Response to campaigns against AFMA's draft transhipping policy

I understand that the Australian Marine Conservation Society and Save Our Marine Life recently commenced a joint campaign about the Australian Fisheries Management Authority’s (AFMA’s) draft transhipping policy.

AFMA is currently seeking public comments on the draft transhipping policy and guidelines regarding the authorisation of transhipping activities in Commonwealth fisheries. The AFMA Commission will consider all public submissions before it decides whether to accept, amend or reject the policy.

AFMA makes decisions on Commonwealth fisheries management using the best available science and other evidence for the benefit of all Australians. To that end, AFMA welcomes vigorous debate on such matters. However, I am concerned that the Australian Marine Conservation Society and Save Our Marine Life have sought to introduce spurious and misleading information which only undermines the quality of the debate.

I am disappointed that you did not attempt to contact AFMA to check any of the claims in your public campaign. I am very concerned that the Australian Marine Conservation Society and Save Our Marine Life continue to mislead the Australian public about the management of Commonwealth fisheries. In the hope that you might correct the inaccurate and misleading statements regarding the draft policy and fisheries management, I have provided some factual information below.

Transhipping does not allow overfishing

Your claim that transhipping will lead catch ‘to increase to industrial scales never seen before’ is not true. AFMA manages fisheries using a sustainable total allowable catch (TAC) limits and quota allocated to fishers based on science. Transhipping does not affect TACs.

Transhipping reduces costs and environmental footprint

Recent research has found that, compared to other sources of animal protein, products derived from marine fisheries and destined for human consumption produce relatively low greenhouse gas emissions (Parker et al 2018 ‘Fuel use and greenhouse gas emissions of world fisheries’ Nature Climate Change). Transhipping can reduce fuel consumption, further minimising the environmental footprint of commercial fishing.

Transhipping already happens in Australian waters

Transhipping already occurs in Australian fisheries; the draft policy is about ensuring best practice and a consistent approach across fisheries. Your claim that the policy allows for ‘easier and faster’ approval is incorrect. Your claim ‘this would make possible industrial fishing on a scale not seen before’ is also incorrect; transhipping is already authorised by AFMA.

Transhipping improves fish quality and value

Transhipping allows for faster processing, improving quality and freshness for seafood consumers. This ensures the best use of the resource and improves economic returns to the Australian community, one of AFMA’s objectives.

Transhipping reduces (the already low) risk of localised depletion

Transhipping means that boats are less likely to stay in one area. This can spread catches out, lowering (the already low) risk of localised depletion, and can reduce conflict between resource users.

Globally, transhipping is seen as vital – authorising it helps Australian fishers stay competitive

Appropriately monitored and regulated, transhipping is globally recognised as vital to fishing (see Pew 2018:

It is true that transhipping, like any other fishing operations (commercial, recreational or indigenous) can be unsustainable if poorly managed. However, AFMA’s strict controls on catch, regardless of whether the catch is unloaded at sea or in port, means that banning transhipping would only make it harder for Australian fishers to compete internationally and domestically.

AFMA’s draft transhipping policy ensures best practice

AFMA’s draft transhipping policy is about ensuring best practice. This includes reporting, monitoring and data sharing with relevant bodies as emphasised by Pew 2018:

AFMA’s monitoring includes the use of cameras and/or on-board observers, as well as compliance officers.

Flawed science

You mention new research showing a 30 per cent decline in fish stocks. This science:
• incorrectly applied a fish count of inshore species like wrasse and luderick to Commonwealth managed fish that do not occur in the shallow waters surveyed
• incorrectly used catch to estimate a decline in biomass without considering other reasons for the decline in catch like fishing effort buybacks or reducing catch to prevent overfishing (and therefore maintain or grow biomass).

AFMA would not use this type of research to manage Commonwealth fisheries as it is badly flawed.
Your statement that ‘this is the first time the sustainability of Australia’s fisheries management has been tested against real fish count data – independent of government’ is not correct. Fishery independent surveys, for example scientific trawl surveys, egg count surveys and acoustic surveys, are used in many of AFMA fisheries.

Super trawlers will not be able to tranship

The Federal Government has permanently banned boats of more than 130 metres in length from fishing in Commonwealth waters. This ban already applies to transhipping and will continue to do so.

Transhipping will not affect Australia’s international obligations

AFMA’s draft transhipping policy only applies to Australian boats in the Australian Fishing Zone (AFZ) that are landing to Australian ports. There are several ways a boat can be an Australian boat as outlined in the Fisheries Management Act 1991 (Section 4).

While the policy only applies to activities in the AFZ, any authorisation involving internationally managed species must be consistent with Australia’s obligations under Regional Fisheries Management Organisations and similar international arrangements.

The public consultation period for the draft transhipping policy and guidelines will close at 5pm AEST on 20 July 2018. The AFMA Commission will consider all submissions received but, in my experience, submissions based on false or misleading information, such as that contained in your campaign materials, tend to have less impact in evidence-based decision making.

In closing I can reassure Australians that they have world class, sustainably managed Commonwealth fisheries, which are underpinned by ecologically sustainable catch limits, world-leading scientific research and a strong legislative and policy framework.

To help the Australian Marine Conservation Society and Save Our Marine Life supporters and other members of the public considering the draft transhipment policy, AFMA will make this letter available on In future, if you or other members of the Australian Marine Conservation Society and Save Our Marine Life are interested in the facts about this, or any other fisheries matters, please do not hesitate to contact us.

Yours sincerely

Dr James Findlay
Chief Executive Officer

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