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Submission to Parks Australia on the Draft Management Plans for the 44

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Submission to Parks Australia on the Draft Management Plans for the 44 20 September 2017 Submission to Parks Australia on the Draft Management Plans for the 44 Commonwealth marine parks in the South-west, North- west, North, Coral Sea and Temperate East regions Summary This is the submission of the Australian Marine Conservation Society, the Pew Charitable Trusts and the Save Our Marine Life alliance (www.saveourmarinelife.org.au) in response to Parks Australia’s Draft Management Plans for the 40 Commonwealth marine parks under review since 2014 and the 44 in total covered by the 5 Draft Plans (SW, NW, North, Coral Sea and Temperate East regions). We are pleased to have the opportunity to comment on the draft management plans. The management arrangements for the marine parks declared in 2012 have been set aside since 2013. As a result of what has effectively been a suspension of the operation of the parks, 90% of Australia’s marine environment -the third largest Exclusive Economic Zone (EEZ) in the world - has been denied the benefit of the network of marine parks as a key management tool. This is of great concern given the increasing pressure Australia’s EEZ is facing from climate change and increasing use. It is also of concern given Australia’s long-standing commitment under the UN Convention on the Law of the Sea to properly conserve as well as sustainably utilise our EEZ. We welcome the Government’s stated intention to have the marine parks operational in the next 12 months. Given the long delay in getting to this point following the parks’ suspension, we strongly support this commitment. We share the Government’s aim here and our submission is written as a contribution to making this possible. We recognise that the Draft Management Plans cover a wide range of management elements. We are supportive of the extent of those elements including in scoping the community engagement – something we strongly support. For the purposes of this submission however, we will keep our comments to the issue of zoning as this is the single most important factor to get right in marine park management, and the matter we take the greatest issue with in the draft management plans. We are most concerned with the proposed loss of 50% of the high-level IUCN category I and II zoning, and its replacement with varying degrees of benthic IUCN IV to VI protection. This is not supported by science. Specifically, we refer you to Ban, N et al 2011, the Commonwealth Marine Reserve Review findings, the submissions to both this process and the Review from the Ocean Science Council of Australia, the Australian Marine Science Association, CSIRO and the Australian Coral Reef Society, and most recently the statement of concern by over 1200 eminent marine scientists locally and globally. The issue of science has been one of the prominent issues during the consultation. We have been told on many occasions by Parks Australia that a change in the zoning depends on science being provided to justify it. We draw Parks Australia’s attention to the raft of science commissioned over the last 20 years by the Environment Department in developing these 44 marine parks and the inputs at every stage of consultation over the last 10 years from highly regarded science organisations as indicated above. In particular, we point to the work commissioned by the Government from the independent Review of the Commonwealth Marine Reserves including the Expert Science Panel’s report. The distance between the recommendations of all these inputs, and the zoning approach taken by Parks Australia in the draft management plans, is inexplicable and unjustified. Further, we interpret the call for “science” from Parks Australia despite this weight of evidence, to be the call for proof of threat to justify zoning. This is contrary to the policy approach of the Australian governments since 1998 when the CAR – Comprehensive, Adequate and Representative – approach was formally adopted (ANZECC (1998) Guidelines for Establishing the national Representative System of Marine Protected Areas), and is counter-productive when developing zoning for marine parks. Marine parks are a pro- active long-term biodiversity conservation tool, not a reactive resource management or impact assessment regime. In 2004 the Howard Government rezoned the Great Barrier Reef Marine Park using a CAR approach. Should the approach being taken now by Parks Australia been adopted then, it is fair to assume that the zoning outcome of 34% IUCN I & II would not have eventuated. Nor would the zoning of the state waters of the Ningaloo Marine Park (also 34% IUCN II). It is also of concern that the economic assessment of the impact of the rezoning proposed in the draft management plans has not considered the direct and indirect benefits of marine park declarations particularly those with adequate no-take protection (eg: SA Centre for Economic Studies (2014) Economic Benefits of Marine Parks, and Eadie L, Hoisington C , Centre for Policy Development (2011), Stocking Up: Securing our marine economy). There are a number of longstanding marine parks in Australia where this evidence is available – including the Great Barrier Reef Marine Park, Ningaloo, Moreton Bay, the Victoria no-take marine parks and Maria Island (Tas). On the flip side, the economic case for the reduction in no-take areas has also not been made beyond the level of rhetoric. The impact on commercial fishing from the 2012 zoning proposals was $11m, or 1% of commercial fishing GVP at that time (ABARES 2012). The benefit of increased access for the commercial fishing industry from the rezoning proposed in the draft management plans returns only $4m catch value industry-wide. This is because most of the areas to lose no-take protection are areas not fished. These intact and important ecosystems, often with unique features (eg: the Diamantina Fracture Zone in the SW Corner marine park) should be fully protected (University of Queensland (2009) Scientific Principles for Design of Marine Protected Areas in Australia: A Guidance Statement, appended to this submission), particularly where there will be little or no impact on fishing. A hallmark of the long process of developing the 44 marine parks since the late 1990s when the process began, has been the degree of consultation. This is something that successive Australian governments should be proud of. It is also something that the Australian public should be recognised for – as they have shown good faith and endurance in providing input numerous times in successive processes and re-processes in this endeavour. One of the greatest assets that Parks Australia has in seeking to finalise the management plans is the support of the Australian public for marine parks and their no-take protection. This is manifestly evident from the consultation processes over almost 20 years. To largely ignore this, as was the case with the Notice of Intent process last year, risks losing the mandate that generations of park managers will need in future. P a g e 2 | 27 The view of coastal communities directly affected by the marine parks is particularly important. However, we contend that the input of those communities has not been well recognised in the draft management plans – with a bias towards the extractive interests who seek less protection – and a bias away from those local economic interests who seek more in the pursuit of the protection of their natural assets and the long term economic base it provides communities. We take this opportunity to correct a commonly held fallacy with respect of marine parks – that they are bad for recreational fishing and that recreational fishers are opposed to marine parks. The experience in Australia from long existing marine parks is that they are good for recreational fishing and supported by fishers. Some of Australia’s best recreational fishing spots are found in marine parks that include no-take zones – including at Ningaloo, the Great Barrier Reef, Moreton Bay etc. All studies of recreational fishing attitudes to marine parks demonstrate that recreational fishers strongly support marine parks and no-take zones (see the map below). It is important that decision makers recognise this overwhelming evidence when making decisions on zoning. Recommendations Informed by the science, economics, multiple stages of consultation and the community and stakeholder views around the nation, we recommend changes to the zoning proposed in the P a g e 3 | 27 Draft Plans. Zoning plans that are responsive to community views along with the science have the best chance of longevity and success. With respect of the science, we are guided in particular by three inputs – the Edgar et al paper (‘Global conservation outcomes depend on marine protected areas with five key features’ Nature 506 p216-220 2014) which has found that to be effective marine parks must have 5 key elements. The others are the University of Queensland’s Scientific Principles for Design of Marine Protected Areas in Australia: A Guidance Statement (appended here) and the CMR Review’s recommendations. We are also guided by the need at this mature stage of the process for practical, simple changes which minimise impact on industry whilst maximising outcomes for biodiversity conservation, local communities and management logistics on the water. Summary of zoning changes sought (Note - where no change is proposed, the zoning in the draft plans is supported) Marine Park Change sought All 44 marine parks ● As a minimum, an adequately sized and placed marine national park zone (MNPZ) in each marine park as per Edgar, G et al 2014, and the CSIRO submission to the Commonwealth Marine Reserve Network Proposal 2011. ● Areas of high conservation value where mining permits do not already exist, particularly within parks adjacent to coastal communities (and not otherwise recommended to be MNPZ or HPZ) – should be zoned SPZ (mining exclusion).
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