Andrew McNee, Delegate for the Minister for the Environment and Heritage
28 November 2005
The Hon Rory McEwen MP
Minister for Agriculture, Food and Fisheries
GPO Box 668
ADELAIDE SA 5001
As Delegate of the Minister for the Environment and Heritage, I am writing to you in relation to the assessment of the South Australian Lakes and Coorong Fishery under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). In August 2005 the Department of Primary Industries and Resources, South Australia (PIRSA) submitted the document entitled Draft Ecological Assessment of the South Australian Lakes and Coorong Fishery for assessment under the EPBC Act.
The submission has been assessed for the purposes of the wildlife trade provisions of Part 13A of the EPBC 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/sa/coorong/index.html.
I am satisfied that the operation of the fishery is consistent with the objects of the wildlife trade provisions of Part 13A of the EPBC 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 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 EPBC 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.
I also propose to include product from this WTO fishery on the List of Exempt Native Specimens so that exporters would not require EPBC Act export permits. The fishery would continue to operate as a WTO for the period of the declaration (3 years) and all WTO conditions would continue to apply.
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, 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 PIRSA 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. 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.
Delegate of the Minister for the Environment and Heritage
28 November 2005
Conditions on the Wildlife Trade Operation Declaration for the South Australian Lakes and Coorong Fishery
- Operation of the fishery will be carried out in accordance with the Fisheries (Scheme of Management - Lakes and Coorong Fisheries) Regulations 1991 and the Fisheries (General) Regulations 2000 in force under the South Australian Fisheries Act 1982.
- Department of Primary Industries and Resources, South Australia (PIRSA) to inform the Department of the Environment and Heritage (DEH) of any material change to the Marine Scalefish Fishery's management arrangements that could affect the criteria on which the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) decisions are based, within three months of that change being made.
- Reports to be produced and presented to DEH annually, and to include:
- information sufficient to allow assessment of the progress of PIRSA in implementing the recommendations made in the Assessment of the South Australian Lakes and Coorong Fishery;
- a description of the status of the fishery and catch and effort information;
- a statement of the performance of the fishery against objectives, performance indicators and measures once developed; and
- research undertaken or completed relevant to the fishery.
Recommendations to PIRSA on the ecologically sustainable management of the South Australian Lakes and Coorong Fishery (LCF)
The LCF is a relatively well-managed fishery with a range of management measures to promote the ecologically sustainable harvesting of species from the fishery. Management measures include size limits for key species, gear restrictions, temporal and spatial closures and limited entry licensing. Species are not currently over-fished and the management arrangements provide the basis to ensure that fishing is conducted in a manner that will not lead to over-fishing.
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. The Department of Primary Industries and Resources, South Australia (PIRSA) should action these recommendations before the next review in 2008 or within the timeframe specified in individual recommendations.
- PIRSA to advise the Department of the Environment and Heritage (DEH) of any material change to the LCF's management arrangements that could affect the criteria on which Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) decisions are based, within 3 months of that change being made.
- PIRSA, within 2 years, to complete the review of catch and effort logbooks, and implement methods to enable catch and effort to be monitored over finer temporal and spatial scales.
- PIRSA, within 12 months, to review available options to validate catch and effort data on target and byproduct species in the LCF. Appropriate validation mechanisms for target and byproduct catch and effort data to be progressively developed and applied in the fishery within 18 months.
- PIRSA, within 2 years, to further refine stock assessments in a process to develop more robust sustainable yield estimates for key species. As a first step, PIRSA to implement ongoing programs, within 12 months, to obtain necessary biological and environmental data to inform stock assessment and performance criteria of key species.
- PIRSA to develop precautionary harvest reference points for bony bream in order to identify any substantial alterations in fishing effort or byproduct catch rates which may indicate changes in stock status.
- Within 18 months, PIRSA to develop a process to improve estimates of all removals of LCF species, including recreational and Indigenous harvests as well as an estimate of illegal take and factor these into the stock assessments and management controls to ensure overall catch levels are sustainable.
- PIRSA, within 2 years, to develop and implement management arrangements to control the extent of harvests of all target and key byproduct species at ecologically sustainable levels. Particular consideration should be directed at addressing the presently uncontrolled increases in catch of Goolwa cockles and risk of overexploitation of cockle stocks.
- PIRSA, within 18 months, to review known biology of harvested species and existing size limits to ensure size limits are sufficiently precautionary and take into account all removals from the fishery.
- PIRSA, within 2 years, to develop and implement an ongoing program to collect information on the composition and abundance of bycatch across the commercial sectors of the fishery.
- Within 2 years, PIRSA to conduct an ecological risk assessment of the impacts of the LCF, including any impacts on the listed ecological character and values of The Coorong, and Lakes Alexandrina and Albert Wetland Ramsar site (Site No. 25). PIRSA to develop and implement any mitigation measures considered necessary.