16.08.04 NRM Sth Tas  

16th August 2004

NRM South
C/o G. P. O. Box 44
Hobart
TAS 7001

To Whom It May Concern:

The Tasmanian Fishing Industry Council (TFIC) is the peak representative body for Tasmanian licenced commercial fishermen, marine farmers and seafood processors. Our members catch and produce over 22,000 tonnes of seafood each year with a landed value in excess of $300 million per annum.

Sea fisheries and aquaculture provide employment for around 7000 Tasmanians in the catch and post-catch sectors, and approximately 56% of the Tasmanian seafood production by value is exported earning valuable export revenue for our state and nation.

It seems appropriate that this submission affords NRM South a brief overview of the adaptive management strategy already in place for Tasmanian seafood primary production.

Fisheries Management
In Tasmania we have legislation such as the Living Marine Resources Management Act 1995, which was enacted to promote the sustainable management of living marine resources, to provide for management plans relating to fish resources and the protection of marine habitats; and the Marine Farming Planning Act 1995 which was enacted to regulate the aquaculture industry.

These Acts embody the principles of risk assessment, based on existing scientific information and taking into account current management processes that are already in place. The Acts are subject to review, as are the specific management plans for the various fisheries and marine farms in state waters. These management plans are based on scientific assessment and adaptive management through the review process.

Research
There is also more to this process. In Tasmania there are Research Advisory Groups (RAGs) that are set up to review and advise on research proposals and to identify priority areas for research. The direction being taken now (and much more so for the future) has a basis of ecosystem based management that will become a pivotal part of the integration of the management plans for various fisheries.

Integration
Research plans by the Tasmanian Aquaculture and Fisheries Institute (TAFI) and funding priorities by the (national) Fisheries Research and Development Corporation (FRDC) have a state/national focus that builds upon work and research currently underway or already completed. Because of the emerging protocol of ecosystem based management, Fisheries Advisory Committees (FACs), the Commonwealth Australian Fisheries Management Authority (AFMA) and State fisheries managers are not only dealing with commercial seafood production issues, but are able to demonstrate (within the marine environment) integration with environmental and community issues as well. This fits well with emerging international trends for resource management.

Existing Reports
The State NRM Framework, the State of the Environment Report and the National Land and Water Audit all clearly identify the major risks to estuarine and near coastal environments as being land-based activities.

This raises a question about the NRM South draft strategy. Within the Executive Summary is a dot point referring to "analysis of the causes and threats to those values and services…" This does not appear to be reflected within the goals of the strategy.

Further to that, when referring to the document entitled 'A Framework for a National Cooperative Approach to Integrated Coastal Zone Management' produced by the NRM Ministerial Council in October 2003, more key issues and criteria relating to pressures and threatening processes on the estuarine and coastal environments are clearly identified. (See dot points on page 5 of this submission). These do not appear to be clearly reflected or addressed within the NRM South draft strategy but are most certainly vital to healthy and productive marine coastal environments.

Integrated Coastal Zone Management
While (as previously described) seafood primary production activities are stringently monitored and managed, there appears to be little emphasis within the draft strategy on encouraging a move towards fully integrated catchment management. A 'whole-of-catchment' management approach should be proposed and then implemented to address land-based activities and the effect (usually negative or adverse) that these activities can have on the seafood industry in the lower catchment and coastal regions.

Water
The most basic and most important resource in Tasmania is water. Humans, industry and environmental processes are totally reliant on water, yet this most vital of resource can be undervalued and degraded, often by land-based activities that are not subject to integrated catchment management. Tasmania has at least two of the most degraded river systems in Australia yet relies heavily on its 'Clean and Green' image to attract tourists and to market products. We need to ensure that this image reflects reality.

It is worth drawing attention to 'The Tasmanian Surface Water Quality Monitoring Strategy' paper released by DPIWE and NHT in January 2003. This paper demonstrates good key points that should be absorbed into any NRM planning process. Dot point 7 on page 11 reads in part: "As a first step hazard analysis and risk assessment of potential catchment impacts on estuaries and near coastal environments is required to determine the need for, and prioritise, baseline sites to monitor estuaries and near coastal environments."

Responsibilities of land-based activities
Most land-based activities are (at some stage) a source of diffuse water-borne pollution yet are not subject to management controls and licence conditions. It seems perverse that the seafood industry downstream is stringently controlled by management and licence conditions, while some upper catchment activities often take little or no responsibility for any effect that their actions have on water quality and quantity.

Shellfish farmers are obliged to not only comply with the Tasmanian Shellfish Quality Assurance Program (TSQAP), but to contribute 70% of its costs. TSQAP is in place to monitor water quality that can be degraded due to upper catchment activities, the management of which lower catchment stakeholders have no input at all.

When the water quality has reached a point where the shellfish may pose a threat to human health, shellfish farmers are not permitted to harvest their product. Why should upper catchment activities create this impost on primary production downstream?

This becomes a 'victim pays' situation. The NRM management strategy should place significant emphasis in recommending appropriate monitoring and management as an integral part of the state policy on water quality management. While water quality and quantity are inseparable, stringent guidelines should be invoked with regard to diffuse and point source pollution from all users of this valuable fugitive resource within the entire catchment.

Even the Tasmanian Water Management Act 1999 ("An Act to provide for the management of Tasmania's water resources and for other purposes") is both ineffectual and misnamed as it only works as a water allocation plan, allocating percentages of an unknown quantity.
The actual use of the water (once taken) is not controlled nor managed, neither is there any monitoring/management protocol in
place to assess soil capabilities or subsequent degradation from water use. There appears to be little or no consideration or
assessment of sources of diffuse pollution that gravitational forces always send downstream.

The NRM management strategy must encourage this situation to be addressed by pushing for the application of responsible, fair
and equitable water use regulations and conditions for all resource users, not just the downstream producers.

Examples
For clear illustrations of these issues, there are a couple of examples that demonstrate the need for whole-of-catchment integrated management. The draft strategy must (for example) take into account proposals for:

1. the conversion of grazing and cropping land into plantation forests; and
2. the establishment of fenced riparian buffer zones on all water courses that are subject to both ingress from stock and nutrient runoff.

Fenced Riparian Buffer Zones
Stock accessing watercourses can often elevate levels of nutrients and E.Coli bacteria within the water and can also (in some instances) lead to watercourse bank erosion, sedimentation and turbidity which can seriously affect seagrass beds and shellfish farming operations in estuarine areas well downstream. Fencing a riparian vegetation buffer zone along watercourses has benefits for all concerned including the farmer.

The point being made here is that all catchment activities need to be assessed against criteria that consider all of the catchments needs for water including the marine environment at the lowest level of the catchment.

Paper OCP 1006, published by the NSW Healthy Rivers Commission, demonstrates that two-thirds of management controls (such as the fencing of riparian vegetation buffer zones) put in place to protect water quality have direct economic benefits to all parties. Examples of these economic benefits include reduced nutrient runoff into watercourses, reduced sedimentation from stock accessing the water and the reduction of bank erosion from stock. These riparian buffer zones also act as a corridor for native animals displaced by agricultural and forestry activities.

Chapter 7
There appears to be a theme through Chapter 7/Appendix 7 of the NRM South draft strategy that refers to overfishing (page 252) or overexploitation of marine resources (page 135) and a push for marine reserves (pages 136 and 137).

Page 252 recognises that 'fishing activities are highly regulated'. (This should be amended to read 'commercial fishing activities…') As described previously here and alluded to on page 252, Tasmania has a high level management of its commercial fisheries, considered by many to be 'world class'. It provides significantly better management than many mainland state fisheries have in place. Perhaps the NRM process should (as a management action) be recommending more funds be allocated from State coffers to address any priority shortfalls in the management plans and legislation that already exist.

While wholesale marine reserves may be a priority on the agenda for some community stakeholders, it most certainly should not be placed at the top of the table (page 137) of 'Highest Priority Management Actions'.

Reserves
The highest priority for our industry is the protection of biodiversity and ecological processes within the marine environment. Any proposed 'Comprehensive, Adequate & Representative Reserve' system for marine, coastal and estuarine areas' needs to be justified by extensive scientific assessment relative to the Tasmanian environment, not by data and experiences from other regions. The draft strategy needs to clearly establish how MPAs in isolation will conserve biodiversity and protect ecological processes, while also advocating scientific assessment and research projects to assess any perceived need for reserves.

While more marine reserves may make some members of the community sleep better at night, it is worth mentioning that commercial fishers pay substantial licence fees to government coffers for the privilege of harvesting a wild resource in a well-managed and sustainable manner. Many can demonstrate generations of history as fishers. To push for marine reserves that are not necessarily scientifically justified in Tasmania is to create unwarranted concern and anxiety within the seafood industry.

Displacement
Displacement of fishing effort by creating marine reserves in active fishing grounds puts more pressure on adjacent fishing grounds, with significant management issues to be considered if the fishery is already fully fished. The establishment of marine reserves must also bring with it the cost of buying back those licences, history, investment and livelihood paid for in good faith by any dislocated fishers. The flow-on impact from dislocating fishing effort to coastal communities can be very severe, so socio-economic issues need careful assessment as part of any perceived need for MPAs.

Protection of the marine environment
With regard to the marine environment, the primary objective of the draft strategy should be the protection of the marine environment, not the establishment of reserves for the sake of having reserves. There are many adverse impacts on the marine environment that have absolutely nothing to do with either commercial fishing and marine farm operations.

Examples of impacts on the marine environment are very easy to find.

• Stormwater outfalls deliver urban pollution effectively and quickly to the marine environment during rain events.
• Marine debris is often from land sources and can be exacerbated by a lack of rubbish disposal facilities at coastal access points.
• Industrial waste is often disposed of into the marine environment.
• Nutrient levels in specific areas are often elevated from sewage discharges.
• Urban 'development' (such as the Walker Corporation Ralph's Bay proposal) has the potential to remobilise encapsulated heavy metals and other pollutants from disturbed sediments.
• Introduced marine pests such as the Northern Pacific seastar and the Japanese kelp Undaria can have devastating effects on critical habitat. Elevated ocean temperatures appear to have brought the invasive sea urchin Centrostephanus south to Tasmania from the mainland as the Eastern Australian current sweeps further south annually. Other adverse effects of this incursion of warmer water into temperate habitats are still to be assessed.
• Topsoil runoff from agricultural activities that coincide with rain/storm events creates sedimentation and turbidity problems that can affect marine nursery areas, seagrass beds and seafood primary production.
• A lack of funding to address and regulate vessel slipway operations (and best practice guideline requirements) means that those operators who have no way or desire to keep toxic waste from entering the marine environment can continue to do so with impunity.
• Illegal poaching of Tasmania's valuable marine resources continues to be a problem. NRM should perhaps consider recommending that additional funding be allocated for enforcement.

With the immense pressure on the marine environment evident from so many external activities that also impact adversely on the commercial fishing industry, attention to mitigating the effects of these other activities should be addressed as a matter of top priority in the NRM process. To this end, the NRM South management strategy should be a planning document to inform government of pressing priorities, clearly identifying issues important to the valuable Tasmanian commercial seafood industry and the marine environment.

NRM Processes
Our seafood industry stakeholders are at the bottom of the catchment and are responsible stewards of both estuarine and marine resources. In the development of priorities for the NRM process, there is perhaps a need to gain direct input from various industry sections. A sub-committee of the various industry representatives with expertise in areas would be helpful, perhaps a sub-committee from each industry, e.g., fishing, forestry, agriculture etc.

For many industries, a process such as NRM is an added impost that many can ill afford. For example, the fishing industry is involved in all three Tasmanian NRM regions, looking at similar issues in the regions.

To give this process the attention that it deserves, it would be realistic to suggest that there is enough work for a full time officer just addressing the issues that can affect the industry. The seafood industry obviously has to invest in the process, but with limited resources and many other issues/projects to handle, there is a limit to the time and energy that one officer can devote to NRM.

Added resources being available to the key industry and community stakeholders would enhance the NRM process.

I trust that this submission is useful and can assist in the formulation of a focussed approach to NRM processes, adopting a sensitive and intelligent perspective of 'whole of catchment', and to all land-based activities that adversely impact upon estuarine systems and the marine environment.

Yours sincerely,

Ralph Mitchell
Executive Officer