slipways_ ft_article augsept_2003.htm  

By Ralph Mitchell

This article (designated Appendix (a)) forms a part of the TFIC submission on the Draft Environmental Management Guidelines for Operational Best Practice at Slipways and other Boat Repair and Maintenance Facilities May 2003

With little regulation to date and no representative body to give slipway operators a voice, the recent production of the Draft Environmental Management Guidelines for Operational Best Practice at Slipways and other Boat Repair and Maintenance Facilities May 2003 caused alarm and concern within the commercial fishing industry and the wider community. Many slipways will have difficulty complying with the recommendations in the document. With marginal economic returns from many facilities, some operators were fearful that they would be forced to close, with those fears spreading very quickly to members of the commercial fishing industry.

Slipway Stakeholders Meeting
To gain a better perspective of the various issues affecting vessel slipways, I personally visited and photographed many slipways around Tasmania. To capitalise on this work, during the public consultation period for comment on the Draft Guidelines I organised a slipways' stakeholder meeting in Launceston. This meeting included slipway operators and representatives from TFIC, the Tasmanian Rock Lobster Fishermen's Association (TRLFA), the Tasmanian Abalone Council, the Environment Division of the Department of Primary Industries, Water and Environment (DPIWE), yacht clubs, local government and other marine users. Outcomes from that meeting and other concerns will be reflected in the TFIC submission.

Concerns voiced
The main concern by most stakeholders was that if these Draft Guidelines became mandatory and enforceable in the short term, then the slipway industry would be in serious trouble. This would have the obvious and inevitable effect of bringing the Tasmanian commercial fishing industry (and many other commercial/recreational boating activities) to a grinding halt. This concern was voiced at the stakeholder meeting. Many stakeholders were relieved to hear the DPIWE representative Dr Frank Cattell make it quite clear that these Draft Guidelines have no specific timeframe for implementation and will be developed as a Code of Practice that slipway operators would be expected to voluntarily work towards embracing.

Dr Cattell indicated that the Department understood that many existing slipways would not be able to comply with all of these best practice recommendations for a variety of reasons. There is, however, an expectation that slipway operators should investigate innovative ways to achieve those objectives that are attainable. Over time, the departmental expectation will be that all slipways will be moving toward improving their operations and waste material containment or minimising activities (such as sand/grit blasting) on some slipways. The possibility exists that there will be some form of regulation/enforcement being commissioned if there is little evidence that improvements are being made.

The Intent of the Draft Guidelines
One major point reinforced numerous times at the stakeholders meeting was that the primary intent of the Draft Guidelines is the minimisation or elimination of pollutants from slipway activities entering into the marine and surrounding environment. It was coupled to the desire to see a further reduction in the risk of introduced exotic marine pests to Tasmanian waterways. TFIC endorses these environmentally responsible objectives.

Submission deadline extension
A good outcome from the meeting was an agreement from the Department to extend the deadline for submissions on the Draft Guidelines for one month to August 11, 2003. Surprisingly, no submissions were received from commercial slipway operators during the last public consultation period on the Issues and Options Paper. The meeting and the deadline extension has hopefully been beneficial to those operators who were being given a chance to have their say on something that will most certainly affect them in some way.

Baseline studies of the effects of Tasmanian slipway operations
The slipways' stakeholder meeting exposed an interesting point. While the State Government wants to bring slipway operations into line with national or international 'Best Practice' guidelines, there have been no tests or modelling carried out to establish the extent of any discernable environmental effects from all of the various slipway operations around the State. There has been no environmental cost/benefit analysis, no attempt at assessing or quantifying pollution transfer levels from slipway activities and no hydrological modelling. In fact, there are no actual modelling or scientific environmental assessment strategies in place at all. Any information used and applied to Tasmanian slipways has been based on mainland and international slipway assessment.


This is not trying to say that Tasmanian slipways have no effect on the surrounding environment. The opposite is obviously quite true. The point being made here is that the Draft Guidelineshave been released with an expectation for additional private slipway investment in methods and infrastructure to achieve objectives over time, yet the actual effects of current slipway operations (on the marine environment) and the outcomes from these proposed changes being implemented remain uninvestigated and unquantified. Why is this the case? I hope to be able to shed some light on that question directly.

Comparisons
In comparison to the mainland, Tasmanian slipways have lower volumes of traffic. In comparison to each other here in the State, they also have varying slipway volumes, tonnage and activities, varying substrate under and adjacent to the slipways as well as varying water volumes/flow rates passing the various slipways. Would it be fair to question whether the use of data from mainland States and international experiences is appropriate for application in Tasmania? Is the slipway traffic in Tasmania low enough on some slipways to make the mainland data meaningless?

There has been little comparison made of activities or events adjacent to many slipways in Tasmania such as urban runoff, sewage outfalls or stormwater events, all contributing to the environmental loading. TFIC finds this process questionable when dealing solely with the slipways' issue and has to ask if this is an appropriate method of assessment? Or is there actually more, perhaps a bigger agenda to this whole issue?

Two non-commercial slipway examples
Gravelly Beach Slipway
Private siltation testing at the Gravelly Beach slipway revealed 0% tri-butyl-tin (TBT) despite the slipway having been in operation since the Second World War. The Tamar River has substantial water flows past this slipway. No commercial vessels use this facility. In comparison to stormwater and urban runoff, it would appear that this low volume, small vessel slipway has little measurable effect on the surrounding environment. Expensive modifications to bring it into line with national best practice may well demonstrate little or no measurable improvement in the effect that this slipway's activities have on the marine environment. What would be the environmental gain from further investment in this low volume slipway?

This of course does not mean that all slipways are the same. It also does not necessarily mean that 'dilution is the solution'. Slipway activities, varying substrates, water flows and work ethics will all contribute to (or reduce) the environmental loading caused by slipway activity.

Derwent Sailing Squadron haulout area
The Derwent Sailing Squadron has a haulout area that has been operational for several decades. Most of the activity on this area is the simple transfer of sailing vessels to and from the water and hard stand storage of these vessels. The hard stand area also gets used for vessel hull washdown, painting and antifouling, with stringent controls on the responsible removal of waste material and application of new coatings. This hardstand area is reclaimed ground constructed from substrate of unknown source and has two stormwater drains adjacent to the haulout area that contribute significant urban waste to the environment.

Without any scientific testing to base the observation on, the marine environment adjacent to the haulout area appears healthy after several decades of maritime activity. Even if baseline studies were to be carried out, how would the stormwater drain's contribution be differentiated from vessel maintenance activities at the haulout? Would expensive modifications such as settlement tanks and filtration systems be any more effective than an audit followed by possible modification of activities carried out on the hard stand area? This is something that also needs to be considered at many commercial slipways.

Two commercial slipway examples
The Strahan slipway


The Strahan commercial slipway is vital piece of infrastructure for this industry, especially so as it is the only one on the West Coast. While having a sealed surface, this relatively low volume facility has no effective way of containing all the (removed) waste material from hull maintenance and has the same height problem as many other slipways. It is difficult to raise vessels one metre above the high tide level. The pollutant output into Macquarie Harbour from this slipway is fairly minimal, but compared to the heavy metal leachate flowing daily into Macquarie Harbour from old mining sites upstream, it is completely insignificant.

Literature is easy to find describing the tonnes of heavy metals (similar to some hull anti-foulants) from the old Mt Lyell mine that flow daily down the King River into the same harbour that the Strahan slipway operates in. When the Hydro power stations upstream are brought on-line after being left off-line for a while, this acidic heavy metal loading can move downstream in a poisonous pulse causing fish kills and serious degradation of the Macquarie Harbour environment. Any money spent upgrading this slipway will make no measurable difference to the pollutant loading already carried by the local environment there. Can an activity modification such as the effective cleanup of hull waste material prior to high tide inundation have the desired effect without expensive slipway modification or installation of settlement tanks and filters?

The Dover slipway
Like the Triabunna slipway, the State Government sold the Dover slipway to a private operator as an operational business. At Dover there is no sealed hardstand surface, but the area between the rails constructed with regularly spaced concrete walls designed to contain the bulk of the material that is removed from vessel hulls. The waste material is physically dug out from this catchment area and disposed of manually rather than it being allowed to enter the water. Sand/grit blasting activities are not permitted on this slipway.

Visually, there appears to be no discernable effect (from slipway operations) on the marine environment adjacent to the Dover facility, with healthy marine biota clearly visible at the slipway rails. To date, it would appear that no quantifiable substrate, water or silt tests have been carried out to determine the impact of slipway activities on the marine environment at this slipway.

The Dover slipway is an important facility playing a vital role in maritime safety as it is the southern-most commercial slipway in Tasmania. As a business it is economically marginal. It is situated on good solid substrate and has excellent clearance away from the high tides but it is unlikely that it can achieve the objectives of many Draft Guidelines recommendations without a significant investment. Like the Triabunna slipway, the Dover facility has excellent potential for compliance with the majority of the recommendations if there were to be sufficient investment in upgrading the facility. Is it timely for the industry to consider a strategy to explore and capitalise on this potential?

The bigger picture…
The slipways issue is only one of many issues that are facing more and more intense scrutiny from a local, national and international standpoint. Vessel hull coatings containing TBT are being phased out internationally and should hopefully be a thing of the past within the next five years. There are still sites around Tasmania that have had vessel maintenance carried out on them in past decades that demonstrate contamination from chemicals such as TBT. Contaminants such as heavy metals and biocides still reach the marine environment from these sites during and after rainfall, storm and flood events. These sites will need to be identified and rehabilitated. Of course the question is as always, who is responsible and who will pay? And when?

Answers to all of these questions may take a while to find, however, it appears that the whole issue is bigger than just Tasmanian slipways management.

ESD applying to slipways? How?
Slipways that have sensitive high value primary production (such as marine farming) adjacent to them have substantially more pressure on them for environmental best practice than other facilities. This is a situation that they may not always be alone in, although there will be a transition time.

Ecological Sustainable Development (ESD) protocols being put in place for national and international compliance in export fisheries are now slowly but surely considering the entire effect of the fishing operations on the entire environment, not just the sustainability of the targeted fish stocks. This is beginning to include areas that have hitherto been quite separate from actual fisheries management and is a new philosophy that is steadily filtering through to fisheries that harvest for the domestic market.

Examples of principles within various fishery codes of conduct can address diverse issues such as:

• animal welfare,
• marine debris,
• engine/fuel types,
• energy optimisation (hull speed and fuel efficiency),
• engine maintenance,
• vessel cleaning chemicals/regimes,
• retention/discharge of vessel/crew organic waste at sea,
• hygiene/health and training of crew,
• gear interaction,
• maintenance of shore-based equipment (e.g., vehicle oil leaks) and
• the environmentally responsible maintenance of the fishing vessels.
For an Australian example of this very thing, the Eastern Tuna & Billfish Fishery 'Industry Code of Practice for Responsible Fishing' makes for interesting reading. (Copies available on request from the TFIC office.)

Codes of Practice
This is the type of change that will happen over a period of time and will probably involve voluntary codes of practice rather than becoming mandatory and enforceable. However, international trading partners who are signatories to international agreements for world environmental conservation principles may well begin to insist that an export fishery must prove that it operates in a way that has minimum environmental impact in all areas of the operation.

In many fisheries nationwide and internationally, Environmental Management Systems (EMSs) are being developed, implemented and regularly audited to ensure that stakeholders are able to prove that they operate within best practice environmental guidelines in each and every facet of their operation.


Trends within the global fishing industry include 'a shifting in the burden of proof' where the industry may be asked to prove that fishing practices are not causing damage to the environment, as opposed to government regulators and other interested parties proving that they are. (See Tsamenyi and McIlgorm (1999), International Environmental Instruments - Their Effect on the Fishing Industry).

As far as vessel maintenance is concerned, public scrutiny is likely to become more interested in areas such as the responsible collection and disposal of hull coating waste material, more environmentally friendly antifoulants, better methods of applying new coatings and the recycling of used oils and plastics. Compliance with agreed codes of conduct between international trading partners may actually be the pressure over time that forces a new approach to the operation of some Tasmanian slipways that maintain commercial fishing vessels. There is more work on this being done in the background as time goes by.

EPBC Act.
Australia is a signatory to a number of United Nations conservation treaties. There are responsibilities that come with joining other nations in treaties such as these. The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) is one of Australia's ways of bringing environmental responsibility into the sustainable harvest or exploitation of natural resources. Over time, this Act and other national initiatives may have far reaching effects on the commercial fishing vessel maintenance industry.

Invasive exotic marine organisms can be easily translocated from port to port locally and internationally, via hull fouling and ballast water. The Derwent River has a massive population of the devastatingly invasive introduced Pacific Seastar and is a graphic illustration of how easily this can happen. It is envisaged that various national initiatives may eventually include provisions that address such things as shore-based vehicles and infrastructure as well as fishing vessels, specifically looking for documented proof that all equipment involved in the harvesting of natural resources is operating in an environmentally responsible manner. An example of this may be for the vessel operator or slipway operator to provide documented proof that vessel hull coatings were removed and disposed of (and the coating replaced) in an appropriate manner, according to best practice guidelines.

Exotic marine pests
This will be very important when considering controls for unwanted exotic or invasive marine organisms. At present there is a high-level working group reporting to a Federal Ministerial Council that is currently looking closely at the translocation of exotic organisms. Fishing vessels have been identified as an established vector and many vessels that move nationally and internationally may soon have to provide documented proof that they are clean and have been maintained according to best practice. One way that this may happen is for those vessels to have maintenance performed and documented at accredited slipways that are certified as conforming to best practice guidelines.

Natural Resource Management
On a national level, Environment Australia (EA) is currently investigating 'Threats to coastal environments and natural resources' as detailed in their document entitled 'A Framework for a National Cooperative Approach to Coastal Issues' (Draft - 21/02/03). Areas in their orbit include introduced pests, marine pollution from vessel sources etc.

Locally, the Tasmanian Natural Resource Management (NRM) Framework is zeroing in on environmental impacts that can affect ecosystem health, water quality, pest introduction, fishery sustainability, fisheries practices and the like.

In current documents, e.g., the NRM Council Secretariat, (Unpublished, May 2003)… "Development of regional plans: Key Element: Strategic, Prioritised and achievable actions necessary to address the range of NRM issues and achieve the regional targets" it is easy to see the thrust or the direction that these environmental initiatives are taking. They will all most certainly take time but eventually these processes may encompass many more areas in the marine primary production sector that can and do have some effect on the environment. It is highly unlikely that slipway activities will escape close scrutiny or the questions being raised about activities and management of vessel maintenance.

With all this work already happening and gathering pace, it is very likely that the department has no need to have a timeframe for implementation of the Draft Guidelines, because other initiatives underway nationally and Statewide will eventually apply the pressure in some sectors anyway.

Complacency
Complacency within the slipway industry has grown from regulators showing little interest in industry activities, as I detailed in the TFIC submission on the Issues and Options Paper. Activities on slipways have continued as they have for decades, even on the State-owned slipways that were recently sold into private hands with little or no disclosure of impending changes. This feeling of complacency was illustrated by the singular lack of submissions to the Issues and Options Paper from the commercial slipway industry.

Illegal hull maintenance
It is very important that Tasmanian vessel slipways continue to function effectively and responsibly, providing timely and economical service to our industry members. Any changes to slipway operations should be phased in over a realistic timeframe, ensuring that there is no backlog of vessels needing slip-time, especially in peak periods. There should be no temptation for operators to put a vessel ashore on a secluded beach somewhere to attend to the hull maintenance, as is alleged to have happened interstate. This activity has the potential to introduce a significant threat into the marine environment should an invasive exotic organism be released from discarded hull coating material.

Is this whole issue actually an opportunity?
The changes facing Tasmanian slipways may well be an opportunity for stakeholders to become proactive in gaining a cooperative approach with State, local government and slipway operator/users. There is a need to explore ways to find a solution to the existing problems, as pressures will inevitably become more apparent over time (perhaps within the next five to ten years). If the opportunity is not addressed and acted upon in a timely way, then other factors such as NRM and international trade partner agreements may slowly force the changes anyway, causing far more problems than there are now.


Given the above scenario, it is easy to see that there is likely to be a divergence within the various slipways. Private and recreational club slipways/haulouts may find it preferable to operate under a code of conduct that they review internally, applying controls as and where necessary to comply with as many of the Draft Guidelines as are achievable on a voluntary basis. Commercial slipways that maintain commercial fishing vessels may find that over time the pressures described above actually dictate a shift in operational procedures, causing accredited 'best practice' to be instituted where possible over realistic timeframes. There is still time for stakeholders to get this issue sorted out intelligently and responsibly.

Definitions
While the Draft Guidelines address the different slipping facilities and the various methods of removing vessels from the water, it would seem sensible to have clear definitions of the various facilities. For instance, is a tractor drawn carriage/cradle (mounted on normal trailer axles) that can support a big vessel considered to be a trailer or a slipway? It performs the same function as rails and wheels, but has no rails. It is drawn by a tractor instead of a winch, but can still be used for hull maintenance. What about crane/sling systems used to lift vessels up onto the hard surface? Is it necessary to clearly define each method of vessel moving device as well as its capacity for use as a slipway?

Assessment of slipways
Many stakeholders believe that all Tasmanian slipway operators and owners should be part of a registered association, then be proactive in the development, implementation and peer-auditing of their own code of conduct. Another belief is that there should be some form of register and an individual assessment of all Tasmanian slipways. This makes good sense, as there are so many variables that should be taken into consideration in the regulation of slipway operations. Small private rails could perhaps be registered and audited via a questionnaire to owners, with guidelines sent to each one clearly stating what boat maintenance activities can and cannot take place on those rails.

Categorisation?
Once this assessment is complete, an interim measure that may well work could involve the categorisation of slipways. A system such as this could be phased in over an appropriate timeframe with all commercial slipways working to an agreed code of conduct. This code should include a determination for all participants to achieve as many of the objectives as possible as are recommended in the Draft Guidelines.

Bear in mind that what is listed below is simply a series of suggestions to get the ball rolling. They may not be workable in this form.

Category A
For instance, those slipways that do full maintenance on larger vessels from a certain agreed tonnage could be designated Category A. They would have to demonstrate a willingness and capacity to conform to an agreed number of the recommendations within the Draft Guidelines and would be able to carry out all necessary vessel maintenance activities as required. They would be situated away from sensitive areas and areas used for recreation, as well as other industries that could be adversely affected by slipway activities.

Category B
Perhaps Category B slipways may only handle vessels to a maximum agreed tonnage (less than Category A) with all slipway activities permitted if the equipment and infrastructure is in place to conform to an agreed number of the recommendations in the Draft Guidelines.

Category C
Those who would normally fit into Category B but are unable to conform to the majority of the recommendations could perhaps have limitations placed on some of their activities, (such as no sand/grit blasting) yet continue their work as Category C slipways. Many may already have limitations placed on them. Slipway activities unavoidably impacting on adjacent industry, primary production or community activities may fall into this category.

Category D
This category may include those that cannot seal or concrete their hard stand area or are unable to control waste material from the hulls, yet can perform other maintenance work. Hull maintenance may be restricted to washing down and repainting, but no paint removal permitted.

Category E
Category E may be those yacht clubs that have haul-out and hard stand areas. They would have to be able to demonstrate that they have agreed limitations placed on activities and that they are conforming to an agreed number of Draft Guideline recommendations. Being part of a code of conduct agreement may be helpful.

Category F



Category F may be privately owned slipways as are common on the West Coast for commercial fishing vessels.

Activities taking place on these slipways would be limited to normal routine maintenance, excluding the removal of anti-foulants.

Normal hull washing may or may not be appropriate.
.
.

Category G

Category G may be all other privately owned slipways that are used simply for putting a boat into the water or retrieving it. Limited or clearly prescribed maintenance would possibly be permitted.

Comments?
The extended period for public consultation on the Draft Guidelines ended on August 11, 2003. However, the department has made it clear that they are keen for good quality input from those stakeholders who have valid input as all stakeholders try to move forward with this whole slipway issue.

Contacts at the department are Dr Frank Cattell, phone 03 6233 2770, and Dr Lynne Powell, phone 03 6233 6714. If you feel that your input will be useful, please call these people, or contact Ralph Mitchell at the TFIC office, phone 03 6224 2332.

TFIC submission