3 March 2015 The Director Sustainable Fisheries Section Department of the Environment GPO Box 787 CANBERRA ACT 2601

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Joel Carpenter
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1 3 March 2015 The Director Sustainable Fisheries Section Department of the Environment GPO Box 787 CANBERRA ACT 2601 Dear Director, Birdlife Australia welcomes the opportunity to provide further comments on the Ecological Assessment of the South Australian Beach-Cast Seagrass and Marine Algae Fishery report prepared by Primary Industries and Regions South Australia (PIRSA). We are strongly opposed to the proposed management of the fishery (the proposal) which is likely to have a significant impact on EPBC-listed migratory and threatened shorebirds including Hooded Plover (eastern), Ruddy Turnstone, Sharptailed Sandpiper, Sanderling and Curlew Sandpiper. The proposal is likely to have a significant impact on nationally and internationally important shorebird habitat in this region and fails to recognise ongoing community efforts to conserve and protect endangered species in this region. We recommend further research to develop a rigorous, sustainable management model for this fishery that will not have significant impacts on EPBC-listed migratory and threatened species. If you require further information in relation to this submission, please contact Dr Grainne Maguire, grainne.maguire@birdlife.org.au or ext 229. Sincerely, Samantha Vine Head of Conservation

2 Current assessment is based on inaccurate, poor quality shorebird data BirdLife Australia has serious concerns about the poor quality of the data used to inform the ecological assessment of this fishery. In particular, the current assessment is based on shorebird occurrence and distributional data (provided by DEWNR) that is out of date and incomplete. It has not incorporated the detailed, up to date data in the Shorebird Sites of the Limestone Coast South Australia report (Christie & Jessop 2007) and BirdLife Australia s Shorebirds 2020 and Hooded Plover databases. The accuracy of the distribution maps for shorebird species is highly questionable, with the distribution of Ruddy Turnstone (Arenaria interpres), Sharp-tailed Sandpiper (Calidris acuminata) and Curlew Sandpiper (Calidris ferruginea) shown as widespread throughout the area, when known records and actual distribution are much more restricted than the mapping indicates. Proposed take and no take zones will not protect shorebirds A spatial limit to harvesting has been proposed with the coast divided into a 50% no take zone and the remaining 50% of the coastline allows for up to 100% harvest of wrack. While the target is Bull Kelp, harvesting is not limited to this species. We believe that no take zones should be based on the requirements of ocean beach dependent shorebirds and seabirds, including Hooded Plover breeding sites, Ruddy Turnstone foraging and roost sites, Sanderling foraging sites and other national and international significant migratory shorebird areas. Under the present proposal, the no take zones do not include important shorebird sites and will not protect resources for shorebirds. The proposal coins these no take zones as habitat protection zones, but we would question the habitat they represent. The no take zones appear to be coastline adjacent to Conservation Parks and Marine Park Habitat Protection and Sanctuary Zones. However, these zones are not ecologically meaningful protection areas for the species that seaweed harvesting is most likely to impact. The Marine Park zones are not based on the intertidal zone/beach values and currently Marine Parks play no role in conservation of terrestrial species occurring above the high-tide mark. Similarly, Conservation Parks have been primarily set aside for terrestrial values which do not take into account nor reflect shorebird habitat values.

3 Proposed take zones include nationally and internationally important shorebird areas There are no temporal restrictions on harvesting in the take zones, meaning that 100% of wrack can be removed in these zones, throughout the year. This is of major concern to BirdLife Australia as the take zones include three internationally important shorebird areas, and the Harvest area Nora Creina to northern end of Beachport Conservation Park is habitat for five to six pairs of Hooded Plovers, representing significant breeding habitat for this EPBC-listed species (1.6% of the South Australian population, total 750 birds, and 0.4% of the Eastern Hooded Plover subspecies, total 3000 birds). Given that Hooded Plovers are a dispersed species and territorial, they rarely occur in high densities. The occurrence of six pairs in the proposed take zone highlights its significant habitat value. Furthermore, this zone contains one of the only vehicle free areas in the proposal area (between Lake George Outlet to Surf Beach in Rivoli Bay), and thus represents a zone of reduced disturbance to breeding Hooded Plovers. Hooded Plovers breed at Stinky Bay and this is also internationally important for Sanderling and regularly supports a flock of up to 100 Ruddy Turnstones. Proposal indicates a limited and inaccurate understanding of Hooded Plover ecology The description of the Hooded Plover and its habitat requirements in the proposal are too simple to adequately address potential impacts on this species. The proposal is not based on current research findings or available expert knowledge. Hooded Plovers do not only feed at the water s edge and they do not only nest on the upper beach. Their habitat zone includes marine and terrestrial habitat, with the birds selecting high energy beaches with rocky reefs offshore and subtidal rock platforms, as well as areas with high availability of beach-cast seaweed (unpublished research Glenn Ehmke, Mike Weston and Grainne Maguire, see Maguire et al. 2014). Their nests can be anywhere above the high tide beach, which can include the mid to upper beach, foredune and dune system. Hooded Plover chicks rely on beach wrack for shelter, refuge from disturbance and as foraging habitat. The birds are highly selective of amphipods (Cuttriss et al. 2015) and these invertebrates are closely associated with wrack presence and abundance. Amphipods can reduce the biomass of dead macro-algae to 50% of its initial weight after 2 days and 20% after 14 days as noted in the ecological assessment and yet the proposal is to remove up to 100% of this fresh kelp (up to 7 days old) from Hooded Plover breeding territories. We know that amphipod abundance is directly correlated with Hooded Plover presence (Cuttriss et al. 2015). If the organic matter that these amphipods rely on is removed, this will directly impact amphipod abundance and thus habitat suitability.

4 Inadequate protection for breeding Hooded Plover The proposal to limit wrack harvesting activities to areas more than four metres from the foredune may have been attempt to limit impacts on breeding Hooded Plovers. However, Hooded Plover may nest anywhere above the high-tide mark within a territory (which on average is 1km of a length of beach). Chicks use the zone between the water s edge and the foredune, moving regularly within this zone and crouching from disturbance and predators within this zone. Removal of their food source and primary cover (i.e. wrack) will result in breeding failure or worse, loss of habitat for the breeding pair. The displaced pair are then likely to search for another territory, disrupting and challenging neighbouring pairs, which can then result in breeding failure for those pairs and disruption to the regional population. Breeding pairs show strong site fidelity and banding studies reveal that pairs use these territories year after year. National recovery actions at risk Significant community support and volunteer effort, coupled with Federal Government and NRM Board funding, has been and continues to be invested in conservation of the Hooded Plover in South Australia including this stretch of coastline. This proposal will jeopardise national recovery efforts by destroying important habitat. Wrack provides the organic material that Hooded Plover prey is dependent on and the wrack itself is a vital refuge and shelter resource for adults and chicks. This will have significant social impacts as community groups involved in Hooded Plover conservation will view the destruction of Hooded Plover habitat and foraging resources as an outrage and insult to their long-standing efforts to conserve the species. Recommendations We strongly recommend that the assessment report be reviewed and amended to acknowledge the importance of the beaches and lakes of the Limestone Coast for shorebirds in South Australia (Christie 2006). It must also take into consideration the report by Christie and Jessop (2007) that reviewed shorebird records for this area. This report found that the Limestone Coast (including the area between Cape Jaffa and Beachport covered by Miscellaneous Fishery licence Y078) regularly supports thousands of shorebirds, with seven species occurring in internationally significant numbers including Ruddy Turnstone, Sanderling, Red-necked Stint, Sharp-tailed Sandpiper and Curlew Sandpiper. The report also found that this area is the second most important site in Australia for Sanderling and provides habitat for two additional migratory species that occur in nationally significant numbers, as well as internationally significant numbers of Banded Stilt (Christie and Jessop 2007). More recent surveys by members of the Australasian Wader Studies Group have recorded internationally significant numbers of Ruddy Turnstone at Wright Bay and

5 Sanderling at Stinky Bay near Nora Creina. These areas are within the harvest areas for Miscellaneous Fishery Licence Y078 and require further investigation and assessment relating to the impact of wrack harvest before any extension of the licence is approved. Summary We believe the proposal will have severe and widespread impact(s) on consumers in the food web and across all the relevant trophic levels (including birds) by removing a huge amount of primary productivity from this natural ecosystem. Beach cast seaweed is a marine subsidy that is the primary source of food and shelter for beach dwelling fauna. It is a key resource at all trophic levels from the invertebrate infauna to apex predators and scavengers. Removal of 100% of this key food and shelter resource from internationally significant shorebird areas and known Hooded Plover breeding sites will have significant ecological impacts. BirdLife Australia believes the precautionary principle should be applied to this proposal and it should be rejected in its present form. Further research is required to develop a rigorous, sustainable model of wrack harvesting for this region that will not have significant impacts on EPBC-listed migratory and threatened species. References: Christie M. (2006) South Australian Wader Studies An Overview. Stilt 50: Christie M. & Jessop R. (2007) Shorebird Sites of the Limestone Coast South Australia. A Report by Friends of Shorebirds SE for the Shorebird Conservation Project/WWF Australia. Cuttriss, A., Maguire, G., Ehmke, G. and Weston, M. (2015) Breeding habitat selection in an obligate beach bird: a test of the food resource hypothesis. Marine and Freshwater Research, 2015, 66, 1 6. Maguire, G., Cullen, M. and Mead R. (2014) Managing the Hooded Plover in Victoria. A site by site assessment of threats and prioritisation of management investment on Parks Victoria managed land. Report to Parks Victoria - May 2014.

30 October PIRSA Fisheries and Aquaculture Attention Commercial Fishing GPO Box 1625 Adelaide SA

30 October PIRSA Fisheries and Aquaculture Attention Commercial Fishing GPO Box 1625 Adelaide SA 30 October 2015 PIRSA Fisheries and Aquaculture Attention Commercial Fishing GPO Box 1625 Adelaide SA 5001 annabel.jones@sa.gov.au Dear Ms Jones Birdlife Australia and the Australasian Wader Studies Group