AMSA received a total of 10 submissions during the consultation period.
• Four submissions were made by seafarers or vessel owners/operators
• Five submissions were made by industry peak bodies on behalf of their members
• One submission was made by a government agency.
Mandatory marking of fishing gear
KEY ISSUE 1: Types of gear and operations to be included in mandatory marking requirements
Most submissions supported the mandatory marking of commercial fishing gear. Some suggested excluding certain types of commercial gear, including: gear that is not left unattended and which could be retrieved if lost, continuously attached gear that is less likely to be lost, and gear that is not vessel unique.
Some submissions outlined that new requirements should not be cost-prohibitive, including consideration of any lost fishing time to place markings and any impact on gear ordering and delivery times.
Submissions were split on whether recreational gear and operations should be included in the new marking requirements. Some submissions noted the difficulty of implementing and regulating marking requirements for recreational vessels.
Some submissions suggested marking aquaculture gear, as losses were reported to be more common and such operations are moving further offshore.
It was also suggested that retrieved gear be returned to the fisher or recycled.
KEY ISSUE 2: Information to be included in marks
The majority of submissions supported marks that identify:
- The vessel, such as the vessel name, international radio call sign or Maritime Mobile Service Number.
- The vessel owner/operator, such as the fishery license number or the personal gear identification number.
One submission suggested that the mark contain information about the gear, such as gear type and size.
One submission acknowledged that the size of marks would limit the information they could contain. It was suggested that a QR code or similar system could be used.
KEY ISSUE 3: Participation in existing marking schemes
The majority of submissions reported participation in existing marking schemes. Types of gear covered by these schemes included crab and lobster pots and traps, trawls, nets, long lines and any gear anchored to the seabed.
Some submissions suggested that current marking requirements will likely be sufficient to meet new requirements.
Submissions noted numerous barriers to participation in marking schemes, including: cost, complex and frequently changing requirements, over-regulation of the industry, and industry attitudes.
Submissions also raised broad issues about the effectiveness and practicality of marking requirements, including: marks could be easily removed before intentional discharges, illegal fishers would not use marks, and gear is not always unique to a single vessel and can be cut, divided and spliced.
One submission raised that markings can have positive navigation safety outcomes if GPS and light-up beacons are used for marking.
Expanded reporting requirements for fishing gear
KEY ISSUE 4: Types of gear and operations to be included in expanded reporting requirements
Most submissions supported the inclusion of commercial gear in the expanded reporting requirements. Some submissions suggested excluding certain types of commercial gear and operations, including: gear that is not left unattended as it can be retrieved if lost and gear used in State/Territory waters as operations in these waters would not be of interest to the IMO.
Submissions were split on whether recreational gear and operations should be included in the expanded reporting requirements. One submission supported that reporting requirements should only apply to recreational gear which is left unattended.
One submission supported the inclusion of aquaculture gear in the expanded reporting requirements.
Some submissions called for more focus on not losing gear and collecting lost gear.
KEY ISSUE 5: Information to be reported and method of reporting
When considering what information was to be reported to the IMO, most submissions supported only reporting aggregated and anonymised commercial-in-confidence data, including the exact locations and the details of specific events.
Some submissions raised reluctance to report any information to the Australian Government and/or IMO. Some submissions supported reporting to the Australian Government through existing schemes and mechanisms.
There was support for reporting to include information on the cause of any loss/discharge to inform the development of future measures.
KEY ISSUE 6: Participation in existing marking schemes
Some submissions reported participation in existing reporting schemes and supported reporting to the Australian Government for new requirements through these schemes and mechanisms to avoid duplication.
Several submissions raised barriers to participation, including: fear of repercussions, complex and frequently changing rules, the belief that the industry is capable of self-regulation, and reporting might indicate higher loss rates than believed.