Dear Dr Rayns,
Thank you for contacting the Australian Marine Conservation Society (AMCS) regarding Australia’s Sustainable Seafood Guide (hereafter the ‘Guide’), an independent guide to the sustainability of seafood available for sale in Australia.
On 12th April 2018, AMCS released updated ratings in the Guide for the majority of species caught in fisheries managed by the Queensland Government, as well as a small number of species caught in Commonwealth-managed fisheries. The updated Commonwealth fisheries included species caught by the Northern Prawn Fishery and other fisheries that target prawns. As noted in our media release, more updates will be added to the Guide over the coming months. This includes the vast majority of Commonwealth-managed fisheries.
Your letter dated 20th April 2018 raised concerns the Australian Fisheries Management Authority (AFMA) has over some aspects of the AMCS assessments of Commonwealth-managed fisheries on the basis that AMCS had updated our Guide. However, at this point, AMCS has not yet published updates on the majority of these fisheries.
As we have previously discussed with AFMA staff, AMCS uses all sources of publicly available, credible information when undertaking the assessment process, including information on the status of fish stocks in reports produced by the Australian Bureau of Agriculture and Resource Economics and Sciences (ABARES) and the Status of Australian Fish Stocks.
In keeping with a modern understanding of seafood sustainability, our assessment process considers not only the stock status of the species of seafood caught in Australian waters, but also the wider impact of fishing activity on the marine environment. These factors include the impact of fishing on marine habitats and marine wildlife (including the different risk levels to a species from fishing activity and the conservation status of the species in question), and the robustness of the management framework under which the fishery in question is managed. Information from other government produced reports, academic literature and the Marine Stewardship Council (MSC) assessment of accredited fisheries is considered within these criteria.
The policy and legislative framework for Commonwealth-managed fisheries is of a high standard, and AMCS staff have been involved in the process to update the Harvest Strategy and Bycatch Policies over the past six years. We also recognise efforts by sectors of the fishing industry and AFMA to improve on-water practices and reduce the impact of fishing on the broader marine ecosystem. However, where sustainability issues remain and are identified in our assessment process these will be reported in the ratings.
For instance, seven species of fish managed by the Commonwealth Government are currently listed on the Environment Protection and Biodiversity Conservation Act 1999 as ‘Conservation Dependent’ due to their overfished status. While rebuilding strategies are in place, it is unclear at this point whether management efforts have been sufficient to support rebuilding of their populations. We hope to see evidence of rebuilding in future reports and will re-assess the relevant rating in the Guide if that evidence is forthcoming.
While we are aware of and support efforts to reduce the capture of endangered and protected marine wildlife in Commonwealth-managed fisheries, mortalities remain a challenging issue to address and there is limited evidence bycatch is declining over time. Where issues remain outstanding, these will be reflected in the outcomes of the ratings in the Guide.
A review of the protected species reports on AFMA’s website shows the following:
- 125 sawfish (listed ‘Vulnerable’ under the Environment Protection and Biodiversity Conservation Act 1999) were killed in the Northern Prawn Fishery in 2016, the highest recorded in a five-year period;
- 68 Australian fur seals (listed ‘marine’ and protected under the EPBC Act) were killed in the Commonwealth Trawl Fishery;
- 34 dolphins (listed ‘marine’ and protected under the EPBC Act) were killed in the Gillnet Hook and Trap Fishery;
- 744 shortfin mako sharks (listed ‘migratory’ and protected under the EPBC Act, and as ‘Vulnerable’ on the IUCN red list) were killed in the Eastern Tuna and Billfish Fishery, and the life status of a further 1,261 was ‘unknown’.
While it is clear Commonwealth fisheries provide timely and clear reports on protected species interactions, it cannot be concluded that issues around threatened species mortalities have been resolved.
We strongly value the Agency’s thoughts on our process and outcomes. To that end, AMCS previously provided AFMA and other Government Departments with an opportunity to understand more about our process; we understood this was well received, and we wish to extend an invitation to Agency staff to organize a further briefing on AMCS’s process and outcomes.
We ask that you publish this response on the AFMA website alongside your letter.
Yours sincerely,
Darren Kindleysides
CEO, Australian Marine Conservation Society