Bay to Sydney Harbour The whole of the waters between a line drawn east from the point 151°19′43.8888″ east, 33°34′40.7532″ south, and a line drawn east from the point 151°16′51.2508″ east, 33°49′58.152″ south.

Sydney Harbour to Bondi Beach The whole of the waters between a line drawn east from the point 151°16′51.2508″ east, 33°49′58.152″ south, and a line drawn east from the point 151°16′37.146″ east, 33°53′30.9696″ south.

Bondi Beach to Botany Bay The whole of the waters between a line drawn east from the point 151°16′37.146″ east, 33°53′30.9696″ south, and a line drawn east from the point 151°13′19.992″ east, 34°00′05.364″ south.

Bombo Beach to Werri Beach The whole of the waters between a line drawn east of the point 150°51′23.0616″ east, 34°39′26.8029″ south and a line drawn east of the point 150°50′06.7020″ east, 34°44′04.1820″ south.

Currarong to Point Perpendicular The whole of the waters between a line drawn east from the points 150°49′20.4636″ east, 34°58′58.6668″ south, and 150°49′20.4636″ east, 35°00′49.5396″ south and a line drawn east from the point 150°48′16.236″ east, 35°05′39.9084″ south.

Inside Jervis Bay The whole of the waters between a line drawn east from the point 150°48′16.236″ east, 35°05′39.9084″ south, and a line drawn east from the point 150°46′06.0456″ east, 35°06′43.992″ south.

Malua Bay to Burrewarra Point The whole of the waters between a line drawn east from the point 150°13′51.1356″ east, 35°47′34.5696″ south, and a line drawn east from the point 150°14′07.7244″ east, 35°50′06.0324″ south.

Cuttagee Point to Thibbul Inlet (Murrah)

The whole of the waters between a line drawn east from the point 150°03′18.2196″ east, 36°29′16.6056″ south and a line drawn east from the point 150°03′27.1296″ east, 36°31′32.7576″ south.



Sub-zone Description

Bithry Inlet to Barounda Inlet The whole of the waters between a line drawn east from the point 150°01′12.2052″ east, 36°37′46.8768″ south, and a line drawn east from the point 149°59′41.7444″ east, 36°41′09.3264″ south.

Mowarry Point to Saltwater Beach The whole of the waters between a line drawn east from the point 150°00′16.5996″ east, 37°08′29.1552″ south, and a line drawn east from the point 150°00′11.484″ east, 37°10′10.8336″ south.

Black Head Anchorage to Nadgee Lake

The whole of the waters between a line drawn east from the point 149°58′21.5148″ east, 37°26′26.358″ south, and a line drawn east from the point 149°58′21.1764″ east, 37°27′54.9648″ south.

Other fishing closures authorised under Section 8 and Section 11 of the FM Act specific to

the SUTS Fishery can be found on the NSW DPI website at

www.dpi.nsw.gov.au/fisheries/info/closures/commercial/suts

3.3.1 Intertidal Protected Areas

Intertidal protected areas (IPAs) have been established to protect selected rocky habitats and

intertidal species. They aim to:

• protect intertidal community biodiversity and structure;

• provide biological reservoirs of breeding stock so exploited areas nearby can be

recolonized or sustained; and

• help ensure harvesting of intertidal invertebrates is undertaken at sustainable levels.

All IPAs extend from the mean high water mark to 10 meters seaward from the mean low

water mark. Collecting seashore animals, such as turban shells and sea urchins is prohibited.

Figure 1: Intertidal Protected Areas in NSW



3.4 Total allowable commercial catch

The TAF Committee first determined a TACC of 60 tonnes for red sea urchins for the period 1

January to 31 December 2002 and in each subsequent calendar year. The TACC is allocated

equally to each endorsement in the SUTS Fishery. The TACC is capped in proportion to the

estimated biomass in each of the five management regions (Table 5).

Table 5: Regional distribution of red sea urchin TACC

Region Area Sub-zones Annual TACC (kilograms)

Region 1 Tweed Heads to Newcastle A – F2 8,000

Region 2 Newcastle to Currarong F3 – L1 28,000

Region 3 Currarong to Brush Island L2 – N3 13,000

Region 4 Brush Island to Narooma P1 – S3 11,000

Region 5 Narooma to Cape Howe T1 – Z5 0

A fishing closure authorised under Section 8 of the FM Act currently prohibits the harvest of

red sea urchins in Region 5 of the SUTS Fishery giving effect to the TAF Committee’s

recommendation of 0 tonnes for this region.

3.5 Marine estate reforms

The NSW marine estate includes the ocean, estuaries, coastal wetlands (saltmarsh, mangroves

and seagrass), coastline including beaches, dunes and headlands, coastal lakes and lagoons

connected to the ocean and islands including Lord Howe Island. It extends seaward out to

three nautical miles and from the Queensland border to the Victorian border.

In March 2013, in response to the Report of the Independent Scientific Audit of Marine Parks

in NSW, the NSW Government announced a new approach to managing the marine estate,

driven by two new advisory bodies established under the Marine Estate Management Act

2014 - the Marine Estate Management Authority (MEMA) to oversee management of the

marine estate with expert advice from the independent Marine Estate Expert Knowledge

Panel.

The MEMA developed a Threat and Risk Assessment Framework to provide a robust and

transparent process for identifying threats and risks to the marine estate. The framework

outlines how to conduct assessments to account for threats and risks to environmental,

economic and social benefits associated with the marine estate that contribute to community

wellbeing.

3.5.1 NSW Marine Estate Management Strategy

In 2017 MEMA released the NSW Marine Estate Threat and Risk Assessment Report (TARA), a

state-wide threat and risk assessment for the NSW marine estate. A draft Management

Strategy was released for public engagement in late 2017, responding to the priority threats

identified in the TARA and provided a framework to coordinate the management of the

marine estate over the next ten years. The final Strategy will be released late 2018 together



with an implementation plan and Marine Integrated Monitoring Program that will monitor

the progress of the Strategy’s actions and address key knowledge gaps.

3.5.2 Hawkesbury Shelf marine bioregion assessment

MEMA has completed an assessment of the Hawkesbury Shelf marine bioregion. The

assessment identified social, economic and environmental benefits derived by the community

from the marine estate; identified threats and risks to those benefits; evaluated current

management arrangements; and developed suggested management initiatives to address

threats to marine biodiversity while maximising community benefits. Further information can

be found on the NSW Marine Estate website at www.marine.nsw.gov.au/nsw-marine-estate

3.6 Compliance

The Fisheries Compliance Unit (FCU) is focused on optimising compliance with the Act, the

Marine Estate Management Act 2014 and their associated regulations. The FCU uses project

tasks and sub-programs, covering functional areas such as aquaculture and commercial

fishing, to achieve risk-based regulation and compliance objectives through education and

enforcement. The FCU is separated into seven geographic compliance zones, with a State-

wide Operations and Investigations Group that undertakes major/complex investigations, and

the Conservation and Aquaculture Group that provides specialist capabilities in aquatic

habitat compliance management. The FCU also provides compliance services to five of the six

marine parks in NSW. The FCU monitors compliance and detects around 7,000 offences per

year. Prosecutions are an important tool in providing effective deterrence and are also

managed by the FCU, utilising a detailed prosecution management and review process.

The FCU has consistently demonstrated its ability to operate as an effective, safe and

innovative regulator, dealing with a large and sectorial client base. The FCU operates across a

geographically wide, challenging and inherently dangerous environment with many ‘moving’

targets. It has also shown its operational flexibility recently in performing non-traditional

operational and technical roles, including significant contributions to shark mitigation

strategies to help address broader NSW Government initiatives. The FCU contribute to a

range of national and international fisheries compliance forums to help develop strategies to

combat illegal, unregulated and unreported fishing.

NSW DPI Fisheries Compliance Plans are regularly reviewed for progress against the

objectives of the Australian Fisheries National Compliance Strategy (AFNCS). The AFNCS

is used as a reference in developing local compliance strategies and plans to ensure a

consistent approach to fisheries compliance throughout Australia complementing

the National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported and

Unregulated Fishing.

In July 2016 the Department for Industry created a Resources Regulator to undertake

compliance and enforcement for a broad range of activities in the resource sector, including

commercial and recreational fishing.

The Resources Regulator Advisory Committee has been established to oversee and advise on

major enforcement actions, providing confirmation to the community that these matters are

conducted under law and without fear or favor. The FCU have briefed the Committee on the



regulatory approach of NSW DPI Fisheries Compliance and the opportunities for

improvement.

The FCU are early adopters of the Quality Regulatory Services Initiative (QRSI), and the design

of Fisheries Annual District Compliance Plans has been reviewed and revised several times, to

improve its effectiveness as an outcomes-focused fisheries compliance management tool.

Recent efforts in developing an 'analytics' environment have also allowed the FCU to better

identify changes in compliance activity and outcomes over time. Regular analysis of

compliance data is undertaken to review the effectiveness of compliance initiatives.

The FCU is currently developing a monthly performance reporting framework to provide

more detailed information on their compliance and enforcement activities by sector. The FCU

also features regularly at QRSI-based workshops and forums.

To support risk-based compliance, functionality has been embedded into business processes

(i.e. inspections) to identify and address knowledge gaps in fishing rules, support for fisheries

management arrangements and reasons for non-compliance. These insights have been

converted to actions addressing damaging behaviours through education and targeted

enforcement.

A copy of the Fisheries Compliance Enforcement Policy and Procedure can be found on the

NSW DPI website at www.dpi.nsw.gov.au/__data/assets/pdf_file/0010/639874/Fisheries-

compliance-prosecution-policy-and-procedure.pdf

3.6.1 Compliance rates

Compliance with the fisheries legislation is measured by analysis of data recorded in fisheries

patrols and operations. Rate of compliance in the SUTS Fishery are shown in Table 6 and 7.

Table 6: Compliance rates in the SUTS Fishery

Year Compliance

Rate

Total contacts Comply Non-Comply

2015 33.3% 21 7 14

2016 23% 39 9 30

2017 40.5% 37 15 22

Total 97 31 66

Table 7: Compliance action in the SUTS Fishery

Compliance action Number Percentage

Field caution 26 32.5%

Cancellation – no action 17 21.3%



Compliance action Number Percentage

Infringement notice 14 17.5%

Prosecution 12 15%

Verbal caution 11 13.8%

3.7 Consultation processes

New consultation arrangements for NSW commercial fisheries were introduced in November

2012 following the Independent Report into NSW Commercial Fisheries Policy, Management

and Administration.

3.7.1 Ministerial Fisheries Advisory Committee

The Ministerial Fisheries Advisory Committee (MFAC) has been established to provide the

Minister for Primary Industries with high-level strategic policy advice on issues relating to the

management of fisheries resources in NSW. This will include broad advice to assist with the

management of commercial fishing, recreational/charter fishing and Aboriginal cultural

fishing as well as issues which impact across fisheries and sectors such as resource sharing,

co-management, cost recovery and ecosystem based fisheries management.

3.7.2 Commercial Fishing NSW Advisory Council

The Commercial Fishing NSW Advisory Council (Commfish NSW) has been established to

provide greater industry representation and input to the Minister for Primary Industries on

strategic and policy issues relating to the commercial fishing industry in NSW.

The Council operates under a Charter which sets out the objectives and mode of operation of

the Council and the roles and responsibilities of members. Further information can be found

on the NSW DPI website at www.dpi.nsw.gov.au/fishing/consultation/ccfnswac

3.7.3 Working groups

Task based working groups are formed on an as needs basis to provide expert advice on

specific issues. Once the task assigned to the working group is complete the working group

will be disbanded. Working group members are appointed by the Deputy Director General,

DPI Fisheries based on skill and expertise relevant to the tasks assigned to the working group.

The policy Fisheries non-statutory working groups: Establishment and Governance is designed

to ensure that working groups are established and operated in a consistent, efficient and

effective manner in line with best practice governance arrangements. Further information can

be found on the NSW DPI website at www.dpi.nsw.gov.au/fishing/commercial/consultation



3.7.4 Total Allowable Fishing Committee

The TAF Committee has responsibility under the Act for determining the annual TACC for the

SUTS Fishery.

The TAF Committee calls for public submission on the appropriate TACC under the

requirements of the Act. SUTS Fishery fishing business owners and endorsement holders,

relevant industry and community bodies and the community are invited to make submissions

on the TACC.

The TAF Committee obtains input from participants in the TACC Committee Open Forum and

receives written reports from:

• DPI Commercial Fisheries Management

• DPI Fisheries Compliance

• DPI Fisheries Research

• Participants in the SUTS Fishery

Public submissions and presentations to the TAF Committee are invited in the Open Forum

Meeting. Confidential submissions are not discussed publicly and the TAF Committee is able

to call for “in-camera” discussions, where appropriate.

3.8 Cross jurisdictional management arrangements

No formal cross jurisdictional management arrangements exist.

3.9 Interaction with threatened or protected species

3.9.1 Frequency and nature of interactions

Refer to the report Broad-scale interactions between fishing and mammals, reptiles and birds

in NSW marine waters (Ganassin and Gibbs, 2005).

The method used to harvest urchin and turban shell (by hand) in the SUTS Fishery is target

specific and there is likely to be little adverse interaction between the fishery and threatened

or protected species, or threatened ecological communities.

3.9.2 Management actions taken to reduce interactions and results of such

actions

Given the selective harvesting method used in the SUTS Fishery no specific risks have been identified that require a management action.

3.9.3 Compliance with TAPs, recovery plans, etc. and also relevant domestic

and international arrangements

None of direct influence in the SUTS Fishery



4 Research and Monitoring

4.1 Research priorities

Refer to ‘Fisheries NSW Strategic Research Plan 2014 – 2018’ available on the NSW DPI

website at www.dpi.nsw.gov.au/ data/assets/pdf_file/0020/423524/Planning-Strategic-

Research.pdf

4.2 Results of any research completed relevant to the fishery

Fishery independent data in the form of an initial estimation of stock biomass was completed

in 2003 for sea urchin species taken in the SUTS Fishery Worthington and Blount, 2003). The

study provides an accurate and robust methodological model for stock assessment and

ongoing monitoring of sea urchin stock biomass in NSW.

Descriptions of current research projects, scientific outputs and any completed research

results by NSW DPI relevant to the fishery can be found on the NSW DPI website at:

www.dpi.nsw.gov.au/research/fishing-aquaculture

4.3 Monitoring programs

The NSW DPI fishery monitoring program includes stock assessment work on key commercial

species; use of scientific observers to record information on catches of target species and

bycatch; collection of catch and effort data; and port monitoring of landed fish products (e.g.

collecting data on fish length and age).

4.3.1 Resource Assessment Framework

The current Resource Assessment Framework for the assessment of harvested marine fish

species harvested in NSW (Scandol, 2004) incorporates a standardised method of reporting

on the exploitation status of fish stocks across all commercial fisheries including an annual

review and interpretation of available data by fisheries scientists. Catch from all sectors

(including estimates from recreational and, where available, illegal sectors) are taken into

consideration when determining the status of a species.

This framework has remained relatively unchanged since it was established in 2004. In 2016

NSW DPI commissioned an external review of the framework to provide advice on whether

the current measures or other frameworks best address the future needs for sustainable

management of NSW fisheries resources.

Key areas outlined in the recommendations related to a transition to the National Status of

Australian Fish Stocks (SAFS) reporting framework. Major recommendations focussed on

communication between management and research groups and a restructuring of resources

to better deliver knowledge to support management of the commercial fishing industry following the implementation of the Commercial Fisheries Business Adjust Program.



4.3.2 Collection of catch and effort data

Catch reporting is an important source of fishery dependant data whereby commercial fishers

record and submit all information relating to the catch taken and effort expended in the

fishery. Further information about reporting arrangements can be found on the NSW DPI

website at www.dpi.nsw.gov.au/fisheries/commercial/catch-effort

4.3.3 Port monitoring

Port monitoring involves the collection of length (and age samples where relevant) of a set of

commercially targeted species. The species are determined based upon risks assessments (as

part of the EIS) and socio-economic values.

5 Catch data

5.1 Total catch and value of the SUTS Fishery

Table 8: Catch and value for the SUTS Fishery 2009 - 2017

Year Sea Urchin Catch (kg)

Sea Urchin Value* ($)

Turban Shell Catch (kg)

Turban Shell Value* ($)

Total value ($)

2009 18,260 70,203 4,162 8,340 78,543

2010 55,582 267,199 5,622 11,977 279,176

2011 51,786 244,338 4,506 13,786 258,124

2012 80,067 337,169 6,973 20,775 357,944

2013 72,959 329,119 5,115 23,327 352,446

2014 73,003 407,964 4,072 25,080 433,044

2015 81,554 584,762 5,701 38,490 623,252

2016 122,115 943,826 11,296 71,029 1,014,855

2017 99,524 680,831 13,971 61,242 742,072

* based on Sydney Fish Market prices ^ data is subject to ongoing validation

Table 9: Sea urchin catch by species (kg) 2009 - 2017

Year Red sea urchin

Purple sea urchin

Green sea urchin

Sea urchin other

Total

2009 6,550.6 11,709.7 0 0 18,260.3

2010 6,067 49,515.3 0 0 55,582.3

2011 6,645.3 45,140.3 0 0 51,785.6

2012 6,706 73,342.9 6.5 12 80,067.4

2013 5,544.1 67,320.7 94 0 72,958.8



Year Red sea urchin

Purple sea urchin

Green sea urchin

Sea urchin other

Total

2014 4,706 68,295.4 2 0 73,003.4

2015 7,663.2 73,854.6 36 0.6 81,554.4

2016 18,100.7 103,885.7 61 67.5 122,114.9

2017 19,003.5 79,708 797.4 15.1 99,524

^ data is subject to ongoing validation

Table 10: Turban shell catch by species (kg) 2009 - 2017

Year Military turban shell

Sydney turban shell

Green turban shell

Turban shell other

Total

2009 2,847.3 4,61.4 0 853 4,161.7

2010 3,655 1,395 0 572 5,622

2011 3,504.5 649.5 35.5 316.5 4,506

2012 4,685.9 1,249.9 77.5 959.3 6,972.6

2013 4,439.9 164.5 27.5 483 5,114.9

2014 2,927.7 707 83.1 354.4 4,072.2

2015 3,414.4 1,163.1 37.5 1,085.8 5,700.8

2016 4,945.7 1,550.3 117.6 4,682.6 11,296.2

2017 6,673.5 2,051.9 363.3 4,882.3 13,971

^ data is subject to ongoing validation

5.2 Harvest by each sector

5.2.1 Recreational fishing

The extent of the recreational harvest of sea urchins is not known but is likely to be less than

5 tonnes, although recreational fishing pressure at local scales can have substantial effects on

local urchin populations.

The recreational catch of turban shells has not been estimated but is likely to be of a similar

magnitude as the commercial harvest.

5.2.2 Aboriginal cultural fishing

No estimate available.

5.2.3 Illegal fishing

No estimate available.



6 Status of target stock The exploitation status for each species is assessed at an annual meeting of fisheries

scientists and managers from NSW, after consideration of all available relevant information

for the species. The exploitation status for each species in the SUTS Fishery is shown in Table

11. Refer to the Status of Fisheries Resources in NSW 2014-15 Summary (NSW DPI, 2017) for

further information.

Table 11: Exploitation status of target species in the SUTS Fishery

Common name Scientific name Exploitation status

Red sea urchin Heliocidaris tuberculata Uncertain

Purple sea urchin Centrostephanus rodgersii Moderately fished

Green sea urchin Heliocidaris erythrogramma Uncertain

Sydney turban shell Military turban shell Green turban shell

Turbo torquatus Turbo militaris Turbo undulatus

Undefined (assessed as a complex of three species)

7 Impacts of the fishery on the ecosystem

7.1 Results of any Ecological Risk Assessments

NSW DPI has produced a Review of Environmental Factors (REF) draft document for the SUTS

Fishery. The REF aims to identify and assess whether the activity of the SUTS Fishery has any

potential impacts on the environment, with all components of the environment being

included – biological, ecological, physical, economic and social.

The preliminary assessment indicates low or negligible potential ecological impacts on the

environment based on the level of activity and harvest levels at the time of the assessment

(refer to Table 12).

Table 12: Preliminary assessment of potential ecological impacts of the SUTS Fishery on the environment

Type of impact Potential impact Ranking

Impacts on target fish stocks

Overfishing leading to serial depletion identified as a potential threat, particularly for H. tuberculata.

All turban species – Low C. rodgersii – Low H. tuberculata – Unknown due to smaller distribution range and past evidence of serial depletion, but low level of activity in the fishery.

Impacts on other fauna

Divers may disturb threatened or protected species inhabiting areas where sea urchins and turban shells are harvested.

Low

Harvesting of sea urchins and turban shells may reduce a potential source of food for some threatened or protected species.

Low



Type of impact Potential impact Ranking

Impacts on other fauna

Vessels used by divers in the SUTS Fishery may disturb or injure threatened or protected species during transit between port and fishing grounds or during harvesting operations

Low

Impacts on habitats Physical damage to reefs or crevices when removing sea urchins with hooks.

Negligible

Removal of sea urchins reduces the proportion of microhabitat available under urchins

Negligible

Damage to algal beds from removing sea urchins or turban shells

Negligible

Ecological impacts - interactions with species, assemblages, habitats and biological diversity

Reduction in density, or depletion of whole patches of Centrostephanus, through harvesting. There have been no studies on the ecological interactions of H. tuberculata with subtidal species assemblages and diversity. There is no information about the effects of removal of turban shells on species assemblages and biodiversity in the SUTS Fishery.

Unknown but designated low due to the low level of activity and small harvest levels in the fishery

7.2 Management actions taken to reduce the impacts

The FM Act and the FM(G) Regulation provide a comprehensive legislative framework

through which the SUTS Fishery operates and provides for management actions that aim to

address the potential impact of the SUTS Fishery on the target stock. This includes the

introduction of a TACC for red sea urchins (H. tuberculata) in 2002 and a system of regulated

closed waters.

The TACC for red sea urchins is capped in each of the five management regions in proportion

to the estimated biomass of red sea urchins in each region. A fishing closure authorized

under Section 8 of the FM Act currently prohibits the harvest of red sea urchins in Region 5 of

the SUTS Fishery giving effect to the TAF Committee’s determination of 0 tonnes for this

region.

Additionally, coinciding with the introduction of a TACC for red sea urchins, changes were

made to the system of closed waters applied to the SUTS Fishery with new fishing closures

introduced in areas previously subjected to intensive fishing and new areas opened,

particularly in Region 1 and 2, to spread effort along the coast.



8 Report against SUTS Fishery conditions and recommendations of

WTO declaration Conditions Progress

Operation of the fishery will be carried out in accordance with the management regime under the NSW Fisheries Management Act 1994 and the NSW Fisheries Management (General) Regulation 2010.

Operation of the SUTS Fishery has been carried out in accordance with the Act and regulations made under this Act.

The NSW DPI to inform the Department of the Environment and Energy of any intended material changes to the NSW Sea Urchin and Turban Shell Restricted Fishery management arrangements that may affect the assessment against which Environment Protection and Biodiversity Conservation Act 1999 decisions are made.

Department of the Environment and Energy advised accordingly.

The NSW DPI to produce and present reports to the Department of the Environment annually as per Appendix B of the Guidelines for the Ecological Sustainable Management of Fisheries - 2nd Edition.

This submission seeks to satisfy this condition.

NSW DPI to develop precautionary fishery specific objectives linked to performance indicators and performance measures for the target species, including triggers to detect any expansion of the fishery.

NSW DPI is considering the development of harvest strategies that will guide the monitoring and management of fish stocks, including the setting of TACCs.

NSW DPI to:

• continue to improve understanding of the stock status of red sea urchin,

• develop measures to better monitor and assess potential for overfishing

of red sea urchin,

• develop appropriate management measures to mitigate the risk of

overfishing or localised depletion of red sea urchin.

Refer to section 6 (Status of target stock) in this submission. NSW DPI’s Resource Assessment Framework provides for the ongoing monitoring of fisheries resources. The fishery for red sea urchins continues to be managed through a number of input and output controls, including limited access, temporal and spatial closures and quota management. A TACC of 60 tonnes applies to red sea urchins, which is further controlled through the limitation of total catch from defined areas, including areas closed to commercial fishing. Commencing 2018, the previous ongoing TACC determination is being replaced by an annual review and determination by the TAF Committee.



Recommendations Progress

NSW DPI to improve estimates of the extent and distribution of recreational and Indigenous catch, and factor these into management arrangements.

Ongoing. As part of the TACC setting and resource assessment processes.

NSW DPI to:

• improve understanding of the stock status of target species in the fishery,

and

• encourage and pursue research to address gaps in knowledge regarding

sea urchin biology and ecology, stock distribution, productivity, and

distribution.

Refer to section 4 (Research and monitoring) and section 6 (Status of target stock) in this submission.

NSW DPI to encourage and pursue research to investigate ecosystem impacts of removal of sea urchins.

A joint FRDC/industry project is underway investigating the ecosystem effects of removing sea urchins at five sites over a five year period. The document entitled ‘Fisheries NSW Strategic Research Plan 2014-2018’ outlines the research priorities across Fisheries NSW and includes tables of research priorities organised into 7 priority programs. Further information is available at: www.dpi.nsw.gov.au/content/research/fishing-aquaculture/strategicpriorities/Planning-Strategic-Research.pdf



9 References Ganassin, C. and Gibbs, P. 2005. Broad-scale interactions between fishing and mammals,

reptiles and birds in NSW marine waters. NSW Department of Primary Industries – Fisheries

Final Report Series No. 80 ISSN1449-9967

NSW Department of Primary Industries, 2017. Status of fisheries resource in NSW 2014-2015

Summary. NSW Department of Primary Industries. Mosman

Scandol, J.P. 2004. A Framework for the Assessment of Harvested Fish Resources in NSW. NSW

Department of Primary Industries – Fisheries Resource Assessment Series No. 15, ISSN 1449-

9940.

Worthington, D.G. and Blount, C., 2003. Research to develop and manage the sea urchin

fisheries in NSW and eastern Victoria. Final Report to the Fisheries Research and Development

Corporation. Project No. 1999/128. NSW Fisheries Final Report Series No. 56. ISSN 1442-

0147. 182pp.



Appendix 1 Sub zones of the SUTS Fishery

A Tweed Heads to Ballina

B1 Ballina to Sandon

B2 Sandon to Red Rock

B3 Red Rock to Coffs Harbour

C I Coffs Harbour to South West Rocks

C2 South West Rocks to Port Macquarie

D1 Port Macquarie to Harrington

D2 Harrington to Tuncurry

E2 Forster to Seal Rocks

E3 Seal Rocks to Hawks Nest Beach

E4 Yacaaba Head and Islands

E1 Broughton Island

F1 Port Stephens to Anna Bay

F2 Anna Bay to Newcastle

F3 Newcastle to Burwood Beach

F4 Burwood Beach to Swansea

G1 Swansea to Norah Head

G2 Norah Head to The Entrance

G3 The Entrance to Terrigal

G4 Terrigal to Broken Bay

H1 Broken Bay to Sydney Harbour

H2 Sydney Harbour to Bondi Beach

H3 Bondi Beach to Botany Bay

J1 Botany Bay to Port Hacking

J2 Port Hacking to Marley Beach

J3 Marley Beach to Garie Beach

J4 Garie Beach to Stanwell Park

J5 Stanwell Park to Wollongong Hbr

K1 Wollongong Hbr to Shellharbour

K2 Shellharbour to Bombo Beach

K3 Bombo Beach to Werri Beach

K4 Werri Beach to Shoalhaven Heads

L1 Shoalhaven Heads to Currarong

L2 Currarong to Pt Perpendicular

L3 Inside Jervis Bay

L4 Nth tip Bowen Island to Wreck Bay

MI Wreck Bay to Bendalong

M2 Bendalong to Ulladulla

N1 Ulladulla to Termeil Point

N2 Termeil Point to Brush (excl. Island)

N3 Brush Island

P1 Brush (excl. Island) to Pretty Beach

P2 Pretty Beach to Sth Durras

P3 Sth Durras to North Head

P4 North Head to Batemans Bay

Q1 Batemans Bay to Lilli Pilli Beach

Q2 Tollgate Islands

Q3 Lilli Pilli Beach to Malua Bay

Q4 Malua Bay to Burrewarra Point

Q5 Burrewarra Point to Moruya River

R1 Moruya River to Black Rock

R2 Black Rock to Tuross Lake

S2 Tuross Lake to Dalmeny

S3 Dalmeny to Narooma

S1 Montague Island

T1 Narooma to Corunna Lake

T2 Corunna Lake to Bermagui

U1 Bermagui to Cuttagee Inlet

U2 Cuttagee to Thibbul Inlet (Murrah)

U3 Thibbul to Bunga Beach (Goalen and

Pressure)



U4 Bunga Beach to Mimosa Rocks (Bunga)

V1 Mimosa Rocks to Bithry Inlet

V2 Bithry Inlet to Barounda Inlet

V3 Barounda Inlet to Tathra

W1 Tathra to Wallagoot Lake

W2 Wallagoot Lake to Short Point Beach

W3 Short Point Beach to Merimbula

X1 Merimbula to Long Beach

X2 Long Beach to Eden Wharf

Y11 Eden Wharf to Red Point

Y12 Red Point to Leatherjacket Beach

Y13 Leatherjacket Beach to Mowarry Point

Y21 Mowarry Point to Saltwater Beach

Y22 Saltwater Beach to Long Point

Y23 Long Point to Bittangabee Bay

Y24 Bittangabee Bay to Green Cape

Y31 Green Cape to City Rock

Y32 City Rock to Wonboyn

Z1 Wonboyn to Jane Spiers Beach

Z2 Jane Spiers Beach to Black Head

Anchorage

Z3 Black Head Anchorage to Nadgee Lake

Z4 Nadgee Lake to Howe Beach

Z5 Cape Howe

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