Ian Cresswell, Delegate of the Minister for the Environment and Heritage, 31 August 2004
The Hon Henry Palaszczuk MP
Minister for Primary Industries and Fisheries
Primary Industries Building
GPO Box 46
Brisbane QLD 4001
I am writing to you as Delegate of the Minister for the Environment and Heritage in relation to the assessment of the Queensland Gulf of Carpentaria Line Fishery (GOCLF) under the Environment Protection and Biodiversity Conservation Act 1999 (the Act). In March 2004 the Queensland Department of Primary Industries and Fisheries (DPI&F) submitted the document entitled Ecological Assessment of the Gulf of Carpentaria Line Fishery for assessment under the Act.
The submission has been assessed for the purposes of the protected species provisions of Part 13 and the wildlife trade provisions of Part 13A of the Act.
I am pleased to advise that assessment of the fishery is now complete. The assessment report will be available on the Department of the Environment and Heritage website at: http://www.deh.gov.au/coasts/fisheries/index.html
I am satisfied that the management arrangements for the fishery require that all reasonable steps are taken to ensure that protected species are not injured or killed and the level of interactions with such species in the fishery is not likely to adversely affect the conservation status of protected species or the survival and recovery of listed threatened species. Hence, the management arrangements for the GOCLF meet the requirements of Part 13 of the Act and I propose to accredit the management arrangements accordingly. Accreditation will ensure that individual fishers operating in accordance with the management arrangements are not required to seek permits in relation to interactions with protected species in Commonwealth waters.
I am satisfied that the operation of the fishery is consistent with objects of the wildlife trade provisions in Part 13A of the Act. I am also satisfied that it is unlikely to be detrimental to the survival or conservation status of any taxon, to which the fishery operation relates, or threaten any relevant ecosystem. The fishery is relatively well managed and operates under an adaptable and precautionary ecologically based regime capable of controlling, monitoring and enforcing the level of take from the fishery. Performance against the Australian Government Guidelines for the ecologically sustainable management of fisheries is adequate, however there are a number of issues that need to be addressed to contain environmental risks in the longer term. Hence, I propose to declare the fishery an approved Wildlife Trade Operation (WTO), under Part 13A of the Act. This declaration would allow the export of product from the fishery for the next three years. I will make the declaration subject to the conditions at Attachment A.
In making my decision I had particular regard to a number of issues that have the potential to impact on the fishery in the medium term including:
- Absence of fishery specific objectives, performance measures and reference points for target, byproduct, bycatch, protected species and ecosystem impacts;
- Absence of a clear process for when a reference point is breached;
- Limited level of collection and reliability of fishery dependent data due to multiple species being listed under a single commercial species grouping;
- Lack of fishery independent data collection;
- Absence of validation of commercial catch information;
- No stock assessments of target species;
- Lack of a fishery status report;
- Paucity of information on recreational and indigenous take; and
- Lack of information on composition and abundance of bycatch.
I commend the commitment to removing all excess effort from the fishery. You should be aware that in making my assessment I had particular regard to the development of the draft Bycatch Action Plan, due for implementation in 2005. I believe the Plan significantly improves on the existing policy and I encourage its finalisation and implementation.
The management regime aims to ensure that fishing is conducted in a manner that does not lead to over-fishing and for fishing operations to be managed to minimise their impact on the structure, productivity, function and biological diversity of the ecosystem. On balance, I consider that the fishery is being managed in an ecologically sustainable manner and is working to address existing problems and to minimise environmental risks.
While there are some environmental risks associated with this fishery, I believe that DPI&F is committed to addressing these issues and is already taking proactive steps in some areas. Officers from our two departments have discussed key areas requiring ongoing and increased attention. I understand that they have agreed to a number of recommended actions, focusing on addressing key issues, to be implemented before the next Commonwealth review of the fishery. The recommendations (Attachment B) have been an important factor in my decision to declare the fishery a WTO and I look forward to receiving your confirmation that they will be implemented.
I would like to thank you for the constructive way in which your officials have approached this assessment and I look forward to reviewing the remainder of the Queensland managed fisheries.
Delegate of the Minister for the Environment and Heritage
31 August 2004
Proposed conditions on the approved wildlife trade declaration wild for the Gulf of Carpenteria Line Fishery
- Operation of the fishery will be carried out in accordance with the Gulf Of Carpentaria Line Fishery management regime in force under the Queensland Fisheries Act 1994 and Fisheries Regulation 1995.
- Reports to be produced and presented to the Australian Government Department of the Environment and Heritage annually, and to include:
- An outline of progress in implementing the recommendations made in the Assessment of the Queensland Gulf Of Carpentaria Line Fishery 2004;
- A description of the status of the fishery, including catch and effort information and results of the annual fishery appraisal undertaken by DPI&F;
- Performance against objectives, performance measures and reference points once developed; and
- Results of any research or surveys undertaken within the year.
Recommendations to the Department of Primary Industries and Fisheries on the ecologically sustainable management of the Gulf of Carpentaria Line Fishery
The Queensland Gulf of Carpentaria Line Fishery is a relatively well-managed fishery with a range of significant management measures to promote the ecologically sustainable harvesting of species from the fishery including:
- A commitment in 2003-2004 to remove all excess effort from the fishery to maintain the present sustainable level of effort.
- The development and implementation of a Bycatch Action Plan by 2005 that applies to the fishery.
- Use of highly targeted and specific fishing methods.
While the fishery is relatively well managed, a number of risks and uncertainties that must be managed to ensure that their impacts are minimised have been identified. The following recommendations aim to address these risks and uncertainties. DPI&F should action these recommendations before the next review in 2007 or within the timeframe specified in individual recommendations.
Recommendation 1: DPI&F to inform DEH of any intended amendment to the management arrangements that may affect the sustainability of the target species or negatively impact on byproduct, bycatch, protected species or the ecosystem.
Recommendation 2: By the end of 2006 DPI&F to develop fishery specific objectives linked to performance indicators and performance measures for target, byproduct, bycatch, protected species and impacts on the ecosystem.
Recommendation 3: DPI&F to monitor the status of the fishery in relation to the performance measures once developed. Within 3 months of becoming aware that a performance measure has not been met, DPI&F to finalise a clear timetable for the implementation of appropriate management responses.
Recommendation 4: From 2005, DPI&F to report publicly on the status of the fishery on an annual basis, including explicitly reporting against each performance measure, once developed.
Recommendation 5: Within 18 months, DPI&F to undertake a risk assessment, in conjunction with other relevant jurisdictions where possible, to identify target, byproduct and bycatch species most at risk from the fishery. Actions seeking to reduce risk to be implemented as appropriate within a further 12 months.
Recommendation 6: DPI&F to implement a commercial catch data validation mechanism in the GOCLF by the end of 2006.
Recommendation 7: Within 18 months, DPI&F to develop a process to improve estimates of recreational and Indigenous take and factor these into stock assessments and management controls to ensure overall catch levels are sustainable.
Recommendation 8: DPI&F to continue to seek out alternative cost effective fishery independent sampling techniques, particularly for target species, and report outcomes in the annual status report from 2005.
Recommendation 9: DPI&F to continue to work towards developing sustainable yield estimates of target species to determine sustainable harvest levels, particularly for Spanish Mackerel and Red Snapper.
Recommendation 10: DPI&F to develop a species-specific target list. DPI&F to develop a clear process for the inclusion of any additional species on the list.
Recommendation 11: By the end of 2006 DPI&F to implement a program to collect information on the composition and abundance of bycatch.