Added 30/12/2012 to assert the exclusive rights of the copyright owner: Copying of these of these documents and computer programs is allowed for private study and research purposes only. Copying for other purposes is not allowed unless express permission is obtained from the copyright owner. An updated analysis for peer review and publication is currently in preparation.

Greenpeace pic of super trawler Margiris

Update on the Review of jack mackerel biomass – Dr Andrew Wadsley

Download …


… and, an alternative analysis technique:

… a MS Excel™ file containing the plotted data from the Neira 2011 Report extracted from the pdf formatted file and scaled to the units shown in the Figures. The zero egg abundance points appear to have been set to a value of 1 and the table was normalised to this. There is some discretization effect, and the values extracted will not be exactly those used in the Neira 2011 analysis, but are more accurate than the previously reported numbers which were digitized from a screen image.

There is no impact on the outcome of my review. Data for Figure 8b has also been included in the Excel file which leads to the same non-weighted P0 value (derived from an exponential trend fit) as calculated from the data from Figure 8a.

The implications of my review need to be spelled out:

• The calculation of spawning biomass given in the Neira 2011 report is wrong. Its results are false.

• This comes about, not from a differing interpretation of the fishery science, but because the reported NLS (non-linear least squares) curves are not derived from the data presented in the plots.

• The attached Excel file contains the data – anyone can check the results of the analysis using the exponential trend fit built into the program.

• Falsification in science is defined as publishing or reporting misleading facts associated with a study, research or experimentation.

• In this case, the falsification could simply be that relevant details and assumptions have been omitted or that the report was not peer reviewed and an error was made in the analysis.

• Why is this important?

o The 2012/2013 TAC for jack mackerel has been established using false data;

o SeaFish Tasmania has made a significant commercial investment based on this improperly determined TAC;

o Many people have relied on the science as the basis for establishing the jack mackerel TAC – they have been misled.

o In particular, the Minister for Fisheries has been misled by the AFMA’s reliance on this report – a science-based approach to setting catch levels cannot be based on a falsehood.

• The University of Tasmania through the office of the Board of Institute of Marine and Antarctic Studies (IMAS – under whose cover the report was issued) or the Office of the Vice Chancellor needs to investigate the issues raised here:

o The results of the Neira 2011 report have been demonstrated to be false;

o The Director of the Fisheries, Aquaculture and Coasts Centre of IMAS has publicly supported the results presented the report, which are now known to be false – public policy has, in part, been based on this support;

o Although the report was not necessarily intended to be used to determine the Commonwealth TAC for jack mackerel, the University had an obligation to ensure that the research was properly carried out, correctly analysed and the results reviewed before publication, independent of the use to which the report was put.

• The release of this report by IMAS has led to significant public disquiet. As Senator Colbeck said recently in the Senate: “It has whipped people into a frenzy. I have had people in my office who say that they cannot sleep at night because of the concerns that have been raised.” All this over bad science.

Yesterday: Catch determination is unreliable, unsafe:

• The Commonwealth Small Pelagic Fishery
Review of Estimates of Jack Mackerel Biomass

August 2012
Dr Andrew Wadsley
Principal, Australian Risk Audit


Estimates of 2002 jack mackerel spawning biomass given in the Neira 2011 Report, on which the increase in the 2012/2013 TAC is based, are inconsistent with the egg abundance-at-age data presented in the Report. Key parameters presented in Table 3.1 of the Report are not reproducible, casting serious doubt as to the reliability and validity of the analysis.

Reproducibility is the hallmark of good and reliable scientific analysis, all the more so in this case when the outcome of setting an unsafe TAC may seriously impact Australian jack mackerel stocks.

Because the calculation of these key parameters is not reproducible, the Total Allowable Catch Determination 2012/2013 set by the AFMA of 10,100 t for jack mackerel is based on unreliable statistical analysis and is unsafe.

Using correct parameters, the TAC of 10,100 t is 21.5% of the estimated spawning biomass of 47,000 t which exceeds the maximum 20% RBC for Tier 1 stock. Under the rules of the Small Pelagic Fish Harvest Strategy for Tier 2 stock the TAC should be no more than 3,500 t.


First published yesterday: Catch determination is unreliable, unsafe

Dr Andrew Wadsley has over 35 year’s experience in industry and academia. After completing an MSc and PhD in Mathematics (Warwick, UK) he joined Shell as a well-site petroleum engineer (Brunei) before moving to Shell’s head office (Netherlands) to work on a variety of enhanced oil recovery studies. He then worked for Intercomp Resource Development and Engineering (UK) as a Senior Reservoir Engineer and Lecturer (simulation and fluid properties), before becoming the Technology Manager for International Petroleum Engineering Consultants (UK). For the last twenty years Andrew has been working as an independent consultant and during this time he has established an international reputation for the quality of his consultancy and teaching services. He has personally developed a fully integrated surface / sub-surface suite of reservoir simulation software which he has used to great effect in his consultancy work and training programmes.

Andrew continues to work as an independent consultant, based in Hobart (Tasmania, Australia).


Kim Booth MP
Greens Primary Industries Spokesperson
Tuesday, 28 August 2012

The Tasmanian Greens tabled a motion in Parliament today detailing a briefing provided to them yesterday by Dr Andrew Wadsley, Principal at Australian Risk Audit, disputing key scientific findings used to justify the recent increase in the quota for fish species targeted by the FV Margiris.

Greens Primary Industries spokesperson Kim Booth MP said Dr Wadsley states that the Small Pelagic Fishery Total Allowable Catch Determination 2012 of 10,100 tonnes for jack mackerel east is based on unreliable statistical analysis and is unsafe.

Mr Booth called on federal Labor and Liberal to take note of Dr Wadsley’s report before they vote on Greens Senator Peter Whish-Wilson’s disallowance motion in the Senate on the 10th September 2012.

“The Tasmanian Greens have long been concerned that the data used by AFMA to justify the raise in TAC was out of date. The findings by Professor Andrew Wadsley would indicate that the data has been incorrectly assessed too.”

“Professor Wadsley used the data provided in the Neira report 2011 and ran it through the same methods that the original author used and yet he came out with a different figure than the author.”

“Professor Wadsley’s analysis concludes that the biomass of jack mackerel east should be calculated at 47,000 tonnes and not the 140,000 tonnes as recommended by the author of the original report as the ‘best estimate’ of current biomass.”

“If Professor Wadsley is correct, the TAC for jack mackerel east would be 21.5% of the Recommended Biological Catch which far exceeds the maximum 20% allowed for under AFMA’s tiered system.”

“The fact that Professor Wadsley, who has more than 37 years of expertise in numerical modelling and uncertainty analysis for the petroleum and steel industries, was unable to reproduce the same result as the author using the same data and methods means that the Neira report fails the basic test for a scientific report and it must be reviewed.”

“I am calling on AFMA to commission a review by IMAS and the University of Tasmania of the Neira 2011 report to ensure that they have not set a TAC that exceeds what is allowable under the Harvest Strategy for the Small Pelagic Fishery.”

“I am also calling on the Federal Labor and Liberal to vote with the disallowance motion tabled by Greens Senator Peter Whish-Wilson until we have certainty whether there is the fish in the sea that AFMA and Seafish Tasmania claim.”

The Age: Questions raised over super trawler’s quota:

THE federal Environment Minister, Tony Burke, is seeking urgent advice about whether he can try to stop the super trawler MV Margiris fishing off the Australian coast.

His announcement follows concern about the integrity of the process that boosted the allowable catch of the giant trawler, which is expected to operate off south-eastern Australia.

The key backer of the Margiris, the director of Seafish Tasmania, Gerry Geen, outlined plans to an advisory committee to raise the jack mackerel quota, before joining other members of the committee to support the proposal, according to confidential records obtained by the Herald.

Recreational fishing and conservation representatives have strenuously rejected proposals to double the quota, which they say are based on old and unreliable data.

Read more:

• Super Trawler Scared Into Slinking Into South Australia

As rumors swirl that the super trawler Margiris may be pulling into South Australian ports, the national Stop the Trawler alliance has urged the public there and their elected representatives to oppose the super trawler seeking sanctuary in South Australia’s ports.

“Public opposition has scared the super trawler Margiris out of Devonport and Fremantle. Now, this super trawler looks to be thrust upon the unsuspecting South Australian population,” said Rebecca Hubbard, Marine Coordinator of Environment Tasmania.

“In a National Day of Action in Adelaide two weeks ago, over forty people were involved a show of opposition to the super trawler, with a local old salt quoting history lessons from Iceland and urging the Australian Government to learn the lessons of other places around the world and not lead us into a situation that is sure to end badly,” said Peter Owen, Campaigns Manager, The Wilderness Society SA.

“The potential for this super trawler to kill protected dolphins and seals as bycatch has still not been adequately addressed, with the exclusion devices promoted by AFMA and Seafish unproven,” said Reece Turner, Campaigner, Greenpeace.

“Questions raised by environment and fishing groups over the science that has been used to back the introduction of this super trawler into Australian waters is now being scrutinized publicly and consolidates our concerns. This super trawler puts unprecedented risk on our fisheries and marine life and must be stopped,” said Tooni Mahto, Australian Marine Conservation Society.

“Over 76,000 people have signed the petition to the Federal Government, calling on them to stop the super trawler, and make Australian fishing sustainable. Now is the time for action,” concluded Ms Hubbard.


The Australian Fisheries Management Authority (AFMA) process for setting Seafish’s 18,000 ton quota of blue and jack mackerel and redbait is being investigated by the Commonwealth Ombudsman