Submissions for the Proposed Australian Biofouling Management
Requirements Consultation Regulation Impact Statement
A submission received from Ecomarine Consulting, Tasmania
Submission
Q1. Do the proposed operating time restrictions on vessels achieve an appropriate balance
between minimising biological risk (which increases with time) and minimising the impact
on vessel operators (who may need more time)? If not, why and what would be a better
balance?
[insert your response here]
Q2. How might vessel operators’ behaviour change in response to the proposed
regulations?
[insert your response here]
Q3. What specific types of flow-on costs and benefits to the Australian economy of the
proposed regulations might be significant?
[insert your response here]
Q4. The estimates of costs are based on average vessel numbers from 2002-2009. Is there
any activity or trends that suggest any significant change in vessel movement or increased
numbers of arrivals?
[insert your response here]
Q5. Are the cost assumptions consistent with industry experience? (see appendix D for all
cost assumptions). Are there better estimates of costs available?
[insert your response here]
Q6. Are the other assumptions used to estimate costs and benefits reasonable based on
industry experience? If not, how could they be improved?
[insert your response here]
Q7. The methodology for estimating the economic value at risk relies on a series of
assumptions about the value of commercial fishing and the Great Barrier Reef. Are there
more plausible assumptions or approaches that could be used?
[insert your response here]
Q8. What other evidence is there of the potential impacts of non indigenous marine species
becoming established in Australia?
[insert your response here]
Q9. What is industry’s view of the likely effectiveness of a voluntary approach to reducing
the risks associated with biofouling compared to a regulatory approach?
[insert your response here]
Q10. Do you have any other comments on the Regulation Impact Statement?
Care is needed to achieve compatibility between the cost estimates for vessel inspections /
practical considerations and the list of Species of Concern being targeted. Some of the 56 SOCs
listed are microscopic or otherwise unlikely to be identified through a diver or video survey.
Likely examples include the sea lettuce Ulva pertusa, isopod Sphaeroma annandalei, Baikalian
amphipod Gmelinoides fasciatus, Haplosporidian parasite Bonamia ostreae, parasitic nematode
Anguillicola crassus, diatom Corethron criophilum, amphipod Ampelisca abdita, Florida
crangonyctid Crangonyx floridanus, amphipod Gammarus tigrinus, green sea fingers Codium
fragile atlanticum, brown algae Fucus evanescens, grey encrusting sponge Gelliodes fibrosa, as
well as a range of barnacles. Additional listed SOCs may also fall into this category. These
species may not be readily identified because of one of the following reasons:



They are microscopic
They would not be readily sampled without specialist targeted techniques
They could not be readily distinguished from other related species without specialist
taxonomic expertise
The SOCs being targeted can have a very large influence on the cost of an inspection survey (as
well as feasibility within necessary timeframes), and hence it may be advantageous to resolve the
issue of SOCs at an early stage to confirm that estimated inspection costs are as accurate as
possible. One potential approach is to perform an analysis to divide the SOCs into categories,
such as:
1. Species readily identified in situ by a non-taxonomic expert on the basis of a video survey
(where the video assessor has access to basic identification tools) [although noting that for
verification/evidence purposes, it would be necessary to supplement such an identification
with acquisition of specimens]
2. Species readily identified by a non-taxonomic expert (with assistance from basic
identification tools) upon obtaining a specimen – where suspected specimens could be
readily obtained without use of specialist techniques (i.e. immobile specimens that could be
readily detected and physically dislodged from the fouled surface by a diver)
3. Species readily identified by a non-taxonomic expert (with assistance from basic
identification tools) upon obtaining a specimen – but where acquiring specimens would
require use of specialist techniques (i.e. techniques other than physical dislodgement of easily
detected immobile species; e.g. techniques to target mobile species within the fouling
community)
4. Species that could only be identified by a taxonomic expert, with digital photos adequate where suspected specimens could be readily detected and obtained without use of specialist
techniques
5. Species that could only be identified by a taxonomic expert, with digital photos adequate and where acquiring specimens would require use of specialist techniques
6. Species that could only be identified by a taxonomic expert through laboratory analysis of
specimens, collected through either specialist or non-specialist techniques [whatever field
collection techniques are applicable, it is suspected that species falling into this category
would need to be excluded due to timeframes involved]
The types of surveys/analysis required to target each species could then be determined, such as:
A.
B.
C.
D.
E.
Video survey [supplemented by specimen collection if detected]
Diver observation survey – no specialist survey techniques
Diver or other survey – specialist techniques
A, B or C above requiring transfer of digital images to a taxonomic expert
A, B or C above involving collection of samples for laboratory analysis
Decisions could be made about the level of complexity of surveys and hence the SOCs being
targeted depending on the vessel type. For example, for yachts, it may be decided that only
species that could be identified through a video survey or by a non-taxonomic expert diver using
non-specialist techniques would be targeted. This decision about techniques to be applied would
be driven primarily by considerations such as risk, expense and ease of survey, and may restrict
the list of target SOCs to just a small portion of the 56 currently listed in the case of yachts. It
may be determined that additional more complex survey techniques are viable and appropriate
for commercial vessels and so decisions could be made about which techniques should be
applied on the basis of risk, cost and feasibility (e.g. as per above, it is unlikely to be feasible to
include species that require a lengthy wait for laboratory sample analysis due to decision
timeframes).
If the above approach resulted in a very minimalist list of SOCs for yachts, for example, then
perhaps an approach could be applied that combines the use of SOCs with the approach used
elsewhere based on levels of fouling. i.e. Based on clear criteria about level of fouling, a
management decision could be made that a vessel needs to be treated even though an SOC
cannot be detected, recognising that many of the SOCs cannot be detected using the limited
techniques applied to yachts.
The above are ideas and examples for consideration; the important thing is that a standard
list/lists of SOCs and associated survey methodologies are developed and applied at an early
stage which are practical and achievable within estimated budgets and other restraints. This will
avoid the need for subsequent lengthy negotiations between vessel operators/DAFF and
inspection service providers about how to approach particular surveys.
Two other related considerations are relevant here:
 The need for auditing of inspection reports – to ensure they are being performed adequately
and targeting the correct suite of SOCs

Identifying criteria to ascertain whether inspections performed overseas have been performed
to a standard considered adequate or comparable to that being applied in Australia.