Freezer Boat Proposal a Threat to Fish Stocks and Australia’s Marine Ecosystem

There are indications that elements of the commercial fishing industry are working together to bring a big freezer boat to fish stocks of small pelagic fishes off Australia's southern coastline. This is bad news for marine ecosystems in this part of the world, as well as recreational fishers and other sectors concerned about Australia’s marine ecosystem.

After three years of declining catches, Triabunna-based company Seafish

Tasmania made the decision to tie up its 50 metre mid-water trawler, MV Ellidi, and put it up for sale. At a recent meeting of the Australian Fisheries Management Authority’s (AFMA’s) Small Pelagic Fishery Management Advisory Committee, (on which I am TCT‘s representative) a Seafish company representative said the decline in catch had been caused by high water temperatures keeping the fish in deeper water, where they were safe from mid-water trawl-fishing gear.

There was no evidence presented to support this assertion. Overfishing as a cause was not even raised or discussed.

Adding to concern that the declining catches are an indication of overfishing, the Seafish Tasmania representative announced that a freezer boat, capable of very high catches and processing them at sea over prolonged periods, would be acquired and would enter the small pelagic fishery.

If this occurs, the catch of small pelagic fish will suddenly expand from current precautionary levels before there is any certainty of sustainability for the fishery. Even more worrying is that there is a complete lack of evidence to suggest that large-scale fishing will not damage the marine ecosystem processes that these fish support.

To properly understand this threat, one needs to understand the likely role the small pelagic fish play in the marine ecosystem of southern Australia. Small pelagic fish, such as jack mackerel, redbait and blue mackerel, are likely to be keystone species in this region, comprising a vital component of the diets of many important marine species, including bottlenose dolphins and Australian fur seals as well as a variety of seabirds and other predators.

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If the small pelagic fishery becomes overfished and collapses, not only will the fishery itself collapse but many species that rely on these fish for food will also face hard times and population declines. The full extent of the ecological consequences is difficult to predict with any certainty but  likely to be serious.

Small pelagic fish are also important predators on various types of plankton; removing these fish may have wide-ranging consequences for ecological processes associated with all these organisms.

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Of course, other fishery sectors depend on a healthy marine ecosystem and would undoubtedly look at such ecosystem damage with great concern.

This is not the first time that there has been a proposal to bring in a large fishing vessel to exploit Australia’s small pelagic fish stocks. In 2004, Irish interests working with some members of the Australian commercial fishing industry announced their intention of bringing a large factory boat into Australian waters to fish small pelagics. The most likely candidate was The Veronica, a huge fishing boat from the European Union. This factory vessel was notorious for having killed more fish than any other vessel in history, and as a consequence was nicknamed by many The Deathstar.

At the time, because of concerns about fishery sustainability and the dramatic increase in catches The Veronica would cause, the Howard government chose not to allow this super-trawler into Australian waters, at least until questions about fishery sustainability and ecosystem impacts had been resolved. Since then, AFMA (the Commonwealth's fishery management agency) has been working towards developing a small pelagic fishery management plan and harvest strategy, which should have ensured fishery sustainability and protection of ecosystem processes.

As a member of both the Management Advisory Committee (MAC) and Resource Assessment Group (RAG) associated with this fishery, I saw great progress being made towards achieving these outcomes – until about two years ago, when the commercial fishing industry appeared to reject the process and the only practical mechanism that could be used to assess stocks of the small pelagics.

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The problem with these species is that stocks can vary from year to year because of environmental and other factors so it is hard to know how many fish are actually available to the fishery at any given time. The big danger during such fluctuations is that fishing rates don’t drop when populations are low. Fishing mortality can exacerbate a low population level and cause fish stocks to crash suddenly, with little warning.

There are many examples from other parts of the world of small pelagic fisheries collapsing, including Pacific sardine, capelin, Icelandic spring herring and Atlantic herring. Stocks may take years to recover and in one case had failed to recover even after 20 years. (For example, see Beverton, RJH 1990, ‘Small marine pelagic fish and the threat of fishing; are they endangered?’, Journal of Fish Biology, 37, 5-16). 

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Concerns about the sustainability of small pelagic fishing in the waters off southern Australia cannot be dismissed – the recent history of Tasmania's small pelagic fishery provides grounds for concern. In the 1980s, a fish meal plant operated at Triabunna, processing schools of surface-caught jack mackerel. During this period, I remember often looking down from the lookout above Pirates Bay, as I was driving down to go for a dive off the Tasman Peninsula, and seeing these schools stretching out towards the Hippolytes. Unfortunately, by the end of the decade the schools had more or less disappeared and the fishing operation that depended on them had disappeared as well.

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Explanations for the disappearance of both the fish stocks and the local fishing industry based on them have been varied. Economic mismanagement and changing weather patterns seem to be popular explanations within the industry sector, with overfishing barely being considered.

More recent analysis of fishery data indicates that the stock structure of the main target species, jack mackerel, has changed markedly: fish are smaller and younger. This is a classic indication of fishing pressure and would seem to indicate that overfishing may have played a large role in the decline of this particular fishery. Twenty years later, anecdotal evidence suggests that jack mackerel have once again become plentiful in Tasmania's coastal waters but the surface schools have still not reappeared.

Strangely enough, the three-year decline in the red bait fishery, which resulted in the sale of the only significant vessel involved, does not appear to have rung any alarm bells with the Federal Government’s fishery managers. The commercial fishing industry’s proposed solution is to simply buy a bigger boat that can go further and catch more fish – which makes the operation more cost-effective (read profitable).

As mentioned earlier, plans to introduce larger vessels into the Commonwealth small pelagic fishery were put on hold in 2004 until concerns about fishery sustainability and ecosystem impacts could be addressed. Steady progress was being made towards this goal until 2008 when the commercial fishing industry decided that it was all getting too expensive. The main sticking point was about an internationally accepted scientific method of assessing small pelagic fish stocks or biomass, called the Daily Egg Production Method (DEPM). Basically, plankton samples taken from relevant oceanic areas are analysed to determine the number of fish eggs present; from this, an estimate of spawning biomass for a particular fish population in a defined geographic area can be calculated. Without this type of fishery-independent estimate, fisheries management is operating in the dark, without adequate knowledge of seasonal variations and the biomass or size of the population being fished. Suggest delete whole paragraph in bold type.

Managing a small pelagic fishery without this information greatly increases the risk of a fishery collapse.

Even before 2004, it was widely expected that DEPM would play a big role in the management of Australia's small pelagic fishery. This was a very reassuring development and would have provided an opportunity to manage – sustainably – the stocks of small pelagic fish. This all changed when the commercial fishing industry decided that it did not want to pay for this vital research. It seemed that it was okay to pay millions of dollars for vessels and processing facilities but the relatively small amount of money needed to ensure that the fishery was actually sustainable could not be found. Some DEPM data had already been collected but provided just a snapshot of the status of some of the small pelagic fish stocks at the time the samples were collected and did not give any sense as to how stocks change with time or the levels of current stocks.

Note from Janice re Tiers: “Jon, you say what the Tiers are based on, but not what they are – limits to catch? – or how they affect actions. Can you explain. NB. Preferably, do we need the info on the three tiers or can you summarise the issue regarding the strategy in place of the these 2 paras and the next 2 pages (for the newsletter readership.”

The formal small pelagic fishery (SPF) Harvest Strategy, now required by the Federal Government for each fishery, has also been undermined. The SPF has a three-tiered harvest strategy. Tier 1 is based on DEPM data, Tier 2 on an assessment of biological data such as age and size, and fishery data such as catch rates, and Tier 3 was based on limited data. The level of catch was highest where current DEPM data was available and lowest (just 500 tonnes) at Tier 3.

Under the original SPF Harvest Strategy, (suggest deletion) which was issued for public consultation and went through several iterations within the SPF Management Advisory Committee and AFMA, the intention was for catches to reduce over time from Tier 1 then through Tier 2 and 3, as DEPM data became dated. A key point was that if DEPM data wasn't collected, the catch rate would continue to decline to Tier 3 levels, ensuring that the fishery and its catches would be based on hard scientific data if the commercial industry wanted to catch more than a token amount of fish.

Just before the SPF harvest strategy was finalised, industry insisted that fishing effort was not to be reduced, and could remain fixed at Tier 2 levels even in the absence of DEPM data. [Note to the editor – Jon needs to explain why this is a problem given that only T1 is dependent on DEPM? – or did I miss something?] This was a huge shift in the commercial industry’s negotiating position and AFMA’s subsequent policy and moves the fishery away from one based on rigorous information about stock quantities to one based on best guess assumptions.

DEPM data that has been analysed is rapidly becoming less relevant because of the time since it was collected, and in the case of some small pelagic fish stocks, including jack mackerel, there are currently no DEPM assessments available at all.

Ecological risk assessment has also been inadequate. A study is planned to get under way next financial year but no proper assessment of the risk posed by this fishery to ecosystem processes has yet been carried out.

Currently, there are several major issues associated with the present management of the small pelagic fishery. These include:

  • no adequate assessment of the proposed 20% harvest rate in terms of ecosystem impacts
  • no current DEPM data to provide a current indication of the actual size of fish stocks
  • no adequate justification of the harvest strategy, in terms of ecosystem impacts
  • DEPM-derived stock biomass data is about to expire with regard to the SPF Harvest Strategy’s Tier 1 and, according to the Harvest Strategy, will soon not allow Tier 1 catch levels
  • existing DEPM data is limited to only one or two years and may not give a true indication of stock variability over time
  • there is no requirement to gather further DEPM data despite this being the basis of the SPF Harvest Strategy and originally widely considered to be the fundamental management tool for the fishery.

To be fair, the current Harvest Strategy provides a useful framework for managing the small pelagic fishery, with the exception of the method for reducing catch from Tier 1 through Tier 2 to Tier 3. [Note to the editor – Jon needs to explain why is this a problem?] However, the problem with Tier 2 justification and the apparent expectation that the fishery will carry on at this level of exploitation in the absence of regular DEPMs, completely undermines the credibility of the management of the fishery – and exposes it to all the biological threats that we’ve seen in other Commonwealth (boom and bust) fisheries of past decades. If a large freezer boat is introduced under the current management regime, Australia's SPF becomes more likely to collapse in the same way that so many other small pelagic fisheries have around the world.

In practical terms, when the current DEPM assessments for the small pelagic fishery expire, there will have been no significant progress towards justifying the proposed Total Allowable Catches for the fishery since the last time the commercial industry wanted to bring a large factory super-trawler into Australian waters.

It is essential that the proposed entry of a large freezer boat be prohibited until DEPM assessments of fish stocks are regularly undertaken so that the SPF management plan can be properly applied and we can be assured that the SP fishery is sustainable and that ecosystem processes – and the marine mammals and seabirds that depend upon them – can be protected.

Jon Bryan
Tasmanian Conservation Trust

Footnote: Jon Bryan, as conservation/environment member, and Graham Pike, as recreational/charter member, have been on AFMA's Small Pelagic Fishery Management Advisory Committee and its Resource Assessment Group since they were formed. They have been working together for many years to protect the SPF fishery from large-scale exploitation before the biology and biomass of the targeted fish stocks were fully understood.