Draft National Plan of Action for minimising the incidental catch of seabirds in Australian capture fisheries
Submission No.: 07
Submission by: CSIRO
Submission:
CSIRO Comments on Draft National Plan of Action for Minimising the Incidental Catch of Seabirds in Australian Capture Fisheries
Below are CSIRO comments in response to the public call for comment on the draft National Plan of Action for minimising the incidental catch of seabirds in Australian capture fisheries (NPOA-seabirds) released by the Department of Agriculture and Water Resources. CSIRO has a long history of seabird-fishery interaction research, dating back to the initial ecologically related species working groups of the Commission for the Conservation of Southern Bluefin Tuna in the mid-1990s. We have continued to work with local and international fisheries and management bodies providing scientific advice and research to assist decision making processes. These include AFMA, ICCAT, IOTC, WCPFC, CCSBT, CCAMLR and covering topics such as seabird bycatch rate estimation, data collection and monitoring, mitigation gear development, population impact assessment modelling, illegal fishing and the impacts of marine debris.
We appreciate the opportunity to comment on the draft NPOA-Seabirds. We recognise that NPOA-Seabirds is not meant to be prescriptive, but rather provide general recommendations and guidelines. We have some suggestions outlined below that we feel should be either included or strengthened within the NPOASeabirds.
Our comments mostly relate to improved recognition of the need for reasonable data collection and assessment, agreed performance measures and indicators, the move to electronic monitoring, and impacts of ghost fishing.
1. Introduction. Additional citations. While generally comprehensive, there are a number of additional citations that consider bycatch impacts of Australian (and global) fisheries from which the document, and in particular the Introduction, would benefit. These papers estimate seabird bycatch numbers from local and foreign vessels within the AFZ, provide best practice guidance for mitigation, provide methods for estimating population impacts and describe the inadequacies of the bycatch rate performance measure (the current metric advocated).
a) Klaer, N., Polacheck, T., 1997. By-catch of albatrosses and other seabirds by Japanese longline fishing vessels in the Australian Fishing Zone from April 1992 to March 1995. Emu 97, 150–167.
b) Klaer, N., Polacheck, T., 1998. The influence of environmental factors and mitigation measures on bycatch rates of seabirds by Japanese longline fishing vessels in the Australian region. Emu 98, 305–316.
c) Baker, G. B., Double, M. C., Gales, R., Tuck, G. N., Abbott, C. L., Ryan, P. G., et al. 2007. A global assessment of the impact of fisheries-related mortality on Shy and White-Capped albatrosses: conservation implications. Biological Conservation. 137(3):319-333
d) Tuck, G. N., Polacheck, T., Croxall, J. P., Weimerskirch, H. 2001. Modelling the impact of fishery by-catches on albatross populations. Journal of Applied Ecology. 38(6):1182-1196
e) Tuck, G.N. and Wilcox, C. 2010. Assessing the potential impacts of fishing on the Lord Howe Island population of flesh-footed shearwaters. Australian Fisheries Management Authority and CSIRO Marine and Atmospheric Research, Hobart. 86p
f) Baker, G.B. and Wise, B. S. 2005. The Impact of Pelagic Longline Fishing on the Flesh-footed Shearwater Puffinus carneipes in Eastern Australia. Biological Conservation. 126: 306-316.
g) Phillips, R.A., Gales, R., Baker, G.B., Double, M.C., Favero, M., Quintana, F., Tasker, M.L., Weimerskirch, H., Uhart, M. and Wolfaardt, A. (2016). The conservation status and priorities for albatrosses and large petrels. Biological Conservation. 201: 169-183.
h) Tuck, G.N. 2011. Are bycatch rates sufficient as the principal fishery performance measure and method of assessment for seabirds? Aquatic Conservation. 21(5):412-422.
i) Phillips K, Giannini F, Lawrence E, Bensley N, 2010. Cumulative assessment of the catch of non-target species in Commonwealth fisheries: a scoping study. Bureau of Rural Sciences, Canberra.
j) Alderman RL, Gales R, Tuck GN, Lebreton JD. 2011. Global population status of shy albatross and an assessment of colony-specific trends and drivers. Wildl Res. 38: 672–686.
k) Wilcox, C., Sebille, E.V. and Hardesty, B.D. 2015. Threat of plastic pollution to seabirds is global, pervasive, and increasing. PNAS, 112: 11899-11904.
2. Introduction. There is a commendable summary of the seabird bycatch measures in place for Commonwealth fisheries under the jurisdiction of AFMA. However, for a “National Plan” it would be desirable to include a similar summary of the seabird bycatch requirements for fishers operating within State waters.
3. Box 2. Favourable conservation status. The first dot point relates to population maintenance (alone). While a favourable condition, maintenance at low levels (where demographic stochasticity might have an effect) is not ideal. As such, the final dot point that discusses population abundances returning to historic levels should be stated before the dot point on population maintenance, thereby indicating pre-eminence. In terms of the ability of the population to return to historic levels, it would be useful to include statements, perhaps later in the document, on how population abundance will be assessed against historic levels (data collection, demographic rates of change, threats, uncertainty) and judged (what are the indicators, e.g. breeding pairs, colony or foraging range; and against what are the indicators being compared, e.g. reference levels).
4. Australia’s capture fisheries. It is stated under the Commercial Longline and Gillnet sections that there is a need for improved and increased data collection. We suggest the collection of base-line data on bycatch and the factors influencing bycatch. This would help inform managers on where current data gaps and inadequacies lie and help achieve the associated NPOA Seabirds actions. There is also a need for a comprehensive review of the magnitude (coverage rates) and adequacy of current seabird bycatch records held within logbooks, human observer programs and electronic monitoring (EM) across all fisheries within the Scope of the NPOA-Seabirds. These should then be assessed against what is needed to meet management requirements.
5. Recreational fisheries. It is stated here that fishing gear and marine debris can also lead to injury and/or the death of seabirds. It could also be noted under a preceding section that marine debris and ghost fishing can impact seabirds not just from recreational fishing but also commercial fishing (Wilcox, Sebille, and Hardesty 2015).
6. Objective 1. We note that 4 of the 5 objectives relate to mitigation implementation and are obviously necessary. Without sufficient data collection and analysis the effectiveness of mitigation, both in immediate bycatch reductions and in population level impacts will, however, remain unknown. The first dot point stating the need for an understanding of the ‘extent’ of incidental catch is quite vague. To assess trends it would be recommended to have a time series of observations so that mitigation measures can be adequately tested against agreed performance metrics for their ability to reduce population level impacts (the main goal). A clear articulation of the types of metadata needed and the levels of coverage is suggested (for example, is 10% sufficient coverage for line fisheries using EM; are logbook records of bycatch comparable to human or EM observations?). An understanding of the heterogeneity of bycatch among individual skippers can also assist targeted efforts to reduce bycatch.
7. When listing the factors that might determine “whether a problem exists” an additional resource will be the population trends from on-land counts of abundance. Clear co-ordination is advisable between authorities responsible for at-sea threats and those responsible for on-land (colony) monitoring – as breeding pair counts may be the first indicator that bycatch is inadvertently affecting a colony.
8. Objectives 2. Case Study 2. We are not sure if the NPOA-Seabirds should be advocating an individual company’s product.
9. Objective 3. The first paragraph states that developers should consider the feasible application of their invention across fisheries. We note, however, that just because a new measure does not work across fleets should not be seen as a deterrent to development.
10. Implementation. Government subcommittee. The stated biennial workshop might wish to invite representation from authorities studying seabird colony abundance (see 6. above).
11. Evaluation and review. This could ensure there is co-ordination with existing initiatives to monitor and reduce seabird bycatch. For example, the updated Australian Bycatch Policy, the various RFMOs and ACAP should all be consulted for consistency.
12. Appendix A. Fishing effort should also include (if not elsewhere), the number of hooks set, hours trawled etc., fishing conditions (weather), offal discharged.
13. Appendix B. Data collection protocols should take into account the growing move to electronic monitoring and how this may improve (e.g. coverage) or remove (e.g. species identification) data for bycatch estimation. Data on lights used (due to collisions), sea conditions (as tori lines can perform poorly) and tori line configuration should also be collected.
14. Appendix E. Objective 1. It is not clear how Action 1.1 differs from Action 1.7. Both, as written, determine the extent/level of incidental catch of seabirds. Action 1.1 requires a qualitative or quantitative assessment of bycatch. Is this to determine current bycatch or bycatch rates, or population level impacts on seabirds? Are there guidelines for this? Action 1.4 requires the identification of gaps in existing monitoring and data collection programmes for recreational fishing. We would suggest this is true for all fisheries under the Scope of the NPOA-Seabirds.
15. Appendix E. Objective 2. Here, and elsewhere, there needs to be clearly identified performance measures against which indicators can be compared within assessment analyses. Noting that bycatch rate thresholds (0.05 birds per 1000 hooks) are inadequate without a measure of corresponding fishing effort, and do not take into account the potential for the recovery of a population to lead to breaches of the threshold.
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