ornamental fish policy working group - ksakoi.com · joint submission to the ornamental fish policy...

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Joint submission to the Ornamental Fish Policy Working Group by The Australian Koi Association Inc.,

The Koi Society of Australia Inc., The Koi Society of Western Australia Inc.

Joint submission to the

Ornamental Fish Policy Working GroupDepartment of Agriculture, Fisheries and Forestry

by

The Australian Koi Association Inc. The Koi Society of Australia Inc.The Koi Society of Western Australia Inc.

March 2006

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10 March 2006

Mr Richard TilzeyOrnamental Fish Working GroupBureau of Rural SciencesGPO Box 858CANBERRA ACT 2601

Dear Mr Tilzey,

We are pleased to make this submission to the Ornamental Fish Working Group on behalf of the more than 2,000 koi enthusiasts that our organisations represent.

We recognise that the privilege of breeding and keeping koi in Australia carries with it a special responsibility to protect our aquatic environment. We believe that our Society’s have embraced these responsibilities and constantly demonstrate a responsible attitude to koi keeping.

In addition, koi keeping has become a very valuable hobby in Australia. It has a long history, is followed by tens of thousands of Australians and a large and valuable industry has developed to support it. We believe that banning the breeding and keeping of koi or the enforced licensing of amateur hobbyists is undesirable and impractical and indeed likely to force the hobby ‘underground’.

The most effective method of managing both the hobby and commercial aspects of koi will be to consider the status of koi in Australia separately from other ornamental fi sh, and for organisations such as ours and government to work together and develop a self regulatory regime of management.

This submission provides information on the status of koi keeping in Australia, comments on the Consultation Draft and our recommendations for future action.

Paul Miglionico Eddie EdwinsPresident President The Australian Koi Association Inc The Koi Society of Australia Inc Bill PasseyPresidentThe Koi Society of Western Australia Inc

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ContentsExecutive Summary ........................................................................................ 4Introduction ................................................................................................... 5Distinguishing between koi and other strains of carp ................................... 6Koi keeping in Australia .................................................................................. 7Comments on the proposed recommendations of the Consultation Draft 14A framework for self-regulation .................................................................... 16 Recommendations for future management ................................................. 18 Appendix 1 Code of Ethics ........................................................................ 20Appendix 2 Directory of koi organisations ................................................ 21Appendix 3 Environmental statement ....................................................... 25Appendix 4 International letters of support ............................................... 28

Enclosed:DVD — The Koi Keepers’ SeriesDVD — Hiroshima Dreaming

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Executive summaryThis is a Joint submission to the Ornamental Fish Policy Working Group of the Department of Agriculture, Fisheries and Forestry by The Australian Koi Association Inc., The Koi Society of Australia Inc. and The Koi Society of Western Australia Inc. Together these organisations represent over 2,000 members who keep the ornamental koi strain of Cyprinus carpio as a hobby.

Koi keeping has become a popular and well established hobby enjoyed by thousands of Australians, supported by a large industry of breeders, suppliers and pond builders.

Carp have been declared noxious in Victoria, Queensland, the Northern Territory, Tasmania and South Australia. In NSW and WA it is legal to for hobbyists to keep koi in aquariums and garden ponds. In states where koi have been banned some aquarists have gone ‘underground’ and operate outside of the law.

This submission provides information on the differences between koi and other strains of carp, the history and status of koi keeping as a hobby in Australia, koi keeping organisations, the commercial koi industry and the responses of hobbyists to issues raised in the Consultation Draft.

This submission argues that the Consultation Draft’s broad brush approach and a lack of understanding of the koi strain and the hobby/commercial industry around it is inappropriate and that a national listing of the koi strain as a noxious species is undesirable, impractical and unenforceable. The submission further argues that the koi strain of carp should be removed to the grey list with a view to Australia-wide classifi cation similar to the ‘Class 3’ classifi cation in NSW which allows for koi keeping under controlled and self regulated conditions.

The submission comments on the proposed recommendations of the Consultation Draft, suggests a framework for self regulation and makes seven recommendations for future management:

1. The status of koi should be considered separately from other ornamental fi sh

2. The koi strain of carp should be removed from the proposed noxious fi sh list and placed in the grey list

3. Consideration should be given to a separate classifi cation for koi

4. The keeping of koi should be legalised throughout Australia

5. The Federal and state governments should work with leading koi organisations to develop effective self regulation

6. Regulation of koi keeping should focus on the role of koi organisations

7. Communications with koi hobbyists in Australia should be improved.

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IntroductionKoi keeping in Australia is a popular and well established hobby, embraced by a wide range of Australian citizens representing our cultural and socio-economic diversity. The hobby has a long history, albeit a rather confused one owing to the various regulations adopted by each state which range from full approval of the hobby to total bans on ownership and breeding.

Various forms of carp were introduced to Australia as early as the nineteenth century. It was not until the 1960s when the Booralla strain of European carp was released into Victorian waterways and hybridized with earlier, more benign introductions to create a highly invasive strain, that the status of carp in Australia attracted more attention.

Carp have since been declared noxious in Victoria, Queensland, Tasmania, the Northern Territory and South Australia and consequently the keeping of koi has also become illegal in those states.

The national regulatory situation is now very confused: management regimes range from total bans in some states to full (but regulated) sanctioning of the hobby which includes the public display of ornamental koi in civic and commercial ponds.

Despite the confusion, the popularity of koi as a highly prized ornamental fi sh has increased, the hobby of koi keeping and the organisations of amateur hobbyists has grown, and the multi-million dollar commercial industry of breeders and suppliers required to support those hobbyists is now well established. In states where koi have been banned aquarists have gone ‘underground’ and operate not only outside of the law, but also outside of the reach and infl uence of organised koi clubs.

We are concerned that despite the widespread popularity of koi in Australia, the Consultation Draft shows a broad brush approach and a lack of understanding of the species and the hobby/commercial industry around it. Consistent national legislation and regulation is needed, as is effective self regulation by the koi keeping fraternity and the associated koi industry. This submission describes the current state of koi keeping in Australia and makes recommendations for future management.

Our key and overriding recommendations are removal of the koi strain of carp from the proposed noxious fi sh list and legalisation of koi keeping on a state by state basis within a self regulated regime of environmentally-safe breeding and keeping.

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Distinguishing between koi and other strains of carpThe species Cyprinus carpio includes a number of strains of carp, such as koi and the common European carp. Worldwide, variants of the species are used for agriculture, recreational angling and one ornamental variant, koi, is collected by aquarists.

Cyprinus carpio is currently included in the Proposed Noxious Fish list within the Consultation Draft, (although the common name for the popular ‘koi’ strain is not mentioned).

Koi are a highly ornamental variant of Cyprinus carpio, refi ned through centuries of selective breeding to achieve renowned beauty. Their aesthetic appeal is judged by distinctive, white, red, blue and metallic colours, colour patterns, body shape and size. They are kept internationally for their aesthetic qualities, collector value, as pets and as a recreational activity. Due to their high value they are always kept in purpose built ponds, many incorporating sophisticated electronic security measures to prevent theft.

Koi strains are understood to have originated in the Black, Azov, Caspian and Aral Seas. The fi rst coloured variants seem to have been fi rst noted in China between AD 700 and AD 1000. They were recorded in Japan around AD 1500. Intensive breeding and refi nement of koi for colour variations seems to have started in Japan around AD 1800. Many further refi nements of the more than 120 distinctly different variations in colour, scale and skin were developed as recently as the 20th century.

The development of koi in isolation over the centuries from a small parent stock has resulted in low genetic variability within modern stock and distinct variation from the wild and feral carp populations in other parts of the world.

Key differences between koi and wild or feral carp are:

• The genetic differences mentioned above.• Highly distinctive appearance.• They are kept in controlled and closed environments.• They are not as invasive as other strains of carp.

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Koi keeping in AustraliaKoi were introduced to the United States of America in 1938, the state of Hawaii in 1947, Canada in 1949 and Brazil in 1953. The fi rst commercial imports to the United Kingdom occurred in 1966.

The history of carp in Australia is unclear, and the history of the koi strain in particular is also unclear, although its history in this country is quite recent. Carp, Cyprinus carpio, were introduced into Australia somewhere between the 1850s and 1870s. Goldfi sh, Carassius auratus, were introduced around the same time. These were once thought to be Crucian carp, a related but different species (Carassius carassius), but it is now thought that there are no Crucian carp in Australia. Carp and goldfi sh are of the same family and can interbreed.

Several strains of European carp were identifi ed in Australia in the 19th and 20th century. These included the ‘Singapore strain’, ‘Prospect strain’ and the ‘Yanco strain’. The latter was orange in colour and looked very much like koi. These strains do not appear to have been especially invasive or to have caused any problems, but the ‘Boolarra strain’ released into public waterways in Victoria in the 1960s certainly was strongly invasive. It is thought that it mixed with a previously established and relatively benign ‘Singapore strain’ to create a very vigorous and invasive strain, and now known as ‘European carp’ it has increased dramatically in numbers throughout inland waterways. European carp are found in every state of Australia except the Northern Territory.

The highly ornamental koi strain is thought to have been fi rst introduced into Australia in the early nineteen sixties, although the website of the NSW Department of Primary Industries refers to ‘An ornamental strain…released near Sydney around 1850-60, and a Singaporean koi strain…accidentally released in the Murrumbidgee area in 1876’.

It is believed that the fi rst koi were brought into Australia by a senior executive of Woolworths who wanted to keep them for his own hobby purposes. Other importations presumably occurred but importation of carp has since been banned.

Current status of koi keeping in AustraliaKoi keeping is a highly popular and well-organised hobby in Australia. The actual number of koi keepers is not known but even just in the organisations that prepared this submission, memberships are high and growing steadily. The Australian Koi Association has 435 members, the Koi Society of Western Australia has over 160 members and the Koi Society of Australia has 1,624 members and numerous branches including Cumberland Branch, Macarthur Branch, Newcastle Branch, Illawarra Branch, Central Coast Branch, Northern Branch and Southern NSW Branch. Junior members are an

important part of koi clubs.

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There is also a fl ourishing commercial sector which specialises in the design and construction of koi ponds and gardens. Our understanding is that in New South Wales alone, some 50 new professionally built ponds are constructed annually at a capital cost in the vicinity of $1.5 million. A signifi cant number of these new owners join societies.

Classifi cation of koi as a noxious species In NSW koi are currently classifi ed as a ‘Class 3’ noxious fi sh under the NSW Fisheries Management Act. This classifi cation allows for the keeping of fi sh in an aquarium or garden pond and for the sale of fi sh, a satisfactory situation for our NSW members.

In WA, it is understood that ornamental fi sh are regulated under the Fisheries Act of 1990. The noxious list, Class 1, Schedule 5 of the Act, does identify the ‘carp’ as noxious. However under the Act, The Fisheries Department does differentiate ‘carp’ from ‘koi’ and as such koi are not banned. This was clarifi ed at a meeting with Fisheries on the 7th February 2005. In practice it appears that koi in WA receive similar consideration to that of NSW under Class 3.

Koi keeping in states where koi are bannedUnfortunately, koi keeping fl ourishes in states where koi are banned. Interstate trading of koi using commercial pet carriers is commonplace. The popularity of illicit koi keeping in those states demonstrates that banning of koi is impracticable and that other approaches to management are required.

We are very concerned that the banning of koi in some states has driven large numbers of enthusiasts ‘underground’, making the task of communicating with them and educating them on environmental issues almost impossible. ‘Underground’ hobbyists are more likely to come into contact with unscrupulous aquarists who breed and deal in illegal and far more environmentally dangerous species. ‘Underground’ hobbyists are also far less likely to have their habits scrutinised by formal koi societies, better-informed aquarists and the general public.

However koi keeping is by its nature a very social hobby. It revolves around a culture of competitions, auctions, swaps, tours and meetings and we believe that making koi keeping legal in all states will bring the illicit hobbyists out into the open and indeed into the culture of organised enthusiasts, where ethical behaviour and adherence to regulations is paramount.

Investment in the hobbyKoi keepers spend large amounts of money on their hobby. A substantial industry has grown around the hobby of koi keeping, including:

• Fish breeders, some (but not all) of whom specialise in koi.• Specialist veterinary services.• Specialist suppliers of koi foods, supplements, water conditioners, medicines, test

kits, nets, books, videos and DVDs.• Suppliers of fi lter materials, pond materials, plants and decorations.• Manufacturers, suppliers and installers of pumps and fi ltering equipment.• Commercial pond designers and builders.

Some of these operations are very large. For example a large koi breeding business in

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outer western Sydney is currently on the market, reportedly for fi ve million dollars.

It is not unusual for koi hobbyists to spend tens of thousands of dollars on their ponds and fi sh. Suburban ponds sometimes reach sizes above the 100,000 litre mark (ten times the volume which the Consultation Draft suggests would be used to distinguish breeders that should have state aquaculture permits). Large, complicated and expensive koi ponds, such as those shown below, are included in architect designed homes and are the key feature of garden landscaping that can cost well over $100,000. Even a modest pond of around 6,000 litres (quite common among our members) can cost more than $4,000 to construct, and several thousand dollars more to equip with pumps, fi lters and lights.

A typical koi pond built by Sydney company Imperial Gardens as part of landscaping in the architect designed home of a Sydney hobbyist. Ponds such as this are not uncommon and usually cost tens of thousands of dollars. All are well in excess of the 10,000 litre size proposed in the Consultation Draft to distinguish between hobbyists and commercial operators.

Koi fi sh are also extremely valuable. Although one of the reasons for the popularity of koi keeping is that entry into the hobby is quite affordable, quality fi sh shown

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at our monthly and annual competitions often change hands for up to $2,000 and some hobbyists in Australia value certain fi sh at up to $5,000. In other countries outstanding fi sh sell for much higher prices. For example in Japan, fi sh have been sold for up to A$700,000 and in the United Kingdom the more famous breeders advertise fi sh for sale for the equivalent of A$45,000 with many beyond that fi gure quoted as being ‘price on application’.

Many established members of our own organisations have invested over $150,000 in their ponds and fi sh, and some spend thousands of dollars each year in trading koi, koi food and medicines, pond supplies and maintenance, koi-related travel, etc. Even novices usually spend around $2,000 on basic set ups and their fi rst few fi sh.

Many of our members are concerned that if koi keeping was banned, or if regulations and licensing systems were introduced that classifi ed their amateur hobby as a commercial business, many people would be forced to give up their fi sh and equipment, causing considerable fi nancial losses and personal anxiety. Our Societies have been inundated with telephone calls from their members since publication of the draft proposals, all of whom are understandably concerned at the potential loss of their pets. To many koi hobbyists, their fi sh are regarded the same way as others would regard their family dog or cat.

Koi organisations conduct a busy schedule of fi eld trips and tours for their members.

Koi organisationsKoi organisations are highly organised and active. They are incorporated, not-for-profi t organisations. They typically conduct regular meetings, lectures and presentations, competition shows and championships, organised tours of outstanding private, public and commercial ponds, dinners and award nights, and social events for members and their families.

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Koi organisations are very family focused—koi keeping usually involves the keeping of a pond at the family home and as a hobby it is suitable for all ages, budgets and levels of knowledge and expertise. Koi shows usually include categories for novice and junior hobbyists. Koi keeping is a very multicultural hobby, with many members of koi organisations coming from Asian and European backgrounds.

Koi shows range from indoor ‘table show’ events to large scale outdoor shows with large vats owned by the koi clubs.

All major koi organisations publish newsletters, videos/DVDs and websites.

Koi organisations have signifi cant investments in equipment such as show bins and trailers, auction bins and trailers, pumps, fi lters and other equipment used at club events and public shows.

The regular koi auctions held by most koi organisations provide a controlled environment for the purchase and sale of koi. In NSW these auctions operate under guidelines previously agreed with NSW Fisheries (now NSW Department of Primary Industries). In addition, records are kept of each bidder and sale, with random telephone calls made after each auction to ensure the fi sh are in good health. In Western Australia, the state government has also given approval for auctions to be conducted. These auctions enable koi keepers to sell excess stock and prevent the establishment of a ‘black market’ in koi and any environmentally unsound disposals of unwanted fi sh.

We are concerned that the new commercial criteria outlined in the Consultation Draft could effectively eliminate our auction/trade days, thereby allowing an uncontrolled black market to develop.

Major koi organisations have codes of ethics (see Appendix 1) and, sensitive to environmental concerns, strive to educate their members to behave responsibly when it comes to dealing in or disposing of unwanted fi sh.

Koi organisations actively seek and welcome new members and have established policies for the mentoring of new members. We believe that membership of organisations is benefi cial not only to individual enthusiasts but is also the key to effective self regulation and best practice amongst koi keepers.

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Koi organisations are an important source of information for their members, including information on environmental issues, disease control, government regulations and humane disposal of sick, injured or unwanted stock.

Commercial interestsCommercial koi operations range from very small part time businesses that might occasionally deal in equipment, food or chemicals, through to very large breeding businesses and pond construction companies.

In South Australia in 2003 Rankin Springs Pty Ltd was awarded an $88,000 New Industries Development Program grant from the Federal government by the former Minister for Primary Industries. The grant was used to establish a koi breeding business that will supply koi to the global market and which will have benefi ts for export trade, tourism, and local business and employment growth.

There are some clear distinctions between hobbyists and commercial breeders.

Hobbyists:• Keep small numbers of fi sh for showing and trading• Keep small ponds (but often much larger than the 10,000 litres mentioned in the

Consultation Draft• Mostly trade with fellow club members or other koi keepers already known to

them• May sell koi to fellow hobbyists in order to dispose of surplus fi sh and to recover

some costs but do not depend on the hobby for signifi cant income

Commercial breeders:• Keep large numbers of fi sh for sale• Keep numerous large ponds and dams• Advertise widely to the public to sell fi sh and other related products• Treat koi as their business, with ABN numbers and large capital investment • Employ staff

Our organisations are extremely concerned that due to inappropriate criteria such as pond volume, hobbyists might be caught up and regulated in any classifi cation and registration of commercial breeders.

Koi in the public eyeKoi are kept in many public places. For example, in NSW they can be found on public display at the Chinese Gardens at Darling Harbour, Campbelltown Art Gallery and Japanese Gardens, Auburn Botanical Gardens, the Bankstown International Hotel, the Three Swallows Hotel at Yagoona, the extensive and internationally renowned Japanese Gardens at Cowra and the Nan Tien Buddhist Temple at Berkeley. The Gosford Edogawa Sister Cities Commemorative Gardens are a major cultural and tourist attraction which has a vast koi pond as their central theme. There are also a great number of Japanese style gardens and water features that have been built in restaurants and corporate offi ces by the company Imperial Japanese Gardens.

Koi shows are extremely popular with the general public and there is an overlap of interests between koi fanciers and other hobbyists. For example The Koi Society of Australia’s Annual Koi Show, which takes up the entire Fairfi eld Showground complex

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and is advertised to the general public, attracts exhibitors of bonsai, pets and birds and unusual and exotic plants. The show draws over 15,000 visitors each year. It is highly regarded by the Fairfi eld City Council as a popular family day and tourist attraction for the district, particularly as no entrance fees are charged.

Response of hobbyists to the strategic review of ornamental fi shOur organisations have held meetings of executive and ordinary members and some have held public meetings and meetings with government representatives. We have received many representations from individuals, including members and non-members of our organisations.

The following concerns have been raised:

• Members are concerned that there might be a possibility that koi keeping will be banned in all states. This would result not only in the loss of their highly valued hobby but could also cause large fi nancial losses and personal anxiety.

• Members are concerned that the review will result in individual licensing of koi keepers and are concerned about the red tape and expense that could be involved.

• Members are concerned by the apparent lack of consultation, communication and consultation by governmental agencies prior to the publication of the draft code.

• Members are concerned that the Consultation Draft gives little consideration to the circumstances of koi, which are, after all, one of the world’s most popular and famous ornamental fi sh. For example, the term ‘koi’ does not appear in either the noxious or grey lists, and the 10,000 litre criteria used in the ‘Ornamental fi sh regulation decision tree’ is completely unrealistic. To put this into perspective, many members with mature koi adopt a policy of 2,000 litres for each koi in their display ponds. Ten koi therefore require 20,000 litres. Some Japanese purists adopt a ratio of 5,000 litres per koi. This is simply the proper and humane housing of the koi.

• Some members are concerned that any attempt to regulate them through individual licences will merely be a ‘Trojan horse’ for the government to identify them and later ban them from their hobby.

• The Asian members of our various associations are a large proportion of our membership. They have a strong cultural relationship with koi keeping, as koi in their society depicts strength, wealth, status and good harmony. These members are extremely concerned with protecting the future of their pets and their hobby.

• Elimination of auction/trade days for hobbyists could allow an uncontrolled black market to develop.

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Comments on the proposed recommendations of the Consultation Draft

Proposed recommendation 1. ‘Agree on and adopt a national noxious species list across all jurisdictions, noting links to existing lists and lists under development for marine pest species.’We support the notion of consistent national management of species. We note that the ‘koi’ strain of Cyprinus carpio is not mentioned in either the noxious or grey lists. We believe that the koi strain should be removed from any lists of noxious fi sh in all states and the keeping of koi under controlled conditions legalised in all states. We see the present NSW Fisheries Management Act ‘Class 3’ classifi cation as being an appropriate model for consistent national regulation of the koi strain.

Proposed recommendation 2. ‘Agree to review the status of fi sh on the ‘grey list’.’We believe that the koi strain of carp should be removed from the proposed noxious list and placed in the grey list. Consequently the status of the koi strain should be reviewed as a high value ornamental fi sh which can be legally kept, bred and traded under controlled conditions.

Proposed recommendation 3. ‘Establish a technical working group reporting to the Natural Resource Management Standing Committee (through the Marine and Coastal Committee), to conduct assessments of fi sh on the grey list over the next 2–3 years.’We would welcome any opportunity to liaise with government agencies to review the classifi cation of koi.

Proposed recommendation 4. ‘Adopt a regulatory framework and licensing to manage large fi sh-breeders and ornamental fi sh importers in each state and territory.’We support this recommendation but we point out that some of the criteria used in the Consultation Draft to distinguish hobbyists from commercial operators (e.g. water volume, method of selling) are not appropriate to practices in koi keeping. Some genuine koi hobbyists would be incorrectly and unfairly classifi ed as commercial operators if these criteria are used.

Proposed recommendation 5. ‘Agree on control mechanisms for noxious fi sh and rare fi sh (eg CITES listed) already in circulation in Australia, again noting links to control plans for marine pests of concern.’We support this recommendation and believe that consistent legalisation and strong self regulation of koi keeping will enable better communications to aquarists about the proper keeping of ornamental fi sh and the control and eradication of pest species.

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Proposed recommendation 6. ‘Request that an appropriate authority (for example, the Weeds CRC) conduct a rigorous review of aquatic plants used in the ornamental fi sh trade, in order to control and regulate the spread of a number of recognised aquatic pest species.’We support this recommendation and believe better communications to aquarists about the control and eradication of pest plant species will be possible under self regulation of koi keeping.

Proposed recommendation 7. ‘Implement a national communication strategy to raise awareness in the community and industry about the management, control and regulation of ornamental fi sh and invertebrates.’ We strongly support this recommendation. Our organisations are enthusiastic and willing to work with governments to develop better communication channels to educate aquarists. We believe that legalisation of koi keeping will fl ush out the ‘underground’ elements in the industry, making the keeping of ornamental fi sh more open to public scrutiny, management and control.

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A framework for self-regulation Self regulation is likely to be more effective than banning or licensing by governmentSelf regulation will create a culture of compliance driven by the ethics of koi organisations and individuals. This culture of compliance will encourage koi keepers to clearly understand the morality, legitimacy and benefi ts of laws they are required to respect, rather than be opposed to laws which they do not understand, and which they may feel have been unfairly imposed on them.

Regulation should be consistent in all statesLegalisation and consistent regulation of koi keeping in all states would enable the signifi cant number of illegal breeders and koi keepers already operating in Victoria, Queensland, the Northern Territory and South Australia to become legal (and responsible) hobbyists. If koi keeping was legal in those states, there would be no reason for those hobbyists not to ‘come out’ and join major koi organisations. Indeed there would be an imperative for them to do so, to enable them to buy and sell fi sh, whether at hobbyist level or on a commercial scale.

Regulation should revolve around communicationLegalisation would open communications channels to all koi keepers. Most koi keepers tend to be drawn towards clubs because of the social nature of the hobby, making it relatively easy to target them with regulatory and educational information. All koi organisations are active communicators, publishing newsletters and websites, and some also publish DVDs and videos.

Opening of communication channels will also enable state and government agencies to promote information about other forms of ornamental fi sh keeping. Some koi keepers do keep other species, and most suppliers of koi keeping equipment and consumables would be in occasional contact with breeders and keepers of other types of fi sh.

Regulation should be low costWe are concerned that administration of any form of regulation might be expensive and every effort should be made to minimise cost. This is one of the reasons why we strongly propose self regulation rather than licensing, particularly at the hobbyist level. Within reason, organisations such as ours would be willing and able to administer records of membership and take on a key role communicating to and educating members. We believe however that there would be widespread resistance to individual licensing by the government.

Regulation should be based on different criteria to that used to manage/regulate keepers of other ornamental species We query the applicability of the decision trees shown in Figure 2 and Figure 3 of the Consultation Draft to the koi industry. Koi keeping, even at the hobbyist level, focuses on bartering, buying and selling of fi sh to improve the hobbyist’s stocks. Hobbyists advertise their fi sh for sale to other hobbyists, usually in club newsletters. Much of this activity takes place between traders without ABN’s, at auctions and shows that might or might not be open to the public. Some koi are bought and sold

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for a few dollars, especially among novices, but outstanding fi sh occasionally change hands for very high prices.

The 10,000 litre water volume used to distinguish hobbyists from those that should have aquaculture permits is totally inappropriate for koi—10,000 litres is not considered a large pond for this species that is mostly kept outdoors

Shown above are examples of hobbyists’ koi ponds. The top photo shows a pond built by the owner; the bottom photo shows a professionally built pond. In both cases the ponds far exceed the 10,000 litre criteria proposed in the Consultation Draft.

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Recommendations for future management1. The status of koi should be considered separately from other ornamental fi shThe history and popularity of koi keeping, the impracticability of banning koi, the economic signifi cance of the hobby and the industry around it, methods of differentiating koi strains from common carp and the willingness of the koi keeping fraternity to develop effective self regulation, all show that there is a need for the status of koi to be reviewed separately from other ornamental, pest or noxious species.

2. The koi strain of carp should be removed from the proposed noxious fi sh list and placed in the grey listAdditional consideration and review is needed to decide the best management and regulatory regimes that will preserve the hobby and industry of koi keeping within strict environmental standards.

3. Consideration should be given to a separate classifi cation for koi Criteria for identifying koi strains of carp should be agreed, and there should be clarifi cation and education for bio-security managers, hobbyists and the general public on the differences between koi and other strains of carp. The koi strain of carp should be placed in a nationally consistent, separate category of ornamental fi sh which can be bred, kept, traded and moved under controlled conditions, similar to the NSW ‘Class 3’ classifi cation.

4. The keeping of koi should be legalised throughout AustraliaIt is impractical and counter-productive to ban koi keeping in Australia. Koi keeping under controlled conditions should be legalised in all states. Legalisation of koi keeping should be contingent on:

• Agreement of standards of controlled keeping, breeding and trading of koi at hobbyist and commercial levels.

• Acknowledgment of the role of koi organisations as a vital link between the government and koi hobbyists.

• Agreement of communication programs channelled through koi organisations to koi hobbyists.

5. The 10,000 litre criteria proposed to distinguish hobbyists from commercial operators should be deleted from the proposed codeThe 10,000 litre criteria used in the ‘Ornamental fi sh regulation decision tree’ is a completely unrealistic way to distinguish koi hobbyists. While it may be a practical way to measure the activities of breeders of much smaller indoor aquarium fi sh, 10,000 litres is adequate for the keeping of only a few large koi.

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6. The Federal and state governments should work with leading koi organisations to develop effective self regulationKoi organisations are well aware that koi keeping in Australia is a privilege and that consequently we must take responsibility for environmental care. Koi organisations have a proven track record in achieving this over many years. Leading koi organisations are willing to accept sensible government regulation and hobbyists are willing to undertake their hobby in accordance with strong self regulation. We hope that the government will work with us to develop and communicate self regulation that meets the standards of control and environmental care that are necessary.

7. Regulation of koi keeping should focus on the role of koi organisationsRather than planning to regulate or license individual hobbyists, government should focus on developing protocols with koi organisations to educate and communicate to their members. Licences or other imposts should not be applied to individual hobbyists.

8. Communications with koi hobbyists in Australia should be improvedA signifi cant number of koi keepers come from ethnic backgrounds, particularly from Asian countries. Communications with these hobbyists needs to be multilingual and consideration should be given to directing communications through ethnic newspapers. Australian koi organisations are starting to focus on the need for such communications to their multicultural memberships but this is a costly exercise, given the limitations on each organisation’s resources. Our organisations have gone to considerable length to produce an ‘Environmental Statement’ in Chinese, Korean, Vietnamese, Japanese and Arabic to prevent accidental or deliberate releases of koi into our waterways.

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Appendix 1

Code of EthicsThe Koi Societies of Australia recognise and are dedicated to the protection of the Australian environment. Within this unique Australian environment we seek preservation and improvement of koi and the koi hobby.

Therefore, in accordance with this Code of Ethics, any person becoming a member of these Societies is expected to:

• Give environmental management priority over all other aspects of our hobby. All members must endeavour to be compliant with state and federal laws and exhibit good responsible environmental behaviour. As societies we endeavour to teach both public and new members the basics of responsible koi keeping.

• Ensure that responsible environmental management of koi is undertaken at all times. Ensure that this Code of Ethics and other Society publications and teachings are exercised as the foundations of responsible koi management.

• Familiarise themselves with the basic needs of koi as to housing, feeding, general well being and healthcare in order to provide a safe and humane standard of housing.

• To dispose of unwanted, sick or injured koi with reference at all times to humane and good environmental management.

• Foster and promote the hobby of koi keeping in Australia through family involvement and the forming of friendships.

• Seek to be a positive member embracing friendship and doing nothing that may bring the Society or the hobby into disrepute.

• Contemplate and undertake breeding only in order to strive to improve the quality of Australian koi and share with others the fruits of these spawnings.

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Appendix 2

Directory of koi organisations

The Australian Koi Association Inc.

President: Mr Paul MiglionicoTelephone: (02) 9862 0472

Correspondence to: The SecretaryThe Australian Koi Association Inc.20 Moira CrescentST MARYS NSW 2760www.akakoi.com

The Australian Koi Association is a Sydney based organisation formed in 1981, dedicated to the protection, preservation and improvement of koi. It has nearly 450 members. The Association conducts monthly general meetings and lectures, monthly and annual koi championship shows, auctions, tours and social events. Show events are open to the general public and family involvement is actively encouraged with competition categories for junior members and social events specially planned for children. The Association is affi liated with the international body, Zen Nippon Airinkai and has close relationships with a number of international koi organisations. Each year it brings internationally recognised experts to Australia to judge, advise and speak at its shows. The Association publishes a monthly newsletter AKA Reporter and a website at www.akakoi.com.

The Australian Koi Association will be conducting its 25th Silver Anniversary koi Show on 2 April 2006 at the Olympic Velodrome, Bass Hill, New South Wales.

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The Koi Society of Australia Inc.

President: Mr Eddie Edwins Telephone (02) 9604 7072

Correspondence to: The SecretaryThe Koi Society of Australia Inc13 Cabbage Tree LaneFAIRY MEADOW NSW 2519.www.ksakoi.com

The Koi Society of Australia (KSA) was formed in Sydney in 1974 and is dedicated to the protection, preservation and improvement of koi.

Growth in membership has been rapid and sustained over the years and reached the stage where for geographic and practical administrative purposes, the Society now has seven branches, from Newcastle down to Southern NSW, with a total of 1,624 members. All branches have their own monthly general meetings, auctions, public displays, koi shows, pond tours and social events, all coordinated by the main body of the KSA, which is elected by the general membership.

In addition to the branch activities, the main body organises and runs the Koi Pet & Garden Show at Fairfi eld City Showground, the biggest show of its kind in Australia. The Koi Society of Australia will be holding its 29th Annual Koi Show this coming May.

The Society is also a chapter of the Zen Nippon Airinkai, the international parent body for koi. Zen Nippon send two certifi ed Japanese judges to oversee the KSA’s annual show at Fairfi eld City Showground and judge the koi. After the 2005 annual show they commented that Australian koi are now rapidly approaching the best quality global standards.

In 1994 the Koi Society of Australia assisted in writing of the KSA Handbook Koi Keeping in Australia. This book is not only available all over Australia, but has been distributed to koi enthusiasts worldwide.

The Society is also proud and honoured to have the Consul General of Japan as its Patron.

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The Koi Society of Western Australia Inc.President William PasseyTelephone 08 9535 7732

Correspondence to: The SecretaryThe Koi Society of Western Australia Inc.20 Rosetta RiseGnangaraWA 6065

The Koi Society of Western Australia is a Perth based organisation formed in 1989. It has over 160 members. The Society estimates that there are more than 10,000 people involved with koi in Western Australia. The Society conducts a major Annual Show where offi cials from Japan judge members’ koi. Up to 3,000 people usually attend such a show. Meetings and social occasions are held monthly throughout the year.130 members and families attended this year’s Christmas Party. The Society also displays koi and supports event such as the RSPCA ‘Day For Animals’ at Ascot Raceway attended last year by over 15,000 West Australians.

Over the years the Society has provide information to thousands of Western Australians and underpins that information with sound environmental advice. It operates a free service collecting unwanted pond fi sh from members of the public to ensure they are not disposed of incorrectly. The Society publishes a newsletter and a website, www.koiclubwa.com. The Society is affi liated with the international body, Zen Nippon Airinkai.

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Zen Nippon Airinkai 9-1-47 Ishigaki-nishi, Beppu, Oita 874-0910 Japan

Zen Nippon Airinkai is the international parent body for koi organisations and is formally recognised by the Japanese government as a important cultural corporation. It sets standards for the hobby which are institutionalised world wide and supplies judges and education to all countries for annual shows.

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Appendix 3

Environmental statementMultilingual educational information distributed in posters and newsletters, promoting environmental awareness (Chinese, Japanese, Vietnamese, Korean and Arabic)

Koi keeping and the environment

It is our duty to safeguard the environment from any release of koi into rivers and lakes. Please do not dispose of unwanted fish or aquatic plants into Australian waterways. Teach your colleagues and children to respect the environment through responsible actions. Koi associations will take care of any unwanted fish you wish to dispose of. Contact your association for further details. Your responsible actions will ensure that koi keepers are seen by the government and the public as environmentally trustworthy and ensure that our hobby can be enjoyed by future generations.

飼養錦鯉與環境保護環境是我們的責任，莫將錦鯉丟進河流及湖泊。請大家切勿將不要的魚或水生植物棄置到澳洲的水道，只要透過負責的行動

，大家就能教導同事及子女尊重環境。錦鯉協會將會照顧你想丟棄的魚，請聯絡你所屬的協會以獲取詳情。只要你的行動具有責任感，就可確保政府及公眾將飼養錦鯉人士視為環境可靠

的人，亦可以保障我們後代可以繼續享受這種嗜好。

Vieäc nuoâi caù cheùp vaø söï baœo veä moâi sinhNhieäm vuï cuœa chuùng toâi laø baœo veä moâi sinh ñoái vôùi baát cöù vieäc thaœ caù cheùp naøo vaøo soâng ngoøi vaø hoà nöôùc.

Xin ñöøng vaát boœœ caù hoaëc caùc caây thuœy sinh vaøo soâng ngoøi cuœa UÙc. Haõy khuyeân baœo ñoàng nghieäp vaø con em cuœa quyù vò ñeå hoï toân troïng moâi sinh qua caùc haønh ñoäng coù traùch nhieäm.

Caùc hieäp hoäi nuoâi caù cheùp (koi association) seõ nhaän laõnh baát cöù con caù naøo maø quyù vò muoán boœ. Haõy lieân laïc hieäp hoäi cuœa quyù vò ñeå bieát theâm chi tieát.

Caùc haønh ñoäng coù traùch nhieäm cuœa quyù vò seõ ñaœm baœo raèng nhöõng ngöôøi nuoâi caù cheùp seõ ñöôïc chính quyeàn vaø coâng chuùng xem laø nhöõng ngöôøi ñaùng tín nhieäm veà maët gìn giöõ moâi sinh vaø ñaœm baœo raèng sôœ thích cuœa chuùng ta coù theå ñöôïc caùc theá heä töông lai vui höôœng.

تربية سمك الشّبوط والحفاظ على البيئة

إن الحفاظ على البيئة بعدم إطالق سمك الشّبوط في األنهار والبحيرات هو واجب يقع على عاتقنا.

يرجى عدم رمي األسماك أو النباتات المائية غير المرغوب بها في مجاري المياه األسترالية. عّلم زمالئك وأطفالك احترام البيئة من خالل التصرف بمسؤولية.

إن جمعيات سمك الشّبوط )Koi associations( على استعداد للعناية بأية أسماك ترغب عدم االحتفاظ بها. اتصل بالجمعية القريبة منك لمزيد من التفاصيل.

إن تصرفك المسؤول سوف يؤكد للحكومة والعموم أن مرّبي سمك الشّبوط أشخاص يوثق برعايتهم للبيئة وسوف يضمن استمرار هوايتنا الممتعة لألجيال المقبلة.

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Appendix 4

International letters of supportLetters received from other international koi organisations

ornamental fish policy working group - ksakoi.com · joint submission to the ornamental fish policy...

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