House of Representatives Committees

Joint Standing Committee on Treaties

TWO INTERNATIONAL AGREEMENTS ON TUNA 3rd Report
CONTENTS

CHAPTER 4

Australian Ports

Port Access

4.1       Under Article IV of the 1996 Subsidiary Agreement, Australia undertakes to permit licensed vessels to enter certain ports. Fishing and port access are considered important levers in international fisheries management and Australia can use those elements to influence the way fisheries are managed.1 DPIE told the Committee that:

The current policy of linking port and fishing access together provides a mechanism to allow port access by as many vessels as Japan has traditionally sought (up to 250 under the current agreement) while capturing for Australia a reasonable share of the benefit that accrues to Japanese vessels from port and fishing access.2

4.2       Under the current arrangements, bilateral subsidiary agreements allowing Japanese vessels, port and fishing access cannot be finalised until the international SBT quota is set by the Commission for the Conservation of Southern Bluefin Tuna. This provides a mechanism for maintaining leverage over fisheries management outcomes important to Australia.3

4.3       Japan has argued strongly for a separation of port access and the fishing access agreements.4 The Japanese would like to sever the linkage because the administrative burden is significant and the nexus with the southern bluefin tuna Commission.5 Some Japanese join the subsidiary agreements to utilise the port access for fuel, recreation and with no intention of fishing in the AFZ.6 Others seek the high quality fish in the AFZ.7 Japan charges a lower fee to its vessels wishing to utilise the port facilities and a higher fee to those wishing to fish in the AFZ as well.8

4.4       The benefits to the Japanese in having access to Australian ports include the facilities and services available, the commercial convenience of not having to travel to other more distant ports and there is single access fee.9 ABARE has estimated the value of access to Fremantle alone as $6.75 million to the Japanese industry.10

4.5       The Commonwealth Government believes that there is adequate scope within the current subsidiary agreement to provide port access to any Japanese long-line vessels seeking it.11 It was pointed out that the agreement provides access to a negotiable number of vessels with no administrative charges other than those applied by the ports.12 Despite requests, Japan has not provided information on the reasons for seeking separate port and fishing access.13

4.6       It was argued that:

Port access to Australia is not critical for Japan. They can use Bali, Singapore, NZ and Fiji. They can also service their vessels at sea through tankers etc., contracted by Japan Tuna Federation. Our view is that the current Australian strategy of using the bilaterals as a lever to get a CCSBT Agreement each year will eventually be counterproductive.14

4.7       ATBOA believes that the continuation of this link may lead to a net economic loss for Australia and is not beneficial to Australia's relationship with Japan.15

4.8       The point was made that Japan has 28 fishing agreements and, of these, the agreement with Australia is the only one that links port access and fishing rights.16 New Zealand has a policy of separate port access and a number of Japanese vessels used New Zealand ports during the boycott.17 There was a general call for the separation of port access and the indirect link with the establishment of quotas.

Legal implications of separate port access

4.9       The question arose during the Inquiry as to whether Australia could grant port access to an unlicensed foreign fishing vessel of one country but refuse to grant access to the unlicensed fishing vessel of another country. The Attorney-General's Department believes that as a matter of international law, Australia has the right to deny fishing vessels access to its port except vessels in distress.18 Further, Australia can place conditions on port access which could include membership of and compliance with the Convention on the Conservation of Southern Bluefin Tuna.19

4.10       The United Nations Convention on the Law Of the Sea has provisions which prevent Australia from discriminating between vessels from different countries in certain circumstances but these do not include access to ports.

4.11       There are also constraints on port access in the Fisheries Management Act 1991 which requires vessels to have a license, or for Australia to have an agreement with their country allowing port access.20 Section 94 of the Act allows for the granting of port permits to unlicensed foreign fishing vessels for a specific purpose such as:

if it was appropriate to do so for the purpose of monitoring movement of foreign fishing boats.21

4.12       UNCLOS requires Australia to give other countries access to unexploited marine resources. It was also noted that:

The obligation to allow other states access to the surplus is framed there, in terms of taking into account all relevant factors. Two of those relevant factors are the significance of the living resources of the area to the economy of the coastal state - namely, Australia - and its other national interests. If we decide that it is not in our national interest to let other countries into our zone, then we do not let them. There is no way that we can be forced to.22

4.13       Further, DFAT pointed out that the dispute settlement provisions of UNCLOS include:

article 297 says that the worst that can actually happen to us if we would be forced, not into arbitration, merely into conciliation. The provision goes on to say that in no case shall the conciliation commission substitute its discretion for that of the coastal state in such matters ... if we do not want to let others into our zone, we cannot be forced to.23

4.14       The other issue is whether, as a matter of policy, Australia would wish to discriminate between flag States in allowing port access by unlicensed foreign fishing vessels.24 The Committee does not consider this to be an insurmountable problem if the condition of entry is the membership of the Flag State to the Convention for the Conservation of the Southern Bluefin Tuna.

4.15       The Committee believes that Australia is now in the position where it needs to actively seek business for its ports and can no longer rely purely on the proximity to the southern fishing grounds.

4.16       The Western Australian Government pointed out that the port of Fremantle provides attractions other than the fishing operations.25 When the SBT reach Western Australia they dive and disappear into deeper water.26 This is when vessels visit the port of Fremantle.27 Vessels visiting Fremantle have usually been at sea for three months and require re-provisioning, repairs, rest and recreation for the crew and crew change overs.28 The value of these visits to Fremantle was estimated to be $21 million including fuel.29

4.17       If Japanese vessels ceased coming to Fremantle then a number of businesses would reduce their staff.30 The supplies provided to tuna vessels on average were about $25 000 while that supplied to cargo vessels was in the order of $2 000.31

4.18       Concern was raised in relation to the sales tax levied if the ship does not visit another port between two stops in Australia. The comment was made that this involved a considerable expense and ensures that vessels are more inclined to go to Indonesia.32 It was also pointed out that Japanese vessels employ an increasing number of Indonesian crew which creates an additional attraction for vessels to use Indonesian ports rather than to visit our ports.33

4.19       Japanese long-line vessels use four main ports in the southern oceans New Zealand, Hobart, Fremantle and South Africa. 34 Cape Town is aggressively seeking business from long-line vessels and has constructed a multi-million dollar facility to store fish at minus 60 degrees as a transhipping facility.35 The Japanese fleet uses Cape Town as an operations base and injects millions of dollars into the local community.36

4.20       The recent boycott of Australian ports is a clear indication that the Japanese will make alternative arrangement if agreements with the Australian authorities break down.37 During the boycott of Australian ports Indonesia constructed the necessary facilities thereby weakening Australia's leverage through port access. The Japanese also used a supply tanker to refuel on the high seas during the boycott.38

4.21       It was suggested to the Committee that the boycott was called by the fisheries association and not the vessel owners and that the reason they have returned to the negotiating table is pressure from the boat owners.39 The additional cost of going to Bali is $100 000 and the cost of the tanker was $50 000 to $100 000.40 The cost staying in port during the season is about $10 000 per day.41

4.22       The Marine Board of Hobart also believes that port access should be separated from fishing rights as this would enable local businesses to plan for the longer term.42 The estimated value of visits to Hobart was $15 million annually.43 They also suggest that this would enable the Port of Hobart and Tasmania to compete freely in the international market place.44 The point was raised that it may not be in the best interest of Australia because not all other countries with long-line capacity are as economically well off as Japan.45

4.23       The Fremantle Port Authority sees the quota issue as having a negative impact on the number of vessels visiting Fremantle.46 The Maritime Agencies of Tasmania believes that the separation of the two would have potential economic benefits for Australia.47 It was suggested that this is purely a commercial decision as it would take an extra 12 days to go to ports in Indonesia. 48

4.24       Businesses in Fremantle and Hobart emphasised that the Japanese spend substantial amounts of money in Australia, they are good payers and there would be significant employment reductions if the Japanese vessels ceased to call into these ports. These companies provided services including ship repair, food services, providores, health and medical services. The estimated value of Japanese long-line vessel visits to Australian ports was estimated to be $46-50 million.49

4.25       However, DPIE believes that the net benefits for Australia are significantly less than the total expenditure when costs are taken into account.50

4.26       One of the difficulties in separating port access and the subsidiary agreements is the increased capacity of those vessels using the nearest port to spend the additional time fishing inside and adjacent to the EEZ. The Western Australian Government raised the point that to deal with the separation of port access and fishing outside the EEZ there may be a need to introduce controls over the take of species other than those already under quota.51

4.27       Port access is not given to unlicensed fishing vessels.52 The concern was expressed that if Australia were to move to a policy where unlicensed vessels were permitted to use our ports then under the law of the sea Australia could be required to allow access to vessels from other countries.53 DPIE pointed out that Australia:

would be under considerable pressure to provide those same privileges to fleets from other countries who are fishing in an unregulated and increasingly unconstrained - in some cases - way on the very resource on which we have a $100 million industry dependent.54

4.28       The Committee also notes that under the Commission for the Conservation of Southern Bluefin Tuna Australia is legally obliged not to facilitate the operations of countries that are not party to the Convention. Further, under the 1923 Maritime Ports Convention countries have the right to control access to their ports except for a vessel in distress but under UNCLOS, vessels from foreign countries should not be treated in a discriminatory way.56

4.29       The point was made that if the fishery collapses because of uncontrolled fishing in the region then there will be no future fishing fleet to use our ports.57 The example was given of the collapse of the cod stock on the Grand Banks off Canada. Canada had an open access policy and trawlers overfished the area outside the Canadian zone.58 Open access which would allow fishermen from a number of countries may lead to the expansion of fishing activity adjacent to the AFZ and potentially undermine the viability of Australian fisheries.

4.30       DPIE emphasised that in relation to an open access arrangement:

While this could in the short term provide for more stable expenditure patterns in Australian ports, such benefits need to be weighted against broader impacts on the sustainability of fishery resources on which our industry (and foreign fleets) depend and the viability of valuable Australia industry sectors which exploit those resources such as the domestic SBT fishery.59

4.31       The Japanese activity in the EEZ will decline as the Australian domestic industry expands. The Committee believes that the separation of port and fishing access will be inevitable if Australia is going to maintain the economic benefits that these visits provide. The Committee believes that the continuation of the current arrangements may discourage Japanese vessels from visiting our ports.

4.32       Further, with the establishment of the IOTC there is now an alternative mechanism for the Japanese to seek the management of SBT stocks. The point was made that Australia would need to maintain the ability to withhold fishing and port access sanctions in the absence of international management measures being agreed within the CCSBT. 60

Recommendation 13

The Joint Standing Committee on Treaties recommends the separation of port access from the subsidiary agreement but making port access subject to the continuation of Japan's membership of the Convention for the Conservation of Southern Bluefin Tuna and participation in the Commission for the Conservation of Southern Bluefin Tuna.

4.33       In addition there would need to be a number of requirements that would relate to fishing in the EEZ and vessels entering our ports to maintain the integrity of our management arrangements. These would include having satellite-based vessel monitoring and the right to inspect.61

Port infrastructure

4.34       It was suggested to the Committee that a number of steps could be taken to improve the quality of service to encourage Japanese vessels to use Australian ports. These ranged from small matters such as not berthing the vessels in areas which require access through three padlocked gates to get to the local business centre.62 The time taken to unload containers in Fremantle makes it not cost effective and would need to be improved.

4.35       It was suggested that the establishment of ship repair facilities could provide significant economic benefits.64 Facilities have already been established in Cape Town, Canary Islands and Peru.65 A number of vessels requesting port access fish on the high seas, although some would also be those currently fishing in the EEZ.66 The Maritime Agencies of Tasmania believes that there is potential for a ship repair industry and transhipment of catch where ships would remain in Hobart while the crews flew home.67

Australian port communities

4.36       Japanese vessels provide a major source of economic activity in Fremantle, Hobart and to a lesser extent in Sydney and Brisbane.68 There are a number of businesses in Hobart and Fremantle which have a substantial proportion of their business dependent on Japanese vessels.69

4.37       Witnesses to this inquiry from businesses all agreed that the Japanese are excellent payers. Ship Agencies Australia Pty Ltd has in the past managed ships from other countries and very few Australian companies benefited from their visits while the point was made that the Japanese appear to have very few restrictions on their spending.70

4.38       Ships are now usually in port for 12 to 24 hours whereas previously they would be in port for three or four days.71 Further, modern vessels need a lot less maintenance than older ones.72 This would indicate that the extent of the services provided previously on a per vessel basis may be significantly reduced over time. Further, in Tasmania and foreign ports a major fishing industry association has acquired social clubs and restaurants where their vessels frequent73 which may impact on the benefits to the local businesses.

4.39       The annual expenditure in Hobart was estimated to be $8-12 million annually and $50 - 70 million in Australia.74 This expenditure has an estimated multiplier effect of about five which means the economic benefit to Australia could be $350 million exclusive of the access fee and the Joint Venture arrangements.75

4.40       In Fremantle, the services utilised include pilotage and mooring, fresh water, and a berth hire charge which is about $2 000 per vessel which is $370 000 in total including research and training vessels.76 Revenue for the port of Fremantle is in excess of $20 million.77 In Western Australia the multiplier effect is thought to be roughly two to one.78 Other estimates were $46 million for Australia of which 50 per cent was for Western Australia.79

4.41       The 1993 ABARE survey estimated the net economic benefit of port access to be 10 to 30 per cent of gross expenditure giving a direct benefit of $3 to $10 million annually.80 DPIE believes that a multiplier effect of 2 to 2.5 applies to the net benefits only and not the total expenditure. 81 It was also pointed out that the estimates of aggregate in port expenditure provided to the Committee in some submissions does not appear to discriminate between bilateral vessels and Joint Venture vessels.82

4.42       Australia probably benefits more from their use of the ports than the Japanese do even though they save money on not having to go to Bali to bunker or to have a mother ship in the fishing grounds.83 Another benefit is that the resources used to provide services for the Japanese vessels such as bunkering oil and providoring can be used by others.84

4.43       Dr Martin believes that if Japanese vessels ceased using Australian ports, this would have an adverse impact on the health of the fishing boat crews and compromise the existing 24 hour priority/emergency medical services currently available to all merchant shipping.85

4.44       The Australian Maritime Officers Union (AMOU) supports the continuation of the Agreement because it represents about 30 per cent of the total pilotage movements through the port of Hobart and the loss of this business would impact on employment levels throughout southern Tasmania.86

4.45       The rural community in Tasmania grow vegetables such as Chinese cabbage for Japanese vessels and there is a significant effect on the State rural sector.87 A number of local companies tailor their services for the particular needs of the Japanese and Indonesian crews.88 Some businesses have used the Japanese business as a base and have also been able to offer these services to the Australian industry.89

4.46       A number of Japanese vessels will be in port for two or three weeks then will come back two or three months later.90 When there are 10 to 15 long-line fishing vessels in Hobart there are also a number of visitors from Japan associated with these vessels. 91 In addition, the crews from Japanese long-lining vessels spend a considerable amount of money on recreational activities such as at the casino.92

4.47       There is some potential to increase Australian business with the Japanese. The Committee was given the example of the possible sale of 2 000 tonnes of mackerel as bait for the Japanese. It was suggested that there was a huge market for bait if a suitable product could be developed.93 Purdon and Featherstone have orders for 300 tonnes for long-line bait for the 1996 season.94

4.48       Mr Goadby emphasised that the bait stocks 95 must be evaluated in terms of the sustainability of the stocks. The point was made that one of the factors determining whether the SBT came near the Tasmania shore was the presence of bait. If the potential bait industry in Tasmania harvests the bait from waters which may have been the feeding grounds for the SBT then the fish may not come close to land.

4.49       It was also suggested that there is enormous potential for the processing and export of bycatch which is no longer kept under the current agreement.96

4.50       Although a large number of Australian fishing vessels use the port of Hobart, piloting services are only needed for vessels over 35 metres. The Committee was told that the economic benefits to the local ports were not as great for Australian vessels because they are smaller hence do not use pilots, pay less in port fees and do not need as many provisions. 97

4.51       The Australian Maritime Officers Union has not found the local fishery to be very labour intensive in the port of Hobart. However, the Committee is mindful that Australian vessels are dispersed amongst a larger number of ports. Should the domestic fishing industry expand to utilise the fish currently being caught by the Japanese such as those adjacent to the Tasmanian coast, there would be a significant economic benefit to Tasmania. In Western Australia, the development of a domestic industry may favour smaller ports such as Esperance and Albany rather than the port of Fremantle.98

4.52       There were a number of arguments presented which outlined the economic benefits of expanding the local fishing industry rather than relying on the benefits from port visits by Japanese vessels:

4.53       Because the Japanese do not land their catch in Australia there are no ongoing benefits compared to that which could be derived from Australian vessels.100

Transhipment

4.54       On one hand the Committee was told that the Japanese had not expressed an interest in transhipping fish via Australia, however, Tropical Traders believes that the Japanese are very keen to tranship their catch from the tuna vessel to a reefer while in port.101 The Japanese currently tranship fish in the ports of Suva and Noumea.102 Cape Town now has a multi-million dollar transhipping facility which stores fish at minus 60 degrees.103 The benefit to the Japanese is that they can sell their catch to the reefer providing an immediate cash flow.104

4.55       It was suggested that the fish could be transferred to a larger vessel or transferred to a refrigerated container and transported to Japan. The advantage of bringing the mother ship into port would increase Australia's ability to monitor fish catches but transfers at sea could not be controlled.105

4.56       No-one has been prepared to try transhipping from Australian ports.106 Transhipment from Fremantle would have a huge potential for the local industry.107 The Committee was told that transhipment would create more employment in Fremantle and more frequent visits of vessels.108

4.57       Ship Agencies Australia Pty Ltd recently shipped albacore to Japan for some Japanese vessels.109 This was acceptable for albacore which is a low-value product but would not be acceptable for SBT or bigeye.110 Hobart already has a cold store with a capacity of 3000 pallets of frozen cargo.111

4.58       The Marine Board of Hobart believes that if transhipment was undertaken, long-line vessels would utilise docking facilities which would benefit the local economy.112 Hobart has the requisite infrastructure to service these vessels.113 A further upgrade of Hobart's dry dock facilities would attract vessels from other countries as Hobart has already established a research vessel base.114

4.59       There may be a potential environmental impact of transhipping because less fishing time will be lost if ships can be serviced at the nearest convenient port. Although this will not impact on the quantity of SBT caught within the EEZ, the Committee is mindful that other tuna stocks do not have quota levels. Transhipment could significantly increase the time available for fishing adjacent to the EEZ which may have a negative impact on fish stocks.

4.60       There is no legal barrier to the implementation of transhipment under the current arrangements except for transhipment at sea which is not permitted for obvious compliance and enforcement reasons.115 The major problem is that facilities are required to ensure the product is maintained at a super low temperature of minus 60 degrees.

4.61       A number of problems would arise if the intention was to unload the product to the domestic market, including displacing other products, lower prices for Australian fishermen and issues under the Customs (Prohibited Imports) Regulations. 116 Customs regulations may preclude the landing of catch without specific ministerial approval.117

Footnotes

[1] Harwood, Transcript, 10 October 1996, p. 423

[2] Department of Primary Industries and Energy, Supplementary Submission No. 33.1 ,

[3] Ibid, p. S 408

[4] Department of Primary Industries and Energy, Submission No. 33, p. S 175

[5] Harwood, Transcript, 10 October 1996, p. 393

[6] Romaro, Transcript, 26 September 1996, p. 313

[6] Ibid, p. 313

[8] Harwood, Transcript, 10 October 1996, p. 392

[9] Ibid, p. 392

[10] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 408

[11] Department of Primary Industries and Energy, Submission No. 33, p. S 176

[12] Ibid, p. S 176

[13] Ibid, p. S 176

[14] Tuna Boat Owners Association of Australia Inc, Submission No. 44, p. S 326

[15] Jeffriess, Transcript, 27 September 1996, p. 348

[16] Pratt, Transcript, 5 September 1996, p. 122

[17] Maritime Agencies of Tasmania, Submission No. 27, p. S 134

[18] Attorney-General's Department, Submission No. 26.2, p. S 379

[19] Ibid, p. S 379

[20] Campbell, Transcript, 10 October 1996, p. 395

[21] Ibid, p. 395

[22] Serdy, Transcript, 29 August 1996, p. 71

[23] Ibid, p. 71

[24] Attorney-General's Department, Supplementary Submission No. 26.2, p. S 380

[25] Millington, Transcript, 26 September 1996, p. 244

[26] Atkinson, Transcript, 26 September 1996, p. 260

[27] Ibid, p. 260

[28] Tropical Traders, Submission No. 13, p. S 51

[29] Ibid, p. S 53

[30] Neel, Transcript, 26 September 1996, p. 324-325;

[31] Paino, Transcript, 26 September 1996, p. 343

[32] Ibid, p. 338

[33] Martin, Transcript, 26 September 1996, p. 341

[34] Atkinson, Transcript, 26 September 1996, p. 260

[35] Rowley, Transcript, 16 September 1996, p. 226

[36] Fremantle Port Authority, Submission No. 12, p. S 43

[37] Purdon & Featherstone, Submission No. 17, p. S 89

[38] Pratt, Transcript, 5 September 1996, p. 129

[39] Romaro, Transcript, 26 September 1996, p. 317

[40] Ibid, p. 318

[41] Neel, Transcript, 26 September 1996, p. 325

[42] Thompson, Transcript, 5 September 1996, p. 95

[43] Marine Board of Hobart, Submission No. 23, p. S 106

[44] Thompson, Transcript, 5 September 1996, p. 95

[45] Romaro, Transcript, 26 September 1996, p. 308

[46] Atkinson, Transcript, 26 September 1996, p. 258

[47] Pratt, Transcript, 5 September 1996, p. 134

[48] Morrison, Transcript, 5 September 1996, p. 140

[49] Ship Agencies Australia Pty Ltd, Submission No. 11, p. S 39

[50] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 417

[51] Millington, Transcript, 26 September 1996, p. 239

[52] Harwood, Transcript, 10 October 1996, p. 393

[53] Ibid, p. 393

[54] Harwood, Transcript, 10 October 1996, p. 393

[55] Ibid, p. 393

[56] Campbell, Transcript, 10 October 1996, p. 394

[57] Harwood, Transcript, 10 October 1996, p. 393

[58] Ibid, p. 399

[59] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 409

[60] Ibid, p. S 410

[61] Harwood, Transcript, 10 October 1996, p. 394

[62] Phillips, Transcript, 26 September 1996, p. 338

[63] Martin, Transcript, 26 September 1996, p. 342

[64] Maritime Agencies of Tasmania, Submission No. 27, p. S 137

[65] Ibid, p. S 138

[66] Harwood, Transcript, 29 August 1996, p. 15

[67] Pratt, Transcript, 5 September 1996, p. 124

[68] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 407

[69] Woods and Cockerill, Submission No. 1, p. S 2; Aqua Scuba Diving Services, Submission No. 2, p. S 4; Reads Electric Co, Submission No. 4, p. S 9; Abernethy Owens and Associates, Submission No. 8, p. S 26; Franmarine Underwater Services Pty Ltd, Submission No. 16, p. S 75; Key Engineering, Submission No. 24, p. S 108; Sabre Marine & General Engineers, Submission No. 34, p. S 206; Neel, Transcript, 26 September 1996, p. 322; Morrison, Transcript, 5 September 1996, p. 137; Kruimink, Transcript, 5 September 1996, p. 175-176; MacMillan, Transcript, 5 September 1996, p. 176; MacMillan, Transcript, 5 September 1996, p. 176;

[70] Ship Agencies Australia Pty Ltd, Submission No. 11, p. S 40

[71] Martin, Transcript, 26 September 1996, p. 336

[72] Phillips, Transcript, 26 September 1996, p. 337, 339

[73] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 410

[74] Pratt, Transcript, 5 September 1996, p. 122; Maritime Agencies of Tasmania, Submission No. 27, p. S 132

[75] Pratt, Transcript, 5 September 1996, p. 122-123

[76] Atkinson, Transcript, 26 September 1996, p. 259

[77] Atkinson, Transcript, 26 September 1996, p. 259

[78] Millington, Transcript, 26 September 1996, p. 246; Atkinson, Transcript, 26 September 1996, p. 264

[79] Romaro, Transcript, 26 September 1996, p. 310

[80] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 407

[81] Ibid, p. S 407-408

[82] Ibid, p. S 408

[83] Romaro, Transcript, 26 September 1996, p. 312

[84] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 407

[85] Westport Medical Centre, Submission No. 40, p. S 237, 240

[86] Morgan, Transcript, 5 September 1996, p. 103: Australian Maritime Officers Union, Submission No. 9, p. S 28-29

[87] Pratt, Transcript, 5 September 1996, p. 130; Morrison, Transcript, 5 September 1996, p. 136

[88] Australian Maritime Officers Union, Submission No. 9, p. S 28

[89] Ship Agencies Australia Pty Ltd, Submission No. 11, p. S 37

[90] Morgan, Transcript, 5 September 1996, p. 108

[91] Thompson, Transcript, 5 September 1996, p. 95

[92] Morgan, Transcript, 5 September 1996, p., 105

[93] Romaro, Transcript, 26 September 1996, p. 318; Morrison, Transcript, 5 September 1996, p. 139

[94] Purdon & Featherstone, Submission No. 17, p. S 90

[95] Goadby, Submission No. 7, p. S 24

[96] Morrison, Transcript, 5 September 1996, p. 142

[97] Pratt, Transcript, 5 September 1996, p. 125

[98] Atkinson, Transcript, 26 September 1996, p. 261

[99] Lister, Transcript, 5 September 1996, p. 145

[100] Ibid, p. 145

[101] Harwood, Transcript, 29 August 1996, p. 16; Tropical Traders, Submission No. 13, p. S 54

[102] Thompson, Transcript, 5 September 1996, p. 94

[103] Rowley, Transcript, 16 September 1996, p. 226

[104] Tropical Traders, Submission No. 13, p. S 55

[105] Atkinson, Transcript, 26 September 1996, p. 264

[106] Pratt, Transcript, 5 September 1996, p. 124

[107] Atkinson, Transcript, 26 September 1996, p. 262

[108] Neel, Transcript, 26 September 1996, p. 323

[109] Romaro, Transcript, 26 September 1996, p. 312

[110] Ibid, p. 312

[111] Thompson, Transcript, 5 September 1996, p. 97

[112] Ibid, p. 94

[113] Thompson, Transcript, 5 September 1996, p. 94

[114] Ibid, p. 100

[115] Harwood, Transcript, 10 October 1996, p. 416

[116] Exel, Transcript, 10 October 1996, p. 417; Rohan, Transcript, 10 October 1996, p. 417

[117] Department of Primary Industries and Energy, Supplementary Submission No. 33.1, p. S 412

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