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16 September 2004
Mr S Bolton,
Manager, Small Pelagic Fishery,
AFMA,
P O Box 7051,
CANBERRA, ACT 2610
Dear Sir,
Future Management of the Small Pelagic Fishery (Zones B, C and D)
Thank you for the opportunity to comment on future management options for the SPF and your AFMA Discussion Paper dated September 2004.
Whilst TFIC is primarily interested in Zone A and the Tasmanian Diversified Sector our focus on the whole SPF has increased recently with the reported possible entry of the worlds second largest trawler MFV Veronica into this fishery in Southern Australia.
We acknowledge that AFMA has now frozen boat nominations to fishing permits to ensure the rational and sustainable development of the fishery subject to consideration by the AFMA Board in November.
We are however very concerned about any future entry of a super trawler into this fishery.
There is limited information available about the small pelagic resources and the biology of the species involved but historically abundance has been low and has varied considerably year by year.
Our stocks are very different from those available in the large scale industrial fisheries in some other countries and over capitalization in our fishery would not be in anyones interest.
From all this we can conclude that the impact of a super trawler on this wide ranging fishery and the marine ecology will probably be devastating. Such a powerful trawl vessel could catch the remaining TACC in all southern small pelagic fisheries this year very quickly in very large quantities and have the same devastating impact in the first few months of next year’s season with compounded disastrous consequences.
We understand the precautionary fishery management catch trigger limits were put in place to slow development at the same time as encouraging traditional Australian vessels to start to utilise the resource. It was certainly never intended that foreign super trawlers would for convenience sake become Australian flagged for a few months in order to devastate the Australian fishery and then move on to another part of the world and operate under another flag.
The broader effects on the marine ecosystem, on other fish stocks and the whole food chain are not able to be measured at this time but unintended bycatch would certainly have a dramatic and adverse impact on State and Commonwealth species which are traditionally managed in a sustainable manner.
A super trawler method of operation is not consistent with current Australian fishing practices and would not operate in a manner consistent with ecological sustainable development and the precautionary principle.
Given the almost certain immense and adverse impact on the small pelagic fishery and the marine food chain we recommend in this management review of the fishery that steps be taken to stop this potential ecological disaster occurring.
Firstly a full environmental and social impact study must be carefully undertaken to assess the consequences of such a vessel. It may also be in Australia’s best interests for instance to rearrange the TACCs into monthly limits to ensure that traditional Australian operators are not locked out of these fisheries and that useful scientific research is obtained from a staggered fishery rather than the removal of a huge amount of fish over a short period.
Additionally we need a careful assessment of all scientific research information to establish if very heavy fishing pressure by a super trawler is an appropriate method of targeting what is a fragile resource with wide ranging implications.
In the meantime we strongly urge the establishment of policies that continue to responsibly manage these fisheries on a conservative basis erring on the side of caution given the far reaching consequences of a super trawler such as the Veronica.
Yours sincerely,
R.K. LISTER
Chief Executive
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