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