20 April 2018

Dear Mr Kindleysides

The Australian Fisheries Management Authority (AFMA) understands that the Australian Marine Conservation Society (AMCS) has updated its sustainable seafood guide for Australian commercial fisheries.

It is disappointing that little of the feedback and input provided by AFMA for the revised guide in September 2017 appears to have been taken into account. For example, significant developments in understanding bottom impacts of fishing, improvement in stock status and bycatch mitigation have not been incorporated into the guide. Further, while protected species are important, most are not threatened.  For Commonwealth fisheries the threatened species list is relatively short and our fisheries stand out as leaders in successfully addressing many of these interactions. This appears not to have been acknowledged in the AMCS rankings of Commonwealth fisheries.

The AMCS assessment is at odds with not only AFMA’s science based assessment of Commonwealth managed fisheries but also those of the Australian Bureau of Agriculture and Resource Economics and Sciences (ABARES), the Marine Stewardship Council and the Status of Australian Fish Stocks (administered by the Fisheries Research & Development Corporation).

ABARES independently assesses AFMA’s performance, including both the assessment of stock status and also commentary on the impact of fishing on the marine environment, for the Australian government. MSC is an international non-government body that certifies fisheries it determines as sustainable, which includes both an examination of sustainable harvesting practices and impact of fishing on the marine environment. The SAFS report draws on state, NT and Commonwealth fisheries data to determine fishery status.

For AFMA managed fisheries, ABARES has assessed that for the last four years no solely Commonwealth-managed fisheries are subject to overfishing, including:

Albacore Tuna Gould’s squid Royal Red Prawns
Alfonsino Gummy Shark Sawsharks
Australian Sardine Jack Mackerel Scallops
Bigeye Tuna Jackass Morwong Scampi
Blue Grenadier John Dory School Shark
Blue Mackerel Mackerel Icefish Silver Trevally
Blue Warehou Mirror Dory Silver Warehou
Blue-eye Trevalla Ocean Jacket Skipjack Tuna
Bight Redfish Ocean Perch Smooth Oreo Dory
Broadbill Swordfish Orange Roughy Southern Bluefin Tuna
Bugs Oreos Striped Marlin
Deepwater Flathead Pink Ling Tiger Flathead
Deepwater Sharks Prawns Toothfish
Eastern School Whiting Redbait Yellowfin Tuna
Elephant Fish Redfish
Gemfish Ribaldo

It is also disappointing that AMCS appears not to have considered the broader implications of its rankings on Australian consumers by leaving them with limited opportunity to purchase Australian seafood in the ‘better’ category. Seafood is a healthy food choice, has a relatively low carbon footprint (compared other animal protein sources) and many family businesses across Australia rely on seafood for employment.  These matters along with a number of others help determine sustainability across ecological, economic and social components. This approach is reflected domestically through the Ecologically Sustainable Development Principles in Commonwealth fisheries law and internationally through the Food and Agricultural Organisation of the United Nations and the United Nations Sustainable Development Goals.

AFMA encourages AMCS to engage with fishery regulators and the seafood industry in a constructive dialogue that will lead to improved fishery sustainability in the future.

I am, as always, willing to have further dialogue on these matters to improve AMCS’ assessment.  If you think this would be worthwhile please contact me on 02 6225 5534.

Yours sincerely

Dr Nick Rayns

A/g Chief Executive Officer