Submissions for the Proposed Australian Biofouling Management
Requirements Consultation Regulation Impact Statement
A submission received from Aquenal Pty Ltd, 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?
Recommend liaison with [company identifier removed] who have recent experience in this field.
Q5. Are the cost assumptions consistent with industry experience? (see appendix D for all
cost assumptions). Are there better estimates of costs available?
I think the number of days allocated to treatment of large vessels represents a significant underestimate. Cleaning oil rigs, for example, could take up to 30 days. It is highly recommended that
DAFF liaise with [company identifier removed] who have direct experience in this area.
Q6. Are the other assumptions used to estimate costs and benefits reasonable based on
industry experience? If not, how could they be improved?
The RIS makes the assumption that hull treatments will be available in the foreseeable future, an
assumption which should be viewed with serious caution. For large vessels, the only in water
treatment likely to be available by 2013 is in water cleaning, which will be contingent upon the
ANZECC guidelines being modified as part of their recent review. While it is recognised that
there are potential hull treatments available (e.g. HST, IMProtector), they are far from being
proven on large vessels (e.g. bulk carriers, drill rigs) and present enormous technical challenges.
One only has to look at similar challenges provided by ballast water treatment – despite more
than 20 years of research, there is still no ballast water treatment that is used widely across the
industry (apart from ballast water exchange). One would expect a similar timeframe for research
into treatment of ships’ biofouling.
If no treatment options are available upon implementation of proposed regulations, then in-water
cleaning is likely to be the only method available for treating certain vessels. This will present
managers with difficult decisions if presented with a vessel that needs treatment, particularly if
the vessel is harbouring a SOC. E.g. where should the vessel be cleaned to minimise risk of
transefer of SOC? Where can it be cleaned safely? Can it be refused entry?
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?
There is increasing evidence that many invasive marine pests (IMPs) are most successful in
disturbed or polluted environments caused by anthropogenic activities. Undisturbed systems
appear to be resistant to invasion by certain IMPs. On this basis, my view is that the risk to the
GBR has been significantly over-estimated in the RIS. IMPs are only likely to thrive in nearshore areas adjacent to port developments on the GBR. So long as ecosystem integrity of the
broader GBR is maintained by appropriate management, my view is that the vast majority of the
GBR is not at risk from invasion by IMPs. It is important to recognise that effective management
of IMPs needs to consider overall ecosystem health in addition to direct management focusing on
IMPs.
In terms of fisheries I think the impacts may have been overestimated. Most fishing operates in
coastal environments that have not been subject to anthropogenic modification. The likelihood of
impacts to wild fisheries is thus considered low and could be reduced in the model.
I consider the main risk IMPs pose to the fishing industry is aquaculture. IMPs have the ability to
foul artificial structures associated with aquaculture infrastructure, the industry also often
operates in sheltered waters where human impacts are greater and risk of invasion by IMPs is
also greater. A suggestion would be to look at the value of the aquaculture industry in Australia
as the main source of economic threat, and reduce the threat posed by IMPs to wild fisheries.
Q8. What other evidence is there of the potential impacts of non indigenous marine species
becoming established in Australia?
There is a paucity of robust data demonstrating impacts of IMPs. Many of the examples cited in
the RIS describe IMP impacts in areas that have been subject to significant human-mediated
modification. While IMPs may still impact such areas, they are not necessarily the primary
cause, but often a symptom of poor environmental health.
The lack of published evidence of impacts (ecological, environmental) makes it difficult to
assess potential impacts of future IMP incursions. It is important to note that despite the large
number of IMP introductions that have occurred in Australia, only a small number have become
abundant enough to be considered pests. Apart from the economic costs associated with
eradication of invasive mussels from Darwin Harbour, it appears that IMPs in Australia have not
caused widespread economic impacts.
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?
1. Validation/verification of inspections
A major concern is the fact that no validation of vessel inspections/treatment by government is
being proposed in the RIS. Without such validation, there is a strong chance that the quality of
inspection/treatment processes may be compromised. For the process to be robust, two elements
are considered necessary, including (1) A minimum standard (inspection/treatment), along with
(2) verification/validation which would ensure that these processes are being conducted in a
rigorous manner.
2. Species List
While there is always debate surrounding the make-up of species lists, I have several concerns.
The number of species is very high, particularly given that inspections will be based on visual
assessments. There are also several species that would be difficult to survey from a practical
point of view in a biofouling inspection. Suggestions for adjusting the list are provided below:
 Freshwater species were included in the species risk assessment, taking the precautionary
approach. My view is that such species present negligible translocation risk and could be
excluded, as follows:
- Crangonyx floridanus
- Dikerogammarus villosus
- Gammarus tigrinus
- Gmelinoides fasciatus
- Corbicula fluminea
- Dreissena bugensis
- Dreissena polymorpha
 Microscopic species should be excluded from the list, since they cannot be practically
surveyed during visual inspections. Species under this category include:
- Acartia tonsa
- Corethron criophilum
- Pseudochattonella farcimen
- Chattonella antiqua
- Bonamia ostreae
 The merits of including small mobile species is also questionable, since such species
would be difficult to detect during a visual biofouling inspection. Furthermore, the
taxonomic identification of such species would almost certainly require specialist
expertise, since these animals are notoriously difficult to identify to species level. Species
in question include:
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- Ampelisca abdita
- Gammarus tigrinus
Inclusion of Didemnum vexillum on the list is problematic from a taxonomic perspective.
This species can only be reliably identified using genetic techniques. Unless a provider of
molecular services can guarantee a prompt turnaround (considered unlikely), then there
will be problems with implementing the model proposed in the RIS.
Inclusion of parasites (e.g. Bonamia ostreae Briarosaccus callosus, Loxothylacus
panopaei, Sylon hippolytes, Anguillicola crassus) on the list is problematic from an
inspection perspective. It may be more sensible to target potential hosts, but this brings
further complexity to the inspection process.
Inclusion of Codium fragile ssp. atlanticum on the list is problematic. In a recent
assessment it was suggested that one variable species of C. fragile should be recognised
(Guiry 2008). On this basis, inclusion of a Codium fragile subspecies on the list would
not be warranted, since introduced Codium fragile subspecies are established in Australia.
I understand that the risk assessment framework included a prescriptive set of guidelines
for determining human health impacts. However, I find it hard to accept the ‘high’public
health ranking of filter feeding species, justified only by the fact they could accumulate
toxins. It is hard to see where introduction of these species would result in additional risk
to public health (given that they would be consuming native shellfish species that also
accumulate toxins). The key threat to public health comes from the toxic algae, not the
species of concern. On this basis I think that the overall risk has been overestimated for
species including Mya arenaria and Crassostrea ariakensis:
3. Species based approach to biofouling management
The current federal government approach to biofouling management is species based, rather than
based on level of biofouling. While there are pros and cons with the respective approaches (i.e.
species based or level of biofouling), consideration should be given to a combined approach,
where level of biofouling is also taken into account. Vessels with very high levels of biofouling
may still represent a significant biosecurity risk even under circumstances where no SOC are
detected in a biofouling inspection. Heavily fouled vessels are more likely to harbour potential
invasive species that were not revealed in the risk assessment. Furthermore, there remains the
possibility that species not previously shown to be invasive in other parts of the world could
exhibit invasive characteristics when established in Australia for the first time.
Thus, a suggested criteria in a combined approach would be ‘SOC detected OR high risk level of
biofouling present’. Under this approach there would be a need for objective criteria for ‘high
risk biofouling levels’. If such an approach was employed, it would be necessary to consult with
experienced workers in this field to reach an agreement on what should be considered a ‘high
risk’ level. For example, a high cover (>50%) of tertiary level fouling might be considered a
‘high risk’ biofouling level.
The other important advantage of this approach is that it would also reduce the likelihood of
translocation of small mobile species (e.g. amphipods) that may be difficult to detect and/or
identify during a biofouling inspection. Such mobile animals are much more likely to be
associated with high levels of fouling compared to cleaner vessels.