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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 ES LINK SERVICES PTY LTD A BN 7 6 08 8 41 4 03 7 4/233 Barker Street (PO Box 10) Castlemaine VIC 3450 T (03) 54705232 [email protected] www.eslinkservices.com.au 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 2 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. 3 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 4 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 5 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) 6 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 7 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. 8 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 9 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 10 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. 11 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. 12 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 13 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 14 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. 15 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. 16