| February 14, 2012 Re: Public Comment Opposing the Prohibition of Sportfishing within the Proposed Coral Sea Commonwealth Marine Reserve Zones- National Marine Park Zone Dear Sir or Madam, Headquartered in Ft. Lauderdale, Florida, The Billfish Foundation (TBF), the leading international billfish conservation organization, has for 25 years advanced the conservation of billfish and associated species to improve the status of stocks, their ecosystems, to support sportfishing and to generate strong economic benefits to nations. TBF takes a three-pronged approach using research (biological, statistical, economic) education and advocacy to persuade and educate decision-makers on science-based conservation and management measures. Central to TBF's mission is a dedicated, passionate global membership network, including many in Australia who depend on the availability of billfish and other highly migratory fish and associated species for their livelihood while others fish for pleasure. For our constituency in Australia, adjacent waters and worldwide, TBF strongly opposes the proposed closure to sportfishing in the Coral Sea. Such a closure would provide minimal benefit towards the conservation of highly migratory fish species, but would erode a world famous sportfishing industry, its economic returns to the region. We would also point out that tagging and returns on black marlin released in this area provide a valuable scientific tool which can assist in the assessment of stock status. The vast majority of the black marlin tagged by TBF volunteers come from the immediately adjacent to the proposed closed area. As is known worldwide, the east coast of Australia is one of world's most historic and culturally significant sportfishing regions in the world. For decades anglers have journeyed to Australia's tropical north in pursuit of black marlin. For most of the past decade, the preponderance of billfishing has been catch and release, with many anglers tagging and releasing, thus adding to the data base of knowledge beneficial in managing billfish. Anglers bring with them friends and families, patronize hotels, restaurants, marinas, and charter businesses all supporting local economies. The generated revenues provide employment and support tax bases that fund municipal infrastructures. By releasing most marlin caught, anglers provide the economic foundation for a sustainable tourism-based economy in the same manner that captains and sportfishermen provided the foundation that built the city of Cairns. The economic impact generated from Australia's sportfishing eco-tourism industry also provides social and conservation positives because this fishery is compatible with sustainable resource use. Citing funded socio-economic research in numerous parts of the world with high densities of sportfishing activity-much like Australia - TBF has persuaded leaders of other nations of the benefits to support the predominantly catch and release sportfishery. A recent study in Los Cabos region of Mexico generated an annual economic impact from anglers visiting the region of US$1.125 billion dollars. Their fishing and associated activities supports more than 24,000 jobs, provides US$245 million in tax revenues, and US$633 million in retail sales. It was the catch and release of striped marlin that in 2007 attracted 354,000 visitors to the Los Cabos region of Mexico. A second study, this one in Costa Rica, documented that sportfishing tourism accounted for US$599.1 million annually, supported 63,000 jobs, and was responsible for US$78 million in tax revenues. These figures are nationally significant for they account for 2.13% of that nation's gross domestic product. While the Coral Sea is not within the economic survey areas of Mexico and Costa Rica the same sportfishing tourism processes are at work on Australia's east coast providing the same foundation for sustainable management, a tool central to fisheries management. In fact, on a global scale Australia's waters and adjacent waters are more famous and enticing than those of the other two regions. Anglers visit communities, spend large sums of money, release the majority of the fish they catch, and provide cascading benefits to the region. These benefits stem directly from healthy fish resources and anglers having access to the waters for fishing. The revenues also provide the most persuasive justification for continued sustainable, balanced fisheries management. The highly migratory nature of marlin, tunas and sharks negate proposed benefits from zones closed to sportfishing for the fish spend large amounts of time beyond the parameters of the proposed zones. While the marlin and tuna move freely, the sportfishing activity off Australia's east coast is largely centered around a few ports of call, which will be the recipient of reverberations from an adjacent marine reserve. If the proposed closed zone, prohibiting sportfishing, were enacted beyond the Great Barrier Reef Marine Park, it would not reflect responsible management, but rather a radical broad brush prohibition driven by groups that desire a protectionist approach, not a responsible user or responsible management approach. The cumulative effect of the proposed closed zone would be economic undervaluation of fisheries resources, eroding justification for their conservation. Marlin and sailfish populations throughout the southwest Pacific Ocean are subject to high rates of mortality from commercial long line gear and purse seine fisheries targeting tuna. The same marlin that attract daily sportfishing charter rates of AUD$3,300 from predominantly catch and release fishing are sold for pennies on the dollar in the markets of Asia. Whether or not the zones closed to sportfishing are in place in the Coral Sea, mortality from longline and purse seine gear will continue beyond Australian waters. These gears are the primary drivers of overfishing of large pelagic species in the Pacific Ocean and should be the target of proposed closures, not sportfishing, which is compatible with sustainable resource management. Sportfishing, very fundamentally, empowers conservation. Anglers travelling to fish provide the economic foundation for community investment. Sportfishing tourism and anglers travelling internationally or domestically to fish waters beyond the GBRMP support investment that benefits the local communities. Sportfishing trips do not pose threats to fisheries populations and are effectively managed under existing regulation. Furthermore, the ability to make these trips heightens the profile of responsible resource use and is publicized through various media-electronic, film, and in print - worldwide. It would cost millions for Australia to generate the positive publicity generated through sportfishing magazines worldwide, this publicity drives tourism to Australia to fish. Marine conservation should be driven by responsible use of resources, which includes the charter and recreational fishing communities of Cairns and the whole east coast of Australia. Those who invest in larger vessels to travel beyond the GBRMP also generate significant economic returns to Australia's east coast. The activities and continued ability of these two groups supports research, conservation and management outreach and education, and provides the impetus for marine conservation, which generates strong economic returns to Australia and the region beyond. The closure of waters beyond the Great Barrier Reef Marine Park in the Coral Sea Commonwealth Marine Reserve would negatively affect communities, decreasing employment, investment, eco-tourism without providing benefits to highly migratory fish species. If the proposed marine reserve drives tourists and investments elsewhere, neither Australia nor the fish benefit. The perception of diminished sportfishing access s essentially the same as eroded consumer confidence in an area, it reduces future investment. The extension of closures to prohibit sportfishing would set a poor precedent that could be adopted in other regions of the world while doing unnecessary harm to a vibrant, ingrained part of coastal Australia's culture. The extension of closed zones in the Coral Sea Basin, Mellish Reef and Kenn Reefs would not decrease pressure on stocks of fish, but it would upset a balance in place. Sportfishing should be exempted from this proposed closed zone. Thank you for your consideration. Sincerely, Ellen M. Peel President |
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