Waterway health data
Waterway health is a key issue for fin-fish aquaculture as the industry
relies on the quality of water it uses. Waterway health is also a key issue for
other stakeholders given the potential for environmental harm if aquaculture operations
are not adequately regulated and monitored.
To ensure that the health of waterways is maintained, extensive
monitoring of areas in which the fin-fish industry operates is undertaken both
as a regulatory requirement and as part of the normal operational practices of
fin-fish aquaculture companies.
Many of the submissions received by the committee expressed concern
about the monitoring of waterway health in areas where fish farming occurs, in
particular the adequacy and availability of data.
The following discussion outlines the monitoring regimes and addresses the issues
raised in evidence by concerned stakeholders and the responses from the
Tasmanian Government and industry stakeholders.
Adequacy and availability of data on waterway health
As discussed in chapter 2, Tasmanian marine farming operations are regulated
through the Marine Farming Planning Act 1995 (MFP Act) and the Living
Marine Resources Management Act 1995 (LMRMA). Together, these two Acts aim
to achieve the well-planned sustainable development of marine farming
activities and the sustainable management of Tasmania's living marine
resources. The Tasmanian Government noted that, in order to achieve these
goals, an adaptive management approach has been adopted so that there is an assessment
of the environment where farming is to occur and an iterative process of
decision making, monitoring and assessment.
The pre-development and operational components of the adaptive
management approach were outlined in the Tasmanian Government's submission.
In the pre-development phase, marine farming development plans (MFDPs) are
established. In doing so, targeted zone assessments are undertaken by the
Institute for Marine and Antarctic Studies (IMAS). These assess substrate type,
habitat distribution, bathymetry and benthic flora and fauna. If required,
additional surveys target threatened species. The MFDPs contain management controls
to manage and mitigate negative effects of marine farming operations.
Management controls include provisions relating to environmental monitoring and
management of marine farming operations.
Licences to farm fish are required under the LMRMA. A baseline
environmental survey must be undertaken prior to the commencement of marine
farming operations. The licence contains specific provisions in relation to
environmental monitoring and management of marine farming operations. The
Tasmanian Government noted that in many cases, conditions contain specific
conditions that expand on the provisions of management controls, defining environmental
standards and outlining reporting and monitoring requirements. Environmental standards
prescribe relevant indicators and trigger levels for ongoing environmental management.
The Tasmanian Government also stated that decision making is informed
not only by the outcomes of statutory monitoring and compliance assessment, but
also through information provided by industry, research institutes or collected
through programs within the Department of Primary Industries, Parks, Water and
Environment (DPIPWE) such as the Environment Protection Authority (EPA)
Division of DPIPWE.
Waterway monitoring and management
There are two aspects of waterway monitoring: assessment of benthic
condition and water quality in MFDP areas. These monitoring programs are
subject to a consistent management framework. Collection and analysis of
samples for monitoring is undertaken by a range of consultants employed by
companies or by the companies themselves. The data from monitoring is reported
to the regulator. Monitoring is also subject to auditing by the regulator.
Benthic condition monitoring is undertaken to assess and manage the
potential effects of particulate organic waste material (fish faeces, waste
fish feed and in situ cleaning effluent) on benthic health in, and around,
marine farming lease areas. Environmental parameters must be monitored in the
lease area, 35 metres outside the boundary of the marine farming lease area and
at any control site(s) in accordance with the requirements specified in the
relevant marine farming licence. In addition, a video survey must be conducted
every 12 months or in accordance with the stocking and fallowing regime of the
The Tasmanian Government stated that monitoring reports and underwater
video footage must be reported by the lease holder pursuant to licence
conditions. These are assessed by the DPIPWE against specific criteria aligned
with relevant management objects and are then reported to stakeholders.
The regulator can direct the lease holder to undertake a range of
management responses to mitigate any significant benthic impact attributable to
marine farming operations. Where monitoring identifies effects that are unknown,
or difficult to clearly attribute, research may be undertaken as part of the
Water quality management framework
Water quality monitoring is undertaken to assess and manage the effects
of stressors including nutrient loading and dissolved oxygen depletion
associated with fish metabolic processes, respiration and biogeochemical
processes within organically enriched sediment.
Results of monitoring are reported to DPIPWE, along with relevant
information on feed inputs and biomass, for assessment. Where unexpected, or
difficult to clearly attribute effects are identified, a range of management
responses can be initiated. These include controls on nitrogen emissions, more
focused monitoring or the undertaking of research. The Tasmanian Government
stated that outcomes of monitoring, compliance reporting and research can then
be used to inform the refinement of the program.
Ongoing water quality monitoring in
the southeast and Macquarie Harbour
In the Huon Estuary and D'Entrecasteaux Channel, the Broadscale
Environmental Monitoring Program (BEMP) commenced in 2009 specifically to
monitor the health of the wider marine environment. The intention of the BEMP
was to provide:
...a monitoring program with the capacity to detect the effects
of those processes judged to be most threatening to the Huon and D'Entrecasteaux
ecosystem at the whole-of-ecosystem level...to provide knowledge of how well the
ecosystem is functioning with an increased nutrient load and to allow any significant
temporal trend(s) in ecological indicators to be detected.
The BEMP has both a water quality component and a sediment component
which monitors sediment chemistry and invertebrate communities. Samples to test
water quality are taken regularly throughout the year at multiple sites which
are located outside of marine farm leases and are distributed across different areas
of the Channel and lower Huon Estuary. Indicators of water quality assessed
include water column nutrients, dissolved oxygen levels and salinity. Sampling
for sediment condition is undertaken regularly and includes visual assessment.
Assessment of phytoplankton is also undertaken.
In Macquarie Harbour, the Macquarie Harbour Environmental Monitoring
Plan (MHEMP) has been used since 2011 to monitor water quality. Indicators of water
quality are sampled monthly and include water column nutrients, dissolved
oxygen levels and salinity. The industry also undertakes additional voluntary
monitoring of some water quality indicators at various sites in the harbour.
Assessment of phytoplankton is also undertaken.
Issues raised in relation to waterway health monitoring
The Tasmanian Government's adaptive management approach for the
aquaculture industry is underpinned by an ongoing environmental monitoring
program. The program is designed to inform government and industry on
environmental performance and to support modification of farming practices if
required. As such, submitters noted that the adequacy of the monitoring program
was significant with EDO Tasmania stating:
...adaptive management will not be effective without
appropriate monitoring and enforcement activities to facilitate adaptation.
The committee received evidence supporting the regulatory and monitoring
framework currently in place in Tasmania. For example, while commenting on some
specific concerns about the monitoring program, WWF-Australia stated that, in
relation to water quality monitoring:
WWF-Australia believes the current frameworks in place to
legislate, regulate, manage and monitor finfish aquaculture operations in the
State of Tasmania provides a strong foundation.
Before any farming licence or approvals are awarded by the
Tasmanian government to any aquaculture company or for any practices in any
region, detailed baseline surveys and more recently, Environmental Impact
Assessments are carried out.
WWF-Australia went on to state that 'the current government requirements
for monitoring and reporting of benthic impacts are consistent with best
However, a range of issues were raised in evidence in relation to the
adequacy of the monitoring program, access to data and the independence of the
Adequacy of monitoring
A number of submitters, including Environment Tasmania, argued that the
adequacy of monitoring of waterway health was poor.
They pointed to a range of specific matters including the lack of baseline data
in the south east, the frequency of monitoring and reporting of some indicators
and the lack of monitoring of some indicators.
It was argued by some submitters that there was a lack of baseline data in
the south east in relation to the BEMP, which undermined confidence in the capacity
of the monitoring program to identify the extent and impact of changes arising
from marine farming activities.
Environment Tasmania noted that monitoring data collected between 2009 and 2012
'has been used to state there has been no broadscale impacts from fish farms,
however, the baseline figures used for comparison are from after fish farming
had already been occurring for over 15 years'.
The Australian Marine Conservation Society added that although the BEMP
...a good step forward in taking a holistic approach...to
ensuring the cumulative impacts of aquaculture are accounted for, concerns
remain about the extent of data that is collected as well as lack of adequate
baseline information upon which to base an adaptive management regime.
The Australian Marine Conservation Society went on to state:
There is limited information prior to the BEMP that provides
stakeholders with confidence that aquaculture impacts have not caused
significant environmental effects at levels that could have consequences for
marine flora and fauna and overall ecosystem health. As it is, the data
recorded since 2009 should not be used as proof of no widespread impacts from
aquaculture, but could be used as a reference point for future monitoring.
While a reference site could be used in the absence of good baseline
data, the Australian Marine Conservation Society stated that there were no
biologically similar sites to the Huon Estuary and D'Entrecasteaux Channel that
could be used for this purpose. It therefore concluded that 'overall, there are
limited opportunities for identification of significant ecosystem wide impacts
that would require mitigation from the industry, and action from government'.
In relation to Macquarie Harbour, similar concerns were expressed about
the lack of baseline data before the recent expansion of aquaculture operations
The Australian Marine Conservation Society commented that for Macquarie Harbour
'there is little information on basics such as bottom-water residence times, and
limited information publicly as to how this lack of knowledge has been
accounted for in precautionary management decisions'.
The Australian Marine Conservation Society stated that marine farms are
situated in dynamic environments and farming activities produce a 'seemingly high
degree of unknown impacts regarding impact of the industry on marine ecosystems'.
Accordingly, an adaptive management approach 'would seem to be an essential
component of ensuring impacts can be mitigated'. However, the Society argued
that 'the lack of baseline data on which to base an adaptive management regime
means managers are unclear on what level of ecosystem health they should be
managing to'. This means that an 'extremely precautionary approach should be
taken'. The Society concluded that this appears not to have been the outcome
with leases being approved with limited datasets on which to base decisions.
Another matter raised was the frequency of monitoring of some parameters.
WWF-Australia, for example, commented that, for the most part, the water
quality monitoring program is consistent with the current standards of the Aquaculture
Stewardship Council (ASC). However, the required frequency of sampling for some
components does not meet best practice with fin-fish farms under the Tasmanian
regulatory regime being required to sample fortnightly 'at best, compared to
the requirement for at least weekly sampling under ASC'. WWF-Australia,
however, acknowledged that some operators routinely sample on a daily basis.
The requirement of video monitoring for sediment health only every
12 months was also questioned. Submitters noted the results of a study
undertaken on behalf of Environment Tasmania by consultant Hugh Kirkman in
The study commented that the current frequency of video samples 'seems
inadequate for a meaningful assessment of impacts' and recommended that surveillance
be conducted more regularly. The study concluded that 'annual monitoring will
not alert managers to impacts that may do permanent damage to the benthos'.
The availability of timely information was also raised by Environment
Tasmania in relation to data collection in Macquarie Harbour. Environment
Tasmania commented that monthly reporting 'limits both the reliability of the
data and the timely usefulness of the data by the regulator'.
In addition to concerns about the frequency of monitoring activities, the
frequency of collation of data was also raised by EDO Tasmania which noted that
BEMP data is collated only every three years.
The monitoring regime requires the sampling of a range of indicators,
however, WWF-Australia noted the lack of turbidity monitoring. WWF-Australia
stated that turbidity is a minimum standard under the ASC. While acknowledging
that turbidity measurement is part of Tassal's monitoring program,
WWF-Australia argued that turbidity measurement should be part of licence
conditions for all operators.
EDO Tasmania pointed to the limited monitoring in the D'Entrecasteaux
Channel for determining whether the cumulative contribution of each lease area
to the nitrogen load exceeds the cap set in the MFDP. In addition, EDO Tasmania
argued that there is no ongoing assessment to determine whether the existing nitrogen
cap is set at a sustainable level particularly as land-based nutrient sources
contribute to the nitrogen load in the Channel.
In Macquarie Harbour, the lack of an integrated approach to monitoring
was criticised by the Australian Marine Conservation Society which stated that,
while monitoring requirements are in place as conditions on a Marine Farming
License, 'this would appear to be specific to an individual company's licence'.
The Society argued that this does not establish an integrated approach to be taken
by all operators.
A final concern relating to the adequacy of data was the lack of
monitoring of impacts beyond 35 metres outside of a lease area. The Australian
Marine Conservation Society commented:
Industry operators are only required to monitor the impacts
of fin-fish farming to 35m outside of a lease area. Due to the nature of water
movement, effluent from fish farms has a footprint that extends over an
arbitrary 35m boundary that escapes any form of monitoring or required
mitigation action. 35m would appear to be based more on operational efficiency
for leaseholders than having relevance for the marine environment and
represents a serious lack of monitoring for the wider marine environment.
This matter is addressed further in chapter 4.
Response to issues raised in
The Tasmanian Government responded to general concerns about the
adequacy of the monitoring system and commented that the management framework
for the salmonid industry provides the means to effectively regulate and manage
the industry in accordance with best practice management principles.
Dr John Whittington, Secretary, DPIPWE, added that the management
controls on companies have 'the force of law' and as part of the controls,
monitoring it required of a range of environmental and fish health parameters.
Reports are provided to DPIPWE with auditing being conducted to ensure the quality
of monitoring activities. Dr Whittington concluded that 'our system of
requiring reporting of environmental parameters to us is, we believe, a sound
one, an efficient one and one that is, I believe, rigorous'.
The Tasmanian Salmonid Growers Association (TSGA) similarly pointed to
the robustness of the monitoring regime undertaken by the industry including
the additional monitoring voluntarily undertaken by companies. Dr Adam Main,
TSGA, commented that the data collected is transparent and 'goes well beyond
meeting basic compliance needs' and that datasets are 'robust, publicly
available, often independently sourced, longitudinal, peer reviewed and audited'.
Dr Main added that the industry's work in this area has been internationally
The TSGA went on to comment that
With the BEMP and MHEMP, a range of quality assurance and
quality control measures are prescribed by the DPIPWE to ensure that sampling
activities produce environmental data that can be interpreted with a high
degree of confidence, and that appropriate methodologies, procedures and
processes are carried out at all of the critical control points – from sampling
in the field, to laboratory analysis and finally to data interpretation.
The TSGA concluded that, currently, there is adequate and available data
on waterway health in terms of quality and quantity to provide sufficient
industry participants to make appropriate management decisions;
regulators to be able to monitor industry and apply regulation;
the scientific community to research, analyse and report on data;
other parties such as certification bodies; and
interested parties in the community, including consumers.
In coming to this view, the TSGA stated that the Tasmanian salmonid
industry relies on credible, scientifically sound and reliable data about its
impact on Tasmanian waterways to make management decisions. The TSGA also
stated that the industry is committed to continuously improving its data
collection and management and contributing to public knowledge of Tasmania's
waterways. In this regard, the TSGA added that the industry has commenced the
an industry data management strategy to streamline data
collection and ensure the standardisation of data collection and therefore ease
of comparability; and
an industry information strategy to guide the way data is
collected and analysed to ensure it is responsive to the needs of management,
researchers and the broader community.
Extensive information on the contribution of scientific research to the development
of the monitoring framework was provided in the submission from the IMAS. Much
of this research has been undertaken in conjunction with the Tasmanian
Government and industry. The IMAS commented that the first study, in 2002, was
specifically aimed at supporting the development of an industry-wide monitoring
program by determining the most reliable and cost effective monitoring
approaches for the management of the Tasmanian industry. The findings of the
study played a key role in the development of the current marine farming
monitoring program regulated by DPIPWE.
The IMAS added that clearly a large body of research has been undertaken
with the specific purpose of establishing the effects of fin-fish farming on
the marine environment. It noted that, while this research has often been
specifically targeted at providing management advice and recommendations for
either the industry directly or regulators, the underlying data also provides a
substantial resource for understanding broader ecosystem processes and
The IMAS concluded:
...it is worth noting that the research understanding outlined
in this document represents two decades of accumulated knowledge and that this
has been developed through a broad range of research collaborations both with
other research providers (notably CSIRO) and in collaboration with industry,
government, various not for profit organisations, funding agencies
(particularly FRDC, Natural HeritageTrust/National Resource Management, various
CRCs), and the community. The research has been progressive, with each question
answered leading quite naturally to further questions. The transition in our
understanding of the interaction of marine farming (and therefore monitoring
requirements) has similarly progressed from a need to understand local-scale
impacts, to a need to define broader-scale impacts, to the situation where
ecosystem interactions and multiple-use management are now the focus. It is to
be expected that as the current research evolves other questions will need to
The TSGA also responded to the specific issues raised in evidence. In relation
to comments on the availability of baseline data, the TSGA agreed that there is
no broadscale baseline dataset available for existing salmon farming regions, that
pre-dates farming or other human influence. However, it went on to comment that
this is the case in other salmon farming regions internationally.
The TSGA noted that it is a requirement of the Tasmania Government's
regulatory regime that a baseline environmental survey must be undertaken prior
to the commencement of marine farming operations. Where farming operations
commence in new regions, such as Storm Bay, pre-farm baseline data will be
available. The TSGA added that the licensing of a lease area for fin-fish farming
is contingent on assessment and approval of the baseline environmental survey
report by DPIPWE.
The Tasmanian Government provided the list of parameters included in baseline
assessments. The parameters include biological analysis, benthic infauna
samples, sediment samples and targeted threatened species surveys if not covered
during the zone assessment.
In relation to frequency of monitoring, the TSGA stated that monthly
broadscale monitoring is only undertaken in Tasmania and nowhere else
internationally. In addition, companies complete voluntary surveys within the
compliance period as required. In relation to video surveys, the TSGA commented
that they are 'a cornerstone of our sampling and monitoring framework' and are
easily comparable to everywhere in the world.
The TSGA concluded that the intent of the BEMP is to monitor water and
sediment quality in the system, as these measures are deemed to be the most
relevant monitoring indicators for assessment of the broader ecosystem. This is
consistent with the outcomes of the Aquafin CRC
research 'which clearly identified that water and sediment quality were the
most relevant and useful indicators for such an assessment'.
In relation to parameters, the TSGA noted that an extensive body of
research supports the basis for the selection of parameters that are currently
monitored in Tasmanian aquaculture areas.
Evidence on the 35 metre zone was provided by both the TSGA and WWF-Australian.
WWF-Australia submitted that the 35 metre zone was based on 'strong evidence
from both international and local research'. It went on to comment that since being
introduced 15 years ago, monitoring by research bodies and farms (as a part of
the licence conditions) has provided the government with evidence that a 35 metre
zone is a suitable distance for the farming environment.
The TSGA noted that farming licence conditions provide that there must
be no significant visual, chemical or biological impacts extending 35 metres
from the boundary of the lease area. The industry also uses fallowing (resting
the seabed by moving pens to different locations within the lease area) to
ensure that the seabed is effectively managed.
The TSGA concluded that:
The adaptive management framework employed by both industry
and regulator alike allows for both results of the process studies and the
monitoring itself to be continually assessed and the need for new
data/information identified, with its collection then incorporated into the
In addition, the committee notes that the Fisheries Research and Development
Corporation has funded 19 research projects related to the adequacy and
availability of data on Tasmanian waterway health.
Access to information
It was argued by some submitters that there is inadequate public access
to data and information about the fin-fish industry. While EDO Tasmania noted
that information related to applications for amendments to marine farming
development plans must be published, access to other information regarding
ongoing regulation of marine farming operations is extremely difficult.
Requests for information held by government can be made under a Right to
Information request, but it was observed that this is generally a slow process
and often results in a refusal on the basis of commercial-in-confidence
exemptions, the volume of material that would need to be supplied or that it
may impair the Government's ability to obtain information in the future.
Ms Rebecca Hubbard, Environment Tasmania, gave the example of attempts
to access data in relation to Huon Aquaculture's hatchery on the Russell River.
Ms Hubbard commented that Environment Tasmania had engaged with the EPA
over the issue of algal blooms in the river and had requested a specific core
environmental baseline report. This information had not been provided.
Following an internal review processes, the matter is under review by the Tasmanian
Ombudsman. Ms Hubbard commented 'but that has been in process for over three
months, and there are still 20 appeals in front of us'.
While acknowledging that some of monitoring data may be considered
commercial-in-confidence information, nonetheless submitters argued that there
is a range of other data which should not be treated as such. WWF-Australia
pointed to natural environment parameters and drew a parallel with wild capture
fishery data and information which is made publicly available.
Dr Imogen Fullagar also commented on the level of data available from TasWater,
while EDO Tasmania pointed to Canada where all information regarding
environmental assessments undertaken must be made publicly available.
WWF-Australia also commented that there appeared to be a significant
variation in the amount and type of information made publicly available by the
three companies with Tassal providing more information, for example, through
its Sustainability Reports.
It was argued that the lack of publicly available monitoring data may
undermine trust and confidence in the industry. For example, Ms Hubbard,
Environment Tasmania, commented:
...it is difficult to ascertain just how accurate the
department claims and the industry claims regarding sustainability and lack of
fish-farming impacts, because water-quality data, as well as scientific and
production reports, are not released publicly and therefore cannot be verified.
This is a really significant point.
Ms Hubbard went on to comment that there was available expertise within
environmental organisations to interpret raw data and that stakeholders can
also access independent scientists to verify assessments.
Ms Jessica Feehely, EDO Tasmania, added:
I absolutely acknowledge that industry is doing a lot of
monitoring. The difficulty is actually accessing that information to work out
how much monitoring is being done, where it is being done and where it is not
being done. So absolutely if there is transparent access to that information it
may be identified that there is no need for additional monitoring. But until
there is public access to all of the information that has been gathered through
that process it is difficult to identify where the monitoring gaps are.
WWF-Australia added that transparency, availability and openness of data
and information are 'paramount for any business or government striving to achieve
and meet best practice governance and business frameworks for operations'.
WWF-Australia noted that the ASC has standards concerning availability of data;
WWF-Australia argued that the Tasmanian Government should 'look to the salmon
standard of the ASC, to learn from and make required changes regarding
accessible data and information'.
WWF-Australia also suggested that the Tasmanian Government could assist
in providing greater amounts of publicly available information by releasing its
own annual aquaculture report for each farming region/zone. This report could
include critical data and information regarding the industry operations as well
as physio-chemical, biological and visual parameters essential for healthy,
responsible aquaculture production and sustainable utilisation of the marine environment.
Response to issues raised in
Both the Tasmanian Government and industry stakeholders responded to
concerns about the level of publicly available information. Dr Whittington,
DPIPWE, pointed to the numerous peer reviewed papers and reports available on
the Tasmanian salmonid industry. He went on to note that the companies
themselves provide extensive amounts of public information:
They have websites that have, for example, sustainability
dashboards. They produce sustainability reports. So there is considerable
information available on the industry.
DPIPWE provides information on its own website, for example, a review by
IMAS of monitoring data collected between 2009 and 2012. This review was
commissioned by DPIPWE and represents a comprehensive summary of both the water
and sediment quality data collected as part of the BEMP.
Dr Whittington also stated that DPIPWE would like to further investigate the
provision of online reporting of some of the environmental data that it
receives and this will be considered over the coming year.
The TSGA stated that the industry recognised the public interest in fin-fish
farming's environmental performance and how the industry's activities relate to
waterway health. The TSGA pointed to the range of information on waterway
health and other aspects of environmental performance made publicly available
by the regulator, the industry, the scientific community and certification
In addition, it noted that each company employs community engagement officers
who are able to facilitate access to data and information where readily
available and appropriate.
Similarly, the Tasmanian Seafood Industry Council commented that the extensive
amount of waterway health data collected by the salmon industry is shared with,
and used by, a diverse array of stakeholder groups and organisations, including
the industry, regulatory bodies and third-party certification organisations. In
addition, waterway health data and information is publicly available online. Mr Julian Harrington,
Tasmanian Seafood Industry Council, concluded that 'this open and transparent
sharing and access to data ensures data quality and quality control'.
Other witnesses also responded to calls for the release of raw data from
monitoring activities. Marine Solutions Tasmania pointed to the risks of the
use of raw data and commented that it:
...understands one of the risks to the industry and to the
environment is that raw data collected from a variety of sources is interpreted
selectively, in isolation, or to address issues which it was not designed to
address. With this in mind, [Marine Solutions Tasmania] believes strongly that
raw data should be interpreted and presented by those who have an understanding
of why the data was collected, how the data was collected, the limitations of
the data, and provide an explanation of the interpretation.
Mr Sean Riley, Aquenal Pty Ltd, also stated that the raw data needs to
be evaluated in terms of the context and interpreted in a meaningful way.
Similarly, Dr Catriona Macleod, IMAS, commented that the main issue with
making raw data publicly available is quality control, interpretation and
contextualisation of the data. Dr Macleod added:
I work with a number of monitoring issues and areas...In a lot
of cases it is not so much the need for the raw data, I think, that people have
concerns about; it is that they truly understand how the interpretation is
being derived. A lot of people talk about real term data and the transparency
with that. Having had a lot of experience with data, that can generally mean an
awful lot of numbers to wade through. I, personally, unless it is a project I
am working on, would rather have that data in association with the
interpretation, so I can actually contextualise it—
...and review it to see if that interpretation is correct, rather
than the raw data per se. So, in principle, no. But I think the problems that
you have with something like that is the fact that if you do not understand
aspects of how the data was collected, or what the data is being interpreted
into then you can get misinterpretations.
However, Dr Macleod commented that IMAS considered it was very important
that its research is understood by all stakeholders involved and that it is
relevant to the issues that it has been asked to address. Dr Macleod went on to
note that IMAS had undertaken the Our Marine Values project which had
been important in understanding 'where the research findings and outputs,
particularly as they relate to environmental monitoring, relate back to the
concerns—whether they be industry concerns, government concerns or community
concerns'. The report, published in early 2014, highlighted the concerns and
issues which will underpin research proposed into issues in a multi-stakeholder
Independence of monitoring
activities, analysis and research
The Tasmanian Government submission sets out information on who collects
data for each stage of the regulatory process. For example, data from ongoing
benthic monitoring is collected by contractors employed directly by the
companies and/or by the companies themselves. Water quality monitoring data is
collected by consultants on behalf of companies. This data is provided to
DPIPWE for environmental assessment and management.
Analysis and research is undertaken by consultants and by research bodies
including CSIRO and IMAS.
The committee received evidence which called into question the
independence of the monitoring activities, analysis of data and research
undertaken. EDO Tasmania, for example, submitted that there is currently
limited independent monitoring of marine farming operations and noted that
DPIPWE relies largely on reports and video surveillance submitted by the operators
The Australian Marine Conservation Society added:
While data on chemical and biological parameters is clearly
being collected by operators, there is no opportunity for independent analysis
of the extent of change in critical parameters such as [dissolved oxygen], and
no transparency in holding operators to account for condition breaches. It
remains unclear what action was taken regarding condition breaches, which
leaves little public trust in the way the Harbour is being managed.
Ms Hubbard, Environment Tasmania, commented on funding of scientific
assessment and research and stated:
...what makes it difficult for the scientists here is they do
receive a lot of funding from the industry and for the management of the
industry. It makes it difficult for them to be critical. That is a very honest
statement, and they would say the same thing...These are critical environments
for other commercial species and protected species. It is really about being
able to give those scientists the space to be able to make fair, objective,
independent and critical assessment and recommendations without fear of
EDO Tasmania also commented on concerns about the reliance of industry
funding for research and stated:
These research organisations continue to provide excellent
research outcomes and direction on improved sustainability. However, the need
for industry funding to sustain these research programmes risks a level of
capture in terms of the research agenda, outcomes of such research and
availability of research data.
Response to issues raised in
The committee received responses from the Tasmanian Government, industry,
consultants and scientists in relation to concerns about independence of
monitoring, assessment, analysis and research activities.
Dr Whittington, DPIPWE, noted that the companies use a range of
consultants with accredited laboratories to undertake collection and analysis
of that work. Dr Whittington also noted that DPIPWE has auditing processes
In relation to monitoring activities, the TSGA commented that a third
party undertakes collection of data and, although hired by industry, is
independent of the industry. The TSGA went on to state that:
A third party contractor acts autonomously but is given a
very strict set of procedures to follow (often set out in regulation or license
conditions). The third party has no power to adapt, change or delete any part
of the methodology. The second party equally has no ability to adapt, change or
delete any part of the methodology.
The data collected by contractors complements other evidence gathered by
the Tasmanian Government. However, the TSGA noted that 'it is still the role of
the government to make the judgement about whether procedures have been
followed and compliance has been achieved'. The TSGA concluded:
Involving another party in the collection of evidence allows
the Tasmanian Government (first party) and the industry (second party) to
gather authentic and valid evidence under specific circumstances in a
The companies undertaking monitoring and assessment activities were
similarly of the view that there is independence in monitoring and research and
went on to note that they did not only work for fish farming companies but for
a range of stakeholders. Stakeholders include environmental organisations with
Mr Sean Riley, General Manager, Aquenal Pty Ltd, stating that the company had
added further resources to ensure that a project commissioned by Environment
Tasmania was completed to a high standard.
Mr Sam Ibbott, Director, Marine Solutions, commented that:
The broad range of clients who we work with includes ENGOs
and aquaculture, and also GBEs and the government. To say that there would be a
lack of independence I think would not be fair across the broad range of those
clients. We are certainly not putting a slant on anything. Also important is
the way that we collaborate with IMAS and with CSIRO for project development...we
have open and frank discussions to make sure that the science that we are
providing is robust, peer reviewed and developed in a manner that has the
correct stakeholder input to make sure that it is actually targeted...
Dr Neil Harstein, Project Manager, Aquadynamic Solutions, noted that information
collected by the company in Macquarie Harbour aligned with that collected by
the EPA and argued that this pointed to the independence of the data
...the information that we have been collecting has been backed
up, if we can put it like that, by EPA as well. So the types of data that we
have been collecting have been matching the EPA dataset very well. I think that
is a good show-and-tell, in terms of having regard to an independent dataset
collection, that we are conducting.
Dr Macleod also commented on the independence of environmental
monitoring of the fin-fish industry and noted that the protocols for that
monitoring are fairly well specified. She went on to comment:
I do not think it really matters who does the monitoring,
whether it is paid for by government, by industry, by wherever. It is more
important that the monitoring that is getting done is right and that the
specifications are clear, so that you can have confidence that what is getting
done is what you think is getting done and it is getting done where you think
it is getting done.
On the more general issue of scientific independence, the IMAS submitted
The Australian Code for the Responsible Conduct of Research
(the Code) is a statement of principles aimed to guide institutions and
researchers in responsible research practices and the promotion of research
integrity. Knowledge of the principles outlined in the Code is essential for
both the conduct and support of research by researchers. From a compliance
perspective, the University of Tasmania endorses and adopts the principles and
practices of responsible research outlined in Part A of the Code.
The TSGA concluded by stating:
The industry absolutely rejects the comment that it intimidates
scientists. The industry respects their right to interpret science based on
their experience and recognises that on occasion there is vigorous debate
amongst scientists as to interpretation.
IMAS and CSIRO scientists represent organisations that have
international reputations for the quality of their work, they participate in
international collaborations in fields of expertise and a significant number of
participants over the 30 years of applied research around the industry in a
number of clearly different sectors.
The committee considers that the Tasmanian Government has instituted a
comprehensive and robust monitoring regime on which to base its management of
the fin-fish aquaculture industry. The committee believes the regime currently
used in Tasmania is comparable to world's best practice.
The committee agrees that adaptive management, particularly in the dynamic
environment where fin-fish farming activities occur, must be based on sound data
collection and analytical regimes and facilitate the effective incorporation of
identified improvements into management practices. In this regard, the
committee notes that monitoring of fin-fish farming operations has long been
required in Tasmania and extensive datasets are now available.
These datasets are used by the Tasmanian Government to inform the
on-going adaptive management of the industry to safeguard the marine
environment. Research undertaken by various bodies over the last two decades,
notably the Institute for Marine and Antarctic Studies, has contributed to the
development of the fin-fish industry regulatory regime as well the
understanding of the environmental effects of fin-fish operations. As the
industry has grown, this research has assisted to refine the monitoring so that
emerging issues are addressed and the monitoring regime meets the needs of
increasing production in the industry
While there were concerns about possible compromise of the monitoring
regime because the industry participants collect the data (or pay for its collection)
and research organisations rely on funding from industry, the committee
strongly considers that this is not the case. The committee received extensive
evidence that underscores the independence of those undertaking monitoring
activities and research. In addition, the Tasmanian Government prescribes how
monitoring is to be conducted and has in place an audit program to ensure the robustness
and accuracy of monitoring information. The committee also notes the evidence
that outcomes of monitoring programs conducted by consultants align with those
of the Environment Protection Authority.
In relation to the specific issues raised in evidence, the committee notes
in particular the calls for more frequent monitoring of some parameters. The
committee acknowledges that some companies conduct monitoring more frequently
than at the intervals prescribed by the government. In some instances, more
frequent monitoring is a requirement of a certification program, for example
the Aquaculture Stewardship Council. The committee considers that this shows
the commitment of the industry to ensure that a robust monitoring system of
their operations is in place. The committee therefore encourages both industry
and the government to provide more extensive information on where monitoring by
industry exceeds the prescribed requirements.
Some submitters called for greater access to information, including raw
data from monitoring activities. The committee notes evidence about the
possible risks of misinterpretation and lack of context should raw data be made
publicly available and, therefore, does not support access to raw data.
Currently, there is an extensive range of information available publicly
from multiple sources including government, companies and research bodies
related to many aspects of the salmonid industry. Nonetheless, the committee
considers that the Tasmanian Government should consider providing more information
about the outcomes of the monitoring regime including audit activities and
compliance. In particular, the committee notes the suggestion from
WWF-Australia that the government should publish an annual aquaculture report
for each farming region/zone. The committee also notes the comments from Dr
Whittington indicating that consideration will be given over the next year to
providing online reporting of some environmental data.
The committee believes that greater access to information would improve
transparency of the regulatory regime, ensure that interested stakeholders can
come to an informed position on areas of concern and allay fears that the
community is not being adequately informed about the impacts on the marine
environment of Tasmania.
The committee recommends that the Tasmanian Government support the
greater provision of environmental information and data relating to the
fin-fish industry by the Department of Primary Industries, Parks, Water and
Finally, the committee was gravely concerned about inferences of lack of
independence of, or constraints to, research and monitoring related to the fin-fish
aquaculture industry including inland river hatcheries. The committee believes
that the scientists and consultants who undertake research and monitoring of
aquaculture work to the highest ethical standards. Research by scientists at the
IMAS, and other organisations, is peer reviewed and acknowledged to be world
class. In addition, scientists and consultants work with a range of
stakeholders including environmental organisations. The committee, therefore, considers
the comments regarding lack of independence to be without foundation.
In particular, the committee notes concerns about possible conflict of
interest and lack of independence of scientific research in relation to the
report on the impacts of salmonid farming on abalone undertaken by Professor
The committee received a response from Professor Buxton to this evidence.
The response addressed these concerns and the committee is satisfied that
Professor Buxton's appointment did not present issues regarding a conflict of
interest or a lack of independence.
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