Rock Lobsters Management Review
Overarching assessment and recommendation
As is made clear throughout this submission, the TCT views the Draft Recovery
Plan as generally inadequate and significantly inferior to the previous plan. We
believe that a key reason for this is that the current draft was prepared by the
Australian Government, with very limited consultation with the responsible state
agencies and no community consultation. In contrast, the previous Plan was
developed by the Tasmanian Department of Primary Industries, Parks, Water
and Environment (DPIPWE) with the assistance of members of the Recovery
Because of the limited time available to prepare this submission (see below for
further comments regarding the consultation process) the TCT has been able to
comment only on priority parts of the Draft Recovery Plan and selected parts of
the Review Report. It is our view that the Review Report should have subjected
to thorough review by scientific peers, former recovery team members and
other key stakeholders before the Draft Recovery Plan was prepared. There is
no evidence that this has occurred. Where we have had time to review the
Review Report it is quite unacceptable in key areas (see comments regarding
the ‘Current Status’). This is a critical error as this report is the primary source of
information used to prepare and justify the new Draft Recovery Plan.
For the reasons state above and below, the TCT recommends that the current
Draft Recovery Plan be comprehensively rewritten following a thorough review
of the Review Report. Unless there are compelling reasons for a change or
addition, the provisions of the existing recovery plan should be retained.
The Draft Recovery Plan includes a number of important and positive additions,
such as an emphasis on illegal fishing, reference to adaptive management and
recognition of climate change as an impact. However, the plan identifies
climate change as an ‘overarching threat’ but provides no strategies or actions
in response to this (see below for further comments).
Similarly, there are major limitations in how illegal fishing is proposed to be
addressed (see detailed comments below).
While the recommendation in the Review Report that adaptive management
should be a ‘key component of the new recovery plan’ the Draft Plan fails to
identify whether the recovery plan might need to be changed to reflect
adaptations and, if so, how this is to occur. Clarifying these matters is critical
because the plan has statutory status at the national level. Also this plan, more
than the previous plan, omits key details. Repeatedly throughout the plan
actions are proposed that should have been completed as part of the
recovery planning process and included in the Plan. Two important examples
are action 1a ‘Assess the effectiveness of current management planning
provisions for lobster conservation’ and 1b ‘Identify sub-catchments for
improved habitat protection to support and maintain healthy lobster
populations’(see below for further comments).
During the fourteen month period between the 30 April 2015 workshop and
release of the Draft Recovery Plan, there should have been ample time to
perform these planning actions.
The TCT is greatly disappointed at the highly restricted consultation that has
been undertaken by the Department of the Environment (DoE), both in the
preparation of the Draft Recovery Plan and in seeking comment on the Draft
The Review Report - published on the Department of the Environment web site
but not apparently part of the consultation process – states that the review of
the ‘Giant Freshwater Lobster (Astacopsis gouldi) Recovery Plan 2006-2010’ was
done by the DoE through a single forum held on 30 April 2015.
We note that no non-government conservation organisation was involved in
the review of the previous recovery plan. This is doubly disappointing given the
current Draft Recovery Plan (page 29) suggests that ‘Conservation groups’ ‘are
expected’ to be ‘involved in review of the performance’ of the recovery plan.
The review of the existing Recovery Plan seems to have been limited to this one
workshop even though a further 14 months passed until the Draft Recovery Plan
was released for public comment. There is no evidence that the participants
were provided with an opportunity to check the draft report of the workshop.
There is no evidence provided that the workshop participants or any relevant
state government agency representatives were provided with an opportunity
to comment on the Draft Recovery Plan prior to its release.
The TCT Director was a member of the recovery team for the GFL and was
acknowledged in the previous recovery plan as a contributor. All previous
members of the recovery team should have been invited to be involved in the
review of the previous recovery plan. They should also have been specifically
notified of the release of the Draft Recovery Plan but this did not happen.
Instead we heard of the recovery plan review through newspaper articles over
the last week.
It seems that consultation for this plan has been reduced to the absolute
minimum required under the EPBC Act.
The Draft Recovery Plan (page 28) states that:
The Draft Recovery Plan for the Giant Freshwater Lobster (Astacopsis
gouldi) (2016) has been developed through extensive consultation with a
broad range of stakeholders. The consultation process included a
workshop in Tasmania that brought together key species experts and
conservation managers, from a range of different organizations, to
categorize ongoing threats to the species and identify knowledge gaps
and potential management options. Workshop participants included
representatives from DotE, DPIPWE, CSIRO, FPA, IFS, Hydro Tasmania,
researchers from UTAS, other species experts and local community groups.
During the drafting process DotE continued to work closely with key
The TCT finds it gravely disappointing that a document that should be factual
and evidence based has made such unsubstantiated claims such as these.
How could it be claimed that the Draft Recovery Plan ‘has been developed
through extensive consultation with a broad range of stakeholders’, when the
Review Report documents the process as being limited to the one workshop
that included only scientists and government managers? The Review report
does not list any ‘community groups’ as participating in the workshop. Forestry
Tasmania was not involved in the workshop.
If there was other consultation with a broader range of stakeholders, including
community groups, then the Review Report fails to present evidence of it.
As stated above, the members of the recover team who prepared the previous
recovery plan should have been an obvious and important group to have
been involved in the review of that plan and preparation of the new plan.
However, they were not.
The TCT have been intimately involved with management of this species since
the 1990s, including assisting with the original nomination of the species
(prepared by Dr Pierre Horwitz) to the then Endangered Species Act. The TCT
should have been involved in the review of the previous plan and preparation
of the Draft Recovery Plan. We could have provided valuable input including
observations of the management of this species going back to its initial listing.
2.1 Conservation Status
If the TCT was involved in the review of the previous recovery plan we would
undoubtedly have cast doubts over section 3.1 of the Review Report
‘Evaluation of the current status and conservation trajectory of the species’.
The evaluation of change in conservation trajectory is overly optimistic and
seems to be solely based on an apparent improvement in average size and
maximum size. Furthermore these results are from just one study (Walsh and
Walsh 2013) which the Review Report says are ‘preliminary indications from
ongoing monitoring’. The Review Report also acknowledges that illegal fishing is
Considering the ample evidence in the Review Report of ongoing threats,
habitat disturbance in the north east (that justify those populations being
‘considered endangered’) and ‘major declines in some north west
catchments’ the current status would appear to be generally worsening.
We further note that climate change impacts are not specifically considered in
the assessment of status.
As with any threatened species, the appropriateness and priority of all
management actions for GFL are affected by its conservation status and this
must be thoroughly reviewed at appropriate intervals to ensure confidence in
the recovery plan. Given that the current status of this species was previously
reviewed when the previous recovery plan was finalised, i.e. prior to 2006, it is
vital that a thorough review is undertaken and be subject to wide public and
scientific peer review.
The review of status should be done by assessing whether actions taken since
the adoption of the current plan have or have not assisted in achieving the
overall objective of the recovery plan, the long term and short tern criteria that
are identified on pages 18-19 of the current plan. The TCT believes there is a
prima facie case for consideration of the GFL as endangered and as such a
thorough reassessment of the species against these objectives and criteria is
important and urgent.
4.2.3 Other potential threatening processes
As stated above, the Draft Recovery Plan identifies climate change as an
‘overarching threat’ to the GFL but provides no strategies or actions in response
to this. While this is a very complex area it deserves greater attention than it
receives in this draft.
We recommend that further details are included regarding the likely threats
from climate change, including from the 2015 DoE document. We note that this
document is referred to in the text but is not included in the references.
5. Populations under particular pressure
The conclusion that ‘all populations of GFLs require protective measures’ and
therefore priority populations are not identified is scientifically unjustifiable. It
ignores the obvious fact that some populations and habitat are protected by
reservation, as identified in Table 2, and the others have various tenures, some
being more prospective for reservation. Clearly the plan should acknowledge
these facts and include a commitment to progressing reserves, with priority
given to those known to be most important and with appropriate tenure.
6. Objectives and strategies
Unlike the previous plan and all recovery plans the TCT has been involved with
developing, this plan does not include an overall recovery objective or
performance criteria linked to this. It is vital that the plan identifies an overall
objective of seeking the down listing of these species to non-threatened and
that performance criteria are included as with the current plan.
This omission makes performance of the plan very difficult to measure.
7. Actions to achieve the specific objectives
Strategy 1 – Increase the reservation status and improve the quality of key
habitat for the giant freshwater lobster.
As stated in General Comments, in regard to actions 1a and 1b, the process of
developing this draft plan should have included an assess of the effectiveness
of current management planning provisions for lobster conservation and
identification of sub-catchments for improved habitat protection to support
and maintain healthy lobster populations.
The Draft Recovery Plan should include an analysis of what gains, if any, have
been made in terms if reservation since the previous plan was finalised, what
obstacles have hindered this, opportunities for future action and
recommendations for further actions.
With advances in technologies these assessments should be much easier to
achieve now than in 2006 when the current plan was finalised.
No reference is made to the Tasmanian Regional Forest Agreement. It is a
requirement of the Tasmanian Regional Forest Agreement to develop and
maintain a recovery plan for the GFL and to seek to reserve key habitat and
populations where possible. An assessment of reserve status and potential for
further reservation should be done as a priority so the results can be considered
in the review of the Tasmanian Regional Forest Agreement that will commence
If any outcomes are to be achieved in these two vital areas then Forestry
Tasmania should be at least listed as a responsible agency.
Action 1c should identify a target of an area of habitat that is to be reserved or
at least an indicative target based upon an assessment of what is available on
Crown land (as mentioned in comments on section 5).
In action 1d, actual programs that exist that may be able to assist with
protecting lobster habitat on private land should be identified and potential
gaps that the Australian government might be able to address. Section 2.1 of
the current plan should be adopted and revised where necessary.
Strategy 2 – Prevent or minimise the degradation of giant freshwater lobster
Action 2a and the relevant performance criteria are too broad and effusive.
The action only seeks to inform agricultural communities about lobster
conservation whereas it should seek to achieve an improvement in
management by agricultural industries. Section 2.2 of the current plan should
be adopted and revised where necessary.
Action 2b, 2c and 2d and the relevant performance criteria are proposed in
response to recent research by Dr Peter Davies and are broadly supported.
While we have some confidence that the FPA will progress the recommended
review of habitat suitability, historically achieving amendments to forestry
prescriptions has been very slow. The FPA’s work would be assisted by the DoE
identifying a responsibility to assist with the action and specifically by making a
commitment to seek funding to progress it.
Also, it is not clear whether these actions apply only to forestry operations as
regulated by the FPA or could be applied by forestry companies to
applications for forestry certification (as with Forestry Tasmania’s ongoing FSC
application) and be applied to other agricultural practices.
As with comments regarding habitat protection, the plan fails to identify
relevant connections with the soon to commence review of the Tasmanian
Regional Forest Agreement.
Also there is no recognition that the FPA are continuing the review of the
biodiversity provisions of the Forest Practices Code and that might include
consideration of the development of a new freshwater ecosystem
management tool in addition to the threatened fauna advisor.
In regard to Action 2g, this does not require or imply that water managers and
regulators achieve or aim to achieve outcomes for the conservation of the
Giant Freshwater Lobsters. The action needs to be reworded so that an actual
outcome is sought.
Strategy 3 – Reduce the impacts of illegal fishing on the giant freshwater lobster.
While the actions and specific performance criteria are supported, it is
frustrating that no actions are recommended that aim to prevent or restrict
access to important populations of GFL. The Draft and current recovery plans
identify that forestry roads, particularly new roads accessing previously unfished
areas, can be critical in facilitating access for illegal fishing.
We recommend a specific action aimed at preventing new roads creating
additional threat to the GFL and identifying existing roads that can be closed
and rehabilitated or those that can have access controlled though gates and
We note that the Tasmanian Government has recently completed a ‘State
Roads Audit’, that recommends a range of options in regard to roads
managed by Forestry Tasmania and Parks and Wildlife Service, including
transferring management to the Department of State Growth and in regard to
PWS, to identify roads that can be closed and rehabilitated and those that can
have access controlled though gates and other barriers.
Strategy 4 – Conduct monitoring and research to increase understanding of
giant freshwater lobster ecology and biology.
Strategy 5 – Engage with the general public, local government and NGOs in
developing and/or delivering conversation measures.
Having been involved with the development of the previous recovery plan and
numerous previous attempts to develop a plan commencing in 1997, it is
disappointing that some of the actions and performance criteria dealing with
community education and engagement have not progressed over this time
period. Perhaps this is because of the failure to consult the community and
conservation groups in preparing the Draft Recovery Plan.
Actions 5b and 5c are the actions dealing with community education and
engagement. The performance criteria for action 5b states that:
Informative material on lobster ecology and conservation, including fact
sheets, colour brochures, posters and stickers, is updated and distributed
to schools, local land care groups and other relevant stakeholders.
While such communication tools may be very effective, I am surprised that
there is not specific mention of web sites, Facebook, etc. As with 5c, why are
key stakeholder groups such farmers, fishers, foresters and irrigation managers
While the use of the lobster as a flagship species for good catchment
management is an excellent idea, the plan should identify what catchment
management programs it might be used in and the specific actions needed to
progress this, noting that there has been only limited use of the species as a
flagship over the years.
Regarding the performance criteria for action 5c, surely we can come up with
more potential approaches than ‘public displays’ and we should aim to do
more than raise public awareness.
I was personally involved in displaying Astocopsis shells, prepared by the Queen
Victoria Museum and Art Gallery, at rural shows, public libraries and schools
throughout the 1990s. If I had been consulted on the preparation of the plan, I
could have provided some meaningful input on the probable success of such
approaches and suggested many more.
If it is intended to display live animals, then, assuming adequate security and
humane conditions are provided, this would be a splendid way to present the
animal. Given the animal’s low level of activity and sensitivity to temperature
and light, there would be difficulties presenting this animal in a way that
ensured the animal was active and engaged the general public.
Rather than simply aim to raise ‘public awareness’ I suggest the priority is to
engage and involve key stakeholder groups such as farmers, fishers, water
managers and foresters.