11 February 2016
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