Responses to Stop the Trawler Alliance campaigns

Ms Rebecca Hubbard  
Stop the Trawler Alliance​

Dear Ms Hubbard

I am writing in response to the most recent Stop the Trawler Alliance email campaign seeking a permanent ban on the Geelong Star and freezer factory trawlers from the Small Pelagic Fishery (SPF). This response focuses on the new issues you have raised and does not repeat my previous correspondence to you on this matter.

I agree that the Albatross mortalities were concerning. Following advice from seabird experts, the Australian Fisheries Management Authority (AFMA) has mandated additional measures on the Geelong Star to reduce the risk of seabird interactions. These are prescribed in the Vessel Management Plan which is available on AFMA’s website. The additional measures include a reduction in the length of the ‘third wire’ (net sonde cable) that is out of the water and the addition of highly visible ‘tori lines’ (streamers) on either side of the cable. The Geelong Star is also required to cease fishing if a single seabird mortality occurs because of the third wire, or if two or more occur on a single fishing trip for any reason until AFMA has reviewed the circumstances of the event. The current measures reflect the best practice advice of the Agreement for the Conservation of Albatrosses and Petrels and are consistent with the National recovery plan for threatened albatrosses and giant petrels 2011-2016.

I can confirm that there have been recent seal mortalities. In response, AFMA met the vessel in port on 15 February 2016 and initiated a review of the approved marine mammal excluder devices. The operators of the vessel, Seafish Tasmania, have also engaged a consultant to review the devices in place. Seafish Tasmania will continue to use an underwater camera to gather more information regarding seal interactions with the net. This information will be used when considering future changes to mitigation equipment aboard the Geelong Star.

The Geelong Star did interact with a whale shark which came into contact with the outside of the net and had two fins entangled. Fortunately crew members were able to free the fins and the interaction was non-fatal. An AFMA observer was present during the interaction and reported that the whale shark swam away without difficulty. AFMA has reviewed the video footage from the vessel’s electronic monitoring system of the interaction. I am informed that this video footage is consistent with the report received from AFMA’s on-board scientific observer. The video footage shows that the time from the animal being brought onto the boat, freed and being released back into the water to be approximately 3min 35sec.

I note with interest the comments about wanting a long term sustainable fishing industry. In a well-managed, quota-based fishery, the size of the boat or the net is of little relevance to fish stock sustainability, providing the quotas have been set correctly. The total allowable catch for the SPF, as you know, is in accordance with the principles of the Commonwealth Fisheries Harvest Strategy Policy and is highly precautionary.

Yours sincerely

Anne Ruston

Ms Rebecca Hubbard  
Stop the Trawler Alliance​

Dear Ms Hubbard

I am writing in response to the most recent Stop the Trawler Alliance campaign seeking a permanent ban on the Geelong Star and freezer factory trawlers from the Small Pelagic Fishery (SPF). Please find below responses to the issues raised by the campaign.

As I have advised you in the past, the use of freezer factory trawlers for processing catch on–board is not a new development in fisheries and is not indicative of the industrialisation of fleets. On–board processing has been practiced over some five hundred years and assists in maintaining the quality of the product, reduces product wastage and increases the product value. Prior to refrigeration fish were typically salted and dried, pickled or smoked.

Small pelagic fish rapidly deteriorate in storage which is why the use of on-board processing is important and allows the fish to be used for human consumption (as opposed to fishmeal, fertiliser or fish oil). Using small pelagic fish for human consumption represents a significant improvement in the economic value and the efforts to improve global food security.

A wide range of fishing sectors rely on on-board processing: prawn trawlers typically pack and snap freeze, most of their catch at sea, larger fin fish caught by long liners are most often gutted and packed with ice before storage, blue grenadier are filleted, packed and frozen, gummy shark caught by gillnets are headed and gutted, and the Geelong Star processes by sorting, boxing and freezing.

Globally, freezing is a commonly used processing method for fish for human consumption, accounting for 54 per cent of total processed fish for human consumption and 25 per cent of total fish production in 2012 (FAO, 2014).

A level of risk of interactions with bycatch species remains in all fisheries, despite the best endeavours of fishers and fisheries managers. Bycatch can be minimised through the application of a range of mitigation measures, including the use of a barrier net. The Australian Fisheries Management Authority (AFMA) is the independent regulator of Commonwealth fisheries and draws on expert advice and the best available scientific information and is working closely with the operators of the Geelong Star to ensure the protection of marine species. For example, in reaching the decision to remove the night fishing ban, AFMA drew on expert advice from a SPF Technical Marine Mammal Workshop which was hosted by the Fisheries Research Development Corporation (FRDC). Participants included experts in the operations of the SPF, pelagic trawl net makers, gear technologists, acousticians, scientists with expertise in marine mammals and in fisheries, fisheries managers and representatives from the Department of Agriculture and Water Resources, the Department of the Environment and FRDC. 

It is not true that AFMA is weakening regulations for the Geelong Star. This fishing vessel is one of the most highly regulated and monitored vessels in Australia’s fishing zone. A significant amount of effort continues to go into finding ways to further mitigate marine species interactions through both regulatory and voluntary (industry) measures. AFMA has also not reduced observer coverage on the Geelong Star. It currently has 100 per cent monitoring by an on–board observer and an electronic monitoring (camera) system.

I am disappointed that there is some misrepresentation about the Scientific Panel’s recommended biological catch (RBC) limits for the 2016-17 fishing season. As you are aware, the RBC is the maximum amount of fish that can be taken from a stock in a given fishing season (to meet the target for a fishery which is set out in the respective fisheries’ Harvest Strategy). The total allowable catch (TAC), on the other hand, is the amount that is allocated to Commonwealth fishers to catch and is decided by the independent AFMA Commission, not the Scientific Panel.

In setting the TAC, the AFMA Commission take into consideration the RBC and other sources of mortality like State managed catch (including any recreational catch). The Scientific Panel’s recommended RBC for 2016-17 compared to 2015-16 is:

• the same for two stocks (jack mackerel east and redbait east)
• higher for the two stocks (blue mackerel east and Australian sardine east)
• lower for all three western stocks (jack mackerel, redbait, blue mackerel).

The RBC increase for blue mackerel east and Australian sardine follows an update to the scientific data on the size of these stocks. Even if the TAC was to increase by the amount represented by the RBC, this would still be highly precautionary with at least 90 per cent of the combined estimated fish stocks left in the water. 

Fish stocks are a public resource and it is important that all sectors work together to use the resource sustainably. Both the commercial and recreational fishing sectors are a valuable part of our nation’s economy and lifestyle. The debate should not focus on choosing one sector over the others, but rather focus on achieving mutually beneficial outcomes. This will be the best outcome for the Australian community.

The government takes seriously its responsibility to protect the environment, and to sustainably manage fisheries for the enjoyment of all Australians into the future. This is why the government places significant emphasis on scientific research, has a strong legislative and policy framework for managing fisheries and to ensure compliance, has an independent regulator. I am satisfied that the current balance is the right one.

This letter will be made available on the Department of Agriculture and Water Resources’ website at www.agriculture.gov.au. The government will not be responding directly to campaign correspondence arising from Stop the Trawler or affiliated websites.

Yours sincerely

Anne Ruston

Ms Rebecca Hubbard  
Stop the Trawler Alliance

Dear Ms Hubbard

I understand the Stop the Trawler Alliance is currently running a nationwide campaign to ‘Support the Small Pelagic Fishery Pledge’. I am writing to you to reaffirm that we are taking all reasonable steps to mitigate further marine mammal deaths in the Small Pelagic Fishery (SPF).

The Australian Government recognises the importance of protecting key species, including seals, dolphins and seabirds. Under the Environment Protection and Biodiversity Conservation Act 1999 (the Act) fishing operators are required to take all reasonable steps to ensure species protected by the Act are not killed, injured or harmed during fishing operations. In addition, the government regulator, the Australian Fisheries Management Authority (AFMA), is responsible for managing the broader environmental impacts of Commonwealth commercial fishing, including minimising the impact on protected species and supporting the diversity of fisheries ecosystems.

I note and share concerns about dolphin and seal deaths. In developing the FV Geelong Star’s Vessel Management Plan (VMP), a significant amount of effort went into finding ways to minimise interactions with seals and dolphins. This effort has continued: the Fisheries Research and Development Corporation (FRDC) recently hosted a successful technical workshop on options for mitigating marine mammal interactions in the SPF. I understand the outcomes will be publically available soon on the FRDC website at frdc.com.au. Unfortunately, there is always a risk of unintended interactions with marine mammals in many on-water activities, including mid-water trawling. However, I can assure you that every effort is being made to minimise these risks by adopting and applying world best bycatch mitigation techniques and technologies. 

As to the remarks about transparency, extensive information is available publically through the AFMA website (afma.gov.au), including the reports of the expert panel, supporting scientific research, the FV Geelong Star’s VMP, the fisheries management plan and harvest strategy for the SPF.

Australian fisheries are rightly regarded as some of the best managed in the world. The Australian Bureau of Agricultural and Resource Economics and Sciences’ Fishery status reports 2013–14 shows that, for the first time in eight years, no fisheries managed solely by the Commonwealth are classified as subject to overfishing. The SPF has been the subject of extensive and recent scientific research projects covering a range of themes from the impacts of mid-water trawlers to small pelagic fish and their impact on other parts of the ecosystem. We have also refreshed our data on the size of Australian small pelagic fish stocks. All this research informs government decisions. More detail about several of the research projects is available on the FRDC website.

This letter will be made available on the Department of Agriculture’s website at www.agriculture.gov.au. The government will not be responding individually to campaign correspondence arising from Stop the Trawler or affiliated websites.

Yours sincerely

Richard Colbeck

cc the Hon. Greg Hunt MP, Minister for the Environment

Ms Rebecca Hubbard
Stop the Trawler Alliance

Dear Ms Hubbard

I understand the Stop the Trawler Alliance is currently running a nationwide campaign ‘Protect our dolphins, seals and fisheries’. I am writing to you to affirm that we are taking all reasonable steps to mitigate further marine mammal mortalities in the Small Pelagic Fishery.

Under the Environment Protection and Biodiversity Conservation Act 1999 fishing operators  are required to take all reasonable steps to ensure species protected by the Act, including dolphins and seals, are not killed, injured or harmed during fishing operations. In addition, the Australian Fisheries Management Authority (AFMA) is subject to a Ministerial Direction requiring it, amongst other things, to manage the broader environmental impacts of fishing, including minimising the level of interactions with threatened or otherwise protected species. The fishing community consider themselves custodians of our ocean, and take this responsibility very seriously. 

As with any mid-water trawl vessel fishing in the Small Pelagic Fishery, the Geelong Star is required to have an AFMA approved Vessel Management Plan in place. The plan is tailored specifically to the operations of the Geelong Star and requires the vessel to apply a range of measures and actions to ensure interactions with marine mammals and seabirds are minimised.

Measures in the plan for the Geelong Star include the use of a marine mammal excluder device which allows marine mammals to escape from the net and catch limits within defined zones to reduce any potential risk of localised depletion of fish stocks. In addition, the plan applies closures to prevent interactions with threatened, endangered and protected species. Trained AFMA observers monitor interactions with threatened, endangered and protected species, as is the case in all Commonwealth managed fisheries.

The news of dolphin and seal mortalities was devastating for all involved. A significant amount of effort went into finding ways to further mitigate these interactions. As new information becomes available about the fishing method and interactions with marine mammals the management measures will be adapted where necessary.

In response to the recent mortalities, additional measures to help protect dolphins have been implemented by AFMA. These prohibit fishing at night and zone closures triggered by any dolphin mortality. These new measures are effective immediately. A copy of the new management measures for the Geelong Star, and the measures applicable in other fisheries, is available on the AFMA website at www.afma.gov.au.

Commercial fish stocks are a public resource and the Australian Government is accountable for their sustainable use. I am satisfied that the current management of Australian fisheries, including the Small Pelagic Fishery, is based on the best available science, protects the future of our natural resources and lays the foundation for a sustainable Australian fishing industry for future generations. I will continue to work closely with the Minister for the Environment and AFMA to ensure all reasonable steps are taken to mitigate further marine mammal mortalities. 

This letter will be made available on the Department of Agriculture’s website at www.agriculture.gov.au. The Government will not be responding directly to campaign correspondence arising from Stop the Trawler or affiliated websites.

Yours sincerely

Richard Colbeck

Ms Rebecca Hubbard
Stop the Trawler Alliance

Dear Ms Hubbard

I understand the Stop the Trawler Alliance is currently running a nationwide campaign seeking a permanent ban on ‘super trawlers’ in Australian waters. I am writing to you to reaffirm that Australia’s fisheries management practices follow internationally recognised best practice and the government is committed to maintaining a balanced and science-based approach to all decisions regarding access to Commonwealth fisheries.

I recognise your concerns about the size of vessels that could operate in Commonwealth fisheries. However, in a well-managed fishery, the number or size of the fishing vessels is largely irrelevant to the sustainability of the target stocks because catches are maintained at sustainable levels through catch restrictions which limit the total catch of targeted stocks. Commonwealth-managed fisheries have conservative catch limits to ensure the health of our fisheries into the future and are consistent with internationally recognised best practice. Additionally the Australian Fisheries Management Authority monitors bycatch levels across each fishery to ensure bycatch is being minimised. Where necessary for a particular fishery each fishing vessel is required to have a plan in place to reduce bycatch and an appropriate level of independent observers.

In the Commonwealth Small Pelagic Fishery, the total catch limit is currently set at 7.5 per cent of the estimated total fish population. This means that 92.5 per cent of the estimated fish stock is left in the water. This is even more precautionary than international guidance. This recognises the importance of small pelagic species to the food chain, and in supporting other fisheries. The government is committed to maintaining a balanced and science-based approach to all decisions.

Two independent expert panels have been appointed to assess the potential environmental impact of large mid-water trawl vessels in the Commonwealth Small Pelagic Fishery. The first panel reported to the Environment Minister, the Hon. Greg Hunt MP, in October this year and is due to be published on the Department of Environment’s website in late November. The second panel will report in March 2015. Following the release of the panel reports the government will consider whether any additional regulation supported by evidence is required in this fishery.

Fisheries are a public resource and the Australian Government is accountable for the sustainable management of all fisheries. We recognise the significant contribution of the fishing industry, both recreational and commercial, to our economy. Limiting the impact of fishing operations on the environment while ensuring a valuable fishing industry is paramount for the Australian Government.

This letter will be made available on the Department of Agriculture’s website at www.agriculture.gov.au. The government will not be responding directly to campaign correspondence arising from Stop the Trawler or affiliated websites.

Yours sincerely

Richard Colbeck