Aquatics advocacy and current issues-Threats to our aquarium industry & the fish species we keep.

Report on CITES Technical Workshop on Marine ornamental Fishes 7 to 10 May 2024, Brisbane, Australia

The aim of this workshop was broadly to develop an understanding of the international trade of non-CITES listed marine ornamental fish, including:

· Identifying species in trade as well as nature and scale of this trade

· Existing data and its limitations when analysing this trade

· Discuss potential impacts of trade on species conservation

· Identify best practice management of marine ornamental fisheries

· Consider the livelihoods benefits of this trade

· Make recommendations of species that may be negatively impacted by international trade.

The agenda of animal liberation NGO's and their aligned academics is to steer the recommendations toward something that would irreparablely damage the trade with negative recommendations, allowing progression to CITES Appendix listing proposals. There method was to target the species in highest volume of trade, instead of their conservation status or vulnerability.

The first 2 days were largely about setting the scene with various presentations of background information and frameworks that could be used to assess sustainability. Dr Matthew Bond from OATA presented an industry recommended framework for assessing sustainability which builds on the good points of other models presented but based on industry experience. It is hoped that this can be used along with Productivity Susceptibility Assessments as a model to assess the sustainability of aquarium fish where required. It was great to see trade representatives from across the world supporting PIAA on our home turf, including Europe, USA, Asia Pacific and the other trade associations present including OATA, Pet Advocacy Network (USA), INOFEFISH, and the Sri Lankan Exporters Association.

Some key points from the first day include:

· There are wide discrepancies in species lists produced by different groups - 1040 to 2600, obviously there is work needed to collate a master list

· There is basic agreement that there needs to be an easy framework for assessing species that may require further assessment for conservation measures

· -trade considers assessment frameworks be based on sustainability not trade volume as suggested by some groups

· -The Secretariat highlights that listing species on CITEs is not going to happen at this workshop. This group makes recommendations to the Animals Committee

· There is a lot of questions/comments about mortality rate in the supply chain

· Input from trade reps TMC, Quality Marine and a couple other groups has been great to highlights gaps/weaknesses in arguments from opponents of the industry

· Productivity susceptibility assessment PSA is the system we are supporting as the tool of choice for assessing vulnerability

Productivity Susceptibility Assessment which looks at a variety of life cycle and other indicators to assess sustainability is still popular at the workshop with a number of parties indicating their interest in this, so we are hoping this is the model that will go forward with which is a significant advantage over what Biondo and Species 360 propose - they want to use trade volume as the trigger for assessment which would mean all the most popular species would be assessed and this runs the risk of these species being promoted for listing on CITES.

The third day consisted of break out groups to discuss issues such as species in trade, how to asses sustainability, best practice management and other points from terms of reference. Discussions were generally good and constructive with a number of outcomes and recommendations made by the groups for the workshop. We were concerned that the workshop might recommend a list of 200 – 300 species that may need further assessment for sustainability and that this list may be based on trade volumes ie include all the top traded species – industry was opposed to this as we wanted any shortlisting to be based on sustainability metrics to ensure any species that might warrant further investigation did not slip between the cracks.

Final day and conclusions

The final day was a review of observations and recommendations coming out of the workshop - a long and somewhat tedious process to arrive at text that was agreeable to all stakeholders.

Our team of trade representatives did well to ensure the concerns of the industry were taken into account and that a balanced outcome was attained. While the final workshop documents have not been released yet, the main outcomes were:

1. An agreed list of species in trade made up from all the lists submitted to the workshop which includes over 2000 species.

2. A number of recommendations of standardising nomenclature / scientific names used, data collection and collation to produce better species based data for analysis

3. Examples of Best Practices Management of marine ornamental fish, including the Hawaii and Queensland Fisheries, as well as areas for different research.

4) A recommendation that some species will require more research and study to determine vulnerability and impact of international trade before any further management measures are considered

These are all good things which will help industry going forward and that we support.

We had hoped that the workshop would result in a more defined process to identify species that may warrant further investigation as to their sustainability and whether conservation measures are needed. While there were a number of models presented to the workshop to assess vulnerability and while there seemed to be consensus that a Productivity Susceptibility Analysis -PSA- would be the best tool, we had hoped that a recommendation to review the current proposed PSA and other models with a view to developing an improved PSA that would be acceptable to all stakeholders. It is hoped that the Animals Committee will recommend that a Working Group be formed to develop this tool after they review this workshops findings.

In all, this was a great opportunity to promote our industry at CITES and I thank all the other trade associations and representatives for taking the time to be involved in the workshop. It was also somewhat of a black eye for the Animal lib NGO's who found themselves outnumbered and unable to secure their desired outcomes.

However, it should also be noted this is just the first step and we still need to see what comes out of the upcoming Animals Committee.

Over the last few months, we have seen some significant developments in the Aquatics space.

The Department of Climate Change, Energy, Environment & Water (DCCEEW) have begun consultation of the proposed changes to the Environment Protection, Biodiversity & Conservation Act (EPBC). These changes stem from the Samuels review and set to ensure that the act is:

• Delivering better environmental protection and laws that are nature positive.

• Speeding up decisions and making it easier for companies to do the right thing.

• Restoring integrity and trust to systems and environmental laws ensuring conservation is considered first and foremost in all decision making.

This all sounds great in theory, but the details are scant when the DCCEEW is asked what specifically this means for our aquarium fish? PIAA are participating in consultations with the department around these changes and have submitted a list of requests that we would like to see recognised and adopted in relation to how the EPBC act deals with aquarium fish.

The above changes to the act WILL set the regulatory framework to how the live import list manages ornamental fish imports and what is legal to keep into the future. This is particularly important as the “grey list” of fish (that is ornamental fish that a historically kept, bred and openly traded in Australia, but not approved for live import) is currently under review with the department working toward a utopian position that would see fish not on the live import list declared as prohibited and unable to be kept, bred or sold.

Given there are well over 450 species that fall into this grey list category. the stakes have never been higher for the future range and diversity of species our industry is able to sell into the future. PIAA have already spent over two and a half years participating in a risk assessment process for these grey list species. Encouragingly the results of these risk assessments appear to bode well for 90%+ of “grey” species assessed with a low environmental risk.

PIAA must continue to strongly advocate for our industry to ensure the right decisions are made and that no arbitrary measures are enacted that would take hundreds of species away from us. PIAA strongly supports adding low risk species to the live import list, as this will ensure proper biosecurity measures are in place and all but destroy the ivory trade market that exists in the illicit trade of ornamental fish. We cannot rest on our laurels, if we are not united and strong in our advocacy, we could easily lose all 450+ grey list species from the trade in Australia all together.

We have also been informed by Biosecurity Australia that they have commenced reviewing the import risk assessment (IRA) to consider approving the import of captive bred marine fish. This process however will also include a review into the effectiveness of current quarantine policy of ornamental fish coming into Australia. While to ultimate outcome of finally being allowed to legally import captive marine fish will be a huge positive for our industry, there is a risk we could see greater import and quarantine conditions applied to ALL ornamental fish imports into Australia. PIAA are in regular contact with Biosecurity Australia and will continue to represent the interests of the Australian aquarium industry to ensure that unnecessary trade restrictive policies are not implemented.

PIAA will always advocate for the least trade restrictive outcome to any changes to government, legislation, policy or regulations whilst ensuring our industry obligations to environmental protection are fulfilled.

We will keep you all updated over coming weeks and months of any developments. It’s never been more important to join PIAA, so if you aren’t already a member join now, as there will be no point complaining into the future if new regulations hurt our industry if you didn’t take the opportunity to join when we can still make a difference. The more businesses we represent, the greater our strength and voice is