DEPARTMENT OF PRIMARY INDUSTRY AND FISHERIES www.nt.gov.au Small-scale aquaculture of ornamental fish species in the Northern Territory Discussion paper for public consultation Open for comment until 31 December 2013 Table of Contents 1. INTRODUCTION ............................................................................................................................. 1 2. SCOPE ............................................................................................................................................ 1 3. DEFINITIONS .................................................................................................................................. 1 4. CURRENT NT SITUATION ............................................................................................................. 2 4.1 4.2 Legislation ............................................................................................................................... 2 Licensing ................................................................................................................................. 2 5. AQUACULTURE LICENCING IN OTHER JURISDICTIONS ........................................................ 2 5.1 5.2 5.3 5.4 5.5 5.6 Western Australia .................................................................................................................... 2 New South Wales .................................................................................................................... 3 South Australia ........................................................................................................................ 3 Tasmania................................................................................................................................. 3 Queensland ............................................................................................................................. 3 Victoria .................................................................................................................................... 4 6. DRIVERS FOR CHANGE ............................................................................................................... 4 6.1 6.2 6.3 Scope of the local industry ...................................................................................................... 4 Biosecurity ............................................................................................................................... 5 National policy ......................................................................................................................... 5 7 ISSUES FOR DISCUSSION ........................................................................................................... 6 7.1 7.2 7.3 7.4 Support for the introduction of a small-scale aquaculture licence .......................................... 6 Licence Fees ........................................................................................................................... 6 Definition of ‘hobby’ ................................................................................................................. 6 Definition of ‘small-scale’ ......................................................................................................... 7 8. PROPOSAL – A TWO-TIERED LICENCING ARRANGEMENT FOR THE AQUACULTURE SECTOR.......................................................................................................................................... 9 8.1 8.2 Tier 1 – Small-scale aquaculture licence ................................................................................ 9 Tier 2 – Full aquaculture licence ........................................................................................... 10 9. SUBMISSIONS ............................................................................................................................. 11 APPENDIX 1- LEGISLATION........................................................................................................... 12 A1. A2. Northern Territory Fisheries Act 1988 ................................................................................... 12 Northern Territory Fisheries Regulations 1993 ..................................................................... 12 Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper i Small-scale aquaculture of ornamental fish species in the Northern Territory A discussion paper for public consultation 1 Introduction NT Fisheries is seeking comment on a proposal to introduce a new category of aquaculture licence specifically tailored to the small-scale breeding of, and trade in, ornamental fish species. This is in line with other jurisdictions in Australia which have recently moved to reduce the regulatory burden and cost of the licensing process for small-scale operators. The intent of introducing a small-scale, ornamental species aquaculture licence is to provide a means to easily regulate and report on this activity as well as encourage start-up investment which may ultimately lead to larger enterprises. 2 Scope This proposal applies to the aquaculture and trade of ornamental species only. This proposal is not intended to consider changes to the NT Fisheries Act or Regulations. Rather it is to explore the possibility of establishing a new class of licence under existing legislation. This proposal only applies to land-based operations and not to sea-based operations, such as small-scale grow-out of giant clams. This proposal does not consider matters around the importation and possession of particular aquatic species. Current legislation determines which species are allowable imports and which are noxious or banned and illegal to possess. This proposal does not address matters associated with development consent or other approvals that may be required by other government departments. It relates only to licencing issues controlled by NT Fisheries. 3 Definitions For the purposes of this discussion paper, the following definitions apply: Ornamental species means any species of fish or aquatic life cultivated for the purposes of exhibition or sale in the aquarium industry but does not include species cultivated for the purposes of human consumption or for the purposes of stocking a farm dam or public water body. Aquaculture is the deliberate farming, culturing, or breeding of fish or aquatic life for sale. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 1 4 Current NT Situation 4.1 Legislation The Northern Territory Fisheries Act 1988 (the Act) and the Northern Territory Fisheries Regulations 1993 (the Regulations) govern aquaculture operations in the NT. Excerpts of specific sections of the legislation relating to aquaculture are listed in Appendix 1. Section 10 of the Act specifies that a person shall not “farm, breed, culture, or keep live fish or aquatic life for sale or the purposes of aquaculture (whether they are sold or used live or dead) or for the purpose of exhibiting any of them for profit; unless the person does so under and in accordance with a licence.” To be legally entitled to undertake aquaculture activities in the NT for sale or the purposes of aquaculture, an aquaculture licence is required regardless of the scale of the activity. The requirement to be licensed before a person can sell fish is clear. In developing an aquaculture licence that caters for small-scale ornamental species operations it is not intended that the Act will be amended to remove this requirement. 4.2 Licensing Applicants for a new licence currently complete a Notice of Intent for an Aquaculture Licence, which describes the nature of the proposed venture, and establishes that other Government consent/ entitlements/ permits/ licences etc., have been obtained. The information on the Notice of Intent can also be used by the Environmental Protection Authority to determine if any formal environmental assessment needs to be undertaken on the proposed activity. Current conditions on an aquaculture licence require licensees to undergo an annual inspection for compliance with the Act, and to submit production and sales data to NT Fisheries on a 6 monthly basis. It is not proposed to change either of these requirements. The compliance inspection helps the industry to demonstrate that it is operating in accordance with the principles of ecological sustainable development. The submission of production data is essential for compilation of industry value and may be used for biosecurity purposes in the event of a disease outbreak. All non-pearl aquaculture operators pay an annual fee for their aquaculture licence. For 2013/14 the fee is $590. In addition, licence holders pay a levy which supports the Northern Territory Seafood Council (NTSC). The levy is currently $845 making a total cost of $1435 for the year. 5 Aquaculture licencing in other jurisdictions 5.1 Western Australia In Western Australia, there is a legal requirement (Fish Resources Management Act 1994 and the Fish Resources Management Regulations 1995) for anyone who keeps, breeds, hatches or cultures fish to hold an aquaculture licence. Fees vary depending on the type of proposal. Exceptions include keeping fish for non-commercial purposes or for display or ornamental hobby purposes. Anyone taking up non-commercial aquaculture must be aware of the differences between keeping fish as a hobby and for commercial purposes. The distinction between keeping fish for business or hobby purposes is determined by reference to the Australian Taxation Office. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 2 5.2 New South Wales Aquaculture involves the breeding, growing, keeping and harvesting of fish or marine vegetation with a view to sale for a commercial purpose (Fisheries Management Act 1994) and requires a permit. An exemption from the requirement to hold an aquaculture permit exists for small scale ornamental fish producers. ‘Small scale’ is defined as any person who cultivates ornamental fish for sale, in a facility that holds less than 10,000 litres. All ponds involved in the culturing of fish are considered in calculating the volume of the ponds or tanks. 5.3 South Australia Under the Aquaculture Act 2001, a person must not carry on aquaculture unless authorised to do so by an aquaculture licence. Aquaculture means farming of aquatic organisms for the purposes of trade or business or research. There are three types of land-based licences: low risk, medium risk, and high risk. To determine which category a licence falls under, factors affecting the ecological sustainability of aquaculture authorised by the licence will be taken into account, including: the treatment and discharge of water from the licence area. whether or not the species to be farmed are native to the locality of the licence area. the susceptibility of the species to notifiable disease. Large scale aquarium breeders and wholesalers may require a licence under the Aquaculture Act 2001. In practice, the determination of ‘large scale’ is undertaken on a case by case basis and considers a number of factors including water volume (>20,000L), purpose (trade, business or research), environmental impacts and risks, biosecurity etc. (pers. comm. Luke Fraser, SA Fisheries licencing). 5.4 Tasmania To breed ornamental fish for sale in Tasmania requires a fish farm operator licence. The sale of fish bred under a fish farm licence requires a fish dealer registration. Assessment of fish farming proposals involves consultation and approvals from various Government authorities and addresses standards in relation to land and water usage, environmental impacts, disease control etc. 5.5 Queensland The Fisheries Act 1994 provides for the management of aquaculture, with aquaculture defined as 'the cultivation of fisheries resources for sale'. Aquaculture requires a fisheries development approval issued under the Sustainable Planning Act 2009 and the Integrated Development Assessment System (IDAS). Aquaculture activities under the Sustainable Planning Act 2009 are divided into two categories: 'self-assessable' (certain types of low impact aquaculture only), and 'assessable'. The 'Code for self-assessable development - low impact aquaculture AQUA01' applies to low-impact projects that will have only a minor impact on the environment and the community. If the proposed activity is permitted under this code an approval from Fisheries Queensland is not required for the project to proceed. It is the responsibility of the aquaculturist to comply with the conditions of the code to avoid prosecution. Such developments must be registered with Fisheries Queensland before they are started. Low impact aquaculture projects are generally self-assessable, providing the work does not cause waste discharge into off-site waters, and the species farmed are: Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 3 5.6 native freshwater fish held in ponds or above-ground tanks with a total water surface area of no more than 5 ha, or native freshwater fish intended for aquarium display or human consumption only, kept in rain-proofed above-ground tanks with a total area of no more than 50 m2 exotic fish intended only for aquarium display, kept in rain-proofed above-ground tanks with a total area of no more than 50 m2 native marine fish intended for aquarium display only, kept in rain-proofed aboveground tanks with a total area of no more than 50 m2 Victoria Aquaculture activities may include hatching, rearing, breeding, displaying or growing specified species for sale or other commercial purposes, and the use of commercial aquaculture equipment. Anyone wishing to conduct an aquaculture activity (including the breeding of ornamental species) is required to hold an aquaculture licence (Fisheries Act 1995). 6 Drivers for change There are a number of drivers which have contributed to the current proposal to establish a new class of aquaculture licence for small-scale breeders of ornamental species, including the belief that current licensing requirements may be a burden to small-scale operators. For small-scale aquaculturists and ornamental fish enthusiasts, licence fees can pose a significant cost burden when compared to annual turnover. This is particularly the case for home-based businesses with limited production capacity. Industry members have previously argued that the aquaculture licensing regime may be a disincentive to those who want to pursue home-based or small-scale ornamental species production operations. Subsequently, it has occasionally been proposed by industry that it may not be necessary to require this sector to have a licence and that it may be administratively easier if they don’t. It is clear that NT legislation requires aquaculture activities to be licensed. However, legislatively there is nothing preventing the creation of a category of aquaculture licence for culturing ornamental species on a small scale. It would, however, be important to ensure the development of an associated policy framework for the management and monitoring of the ornamental species industry. This approach has support from the Minister. 6.1 Scope of the local industry Currently, detailed information on the scope of small-scale activities involving the aquaculture and/or trade of ornamental species in the NT is not available. The information that is available generally relates to business owners who are currently licenced, with the result that the true nature and extent of unregulated (legal and illegal) activity is open to speculation. The current requirement for licencing and the associated fees may be a factor contributing to unregulated activities. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 4 6.2 Biosecurity In the NT, trade in ornamental species can represent a significant biosecurity risk. Exotic fish may be accidentally or intentionally released into waterways, establish self-sustaining populations and become pests. Fortunately, the NT’s waterways are generally free of serious pest fish problems which are present in many other states (e.g. carp and tilapia) however, an increasing number of small creeks and streams in urban areas are becoming populated by common aquarium species such as guppies and platies. Exotic fish may also carry and spread foreign diseases which can be incredibly destructive in native species. To effectively manage the response to a biosecurity incident, knowledge of associated industries and trade is essential to facilitate inspections, tracing, containment, education etc. Providing a simple licencing process for small-scale ornamental aquaculture should: provide NT Fisheries with greater knowledge to better manage biosecurity incidents; enable educational materials to reach the hobby sector; give value to aquarium species for the hobbyist; and may aid in the reduction of disease events and the illegal trade of fish. 6.3 National policy The importation of ornamental fish into Australia is controlled by the Australian Government through a list of permitted species under the Environment Protection and Biodiversity Conservation (EPBC) Act 1999. The Department of Agriculture Fisheries and Forestry Biosecurity inspect shipments that include ornamental fish. Once in Australia, State and Territory legislation controls the keeping and movement of species. The inconsistent approaches between the States and the NT often impede the effective management of the ornamental industry. In 2006, this inconsistency was reflected in the report ‘A strategic approach to the management of ornamental fish in Australia’ published by the Australian Government. It includes recommendations from the national Ornamental Fish Policy Working Group (OFPWG) for the management and regulation of the ornamental fish trade in Australia. The document highlights the lack of consistency across Australian jurisdictions for the control and regulation of the breeding and sale of ornamental species. A major issue in the industry is the hobby or enthusiast sector, with the line between ‘hobby’ and ‘commercial activity’ being open to interpretation. To assist the development of a consistent approach to the management of ornamental aquaculture operations, the OFPWG developed decision support trees to classify operations as retail, wholesale, hobby, pets etc. The decision trees utilise criteria such as intent to sell, presence of active breeding activities and volume of water (10,000L), and suggests a tiered permit or registration system for aquaculture activities. In all jurisdictions, the breeding of ornamental fish is considered an aquaculture activity and is required by Fisheries legislation to be licensed. Development approvals and/or environmental impact assessments are also often required by other state or local government agencies. Generally, the licensing requirement is not limited by the size of the facility. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 5 7 Issues for Discussion 7.1 Support for the introduction of a small-scale aquaculture licence Before such a licence can be introduced, there needs to be broad support from government, industry, and representative industry and hobbyist organisations. All are invited to provide comment on this discussion paper. Discussion question 1: Do you/your organisation support the introduction of a small-scale aquaculture licence for ornamental species? 7.2 Licence Fees A driving factor for the introduction of this licence is the prohibitive nature of the current aquaculture licences fees on the development of small-scale ornamental species aquaculture ventures. A significant portion of this fee is the NTSC levy. Possible exemption from the NTSC levy It is suggested that such a levy would not be compulsory for this licence. Consequently, however, the licence holder would not be a member of, nor be represented by, the NTSC. Reduction of NT Fisheries fee It is also intended that the NT Fisheries portion of the licence fee be reduced to a figure more in line with the scale of operations catered for by this licence. Discussion question 2: Is exemption from the NTSC levy supported? 7.3 Definition of ‘hobby’ Determining what constitutes an aquaculture ‘hobby’ as opposed to a small-scale aquaculture business is necessary in order to provide clarity around who is, or is not, required to be licenced. A person conducting fish culture as a hobby would not require a licence. Two criteria need to be considered: Intent to sell The Fisheries Act is clear that a licence is required in order to farm, breed, culture, or keep live fish or aquatic life for sale. Therefore private individuals producing fish for their own personal use, and not for sale, may be considered a ‘hobbyist’. Purposes of aquaculture The Fisheries Act is also clear that a licence is required to farm, breed, culture, or keep live fish or aquatic life for the purposes of aquaculture (whether they are sold or used live or dead). Aquaculture is defined as including the farming, culturing, or breeding of fish or aquatic life for the purposes of trade, business, or research. Therefore, fish culture activities that are not undertaken for the purposes of trade, business, or research may be considered a ‘hobby’. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 6 Definition A person keeping and culturing aquatic life which is not for sale, or trade, business, research or commercial display is considered a hobbyist and is not required to have a licence under the Fisheries Act. Discussion question 3: Do you agree with the definition of a hobbyist? 7.4 Definition of ‘small-scale’ Determining a cut-off point between small-scale aquaculture businesses and those requiring a full licence is a difficult but necessary step required to clarify the scope of a ‘small-scale’ licence. Possible criteria which may be used to define ‘small-scale’ are: Volume of water held The national Ornamental Fish Policy Working Group, in its report ‘A strategic approach to the management of ornamental fish in Australia’, recommended that facilities breeding fish for sale and using a volume of water less than 10,000 L be considered a hobby, while those using more than 10,000 L require a the applicable State or Territory licence/permit. Based on this recommendation, in 2009, NSW amended fisheries legislation to provide an exemption from the need for an aquaculture permit for those cultivating ornamental fish with a view to sale in a facility that holds less than 10,000 L. As noted above, the NT Fisheries Act requires that to farm, breed, culture, or keep live fish or aquatic life for sale or for the purposes of trade, business, or research, a licence is required. Discussion question 4: Is it feasible to distinguish between small and large-scale aquaculture based on water volume? If no, please give reasons and proceed to question 6. Discussion question 5: For those breeding aquatic life for sale or for the purposes of trade, business, or research, is a volume of 10,000 L of water an appropriate volume to distinguish between small-scale operations and those requiring a full aquaculture licence? If no, what is an appropriate volume? Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 7 Surface area The surface area of water (the total area of ponds and tanks) used may provide an alternative measure to water volume to characterise a small scale operation. Discussion question 6: For those breeding ornamental fish for sale or for the purposes of trade, business, or research, is surface area an appropriate measure to determine small scale? If no, please give reasons and proceed to question 8. Discussion question 7: What surface area of water is appropriate to distinguish between small scale operations and those requiring a full aquaculture licence? Australian Tax Office - GST registration requirement. The Australian tax Office (ATO) defines a small business as “an individual, partnership, trust or company with an aggregated turnover of less than $2 million.” A small business must register for GST when it has an annual turnover of $75,000 and it must also have an ABN. The level of gross turnover for a business could be used as a guide for the capacity of the business to pay the full licence fee and levy. It is suggested that rather than pick an arbitrary figure of gross turnover, the limit could be linked to the ATO’s registration requirement for GST. Currently, a business must register for GST if their annual gross turnover (the value of all supplies made) is $75,000 or greater. This would mean that businesses with a gross turnover of less than $75,000 would be classed as ‘small-scale’. By linking the NT’s definition of small-scale aquaculture to the ATO GST limit, when the limit is adjusted, so too would the NT’s ‘small-scale’ definition. Discussion question 8: Is linking the measure of ‘small-scale’ to the ATO’s registration requirement for GST appropriate? Discussion question 9: Is a gross turnover of $75,000 an appropriate indicator of small vs. large scale? Is some other alternative measure of turnover more appropriate? Characteristics of the operation Various characteristics of an operation (or a combination thereof) may be an appropriate way to determine ‘small scale’. These may include: General land use in the area – i.e. is the facility on a residential block or in a rural or commercial zoned area Type of equipment and methods in use – e.g. aquariums, above-ground ponds or inground ponds, recirculating systems Water treatment/discharge volume Number of staff Species being cultured Projected turnover/production (value)? Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 8 Discussion question 10: Is it appropriate to define a small-scale aquaculture business based on the characteristics of the operation? What characteristics of an aquaculture facility suggest that it is small scale? Other measures Discussion question 11: Are there other possible measures more appropriate than those listed above to distinguish between small and large-scale ornamental species aquaculture operations? 8 Proposal – a two-tiered licencing arrangement for the aquaculture sector In order to address the issues surrounding the current licencing arrangements and their impacts on the aquaculture of ornamental species, the following tiered registration and licencing arrangement is proposed. The distinction between the two tiers is not yet determined and will be finalised following reference to feedback received on the discussion points above. NT Fisheries is seeking comments on this proposed structure: Tier 1 – Small-scale aquaculture licence 8.1 Scope of activities Aquaculture activities are actively undertaken with intent to sell, or for the purposes of trade, business, or research. The fish being produced are not intended for human consumption, that is, they are produced for the ornamental fish trade. The facility meets a number of conditions which characterise it as small scale. These may include reference to: A measure of water volume or surface area Other characteristics of the facility such as: land use, staffing numbers, etc. Annual turnover Biosecurity risk Other factors as considered appropriate Licence applicants will need to complete a Notice of Intent (NoI), which describes the nature and scale of the venture, and establishes that other Government consent/entitlements/permits/licences have been obtained (or are not required). The NoI will also be used by the Environment Protection Authority to determine if environmental assessment is required. Requirements and obligations of the licence holder Maintain a current aquaculture licence: ‘small-scale aquaculture of ornamental species’, including the payment of an annual fee Adhere to licence conditions which provide the basic framework of what can, and what cannot, be done as part of the activity of aquaculture. These may include: o Keep business records including: a record of fish received and sold o Identify which species are allowed to be cultured o Notify the Director of Fisheries of any significant disease event Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 9 o Submission of production records to NT Fisheries every 6 months; o Other conditions that may be imposed from time to time Notify the Director of Fisheries if the activity or the facility changes from that originally described. Requirements and obligations of NT Fisheries Similar to current aquaculture licencing arrangements, including: Conduct regular (e.g. annual) inspections of each facility to check for adherence to licence conditions. Maintain a register of licence holders. Provide extension support and advice on production, biosecurity and fish health. Discussion question 12: Do you support the requirements and obligations of the proposed small-scale licence? Why/ why not? Tier 2 – Full aquaculture licence 8.2 This tier 2 licence is intended to be consistent with current aquaculture licencing requirements. Scope of activities Aquaculture activities are actively undertaken with intent to sell, and/ or for the purposes of trade, business, or research. Fish may be produced and sold for human consumption. The facility does not meet the conditions that classify it as small scale. Requirements and obligations of the licence holder Requirements are as per current aquaculture licencing arrangements and include: Licence applicants must complete a NoI describing the nature of the proposed venture, and establish that other Government consent/ entitlements/ permits/ licences have been obtained. The NoI will also be used by the Environment Protection Authority to determine if environmental assessment is required and an environmental management plan will need to be developed. Notify the Director of Fisheries if the activity or the facility changes from that originally described. Notify the Director of Fisheries of any significant disease event Conduct operations according to licences conditions. These provide the basic framework of what can, and what cannot be done as part of the activity of aquaculture. A range of legislation covers various aspects of aquaculture and its environmental sustainability. Obligations and requirements of NT Fisheries Obligations are as per current aquaculture licencing arrangements and include: Conduct regular (e.g. annual) inspections of each facility to check for adherence to licence conditions. Maintain a register of licence holders. Provide extension support and advice on production, biosecurity and fish health. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 10 9 Submissions Submissions on this discussion paper must be submitted by close of business (16:21) on December 31, 2013. Written submissions can be mailed to; Fisheries Department of Primary Industry and Fisheries GPO Box 3000 Darwin NT 0801 or emailed to: Fisheries@nt.gov.au Questions relating to the review can be referred to: Glenn Schipp Director Fisheries Development 08 8999 2213 or glenn.schipp@nt.gov.au Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 11 Appendix 1- Legislation Listed below are excerpts from the NT Fisheries Act and Regulations that are relevant to aquaculture and associated licencing requirements. Please note that these are not complete and should not be interpreted without reference to the full legislation. The entire Fisheries Act and Regulations can be accessed via the NT Fisheries website: http://www.nt.gov.au/d/Fisheries/index.cfm?header=Legislation A1. Northern Territory Fisheries Act 1988 Division 2 Licensing A person shall not farm, breed, culture, or keep live fish or aquatic life for sale or the purposes of aquaculture (whether they are sold or used live or dead) or for the purpose of exhibiting any of them for profit unless the person does so under and in accordance with a licence. Definitions aquaculture includes the farming, culturing, or breeding of fish or aquatic life for the purposes of trade, business, or research. aquatic life means any species of plant or animal life (except species of birds) which, at any time of the life history of the species, must inhabit water, and includes the plant or animal at any stage of its life history, and also includes any part of such plant or animal, but does not include fish, or aquatic life declared by the Minister by notice in the Gazette to be aquatic life to which this Act does not apply. fish means any species or class of fish including crustaceans, echinoderms, and molluscs, and includes an aquatic animal (except a species of bird) declared by the Minister by notice in the Gazette to be a fish for the purposes of this Act . . . sale includes every method of disposition for valuable consideration, including barter, and includes the disposition to an agent for sale on consignment, and also includes offering or attempting to sell, or receiving or having in possession for sale, or exposing for sale, or sending or delivering for sale, or causing or permitting to be sold, offered, or exposed for sale, and also includes disposal by way of raffle, lottery, or other game of chance. A2. Northern Territory Fisheries Regulations 1993 Part 10 Aquaculture Division 1 Licensing generally 159 No breeding for sale without licence A person shall not breed, farm or hold live fish for sale unless he or she holds a licence in respect of this Part. Division 2 170 Aquaculture licence No aquaculture without licence (1) A person may take fish as broodstock, purchase fish, breed fish or aquatic life, rear or hold such fish or aquatic life and process and sell such fish or aquatic life, under and in accordance with an Aquaculture licence. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 12 174 Sale of fish An Aquaculture licensee may sell fish or aquatic life to the following: (a) an Aquarium Fishing/Display Fishery licensee; (b) a Fish Broker licensee; (c) a Fish Retailer licensee; (d) a Fish Trader/Processor licensee; (e) an Aquaculture licensee; (f) an Aquarium Trader licensee; (g) a Public Aquarium licensee; (h) a member of the public not purchasing fish or aquatic life for resale. Department of Primary Industry and Fisheries: small-scale aquaculture discussion paper 13