such as Seal Exclusion Devices and independent observers on board. The Seal Exclusion Devices have notbeen shown to be effective on the gear that this ship will use and we do not know if they will actuallyprotect seals and dolphins or just dispose of dead animals before they are brought to the surface.Lanternfish are another small and important species of fish in the food chain. Due to their size they usuallyslip through the trawl nets without being captured; however, they are incredibly sensitive fish and can bekilled from a touch, yet there has been no assessment of these mortalities or ecosystem impacts.Claims that there will be 100% observer coverage on the Margiris are of only minor consolation and to acertain extent misleading. We expect that this ship will be undertaking fishing and/or processing operationsfor extended periods of time, and at times may be working continuously for periods of 24 hours or more.For observer coverage to be effective, and for this coverage to actually be 100%, there would need to be atleast three observers on the ship who could then work 8 hour shifts. We have been informed that thecompany is only planning to have a single observer on this ship, so it seems unlikely that 100% observercoverage would be possible. Observers in any case are only able to report on the outcomes of fishingoperations. While they contribute to compliance, they cannot prevent environmental damage fromoccurring. If some form of video/e-monitoring was to be used to lighten the load on the observer/s, therewould need to be funding to support the analysis of this data. There has been no commitment by thecompany to fund this work, and it appears that AFMA is no position to do this analysis.
Stock assessments and fisheries management issues
Stock assessments are based on just one or two years of sampling and are too old to ensure an accurateestimate of fish numbers or how the populations of these fish change over time. Blue mackerel were lastsurveyed in 2004, redbait were surveyed in 2005 and 2006 and data for jack mackerel comes from 2003
.Due to the poor track record of small pelagic fisheries around the world
and the failure of two smallpelagic fisheries in the Tasmanian regions where large quantities have been taken and local depletionappears to have occurred, it is a matter of urgency for these assessments to be updated, so that we can besure that the quota will not risk the population or broader marine ecosystem. During the development of the Commonwealth Fisheries Harvest Strategy, regular Daily Egg Production Method (DEPM) stockassessments were included as a necessary way of assessing population health and supported byconservation representatives. However, this was removed by AFMA at the last minute.
Industry has made commitments to DEPM stock assessments in the past and has repeatedly walked awayfrom them
Seafish Tasmania has said they will support DEPM assessments of jack mackerel and redbait inOctober (two months after they propose to start fishing) and to repeat them biannually thereafter.However, they will not agree to this being included in the conditions of their quota.
The Small Pelagic Fishery
Seafish Tasmania has been allocated a quota of around 18,000 tonnes of jack mackerel, blue mackerel andredbait for the coming year, to be taken equally from the west and east zones of southern Australia (westincluding west coast of Tasmania to Western Australia, and east including east coast of Tasmania up to NewSouth Wales). Jack mackerel quota was doubled this year on the basis of old data from 2003 that was noteven collected for this type of assessment, and may not provide an accurate assessment of current fishstocks.
Woodhams, J,Stobutzki, I, Viera, S, Curtotti, R & Begg, GA (eds) (2011) Fishery Status Reports 2010: status of fishstocks and fisheries managed by the Australian Government, Australian Bureau of Agricultural and ResourceEconomics and Sciences, Canberra
Beverton, R. J. 1990. Small Marine Pelagic Fish and the Threat of Fishing: are they Endangered? Jour. Fish. Biol. 37:5-16. Around the world, many small pelagic fish stocks have collapsed due to overfishing, including: Atlantic Herring,Icelandic Spring Herring, SE Atlantic Pilchard, Peruvian Anchovette, Capelin, Pacific Mackerel and Pacific Sardine.