October 17, 2007
At the recent Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), held in June 2007, the USA and Kenya proposed the listing of the entire family of sawfish, classified as Critically Endangered globally by the IUCN, on Appendix 1. This listing would have afforded this highly threatened family the greatest protection from international trade under the Convention. However, Australia proposed the successful listing of one species, freshwater sawfish, Pristis microdon, on Appendix II with an annotation to allow their export "for the exclusive purpose of allowing international trade in live animals to appropriate and acceptable aquaria for primarily conservation purposes". This was to allow the continued collection and trade of sawfish from one exporter in northern Australia, Cairns Marine Aquarium Fish.
Cairns Marine Aquarium Fish have now applied for Federal Government approval to export 6 freshwater sawfish to public aquaria in the USA and France, and have drafted a Non Detriment Finding for this trade, as per CITES requirements, to demonstrate that the removal of the these fish from the wild population is not detrimental to the survival of the species. In addition, as freshwater sawfish are listed on the Commonwealth Environment Protection and Biodiversity Conservation Act (EPBC) as a vulnerable species, the Government has drafted an Ambassador Agreement to outline the conditions under which the export will take place, in accordance with the EPBC Regulations. Both of these documents are now open for public comment and can be accessed at: http://www.environment.gov.au/biodiversity/trade-use/invitecomment/sawfish.html.
The freshwater sawfish is recognised as a Critically Endangered species worldwide. Pressure from the impacts of commercial and recreational fishing, coupled with habitat loss and degradation over most of its range, have so reduced global populations that the IUCN considers the species is facing an extremely high risk of extinction in the wild.
Furthermore, given the lack of abundance estimates and population modeling, there is simply not enough information on the status of Australian freshwater sawfish populations to permit the collection of individuals from wild populations with any confidence. The Government must be precautionary when the fate of such a vulnerable species is hanging in the balance.
Act by 24th October 2007
Send your comments to The Director, Wildlife Trade Assessments, Department of the Environment and Water Resources, GPO Box 787, Canberra ACT 2601 or by email to email@example.com.
Points to make regarding the draft Non Detriment Finding (NDF):
- The quota of juvenile freshwater sawfish to be collected from the Queensland Gulf of Carpentaria population is based on advice given to the Department of Environment and Water Resources that it is ' likely' this number can be taken from the wild each year without adversely impacting on the species. This quota is unsubstantiated in the NDF. There is no reference to the source material that provided the basis for this estimate, nor the science or population modeling that would enable such an estimate to be made with any confidence.
- It is widely acknowledged, both in the NDF, and in the wider literature that information on abundance, stock size, population trends and dynamics of P. microdon is scant. Accordingly, there is no quantification of the abundance of P. microdon in northern Australia, let alone the region of proposed collection, given in the NDF. Without adequate and representative sampling of P. microdon to determine the abundance, demographic structure and population trends of the species, it is premature and wholly speculative to hypothesise that the collection of any number of individuals will not have an impact on the wild population.
- The NDF makes continual reference to an impending priority management directive to the Queensland Department of Primary Industries and Fisheries, which will prohibit the retention of incidentally caught P. microdon in the Queensland Gulf of Carpentaria Inshore Finfish Fishery, when referring to the effectiveness of protection measures and regulation. This directive, however, will not come into effect for another two years. The purpose of the NDF is to demonstrate that the harvest of this species for international trade is not detrimental to the species, in the face of current management initiatives.
- The NDF purports that the trade of freshwater sawfish for display in public aquaria will benefit the species by contributing to a greater international awareness. There is, however, no evidence to suggest that the exhibition of an animal directly translates into conservation benefit for the species, nor is there any benefit to Australian populations as all fish are to be exported overseas.
Points to make regarding the Ambassador Agreement:
In order to ensure the strictest protection for an EPBC listed species, and to ensure the strictest implementation of the CITES Appendix II annotation resulting from an Australian proposal, the Ambassador agreement for freshwater sawfish must be strong.
The current agreement is not prescriptive enough to ensure the long term health and welfare of the animals.
- In order to guarantee an overseas public aquaria is ' appropriate and acceptable' as per the CITES Appendix II annotation, a specific set of conditions for the overseas export of freshwater sawfish must be developed to include details of pre-export requirements as well as minimum transport requirements, and most importantly, conditions that the recipient must show they can meet in terms of minimum display requirements, food supply and staffing expertise.
- Such conditions would be consistent with those that need to be met under other Ambassador Agreements for the export of native Australian wildlife such as koalas and macropods as viewed online at: http://www.environment.gov.au/biodiversity/trade-use/publications/export-conditions/index.html
- As the sawfish may be exported to more than one public aquarium, they may end up in different conditions. It is therefore essential that the final Ambassador Agreement for each aquarium is amended as needed to require specific actions or undertakings.