seafood exporters - home - the australian fisheries ...€¦ · wa seafood exporters wa seafood...
TRANSCRIPT
WASEAFOOD EXPORTERS
WA Seafood Exporters (1994) Ply Ltd
Head Office9-11 Mutton StreetOsbome ParkWestern Australia 6017
ABN 93 065 310456
A.C.N.065310456Plant Telephone: (61 8) 9444 699912 Mutton Street Facsimile: (61 8) 9444 8673
Osbome ParkWestern Australia 6017
EXPORT PROCESSORS AND PACKERS • WHOLESALERS • IMPORTERS
Fiona Hill
Manager- Northern Prawn Fishery
Australian Fisheries Management Authority
COMMENT ON THE DRAFT NORTHERN PRAWN FISHERY MANAGEMENT PLAN 2012
Dear Fiona
Firstly thank you for the opportunity we have been provided in being able to make a submission on the
'Draft Northern Prawn Fishery Management Plan 2012'.
Being a director of 'NPF Industry Pty Ltd' I very much support the submission that has been sent to you
on behalf of all shareholders of this company. I don't wish to re hash everything that has been stated in
that submission but I feel so strongly about this matter that I thought I must have my personal input.
1. It has been said that we as industry had 'done a deal' with government to secure the 'Fishing
Futures Package'. My recollection of this is that industry would consider the move to being
managed by quota once all the facts were presented and well considered by all stakeholders
and other related parties. Having sat on the 'NORMAC' for many years now I personally had
proceeded through this process of moving towards quota with an open mind. The problem has
been that the further we looked into this issue the more apparent it has become that quota
management is not the best way for the 'NPF' to be managed but it is in fact a very dangerous
way of managing this fishery with regard to sustainability of the resource and viability of the
operators.
2. The inability to seta robust TAG for both Banana and Tiger Prawns could do irreparable damage
to the stock we have fought so hard to protect for many years (this was highlighted again in
2011 with the predicted Tiger prawn TAG being over estimated by approximately 1100 tones).
Tiger prawns are the species we have the most information on. What chance do we have of
setting a robust TAG on Banana prawns when we have very limited information?
3. An increase in management costs of at least $500,000 (excluding research) is just mind blowing.
I have a real problem in understanding how it could be expected that industry could absorb such
an increase and still remain viable. While there MAY be some small efficiencies that come our
way as a result of operating under a quota, I fail to see any that will outweigh this dramatic
increase in management costs. In an environment such as this when we see an exchange rate of
$1.06 Australian / $US company's such as mine must cut our costs just to keep our doors open.
We are under siege from cheap imported products, we are limited to what our traditional
exports markets will pay to help offset the exchange rate pain and we are paying record prices
for fuel for which we have no alternative. So to suggest that industry could absorb such an
increase in management costs is very naive and insulting.
4. As well as the increase in management costs it is expected that the operational costs of
individual operators dramatically increase due to the complexity of compliance required when
operating under quota management. Having to deal with issues such as: Quota
decrementation. Control of unloads, Reconciliation of catches, Control of over pack on fixed
weight cartons, reporting requirements are just a few issues that will require a dramatic
increase in time and money from individual operators. These are additional to our current
operating costs of which I am not sure if any will disappear under quota management.
5. I fail to see how individual businesses will be able to extract extra money for the product that
we will catch under quota management versus what we are currently doing. The only thing that
is keeping businesses like mine profitable (albeit just) is the volume of our catch. If that volume
is capped (not due to sustainability reasoning but simply because that's what quota
management requires) I can't see how I can extract extra money for the product we do catch.
Again it is very naive to suggest that we are not currently achieving as much as we possibly can
for our product because of the way our fishery is managed!
6. It has been suggested that the 'NPF' needs quota management to address the issue of effort
creep in the fishery. This is simply not the case. The industry has been dealing with effort creep
for many years prior to the governments introduction of the 'Fishing Futures Package'. Also the
'NPFs' Harvest strategy requires that we monitor and adjust any effort creep that may come into
the fishery. I am sure that if government required some sort of formal guarantee that industry
will deal with effort creep in house in the future then I am sure something robust could be
drafted that industry would support.
Fiona I formally request that AFMA suspend its plans for the introduction of the proposed 'Northern
Prawn Fishery Management Plan 2012' until all the issues highlighted by industry are dealt with.
Yours sincerely
Norman Peovitis
Managing Director