Submissions for the Proposed Australian Biofouling Management
Requirements Consultation Regulation Impact Statement
A submission received from Australian Museum, NSW
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?
The timelines are appropriate for medium risk vessels arriving for very short visits. However,
high and extreme risk vessels have a higher probability of containing species of concern (SOC),
referred to here as marine pests. It is very unlikely that the interview, hull inspection and
determination of the presence of any marine pests can be completed within 48 hours of arrival, as
in some cases material will need to be checked by the relevant expert to confidently identify the
suspected pest species.
As an alternative it may be better to confirm the absence of any marine pests prior to departure
from a foreign port. This is what currently occurs in Western Australia for non-trading vessels
arriving in Western Australia that are mobilising for projects subject to Ministerial Conditions
under the WA EPA Act. This includes a wide range of vessels that are currently being inspected
overseas, including dredges, tugs, barges, drilling rigs, etc. If a vessel is inspected overseas by a
recognised inspector, the vessel is allowed to enter WA waters if no potential marine pest species
are found. If a potential marine pests is found, the vessel must be cleaned and re-inspected. If no
pests are found on the subsequent inspection(s) entry is permitted. However this practise is not
the current situation in any other Australian State or Territory.
Another approach is for the vessel to be inspected within 48 hours of arrival as occurs in WA.
Other States have less stringent controls. In WA, the vessel is not allowed to operate until it is
confirmed not to have a marine pest. If a marine pest is present the vessel must be taken from the
water and cleaned. If the vessel cannot be cleaned out of water in WA (i.e. it is too large,
facilities are fully booked, etc.), the vessel must return overseas and be cleaned. This commonly
occurs in Singapore, but this is an expensive solution. This obviously has costly flow-on effects.
However in WA, such incidents have been well publicised and the industry is thus aware of the
costs and this has resulted in a high degree of compliance (according to marine consultants in
WA). All costs are borne by the vessel owner/operator.
A similar mechanism could be used for fishing boats and yachts.
An alternative for yachts is the system used in the Northern Territory where vessels entering the
small boat marinas of Darwin Harbour must submit documentation on their risk profile to NT
Fisheries. NT Fisheries then determines if the vessel must be inspected, and, if necessary,
cleaned. NT Fisheries bears the costs for these smaller boats. In other States this approach has
not been regularly enforced.
Q2. How might vessel operators’ behaviour change in response to the proposed
regulations?
It is essential that the requirements are mandatory. Failure to do so will result in considerable
expense and serve as a powerful deterrent. We believe that if the requirement is not mandatory
some operators will not adhere to the intent and lead to increased risk of marine pest incursions.
In 2011, the WA Fish Resources Management Act 1994 was amended to give the Chief
Executive Officer powers to combat a marine pest incursion and then to recover the costs from
the person or organisation that introduced the marine pest. Such costs could be substantial. The
removal of Mytilopsis sallei from three small marinas in Darwin in 1999 cost $ 2.2 million, a
figure that would be substantially higher in 2012 dollars or for a broader incursion.
No other marine pest has been successfully removed from Australian waters. The situation in
Darwin is unique in that the marinas are closed off during low tide so as to retain water within
the marina during the entire tidal cycle. This unique situation provides an opportunity where
chemicals can be added to the water to kill off the marine pest (Willan et al. 2000). Voluntary
regulations based on a public education programme are unlikely to change people’s behaviour.
Q3. What specific types of flow-on costs and benefits to the Australian economy of the
proposed regulations might be significant?
The regulatory costs will add a minor burden to the Australian economy. However, there is a
much greater potential economic cost from the establishment of a marine pest in Australian
waters, in addition to potential loss of environmental amenity. The impact of marine pests on
Australia’s marine biodiversity is still poorly known, as are the potential consequences of
successful incursions.
Apart from the cost of eradicating Mytilopsis sallei from Darwin Harbours, the cost of other
marine invasions are not available. In the case of the North Pacific seastar, substantial losses to
the aquaculture industry in the infected rivers and estuaries have been recorded (Hutson et al
2005; Ross et al. 2002). It is far more difficult to calculate the cost of the impact of this starfish
on the native biota, but certainly benthic communities have been dramatically altered, with the
starfish consuming a wide variety of prey. In WesternPort Bay the European fan worm Sabella
spallanzanii has changed the benthic communities where dense populations are found. But again
it is difficult to quantify these impacts (O’Brien et al., 2006).
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?
There has been a considerable increase in arrivals of extreme risk vessels in northern Australia as
a result of the resources boom. This is likely to continue and increase further. The pattern of ship
movements is changing, both in terms of international arrivals and coastal shipping. In addition,
there has been a substantial increase in the number of cruise ships arriving in Australian ports.
Anecdotally, the number of cruising yachts is also increasing, and these are far more difficult to
control. New ports are being planned for far north Queensland and shipping in this area will
change dramatically and bring with it increased risk of introductions. The native biota is still
being documented in many of these tropical areas and this will compound the problem of
recognising new invasive species.
Q5. Are the cost assumptions consistent with industry experience? (see appendix D for all
cost assumptions). Are there better estimates of costs available?
The Australian Museum is unable to comment on this question.
Q6. Are the other assumptions used to estimate costs and benefits reasonable based on
industry experience? If not, how could they be improved?
The Australian Museum is unable to comment on this question.
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?
We believe that concentrating on the Great Barrier Reef (GBR) is simplistic and inaccurate. An
analysis with a broader geographical coverage and more detail is required. To date there is no
evidence that fisheries are being impacted by marine pests on the GBR or elsewhere. It is the
aquaculture industry which is most impacted as this tends to occur in bays and estuaries,
predominantly in temperate waters.
Most of the pest species that have become established in Australia are in temperate waters. While
the Great Barrier Reef (GBR) is a key marine asset of international significance, to date it has
been little affected by marine pests (Hilliard et al. 1997). The threat is Australia-wide. With the
Indo-Pacific distribution of most tropical species, the GBR may be at a lower level of risk than a
temperate system (Hutchings et al. 2002). In addition, there is strong evidence that undisturbed
natural habitats are relatively more capable of resisting invasions than disturbed systems such as
ports, lessening the accuracy of estimates based on a tropical, relatively undisturbed system.
The distributions of marine pests are variable even within temperate waters. For example, the
distribution of the European fanworm Sabella spallanzanii is not uniform along the southern
coast of Australia. It is concentrated in the disturbed environments of ports and harbours, and
does not occur on open coasts. Even in environments where it occurs, populations of the
fanworm come and go. Similar patterns have occurred with the date mussel Musculista
senhousia and other species. To date the majority of marine pests have been found to occur in
estuaries and bays and have not moved out into open water.
Q8. What other evidence is there of the potential impacts of non indigenous marine species
becoming established in Australia?
There is a wealth of scientific literature that details the potential impacts of such establishment.
The threat from vessels is real, as evidenced by the scores of detections made of marine pests on
vessels mobilising to Western Australian resource projects. However, we should stress that
resources need to be made available to distinguish between undescribed native species and non
indigenous marine species (Hutchings, 2007). Commonly, representatives of the same genera
occur as native species, for example Australian species of Sabella and Hydroides occur, and both
genera include non indigenous species.
It is also critical that Australia develop accurate lists of species that warrant triggering an
incursion response. For example, the Vessel Biofouling Risk Assessment document (Table 1) lists
Briarosaccus callosus and Carcinoscorpius rotundicauda as among species most likely to arrive
in Australia, and which could cause a high degree of harm. There is no scientific basis for this
determination. Briarosaccus callosus is a deepwater parasite of lithodid crabs and occurs
worldwide, including Australia. Carcinoscorpius rotundicauda has only ever once been recorded
as an invasive – one instance in New Zealand in 1910 (Ahyong & Wilkens, 2011).
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?
We strongly reject the effectiveness of a voluntary approach to risk minimisation.
Voluntary approaches are only effective if there are economic advantages. Thus, the outer hulls
of high-speed merchant vessels are typically well maintained voluntarily because of the positive
effects on transit time. However, niche areas that do not affect vessel speed, such as sea-chests,
are typically not cleaned, and these usually harbour significant levels of biofouling (Coutts &
Taylor, 2004; Coutts & Dodgshun, 2007). Transit of slow moving craft, such as barges and oil
rigs is much less affected by the level of fouling than container vessels. Moreover, these often
have a much greater potential for transport large volumes of invasives and propagules because of
the larger, and usually more complex surface area (Yeo et al., 2010).
Q10. Do you have any other comments on the Regulation Impact Statement?
The Australian Museum supports the aims of the approach to preventing the establishment of
marine pests in Australian waters and the work of DAFF and the Marine Pests Sectoral
Committee (and its predecessor group the National Introduced Marine Pests Coordination
Group). Several Australian Museum staff have provided verification of introduced species as
well as highlighting the real problems of marine introductions (Australian Museum Business
Services, 2002; Hutchings et al., 1987; Bishop & Hutchings 2011, Pollard & Hutchings,
1990a,b).
Reading the associated papers for this document, we became aware that workshops were held in
most Australian cities in late 2011. However the workshops were poorly advertised and known
only to a few members. There was no apparent attempt to advertise the workshops directly to
organisations such as the state museums, where most of the experts in species identification
work.
While strongly supporting the concept of a national system, the Museum acknowledges the
difficulties in implementing and resourcing an effective National System.
 Currently, vessel operators are faced with uncertain regulations that differ between states and
the NT. A national approach is essential. As the DAFF documentation demonstrates, and is
described above, WA and the NT have recognised the problems of marine pests and are
acting proactively to prevent the arrival of marine pests (Williamson and Fitter, 1996). Unless
the National System meets the stringent requirements in place in WA and the NT, controls
will be fragmented and, because of coastal shipping, translocation and nearshore water
currents, effectiveness will be determined by the lowest benchmark (see next point). It is
essential that we have single Australian system.
 While it is important to miminise the risk of new introductions, we should also be looking at
ways to restrict the spread of marine pests which are already established in Australian waters.
For example, it seems highly likely that the North Pacific seastar was accidently introduced
into Westernport Bay from estuaries in eastern Tasmania by either the aquaculture industry or
the live fish trade. Controls/regulations need to be put into place to minimise such events in
the future (Grannum et al., 1996; Murphy & Evans, 1998). The proposal that such species
not be included in the new list of marine pests being developed by DAFF is short-sighted.
 We would also like to comment on the problems of obtaining accurate identifications of
potential marine pests in a timely manner. There are very few experts in Australia capable of
identifying these organisms. In some groups there may not be a taxonomist or relevant
molecular (DNA) data available. While it has been suggested that marine pests can be
identified from photographs sent by email, this will not work for most groups because of the
detail required (including some internal characteristics) to ensure accurate identifications.
There have already been very serious mis-identifications made on the basis of photographs of
whole animals. Accurate identifications for many of the groups will require that a specialist
have specimens on hand for analysis. Ideally we should have detailed morphological
descriptions of marine pests as well as molecular profiles, together with voucher specimens
lodged in the relevant state museum. The increasing use of molecular techniques for species
identification may prove to be an extremely cost-effective approach, but full effectiveness
will require both morphological and molecular approaches and the establishment of 'libraries'
for comparisons. Funds need to be made available to support this work.
 Accurate identifications underpin the approach to this critical issue, and mis-identifications
can prove costly. The original record of North Pacific seastar was inaccurately identified and
thought to be a native species. By the time the animal was correctly identified, there were
many 1000’s in the Derwent River (Grannum et al., 1996).

As an example of the difficulty in obtaining reliable identifications, consider the polychaete
worm Hydroides dianthus that is on the national marine pest list. There are only two or three
specialists in this group in Australia. The family has 46 recognised genera and there are 89
valid species in the single genus Hydroides, many of which are present as fouling species.
Several native species of Hydroides occur in Australian waters as well as introduced species.
Accurate identifications require dissection by a skilled expert knowledgeable in the group.
Identifications cannot be based on photographs and will never be completed within 48 hours.
 A way forward is to adopt a system similar to that used by New Zealand in which marine
biosecurity identifications are handled through a centralised end-to-end identification service
that maintains/retains a network of national and international experts to provide contracted
authoritative identifications (Gould & Ahyong, 2008). This should draw on expertise from
various Australian and New Zealand museums and research institutes.
References cited in this submission
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Carlton, J.T. (eds), In the Wrong Place – Alien marine Crustaceans: Distribution, Biology and
Impacts. Springer, pp. 451–485.
Australian Museum Business Services 2002. Port Surveys for Introduced marine species—
Sydney Harbour Final Report. 146 pp.
Bishop, MJ and Hutchings, PA. (2011) Taxonomic difficulties compromising documentation
of exotic species diversity by port surveys Marine Pollution Bulletin 62, 36-42.
Coutts, A.D.M. & Dodgshun, T.J. 2007. The nature and extent of organisms in vessel sea-chests:
a protected mechanism for marine bioinvasions. Marine Pollution Bulletin 54: 875–886.
Coutts, A.D.M. and Taylor, M.D. 2004. A preliminary investigation of biosecurity risks
associated with biofouling on merchant vessels in New Zealand. New Zealand Journal of Marine
and Freshwater Research 38: 215–229.
Grannum, R.K., Murfet, N.B., Ritz, D.A. and Turner, E. 1996. The distribution and impact of the
exotic seastar Asterias amurensis (Lútken), in Tasmania. In: The introduced northern Pacific
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Gould, B. & Ahyong, S.T. 2008. Marine Invasives Taxonomic Service. Biosecurity, 85: 18–19.
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