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14
Proposed Australian Biofouling Management Requirements
Consultation Regulation Impact Statement
Q10. Do you have any other comments on the Regulation Impact Statement?
As a general comment, I consider the proposed regulatory biofouling requirements, in
which a specific number of biofouling species are declared as quarantinable pests,
with quarantine action at the border to try and establish the presence or absence of any
one of these species, to be deeply flawed, impractical and unachievable. Additionally
it does not address the potential problem of many, as yet unidentified species, that
could pose a greater risk than the listed SOC.
Government’s pursuit of this regulatory approach was, unfortunately, the consequence
of a unilateral decision by AQIS in 2006 that was made outside of NIMPCG, and
ignored the recommended approach to the management of international biofouling
developed within NIMPCG that built on specialist consideration and advice from the
NIMPCG biofouling working group. The government has since persisted with this
approach, despite industry advice on the impracticality of the proposed approach and
potentially greater benefits that could be achieved by proactive, rather than reactive,
measures to minimise biofouling on merchant ships.
Nonetheless, accepting the commitment of Government to pursue this regulatory
approach, I commend the attempt to scientifically justify the selection and designation
of species of concern (SOC), and quantify the invasion likelihood and potential risk
posed by these species. However, in reviewing the two documents prepared to support
the requirements, and used in developing the RIS, I have encountered errors,
inaccuracies and questionable interpretations. A logical two stage process, which
involved developing the risk assessment process and a preliminary list of SOC,
followed by review and assessment of the proposed SOC by taxonomic and species
group specialists, would have seemed appropriate and ensured a more robust list of
SOC ahead of regulatory actions. From my own speciality and experience, I believe
addressing the errors, inaccuracies and questionable interpretations in the species risk
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assessment will significantly reduce the number of SOC proposed (from 56 to ~31),
which in turn identifies a source of over-estimation of impact costs and regulation
benefits calculated in the RIS.
Please find attached for your consideration my specialist, scientific reviews of the
biofouling requirements and RIS support documents:
Species Biofouling Risk Assessment; and
Estimate of the likely establishment rate for non-indigenous marine species in
Australia
John A. Lewis
BSc(Hons) MSc CMarSci MIMarEST
Principal Marine Consultant
ES Link Services Pty Ltd
28 February 2012
Attachments:
1. Review of: Species Biofouling Risk Assessment
2. Review of: Estimate of the likely establishment rate for non-indigenous
marine species in Australia
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Attachment 1:
Proposed Australian Biofouling Management Requirements: Consultation
Regulation Impact Statement
Review of:
Hewitt et al., 2011. Species Biofouling Risk Assessment. DAFF, Canberra
Introductory Comments
The general structure and methods applied to quantifying risk in this report are
good, and represent a valid scientific approach to identifying species of concern.
However, given my following comments, it is clear that the process to determine
Species of Concern for declaration of quarantinable biofouling species should have
been a two-stage process, with this initial risk assessment by generalist invasion
biologists/ecologists distributed for review by relevant taxonomists, or by a
committee of specialists. Australia is fortunate to have a resident pool of such
experts, and their wealth of knowledge could have been exploited by DAFF in this
exercise to produce a defendable list of SOC.
As presented, this report contains errors, inaccuracies, out-dated information, and
questionable interpretations which, together, result in an inflated, and for some
irrelevant, list of species of concern (SOC) which would be impossible to apply as
proposed. The problems can be summarised as:
Assignment of distribution and therefore transportation risk at a very broad
bioregion level;
Non-assignment of zero risk, or non-assignment of zero to “negligible”, for
calculating overall risk from likelihood and consequence;
Errors, or out-dated information, on:
o Nomenclature and taxonomy
o Distribution
Non-recognition of life history characteristics of individual species that
reduce or eliminate risk;
Non-recognition that some attributed impacts do not heighten the risk posed
by native species or established NIS;
Questionable assignment of impacts, consequences and risks to individual
species; and
Lack of validation of the assessment against established NIMS in Australia.
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The consequences of an inflated list could be interpreted as a precautionary
approach to the declaration of quarantinable marine biofouling species, but the
higher the number, the more difficult is the ability to detect, identify and declare a
vessel SOC-free. For a realistic and functional precautionary approach, a proactive
approach to minimise any biofouling on vessels would be more effective, as this
addresses the unknown, as well as the known, potential pests.
I add that only a small proportion of the total species pool of potential marine
biofouling species has been described and documented in Australia, particularly
along the western and northern coasts. For example, in the 1999 marine pest survey
of the port of Port Hedland, less than 30% of invertebrates and no macroalgae were
identified to species level and, in the survey of the port of Cairns, the percentage of
identifications was even less. Apart from not knowing what species are native, and
what are unrecognised NIMS, this adds to the difficulty of identifying and/or
differentiating designated SOC and other potential harmful NIMS from native
species, particularly by non-specialists.
Precision in nomenclature and taxonomy would also seem fundamental to the
process of legally declaring and inspecting for quarantinable marine biofouling
species. Without this there will be uncertainty in recognising and identifying the
presence and/or absence of species of concern. Despite the view of some, that there
will always be uncertainty and variation in assignment and application of species
names, both botanical and zoological nomenclature is governed by very precise rules
to avoid such confusion. Up-to-date knowledge of the relevant taxonomic literature
would ensure that such inaccuracies do not occur.
My own specialist taxonomic knowledge is largely restricted to macroalgae,
barnacles and serpulid tubeworms. While I offer some comments on species of
other groups on which I have a little knowledge, given the number of errors and
inaccuracies found in the groups in which I specialise, I strongly recommend that the
risk assessment be reviewed by relevant taxonomic experts.
My more detailed and specific comments follow.
Regional Occurrence and Transportation Risk
The use of the 18 large-scale World Conservation Union (IUCN) marine bioregions for
determining transport pressure rank is justified in the report on the basis that:
They are considered closer representatives of widely accepted biological
provinces and offer a more conservative approach to estimating distribution
than finer scale ecoregions…; and
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The assumption avoids an overly restrictive data collection exercise.
The broad extent of these bioregions, particularly the latitudinal spread of a number
across tropical to cold temperate, or even sub-Antarctic waters, means that the
transportation risk can be greatly over-estimated. Having the entire Australian and
New Zealand coastlines designated as one bioregion further adds to imprecision of
the assessment. Transport pathways between, for example, Alaska and Darwin or
Singapore and Macquarie Island are consequently considered to present the same
transport risk for NIMS as between Osaka and Melbourne, or Djakarta and Darwin.
My earlier comments on a conservative or the precautionary approach also apply
here.
The analysis also takes no account of the freshwater habitats of numerous species
within their invaded range in any one of the broad bioregions, which would mean
there is no transport pathway to Australia.
Taking the broad bio-region approach further, admittedly absurdly, IMS occurring in
New Zealand and not Australia should be considered already established in Australia
and addressed through domestic biofouling management. As a related aside to this, I
find it difficult to accept the argument given for not including Perna canaliculus in
the assessment. There are already significant invasions of New Zealand species in
eastern Australia (e.g. Maoricolpus, Petrolisthes), active transport vectors are in
place and known to carry P. canaliculus, and the incursion history differs little to that
of Perna viridis in northern Australia and Amphibalanus improvisus (all have
recorded incursions, colonisation, but no known establishment as yet). If the
argument is that if it could have established, it would have already, then the same
argument applies to P. viridis and A. improvisus – a brave decision in a time of
climate change.
I maintain that, if a quarantinable marine species approach is to be pursued, then
precision and accuracy in declaring species is essential to ensure the effort and cost
of detecting species is effectively directed, as well as avoiding the risk of unnecessary
detainment or operational and remedial costs to shipping.
Non-assignment of Zero to Likelihood Rankings in the Calculation of Risk
Categories
Any number multiplied by zero results in zero, and the non-assignment of zero to
“neglible/very low” rankings, or the absence of a zero ranking, results in some
nonsensical SOC listings. The best, or more correctly worst, example is the cold
water diatom, Corethron criophylum. This is a planktonic species through its entire
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life history and, not surprisingly, has never been recorded associated with biofouling.
However, it is assessed to be a SOC.
For reasons to be discussed later, this species needs to be cut from the list for other
reasons, but it highlights a flaw in the process. Assignment of any microalgae as
SOC, would also prevent any vessel or any size to be declared free of SOC unless it is
still in dry-dock after cleaning and repainting.
Errors or Out-dated Information on Species Taxonomy, Nomenclature and
Distribution
Algae
Corethron criophyllum
A junior synonym of Corethron pennatum
Known from Tasmania.
Distribution also includes Brazil, Argentina, the Southern Ocean and Antarctica.
Ref: Jameson & Hallegraaf 2010.
Ineligible for listing as “known to be present in Australia.”
Codium fragile ssp. atlanticum
“Although often regarded as an introduced subspecies in Britain and Ireland,
there is no evidence of its occurrence elsewhere in the world, and the earliest
collection date back to the eighteenth century”
Ref: Maggs & Kelly 2007.
Ineligible for listing as “no demonstrable invasion history.”
Ulva pertusa
A junior synonym of Ulva australis.
Known from southern Australia.
Refs: Kraft et al. 2010, Couceiro et al. 2011.
Ineligible for listing as “known to be present in Australia.”
Pseudochattonella farcimen (previously Chattonella aff. verruculosa)
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Pseudochattonella spp. are Dictyochophytes, not Rhaphidophytes
Refs: Hallegraeff 2010b, CABI 2009.
Minor correction needed in nomenclature.
Chattonella antiqua
The separation between C. antiqua and C. marina, which is known from southern
Australia, is uncertain. C. antiqua has been relegated by one author to a variety
of C. marina (C. marina var. antiqua).
Ref: Hallegraeff 2010a
Possibly ineligible for listing as “known to be present in Australia”; specialist
advice needed (e.g. Gustaaf Hallegraeff).
Barnacles
Balanus eburneus, Balanus improvisus
These species now all belong under Amphibalanus, as A. eburneus and A.
improvisus
Refs: Pitombo 2004, Carlton & Newman 2009.
Minor correction needed in nomenclature.
Non-recognition of life history characteristics of individual species that reduce or
eliminate risk
Freshwater Species
A number of species determined to be SOC are predominantly freshwater species
and, although they may tolerate brackish or low salinity water, they would not
tolerate exposure to oceanic salinities in biofouling communities for the required
duration of the transit to Australia. These species include:
Crangonyx floridanus
Dikerogammarus villosus
Gmelinoides fasciatus
Corbula fluminea
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Dreissena bugensis
Dreissena polymorpha
Planktonic Species
A number of holoplanktonic species have been determined to be SOC, and these
would not be transported as biofouling. These include:
Acartia tonsa
Pseuochattonella farcimen
Chattonella antiqua
Corethron criophyllum
No Biofouling Association
A number of the species determined to be SOC have no documented or likely
association with vessel biofouling. Some of these are infaunal species listed as having
“the potential to survive in sea chests” but biofouling association rank should be no
higher than “very low” unless there is documented evidence of them being found in
sea chests. These species include:
Briarosaccus callosus
Loxothylacus panopaei
Polydora nuchalis
Avrainvillea amadelphis
Corbula amurensis
Anguillicola crassus
Cliona thoosina
Unlikelihood of Long Distance Biofouling Transport
The two large brown macroalgae on the list, Sargassum muticum and Fucus
evanescens, both lack a dimorphic life history, regenerative basal crust or other traits
found in invasive macroalgae dispersed as biofouling over long distances. The
unusual propagation of Sargassum muticum also results in a limited propagule
spread of 2-3 m from the parent plant which reduces the capability and likelihood of
this species colonizing international shipping. Acknowledging these traits should, at
the least, downgrade inoculation likelihood to moderate and very low for S. muticum
and F. evanescens respectively.
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Species Impossible to Detect or Declare Absent in a Biofouling Inspection
Microalgae
The following microalgae determined to be SOC have been listed previously as
having no association with biofouling, but microalgae would be impossible to detect
during an in-water inspection or their risk of presence flagged in any MGRA because
of their occurrence as biofilm species:
Pseuochattonella farcimen
Chattonella antiqua
Corethron criophyllum
Micro-invertebrates and small macroinvertebrates
The copepod Acartia tonsa is categorised in the same way as the above microalgae.
However, particular spceeis small macroinvertebrates such as amphipods would be
similarly difficult to accurately detect during an in-water biofouling inspection, due
both to their small, mobile form, and the high diversity of known and unknown
species potentially associated with vessel biofouling. Species listed as SOC include:
Ampelisca abdita
Gammarus tigrinus
Gmelinoides fasciatus
Parasites
Parasites represent a secondary infection better addressed by managing the hosts.
They would also be impossible to detect in an in-water biofouling inspection unless
all potential hosts are sampled and individually examined. Parasitic species listed as
SOC include:
Briarosaccus callosus
Loxothylacus panopaei
Sylon hippolytes
Anguillicola crassus
Banamia ostreae
Species Impossible/Difficult to Distinguish in a Biofouling Inspections
Numerous species listed as SOC, for example, the acorn barnacles would be difficult
to distinguish from non-SOC as juveniles, even if sampled from the vessel and
examined by a taxonomic specialist in the laboratory. However adults and sub-adults
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should be identifiable. Didemnum vexillum would similarly almost impossible to
separate as a juvenile from the numerous native didemnids, and adults require
microscopic examination to confirm their identity, as would Sargassum muticum
from the numerous described and cryptic native species.
However, the serpulid tubeworm Hydroides dianthus cannot be distinguished from
the commonly occurring co-genors, which include the common established vessel
fouling species H. elegans, H. ezoensis and H. sanctaecrucis and numerous native
species, unless the individual worm is extracted from the tube. Any vessel with
Hydroides tubeworms could not, therefore, be declared free of this SOC unless every
tube is removed. The similar life history, ecological and invasive traits of H. dianthus
with the established NIS of Hydroides mentioned above also means that
establishment of H. dianthus in Australia would not impose any additional impact, as
Non-recognition that some attributed impacts do not heighten the health risk
already posed by native species
The two attributed impacts that would not heighten the risk posed by native species
or established NIMS that attracted my attention are:
Sharp shells may cause lacerations
Amphibalanus eburneus
Amphibalanus improvisus
Demonstrated to bioaccumulate microcystin toxins
Charybdis japonica
Crassostrea ariakensis
Limonoperna fortune
Mya arenaria
Perna perna
Perna viridis
Or to host bacterial pathogens.
Crassostrea virginica
In the first case, the health risk is no greater than that presently posed by similar
native species and, in the second, it is the microalga or bacteria that presents the
risk, not the biofouler, and native or cultivated filter-feeding organisms pose a
greater risk because of their established numbers and the commercial or
recreational fishery of these for human consumption. These supposed impacts
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should be deleted from the risk assessment, or at the minimum re-ranked as very
low.
Questionable assignment of impacts, consequences and risks to individual species
For a number of taxa, the impact is “inferred”, which would seem to mean that there
is no documented evidence. The importance and impact of the approved list of SOC
is too important for such questionable assignments, and assigned impacts should be
deleted or, at the very least, downgraded. This includes:
Polydora nuchalis (Environmental – High (also listed wrongly as Economic))
Amphibalanus eburneus (Environmental – High, Economic - Low)
Amphibalanus improvisus (Environmental – Moderate, Economic – High)
Chthamalus proteus (Environmental – Moderate)
Loxothyacus panopaei (Economic – High)
Pachygrapsus fakaravenis (Environmental – Low)
Solidobalanus fallax (Environmental- Extreme, Economic – Moderate)
Anomia nobilis (Environmental – Moderate)
Errors and inconsistencies in rank assignment and calculation of risk
Examples of inconsistencies include:
Amphibalanus eburneus and A. improvisus in which almost identical text
results in consequences of high & low for the former, and moderate and high
for the latter species
Example of apparent errors include:
Solidobalanus fallax – assignment of Extreme risk to “possible overgrowth
and smothering
Solidobalanus fallax – No evidence of nuisance fouling in the literature, and
this species not mentioned in the cited reference (Leppakoski & Gollasch)
Lack of validation of the assessment against established NIMS in Australia
An extremely useful exercise to validate this risk assessment would be to apply the
same criteria to NIMS established in Australia. This may well highlight which species
or species types could be discounted on the basis of comparative risk, and also serve
to highlight the potentially much greater risk categorisation of some of these, in turn
stressing the need and possibly higher priority that should be afforded to the
management of domestic biofouling risks.
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References
CABI, 2009. Pseudochattonella verruculosa [original text by J.A. Lewis]. In, Invasive
Species Compendium. CABI, Wallingford, UK. (www.cabi.org)
Carlton, J.T., Newman, W.A., 2009. Reply to Clare and Høeg 2008. Balanus amphitrite
or Amphibalanus amphitrite? A note on barnacle nomenclature. Biofouling 25, 7780.
Couceiro, L., Cremades, J., Barreiro, R., 2011. Evidence for multiple introductions of
the Pacific green alga Ulva Australis Areschoug (Ulvales, Chlorophyta) to the Iberian
Peninsula. Bot. Mar. 54, 391-402.
Hallegraeff, G.M., 2010a. Raphidophytes (Chrysophyta). In, Hallegraeff, G.M., Bolch,
C.J.S., Hill, D.R.A., Jameson, I., LeRoi, J.-M., McMinn, A., Murray, S., de Salas, M.F.,
Saunders, K. (Eds), Algae of Australia: Phytoplankton of Temperate Coastal Waters.
ABRS, Canberra. Pp. 361-365.
Hallegraeff, G.M., 2010b. Dictyochophytes (Chrysophyta). In, Hallegraeff, G.M.,
Bolch, C.J.S., Hill, D.R.A., Jameson, I., LeRoi, J.-M., McMinn, A., Murray, S., de Salas,
M.F., Saunders, K. (Eds), Algae of Australia: Phytoplankton of Temperate Coastal
Waters. ABRS, Canberra. Pp. 366-370.
Jameson, I., Hallegraeff, G.M., 2010. Planktonic diatoms. In, Hallegraeff, G.M., Bolch,
C.J.S., Hill, D.R.A., Jameson, I., LeRoi, J.-M., McMinn, A., Murray, S., de Salas, M.F.,
Saunders, K. (Eds), Algae of Australia: Phytoplankton of Temperate Coastal Waters.
ABRS, Canberra. Pp. 16-82.
Kraft, L.G.K., Kraft, G.T., Waller, R.F., 2010. Investigations into southern Australian
Ulva (Ulvophyceae, Chlorophyta) taxonomy and molecular phylogeny indicate both
cosmopolitanism and endemic cryptic species. J. Phycol. 46, 1257-1277.
Maggs, C.A., Kelly, J., 2007. Codium. In, Brodie, J., Maggs, C.A., John, D.M. (Eds)
Green Seaweeds of Britain and Ireland. British Phycological Society. Pp. 189-201.
Pitombo, F.B.,2004. Phylogenetic analysis of the Balanidae (Cirripedia,
Balanomorpha). Zoologica Scripta 33, 261-276.
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Summary
Synthesizing my comments above, which in turn should be subjected to specialist or
peer review, would give the following revised list of Species of Concern: a total of 31
species, or34 if the small crustaceans are included. Interestingly, most are mussels,
oysters, barnacles or crabs.
Organism
Type
Overall
Ranking
Overall
Risk
Charybdis japonica
Crab
13
E
Eriocheir sinensis
Crab
12
E
Tunicate
9
E
Mytilopsis sallei
Mussel
9
E
Limnoperna fortunei
Mussel
9
E
Perna perna
Mussel
8
E
Perna viridis
Mussel
8
E
Perna canaliculus
Mussel
8
E
Mytilopsis leucophyta
Mussel
8
E
Crassostrea virginica
Oyster
7
E
Gastropod
6
E
Rhithropanopeus harrisi
Crab
6
E
Hemigrapsus sanguineus
Crab
6
E
Mussel
6
E
Seaweed
5
E
Oyster
5
E
Gastropod
4
H
Amphibalanus improvisus
Barnacle
3
H
Amphibalanus eburneus
Barnacle
3
H
Crab
3
H
Scientific Name
Didemnum vexillum
Crepidula fornicata
Brachidontes variabilis
Sargassum muticum
Crassostrea ariakensis
Rapana venosa
Callinectes sapidus
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Organism
Type
Overall
Ranking
Overall
Risk
Crab
3
H
Oyster
3
H
Balanus glandula
Barnacle
3
H
Solidobalanus fallax
Barnacle
2
M
Mytella charruana
Mussel
2
M
Anadara demiri
Bivalve
2
M
Chthamalus proteus
Barnacle
1
M
Geukensia demissa
Mussel
1
M
Crab
1
M
Fucus evanescens
Seaweed
1
M
Gelliodes fibrosa
Sponge
1
M
Scientific Name
Carcinoscorpius rotundicauda
Anomia nobilis
Pachygrapsus fakaravenis
Small crustaceans – difficult to detect and identify
Sphaeroma annandalei
Isopod
4
H
Ampelisca abdita
Amphipod
1
M
Gammarus tigrinus
Amphipod
1
M
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Attachment 2:
Proposed Australian Biofouling Management Requirements: Consultation
Regulation Impact Statement
Review of:
Hewitt, 2011. Estimate of the likely establishment rate for non-indigenous
marine species in Australia. In, Proposed Australian Biofouling Management
Requirements: Consultation Regulation Impact Statement. DAFF, Canberra.
Appendix F.
I have two comments to make on this report: firstly I question the calculated
establishment rate, and secondly the calculated probability of arrival.
Establishment rate:
The data used to calculate the establishment rate is the date of first reports of NIMS
in Australia. This is then equated to “detection” and “arrival”. The logic here is
questionable and most probably false, as the peak in new reports does not
necessarily relate to “arrival”, but to the increased taxonomic effort, sampling, and
marine biological surveys during this time, led by the PPB survey in 1957-1963 (with
results published in 1966 and 1971), followed by further bay-wide surveys in 1976-77
and 1991-96, the advent of scientific diving in the 1970s, and the first round of port
surveys commencing in the late 1990s. Drawing similar histograms to those
presented to show the times of first NIMS reports for the published descriptions of
native marine species show the exact same trends. Assuming that species reported
since 1960 arrived since 1960 is misleading, as many of these species most likely
arrived long before but were not detected. The establishment rate is therefore likely
to be much less than 4.9 NIMS/year or 3.39 to 4.06 biofouling NIMS/year.
Probability of arrival:
I cannot follow the logic of calculations used to generate the probability that one of
the arriving NIMS will be a SOC.
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Accepting the number of SOC is 56, and the establishment rate of 3.39 to 4.06 per
annum, I agree that the percentage of SOC in the total pool of 1068 NIMS not
established in Australia is 5.42%. I would then say that the calculated establishment
rate of SOC is between 0.0542 x 3.39 (0.184) and 0.0542 x 4.06 (0.220) per annum, of
one SOC every 4 ½ to 5 ½ years.
The probability equation presented (Eqn 1) is not explained, nor how the
probabilities of 15 to 20% are estimated, and I understand neither.
If the number of SOCs is only 31 (as per Attachment 1), and the establishment rate
reduced to, say, 3.0 NIMS/annum (2.07 to 2.48 biofouling NIMS), the establishment
rate of SOCs would be between 0.060 and 0.072 per annum, or one SOC every 13 ½
to 16 ½ years.
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