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.
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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
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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). In addition, the following changes to specific marine parks are proposed:
Coral Sea ● Restoration of a large contiguous offshore MNPZ over the deep-water area (in line with the Review recommendations, although flexible on specifics with users in mind). ● Restoration of MNP zoning over key reefs: o West Holmes Reef – using the box format that the Review recommended o Marion Reef – as per draft management plan but extend the MNPZ in the north from hugging the reefs edge to create a MNPZ box of similar size to the HPZ Reefs box in the south. o Wreck Reef – as per the Review
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o South Flinders Reef - restore MNPZ box at south Flinders as recommended by the Review o Osprey Reef - restore MNPZ protection as recommended by the Review ● Reject the introduction of longlining, purse seining and mid-water trawl and create a recreational fishing and small-scale line, trap and collection commercial fishing zone over the 2012 Habitat Protection Zone (Coral Sea) (much the same areas as AFMA’s Area E/Coral Sea Zone of the Eastern Tuna Billfish Fishery) with a mix of MNPZ and HPZ (Reefs) over key reefs therein (as per above). ● No mid-water trawl or purse seining in the entire park ● Limiting the Special Purpose Zone (Trawl)–to the Review’s recommendations.
Norfolk Island ● As per the Review’s recommendations, plus the extension of the MUZ around the Island to 67nm x 40nm, as per the local community wishes.
Lord Howe ● As per the Review’s recommendations, other than the loss of a significant part of the longstanding MNPZ over Middleton Reef.
Hunter ● As per the Review’s recommendations.
Bremer ● 2017 draft zoning is supported plus restoration of the remainder of the inner shelf MNPZ declared in 2012/13.
SW Corner ● Restoration of the remainder of the MNPZ over the Diamantina Fracture Zone.
Geographe ● As per the Review’s recommendations for the two MNPZ zones, with the addition of the no-mining zoning in the draft management plan.
Southern and ● Both parks to be zoned entirely SPZ (mining Western Kangaroo exclusion) Island parks
Perth Canyon ● As per the Review’s recommendations with restoration of the 2012 MNPZ at the head of the
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Canyon.
Twilight ● Restoration of the full MNPZ status of the park
Ningaloo ● A network of MNPZs matching those in the state waters park, as has been recommended in the Coral Sea area adjacent to the Great Barrier Reef.
Gascoyne ● As per the Review’s recommendations
Argo Rowley Tce ● As per the Review’s recommendations
Mermaid Reef ● Retention of IUCN 1a
Roebuck, 80 Mile ● SPZ (mining exclusion) zoning and the area around Rowley Shoals
Kimberley ● As per the Review’s recommendations, but with the addition of a MNPZ over the Holothuria Banks, and the Native Title area of the Wunambal Gaambera should be recognised in the zoning.
Limmen ● As per the Review’s recommendations
Wessel ● As per the Review’s recommendations
Oceanic Shoals ● As per the Review’s recommendations
Gulf of Carpentaria ● As per the Review’s recommendations
West Cape York ● As per the Review’s recommendations
Arafura ● As per the Review’s recommendations
Arnhem ● SPZ (mining exclusion) for the entire park
KEY ISSUES OF CONCERN
Summary of the main points of concern
The draft plans propose to revoke 40 million hectares of MNPZ, which keep marine ecosystems functioning in their natural state without the pressure of mining or fishing. This is an area twice
P a g e 6 | 27 the size of Victoria and representing almost half of the MNPZ in the network of 44 marine parks. What is proposed by the Turnbull Government is equivalent to revoking almost half of Australia’s national parks on land, and is unprecedented globally. Inexplicably, reductions in protection proposed by the Turnbull Government radically ignores the zoning advice of the Government’s own independent science Review (released last year), which endorsed the science and process underpinning the original declaration of the marine parks, and proposed an increase in protection in 4 of the 5 marine regions being reviewed.
MARINE REGION MNPZ CUT MNPZ RECOMMENDATION % OF MARINE REGION PROPOSED BY OF THE GOVERNMENT’S THAT WOULD HAVE A TURNBULL SCIENCE REVIEW PANEL per MNPZ AFTER THE GOVERNMENT per region GOVERNMENT’S region PROPOSED CUTS
Coral Sea 53% cut 9.8% cut 24%
South-west 40% cut 15% increase 7%
North-west 49% cut 16% increase 5%
Temperate East 2% cut 2.5% increase 4%
North 57% cut 10% increase 1%
Australia’s bi-partisan legacy of marine protection which stretches back over 40 years to the Whitlam and Fraser Governments is at risk. In 1998, having secured an agreement from ANZECC to declaring the world’s first network of science-based marine parks, the Howard Government went on in 2004 to set the gold standard for marine park management by declaring Green Zones in 34% of the Great Barrier Reef Marine Park. Between them, the Howard and Gillard Governments declared 60 federal marine parks and completed the network. The proposed cuts are not science-based – CSIRO recommends that each marine park should have at least one MNPZ (CSIRO submission to the Commonwealth Marine Reserve Network Proposal 2011). Yet 16 of the marine parks would have no high-level protection under these proposals. Further, the Government’s own Expert Science Panel recommended that all primary conservation features have at least some representation within MNPZ. Yet the draft plans leave 259 of Australia’s primary conservation features and 20 entire biological regions unrepresented in MNPZs. The MNPZ in the marine parks being reviewed are proposed to be replaced by zones that provide only partial protection. This is not supported by the science. These yellow (Habitat Protection) and blue (Multiple Use) zones protect the sea floor only – not the water column where most of the marine animals live and where the critically important ecosystem processes occur. The evidence from long standing marine parks finds that zones of partial protection are the ‘support-act’ in a marine park, but by themselves do not drive the biodiversity conservation outcomes – offering little improvement relative to areas fully open to exploitation. Reefs protected in MNPZ have significantly higher numbers of fish, and are recovering much faster from cyclone and coral bleaching damage than adjacent unprotected reefs. The Government’s
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own Expert Science Panel noted this difference citing recent research in the Coral Sea which showed that reefs within MNPZ including Coringa-Herald and Lihou Reefs supported approximately 70% higher fish biomass and approximately 90% higher shark biomass than reefs where some fishing was allowed. Australia’s contribution to the global endeavour of marine protection is at risk. The Coral Sea Marine Park – one of the largest and most iconic areas in the world – would lose half of its high- level protection under these plans. The world’s only known black marlin spawning ground, whale-shark breeding areas and most of the 37 Coral Sea reefs (many of which are unique in the world) would be left unprotected. The Coral Sea’s large deep water no-take zone is one of the few in the world big enough to provide protection at the scale necessary for marine species with large ranges and which are under great pressure in the Pacific, including tunas, turtles, cetaceans, sharks and seabirds. Further, the Coral Sea is a beacon for international tourists flying into Cairns – including high-end divers and game fishers – travelling a long way to see the world’s most intact reef environments. MNPZ are the exemplar of good management and as such are the most powerful beacon possible for tourists.
The proposals undermine Australia’s regional economic development - Australia’s marine tourism industry is worth $28b per annum (ref: The Australian Institute of Marine Science/AIMS Index of Marine Industry 2016). Whereas the catch value being returned to the commercial fishing industry from the MNPZ cuts is only $4m per annum (ref: ABARES Potential displacement of commercial fisheries by a Commonwealth marine reserve zoning scheme. Revision 1 July 2017), which represents only 0.3% of the total revenue from Australia’s wild catch fisheries.
There is so little catch value being returned to the fishing industry from these proposals as the biggest areas of MNPZ proposed to be cut are not or have never been fished (eg: the Diamantina Fracture Zone, and the large far offshore MNP zones in the Gascoyne, Argo Rowley Terrace and Coral Sea Marine Parks). These areas are many hundreds of kilometres offshore and often far from suitable port facilities. To fish these far offshore areas economically, major changes in economic conditions and most likely regulation would be required – including big reductions in fuel prices and significant changes to Australia’s maritime laws in order to allow foreign flagged vessels into Australian waters with the necessary freezer capacity and cheap crews.
There is little justifying economic argument for the proposed cuts – not only is the value of catch returned to the fishing industry tiny, the marine park management costs will at best remain the same through the creation of greater zoning complexity but with vastly reduced tourism and conservation outcomes.
The Government’s draft plans are based on bad process – with 54,000 submissions including from 5000 recreational fishers, the statutory consultation process conducted by Parks Australia in September/October 2016 returned a finding overwhelmingly in favour of increasing MNPZ, not a major reduction. This stands in stark contrast to the Government’s rezoning proposals released for consultation in July 2017.
The case for marine parks with adequate no-take zones
Marine parks – areas of the sea managed for conservation like national parks on land – are a key component of effective marine management. With the increasing impact of climate change (coral bleaching, loss of kelp and mangrove forests, rapidly shifting ranges of fish and other marine species
P a g e 8 | 27 as waters warm), overfishing and marine pollution (eg: stormwater and plastics), the need for key parts of the ocean to be kept operating in its natural state, is becoming more and more important. The science is clear – marine parks with large areas of high level no-take protection are the most effective way of ensuring marine environments overall are resilient in the face of increasing pressure on our oceans. Research has found that to be effective, marine parks need to be 5 things – no-take, well enforced, old (>10 years), large (>100km2), and isolated by deep water or sand (Edgar et al Nature v 506 2014 http://www.nature.com/nature/journal/v506/n7487/full/nature13022.html?foxtrotcallback=true). This is borne out by the success of existing long term no-take marine parks in Australian waters – the Great Barrier Reef, Ningaloo, Maria Island (Tas), Lihou, Coringa Herald, Ashmore, Cartier and Middleton Reef Marine Parks. Australia’s marine environment is the best in the world – the global Census of Marine Life (www.coml.org) found Australia to have one of the world’s two most important marine environments. Australia has the third largest area of ocean, and encompasses tropical, temperate and sub-Antarctic environments, being at the junction of 3 major oceans. Given geological isolation and unusual current patterns, much of Australia’s marine life, particularly off its southern shores, is unique (up to 90% of fish in some regions). Good marine management relies on both sustainable fisheries management and marine biodiversity conservation mechanisms like marine parks. Synergies between them exist – biodiversity conservation is enhanced by effective fisheries management and marine national park zones are the most effective fisheries risk management – but one is not a substitute for the other. Economically important - Australia’s marine environment is a major natural asset upon which many regional communities depend. Marine tourism is a major and growing area of regional economic activity – worth $28b a year, alongside commercial fishing and aquaculture which is worth $16b a year, recreational fishing $2b a year and oil & gas $31b a year (AIMS Index of Marine Industry 2016 - http://www.aims.gov.au/documents/30301/0/AIMS+Index+of+Marine+Industry+2016/f2f7f8f3- 6ae3-4094-b8d4-cb8aa90f5ae1). Good quality marine parks are the best asset management tool – with much of Australia’s marine biodiversity in good condition, marine conservation is an investment in asset maintenance, not an act of recovery. Highly protected marine parks are the fence at the top of the cliff, not the ambulance at the bottom – they should be declared in habitats that are high quality and intact. Areas that are damaged by overuse should be managed by impact assessment laws, recovery plans and resource regulation. Community and fisher support – Hundreds of thousands of Australians have contributed to the development of Australia’s marine parks and their marine national park zones. Every published government and scientific survey (see graphic p3) shows the vast majority of recreational fishers overwhelmingly support marine parks and no-take zones, and some of Australia’s most revered fishing destinations are in marine parks with high levels of marine national park protection – eg: the Great Barrier Reef, Ningaloo, Solitary Islands, Moreton Bay. Australian leadership – Australia was the first country to put in place a nation-wide network of marine parks around its coastline. In the last decade the rest of the world has followed Australia’s lead http://www.mpatlas.org/media/filer_public/10/33/10334e01-1583-47d6-a286- 16491cedac93/vlmpa_jan2017.jpg Winding back marine protection now will set back the global endeavour of safeguarding the world’s oceans for decades to come.
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Network-wide issues
● We reject the cut backs of marine national park zones (IUCN II) across the Network and recommend that Parks Australia increase the IUCN II zoning. The Government’s independent Review recognised the extensive science and consultation that led to the creation of the 40 parks in 2012. However, Parks Australia’s draft management plans recommend reducing, relocating and in most cases completely removing the marine national park protection over key habitats, particularly in the globally important Coral Sea. In the face of devastating coral bleaching, mangrove dieback and vanishing kelp forests, marine national park zone coverage in Australia’s Marine Parks are even more important now than ever.
● The marine park zoning must be science-based – the Government’s own Expert Science Panel found that marine parks declared in 2012 were the result of sound science and consultation. Further, leading scientists found that the 2012 network would need more marine national park coverage, not less (eg: Barr and Possingham, Are outcomes matching policy commitments in Australian marine conservation planning? Marine Policy 42, 39-48 2013).
● Partial protection zones are not a substitute for marine national park zones IUCN II protection – claims by government that Habitat Protection (HPZs/yellow zones) are equal to Marine National Park zone (MNPZ/green zones) are misleading. Protecting the sea floor provides only partial protection and does not protect the marine life living within the water column. Each marine park should have adequately sized and located zones of high level MNPZ protection, with partial protection zones used in an ancillary way. It is well established in the scientific literature that partial protection does not generate biodiversity benefits comparable to full protection.
● We reject the proposal to allow for mining extensively through the marine parks network – the Government proposes to allow mining and pipelines in the vast majority of the parks. Marine parks not currently containing mining exploration rights should be considered for protection from mining. As emphasised at the recent World Conservation Congress, industrial activities like mining are not compatible with marine parks. Where possible, marine parks should be fully protected from mining as has been achieved in the Great Barrier Reef and Coral Sea Marine Parks.
● We reject the proposal for destructive commercial fishing activities such as trawling, gillnetting and longlining in the marine parks. By opening up 38 of the marine parks to destructive commercial fishing practices such as trawling, gillnetting and longlining, Parks Australia is proposing to ignore the findings of the independent Fishing Gear Risk Assessments it commissioned and then had reviewed as part of the CMR Review, which found those types of fishing to be incompatible with many of the conservation values in the parks. Further, allowing destructive forms of commercial fishing puts at risk the benefits that marine parks provide not only to marine life, but also more broadly to tourism, recreational fishing and other types of commercial fishing that can operate sustainably inside parks alongside MNP zoning.
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● There is no justifying economic argument – Australia’s marine tourism industry is worth $28b per year, whereas the catch value being returned to commercial fishing from the network-wide MNPZ cuts is worth only $4m per annum – only 0.3% of the total revenue of Australia’s wild catch fisheries.
● The draft plans do not reflect results of the consultation process - it is deeply concerning that despite the vast majority of the 54,000 submissions to Parks Australia’s first consultation round/Notice Of Intent last year strongly supporting the restoration and increase in MNP zone protection, Parks Australia’s draft plans take the opposite approach in all but 1 of the 44 marine parks.
The Coral Sea Marine Park – issues and recommendations
The Government’s Expert Science Panel recognised the Coral Sea as a significant biodiversity hotspot for sharks, tuna and marlin. It acknowledged it as one of the few remaining areas globally that hasn’t been impacted significantly by humans. It also recognised the value of its unique reefs and acknowledged that they warrant higher protection.
However, Parks Australia proposes:
● Large cuts of 53% and fragmentation of the MNPZ coverage in the park - the large offshore oceanic Marine National Park Zone in the Coral Sea is Australia’s major global contribution to the protection of intact tropical pelagic marine life at a large scale. With such values and little if any fishing, this area is intact and therefore an important, achievable and rare opportunity for inclusion in the marine parks network as a large area of high level protection. Under the government’s proposals, most of the park would be opened up to longlining – a commercial fishing activity that the Government’s independent Fishing Gear Risk Assessment, concluded posed an unacceptable risk to the conservation values of the Coral Sea Marine Park.
● Reducing protection at a number of ecologically important reefs (Osprey, Shark, Vema, Flinders, Holmes, Marion and Wreck). The Government’s Expert Science Panel recognised the need to increase protection at key reefs. However, the draft plan fails to do so, proposing MNPZ protection for only 7 of the Coral Sea’s 37 or so reefs. Fully protecting reefs protects fish and shark populations that are highly valuable to the dive tourism industry and will help build reef resilience in the face of climate change. This is not only to the benefit of marine life but also delivers economic certainty to dive operators who need a diversity of reefs protected against extreme weather events such as cyclones and coral bleaching. Recent research in the Coral Sea shows that reefs not in Marine National Park Zones see their shark populations depleted by 90% of their original biomass, with populations of other large predators halved and fish populations depleted by 70% (CMR Review, Expert Science Panel report). The importance of protecting the Coral Sea’s reef sharks was highlighted by the Expert Science Panel which identified that: “Coral Sea reefs comprise a globally significant hotspot for reef sharks”.
● Partial protection (Habitat Protection Zones) as a substitute for full protection. The role of partial protection zones (yellow or blue on the map) is to achieve particular social or economic outcomes, or to act as a buffer to the marine national park zones which drive the biodiversity conservation outcomes in the parks. Scientific evidence P a g e 11 | 27
clearly shows that full protection is one of five keys factor in effective conservation of marine life. For example, the Government’s Expert Science Panel found that areas within the Coral Sea outside fully protected areas have suffered a 90% depletion in their shark populations. Furthermore, almost all the Habitat Protection Zones allow destructive commercial fishing activities such as longlining, mid-water trawl, and purse seining. These are commercial fishing activities that the Government’s independent Fishing Gear Risk Assessment, concluded posed an unacceptable risk to the conservation values of Australia’s marine parks.
● The draft management plan recommends significant losses in protection at the Osprey Group of Reefs - with Marine National Park Zones completely removed for Shark and Vema Reefs and a very large section of the Marine National Park Zone protection of Osprey Reef also removed, leaving the iconic and economically critical shark populations vulnerable to the 90% depletion that has been documented on other unprotected coral reefs within the Coral Sea. The Review recommended increased protection for other key reefs like Holmes and Flinders due to their ecological and economic value to the dive industry but the Government has ignored this recommendation in the Draft Management Plan.
● The proposed management plan undermines the economic viability and security of the Coral Sea’s biggest industries - dive tourism and its potential to expand, by removing protection of the reefs most critical to the industry’s future (Osprey, Holmes and Flinders). Coral Sea dive tourism is estimated to contribute $6m in direct sales to the economy per year (KPMG Econtech (2010), Economic analysis of a Coral Sea Marine Park). For scale, this direct revenue is much larger than the total $4 million projected gain for commercial fishers across all 44 of Australia’s marine parks, let alone the small set of commercial fishers operating in the Coral Sea.
● Commercial fishers argue that marine national parks are having too great an impact on their activities - this position is not supported by the evidence. The total maximum potential negative impact on commercial fishers from the 2012 plans, before taking into account the variety of potential positive impacts, is less than 1% of commercial fishing activities across the network. In the Coral Sea, some of the commercial fisheries that have been promoted as being heavily affected are estimated to be displaced by as little as 0.1%.
● The draft management plan proposes the reintroduction of longlining, mid-water trawl and purse seining into what was effectively Australia’s largest and most prized recreational fishing zone. The removal of longlining in the 2012 declaration was to protect the world’s only known black marlin spawning area and the highly valuable recreational fishing in this area.
The 2012 zoning, for the first time in Australia created a 180,000km2 area where for recreational fishers, billfish and tuna stocks were protected from all currently occurring commercial fishing methods. This meant that tuna and billfish stocks would become effectively the exclusive preserve of pelagic game fishers in this area. This zone overlaps with one of the world’s most iconic marlin game fisheries, including the Townsville Trough breeding grounds for black marlin, and also breeding grounds for yellowfin tuna and bigeye tuna. Commercial fishing that targets reef associated species, and deep sea commercial fishing methods targeting bottom fish are still permitted in this zone, which
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was named “Habitat Protection Zone (Coral Sea)” in the 2012 plan. This zone prohibited purse seining, mid water trawling, long-lining and gill netting.
The 2012 HPZ Coral Sea (much the same area as AFMA’s ‘Area E’) should be reinstated to the 2012 zoning in order to create what was ‘effectively exclusive access for recreational fishing’. The term ‘effectively exclusive access for recreational fishing’ is used because while these zones don’t prohibit every commercial fishing activity that takes place in them, they do restrict commercial fishing activities that target key species of importance for recreational fishers. We believe this area if restored will provide a real benefit for recreational fishers, whilst preserving the tourism, small scale commercial fishing and conservation outcomes from the mosaic of protection afforded the reefs in this area.
● The draft plan proposes the introduction of damaging fishing techniques like mid- water trawl, purse seining, bottom trawling and demersal longlining throughout vast sections of the Coral Sea marine park. These fishing practices not only have a significant impact on the conservation values of the park but the recreational fishing values of this globally iconic location of the world’s oceans.
The case for increasing large offshore no-take zoning in the Coral Sea Parks Australia’s Draft Management Plans: ● offer no IUCN II protection for the Coral Sea Abyssal Basin Sub region1. This key ecological feature is entirely unprotected in the proposed management plans. This eco-physical region is one of 5 distinct regions in the Coral Sea. o The region is over 4,000m deep and some of the least explored habitat in the Coral Sea. Little is known about the deep-sea communities with benthic habitats likely to support vertically migrating fish such as lantern fish.1 o A series of deep sea canyon within this region may serve as an aggregation point for larger pelagic fish looking to feed on upwellings.1 o Research suggests the deep-sea communities might be dominated by foraminiferans and nematodes. 2
● propose to reduce half the protection for the Queensland Plateau and the Queensland and Townsville Trough o Protection for the Queensland Plateau has dropped from 54% to 23% (this is equal to a 57% reduction in protection) under the draft management plans ▪ The Queensland Plateau is one of the most studied areas of the Coral Sea with a rich diversity of sharks, turtles and other reef species. ▪ Coral reefs of the Queensland Plateau are home to three species of shallow- water rays; blue spotted stingrays, eagle rages and bull rays.3
1 Brewer DT, Flynn A, Skewes TD, Corfield J, Pearson B, Alawo J, Young JW (2007) Ecosystems of the East Marine Planning Region. Report to Department of Environment and Water Resources. CSIRO, Cleveland
2 Alongi DM (1987) The distribution and composition of deep-sea microbenthos in a bathyal region of the western Coral Sea. Deep-Sea Research I 34:1245-1254 3 Ceccarelli D, Ayling AM, Choat JH, Ayling AL, Williamson DH, Cuff B (2009) Lihou Reef National Nature Reserve Marine Survey – October 2008. Report to the Department of the Environment, Water, Heritage and the Arts by C&R Consulting Pty Ltd., Townsville P a g e 13 | 27
▪ Deep-water sharks are also known to inhabit the deeper waters of the Queensland Plateau.4 ● Protection for the Queensland and Townsville Trough has dropped from 8% to 3% (this is equal to a 65% reduction in protection) under the draft management plans ▪ The Queensland and Townville troughs are important feeding grounds for larger pelagic species such as tuna, billfish and whale sharks, attracted to this area to feed on spawning aggregations of lanternfish. It is thought that these lantern spawning events may support a subsequent annual spawning of yellowfin and bigeye tuna larvae.5 ▪ The Queensland and Townsville Trough is host to the annual Black Marlin spawning aggregation. This extends from the ribbon reefs in the GBR to the southern end of the trough and supports what is considered the world’s premier black marlin sport fisheries.6
● Reduction in protection for Tasmantid Seamount chain and the Cato trough o The Tasmantid seamount chain is a ‘key ecological feature’ recognised for its ecological function, integrity and biodiversity7 . This seamount chain is made up of a collection of submarine guyots, plateaux and terraces running north south. 19 of these features are located in the Coral Sea region.8 o Under the 2012 zoning 8 of these 19 features were protected in Marine National Park zones. Under the draft management plans, just 3 of are protected within Marine National Park zones. o The Tasmantid Seamount chain supports a diverse range of habitats, including sea sponge gardens, near pristine coral reef communities, and are considered a hotspot for both demersal and pelagic biodiversity. They are known feeding grounds for large ocean species such as turtle, marine mammals and billfish.9 o Connection between some of the larger reefs that are part of this seamount chain has been cut. Mellish Reef and Kenn Reefs were previously connected within the large MNPZ allowing protection for migrating pelagic fish. o The Cato trough is a large geomorphic feature which covers the central section of the Tasmantid Seamount chain. It is typified by dynamic currents, upwellings of nutrient rich water and associated high populations of billfish10. The protection of this feature has fallen from 12.5 to 3% under the draft proposed management plans.
● A reduction in the protection of seamounts’ smaller brother- knolls. The draft management plans propose a reduction in the protection of knolls in the Coral Sea from 47% to 23% (this is equal to a 50% reduction in protection)
4 Compagno LJV, Stevens JD (1993) Hemitriakis falcata n.sp. and H. abdita n.sp., two new houndsharks (Carcharhiniformes: Triakidae) from Australia. Records of the Australian Museum 45:195-220 5 McPherson G (1988) A possible mechanism for the aggregation of yellowfin and bigeye tuna in the north-western Coral Sea. Fisheries Research Branch, Technical Report No FRB88/8:14, Department of Primary Industries, Queensland 6 Speare P (2003) Age and growth of black marlin, Makaira indica, in east coast Australian waters. Marine and Freshwater Research 54:307-314 7 DSEWPC (2012) Marine Bioregional Plan for the Temperate East, Australian Government. Available at http://www.environment.gov.au 8 As defined by Marine Key Ecological Features dataset- Dept of Environment- Marine Key Ecological Features Dataset. Available at data.gov.au 9 DSEWPC (2012) Marine Bioregional Plan for the Temperate East, Australian Government. Available at http://www.environment.gov.au 10 Director of National Parks (2013) Coral Sea Commonwealth Marine Reserve Management Plan 2014-2024 P a g e 14 | 27
o Knolls are the little brother to seamounts rising less than 1000m from the seafloor. Peaks must rise about 1000m to be classified as seamount. o A total of 83 knolls were protected by the 2012 large MNPZ. This has dropped to just 47 under the proposed management plans. The majority of this loss in protection is in the Eastern half of the Coral Sea around the Tasmantid seamount chain. o Recent studies on knolls in the Queensland trough have found a series of knolls supporting cold water coral communities11 and similar aggregations of marine life associated with seamounts. o Seamounts tend to host communities made up of sponges, cold-water corals and less mobile vertebrates. These communities attract benthic fauna and in term larger pelagic fish come to the area to feed on the intricate food web.
● A reduction in important protection of provincial bioregions o The draft management plan proposes a reduction in protection of Kenn Province bioregion from 47% to 3%. o The draft management plan proposes a reduction in protection of Northeast Province from 50% to 1%.
Further, the draft Coral Sea management plan proposes -
● reduction in protection of Northeast Province from 50% to 1%; ● reduction in protection for Mellish Plateau by 50%; ● a drop in protection for the Coral Sea basin and Coral Sea basin rise (broad scale geomorphic features) from 100% to 0%; ● reduction in protection for Kenn Plateau and D’Entrecasteaux Basin (see table 1 below); ● in 2012 the Australian Government declared a large MNPZ along the New Caledonia border in order to enable matching protection in the developing marine park in adjacent New Caledonian waters. In proposing the removal of the large MNPZ along key sections of the Australia/New Caledonia border, Parks Australia is undermining this concept of creating a large, connected cross border no-take area of marine protection – a rare an important opportunity in cross-jurisdictional cooperation and mutual outcomes.
Table 1. Change in protection of broad scale geomorphic features of the Coral Sea
Geomorphic Features Sanctuary Sanctuary Change in protection under protection by Sanctuary 2012 zoning proposed 2017 protection MPs
Bligh Trough 0% 0% 0%
Capricorn Trough terrace 0% 0% 0%
Cato Trough 12% 3% -9%
11 Beaman RJ (2010b) Biological implications of the geo-diversity in the deep Coral Sea. NPA News 80:5-7 P a g e 15 | 27
Chesterfield Plateau 0% 0% 0%
Coral Sea Basin 100% 0% -100%
Coral Sea Basin rise 100% 0% -100%
Coriolis Ridge 19% 0% -19%
D'Entrecasteaux Basin 100% 39% -61%
Eastern Plateau 75% 58% -17%
Kenn Plateau 97% 11% -86%
Louisiade Plateau 100% 63% -37%
Louisiade Trough 100% 100% 0%
Mellish Plateau 88% 83% -5%
Middleton Basin 0% 0% 0%
North Marion Plateau 4% 11% 8%
Osprey Embayment 31% 31% 0%
Queensland continental 0% 0% 0% shelf
Queensland continental 0% 2% 2% slope
Queensland Plateau 54% 23% -31%
Queensland, Townsville 8% 3% -5% Trough
Saumarez Plateau 0% 0% 0%
South Marion Plateau 0% 5% 5%
Tasman Basin 0% 0% 0%
Tasman Basin rise 0% 35% 35%
U/N 84% 22% -61%
Coral Sea Marine Park Recommendations
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The following are our recommendations to Parks Australia in relation to the finalisation of the Coral Sea Marine Park Management Plan. We - 1. Reject the proposed major loss and fragmentation of the large deep-water marine national park zone;
2. Reject the loss of protection at Osprey Reef, Shark and Vema Reefs. Osprey Reef needs high level no-take protection in order to deliver economic security to the valuable dive industry;
3. Reject the proposed loss of protection for Flinders, Holmes and Wreck Reef – reefs the Review found required protection;
4. Accept the proposed new MNPZ protection at the border with the Great Barrier Reef;
5. Accept the MNPZ protection at Bouganville Reef;
6. Reject the proposed opening up of the Coral Sea to longlining, purse seining and mid-water trawl in the ‘Area E’ Coral Sea Zone of the Eastern Tuna Billfish Fishery (formerly zoned as HPZ (Coral Sea) in 2012 . Removal of these damaging commercial fishing techniques should be achieved in this area to ensure protection of the Queensland Plateau, Queensland Trough and the world’s only known spawning ground for Black Marlin and their recreational fishing, economic and social values;
7. Reject the proposed loss of no-take protection for Marion Reef. Marion Reef is the only location where protection is proposed for the coral reefs, cays and herbivorous fish of the Marion Plateau which is a key ecological feature of the Coral Sea;
8. Reject the proposed expansion of mid-water trawling, purse seining, demersal longlining and prawn trawling within the Coral Sea.
The Temperate East Marine Parks - issues and recommendations
The Temperate East marine region is recognised as an area of global significance for a number of protected marine species including the critically-endangered east coast population of grey nurse shark and the vulnerable white shark. The network includes: important offshore reef habitat at Elizabeth and Middleton Reefs (one of Australia’s longest standing highly protected marine parks), Lord Howe Island and at Norfolk Island that support the threatened black cod; the southernmost extent of many reef- building coral species; as well as important breeding, foraging and feeding areas for several species of seabird including the little tern.
● Regarding Lord Howe Marine Park – we are concerned about Parks Australia’s proposal to remove protection over part of the seamount ecosystem of Middleton Reef – one of Australia’s longest and most highly protected remote coral reef habitats, declared 30 years ago in 1987. The catch value returned to the fishing industry from the loss of this important ecosystem is estimated by ABARES to be just $31,000 per annum, or $770 per annum to each of the 40 active longlining vessels in the Commonwealth’s Eastern Tuna and Billfish Fishery. Therefore, there is no economic justification for the loss of such an important legacy area of Australia’s marine parks network.
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We are also concerned that the Government is ignoring the advice of its expert Review, in downgrading the zoning in the northern half of the Lord Howe marine park outside the pre- existing Elizabeth and Middleton Reef area, from the recommended Habitat Protection Zone (yellow) to the very low level Multiple Use Zone (blue) which will in particular allow mining.
● Regarding Norfolk seamount protection – we are concerned that Parks Australia does not propose MNPZ protection for any of the Norfolk Seamounts despite being identified by the Howard Government as one of Australia’s 11 most unique habitats for marine life. Parks Australia’s proposals are contrary to the recommendation of the Government’s own Review, which found that the Vening Meinsez Fracture Zone some way south of Norfolk Island should be given MNPZ protection. Research trips have found it to be covered with a thick manganese crust and a community of benthic organisms using it as substrate. The biological samples included: Gorgonians, black coral, soft coral, crinoids, bryozoans, bivalves, gastropods, silica sponges, brittle stars, ascidians, tunicates and polychaete worms.
● Regarding protection levels in the Norfolk Marine Park – we are concerned that Parks Australia is again ignoring the advice of the Government commissioned expert Review, by not upgrading the zoning outside the MNPZ and the Island’s extended MOU Box, from the very low level protection Multiple Use Zone (blue) to Habitat Protection Zone (yellow). In doing so, Parks Australia is opening up much of the marine park to the possibility of becoming an oil field, and/or the possibility of highly destructive seabed mining. Geoscience Australia reports consider the region to be somewhat prospective for oil and gas.
● Regarding high level protection in the Temperate East region – we are concerned that Parks Australia is not proposing to increase MNPZ protection in the Temperate East marine region despite 96% of the region having no MNPZ protection, and 85% of the region having no protection at all. Further, the proposed zoning fails to implement the CSIRO recommendation for all marine parks to contain at least one Marine National Park Zone, with the draft plan proposing no marine national park zoning for the Gifford, Hunter and Jervis Marine Parks.
Temperate East marine region Recommendations
1. We support the Government’s proposal to increase protection from mining in the Central Eastern, Jervis and Hunter Marine Parks;
2. We reject the proposed removal of MNPZ protection at the long standing highly protected Middleton Reef in the Lord Howe Marine Park;
3. We reject the proposal to ignore the Review’s recommendation to create a MNPZ over the Vening Meinsez Fracture Zone in the Norfolk Marine Park;
4. We reject the proposal to ignore the Review’s recommendations at both Norfolk and Lord Howe Marine Parks with respect of upgrading the Multiple Use Zones to Habitat Protection Zones.
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The South-west region marine parks – issues and recommendations
The South-west region includes the cooler, temperate waters of southern Australia, home to an extremely high number of unique species restricted to our southern coastline including the fascinating Ruby seadragon, the Australian sea lion and the Western Rock Lobster. The SW region hosts two of only three known places in Australian waters where the largest animal ever – the blue whale – comes to feed from vast distances away. The mysterious, wild waters of the Great Australian Bight is where many threatened species – such as the southern right whale and their calves – seek sanctuary at important stages of their life cycles. ● Regarding overall Marine National Park Zone protection across the South-west region – we are concerned that the Government proposes to cut MNPZ protection in the South-west by 40%, despite the Review and the science community finding the need for more high-level protection MNPZ, not less.
● Regarding Geographe Marine Park – we are concerned with the Government’s proposal to remove both the MNPZ in the Geographe Bay Marine Park, replacing them with weaker (yellow) Habitat Protection zones. These yellow zones have only been applied elsewhere in the region in waters more than 600m deep – a very different environment to shallow, sheltered and heavily pressured Geographe Bay. The removal of the MNPZs is contrary to the science recommendations from the Government’s own Review. Acknowledging the level of consultation, the science evidence and the ‘intense community interest’, the Review recommended retaining the two MNPZ, while reconfiguring them to better align with immediately adjacent MNPZ in the Ngari Capes Marine Park established by the Barnett Government, and to improve ease of navigation for fishers. These two MNPZs recommended by the Review would deliver improved outcomes for the local community and create a tourism beacon for the region.
● Regarding Perth Canyon Marine Park – we are concerned about the proposal to move the 2012 MNPZ protection at the North Head of the Canyon away from a key area of productivity in the marine park. This site is an aggregation area for shortfin makos and dwarf minke whales (ref: Bouchet PJ, Meeuwig JJ. 2015. Drifting baited stereo-videography: A novel sampling tool for surveying pelagic wildlife in offshore marine reserves. Ecosphere, 6: art137.
● Regarding Twilight Marine Park - we are concerned about the proposal to reduce over 1,000km2 of MNPZ in this park. For comparison, this is an area larger than the entire NSW state waters MNPZ network, with the maximum economic benefit to fisheries estimated by the Government commissioned ABARES report to be only $82,500 per annum, or $2,500 per annum to each license holder in Zone 2 of the WA Temperate Gillnet Fishery. This combined with the loss of critical continental shelf protection at Peaceful Bay (in the SW Corner Marine Park) and at the head of the Bremer Marine Park (western side) leads to an overall loss of shelf protection across the South-west marine reserve network when there was too little to start with, as per the 2011 Science Statement of Concern - http://www.meeuwig.org/wp- content/uploads/2015/08/2011_ScienceStatement_SW-National-System-Reserves.pdf
● Regarding SW Corner Marine Park/Diamantina Fracture Zone – we are concerned about the loss of a very large area of Marine National Park Zone over the Diamantina Fracture Zone – a Key Ecological Feature whose ridges and seamounts are thought to act as ‘stepping stones’ for species dispersal and migration across the region and the wider abyssal plain (Wilson & Kaufman 1987, in Richardson et al. 2005). Further, its size, physical complexity and isolation indicate that it is likely to support deep-water communities characterised by high species diversity and
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uniqueness – ref: https://www.environment.gov.au/sprat- public/action/kef/view/22;jsessionid=ACF4D013818E181DD36A2CF029BE5656 The zoning proposed is a downgrade to the lowest level of protection in the park system – Multiple Use (blue) zone – which will allow mining and most forms of fishing, despite its extremely remote, rough and deep location – making it unsafe for oil and gas drilling (with an adequate oil spill response most likely impossible) and highly unlikely to be a serious economic proposition for fishing.
● Regarding the Western and Southern Kangaroo Island Marine Parks – we are concerned that despite there being no oil and gas leases over these two parks, the strong desire of the local community for their island to be as protected as possible from debilitating oil spills and the long term effects of oil and gas industrialisation of pristine seas, has not been heeded with an upgrade of zoning to ‘Special Purpose Zone (Mining Exclusion)’, as has been afforded to the northern most section of the Great Australian Bight Marine Park. This is perplexing as the area around Kangaroo Island is considered to be highly prospective for oil and gas discovery, and therefore at significant risk of such operations being allowed in the foreseeable future. Creating an oil or gas field in these near-shore marine parks would put the Island’s important fishing and lucrative tourism industries at risk. This will greatly diminish the reputation and facility of marine parks in this community. South-west marine region Recommendations
1.We support the draft management plan where the Marine National park zones have not changed from what was declared in 2012, or where there are new and/or increased MNPZ, ie –
● the new MNPZ in the Bremer Marine Park (the transect and over the Bremer Canyon); ● the new MNPZ transect over the Swan Canyon in the SW Corner Marine Park; ● the increased MNPZ area in the Two Rocks Marine Park.
2. We reject the draft management plans where the MNPZs are reduced or removed entirely, ie:-
b. in the SW Corner Marine Park (Diamantina Fracture Zone section), at the Twilight Marine Park; and over the western inner-shelf area in the Bay at Bremer Marine Park – all which have important areas of MNP zoning removed; c. in the Geographe Marine Park, and the Peaceful Bay section of the SW Corner Marine Park where the Marine National Park Zones are removed entirely; d. In the Perth Canyon Marine Park where the MNPZ over the Head of the Canyon has been moved away from the critical habitat of a protected species, to an area of far less ecological importance.
3. Mining – we support the Draft’s proposal to put in place a large no-mining zone ‘Special Purpose Zone (Mining Exclusion)’ in the Great Australian Bight Marine Park, and recommend that the Western and Southern Kangaroo Island Marine Parks are given the same zoning upgrade throughout. Further, we recommend that the other key coastal communities adjacent to commonwealth marine parks be given protection from mining – at Esperance (the SW Corner and Eastern Recherche Marine Parks), Peaceful Bay (SW Corner Marine Park) and Perth Canyon Marine Park.
4. Gillnetting – we recommend that the provision of permanent protection for Australian Sea Lions
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from gillnetting be provided in the relevant Commonwealth marine parks by ensuring that the zoning does not offer less protection than existing state and federal fisheries closures.
North-west Marine Park – issues and recommendations
The North-west region is home to iconic Australian marine species, including turtles, dugongs, sharks, sea snakes and sawfish. The whale shark – the world’s largest fish - aggregates every year off the World Heritage-listed Ningaloo Reef. The world's largest population of humpback whales - estimated to be made up of more than 29,000 individuals - migrates every year from their summer feeding grounds in Antarctica to breed in the warm tropical waters off the Kimberley coast. Many species in the North-west region face serious threats to their survival elsewhere in the world. With this in mind, the following are our concerns -
● Regarding MNPZ protection in the North-west region – we are very concerned that the government is proposing to reduce MNPZ protection across the 11 parks in the region by 49% when the Review and the science is clear that there should be more, not less.
Further we are concerned that the Government is proposing to leave 6 marine parks in the NW region without any high level MNPZ protection at all – at Roebuck, Eighty Mile Beach, Montebello, Carnarvon Canyon, Ningaloo and Shark Bay Marine Parks - despite the CSIRO recommendation that each marine park should have at least one MNPZ.
● Regarding the Argo-Rowley Terrace Marine Park – we are concerned that the Government is proposing to open-up the globally significant Rowley Shoals ecosystem to trawling and is not dealing with the risk of mining. The Rowley Shoals is an iconic area for marine life, a key Australian tourism asset (being one of the world’s greatest collections of coral Atolls, and one of the best dive sites in Australia) and contains recreational fishing values – yet the draft plan proposes compromising these values for a maximum economic benefit to fishers estimated by ABARES to be $36,900 per annum or $5,271 per annum to each license holder in the North-west Slope Trawl Fishery.
The draft fails to protect the Rowley Shoals from mining even though the Federal Environment Minister (when the Federal Resources Minister) last year rejected proposals to mine the area for oil and gas, by cancelling new acreage inside the park near the Shoals. No protection is afforded the tourism and recreation sector, despite the Shoals’ standing.
Further, we are concerned that a large area - 29,730km2 - of the Argo Rowley Tce Marine Park would be downgraded from high level MNPZ protection to the lowest level zoning – Multiple Use Zone. This represents a loss of 42% of the MNPZ in the park. The canyons at the north of the MNPZ feed the ecologically important Scott Plateau. These canyons are thought to be some 50 million years old and are responsible for creating upwellings of colder nutrient rich water from the abyssal plain onto the plateau. These upwellings create nutrient rich cold-water habitats, important food sources for predatory fish, sharks, toothed whales and dolphins. The Scott Plateau is an important breeding ground for sperm and beaked whales. The canyons linking the Argo Abyssal Plain to Scott Plateau are also considered a National Key Ecological Feature, and are fed by the ecological processes that occur in the Argo Abyssal Plain that would lose its protection under the draft plan.
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● Regarding the Gascoyne Marine Park adjacent to Ningaloo – we are concerned that another large area in the NW marine region - 24,305km2 – would be downgraded from high level MNPZ protection to sea floor protection only (yellow Habitat Protection zone), representing a loss of 73% of the MNPZ in the park. The large deep water MNPZ in the Gascoyne Marine Park is located over the Cuvier Abyssal Plain. This abyssal plain feeds a series of canyons, linking the nutrient rich deep waters to the Cape Range Peninsula. These deep waters support the rich diversity of marine life around the Cape Range peninsula, and Ningaloo Reef. The canyons that link the Cuvier Abyssal Plain with the Cape Range Peninsula are considered a National Key Ecological Feature (a feature that is considered to be important for regional ecosystems function and integrity). The upwelling at the heads of the canyons are known to support species aggregations of humpback whales and the highest recorded aggregations of whale sharks in the world. These deep waters are the life blood of Ningaloo Reef - the only extensive coral reef in the world that fringes the west coast of a continent, extending over 260 kms, with over 200 species of coral and 460 species of reef fish.
Both the cases of MNPZ loss above demonstrate a key issue – ecological processes are crucial for ecosystem function and as such should receive adequate high-level protection in marine parks.
● Regarding the Dampier Marine Park – we are concerned at the loss of two thirds of the original MNPZ at the Dampier Archipelago and opening up 84% of the marine park to mining. The Government’s proposal to replace the original MNPZ with a smaller area not contiguous with the Archipelago and offering less continuity with the Marine Park being planned by the WA Government is a poor outcome for one of Western Australia’s highest conservation value marine environments.
● Regarding the Kimberley Marine Park – we are concerned about the proposal to remove 2,860km2 of MNPZ over critical tropical shelf habitats in this park. For scale, this single loss of MNPZ equates to an area almost equivalent in size to all the marine sanctuaries in the New South Wales, Victorian, Tasmanian and Northern Territory state waters combined. This park is important not just for its conservation values but its economic value to the growing tourism industry. It will also play an important role as a buffer to the increasing mining activity in the Browse Basin and therefore should have its zoning upgraded in general. Like at the Bremer Marine Park, there are no mining permits or leases over the park, and very limited commercial fishing activity.
We are disappointed that the Federal Government is not proposing protection of the globally significant values of Adele Island within a MNPZ in the Kimberley Marine Park or to match the proposed MNPZs in the North Kimberley’s state waters marine parks. The Government misses a key opportunity to improve the protection of one of Australia’s most globally significant marine environments including around the Lacepede Islands which are one of the most important seabird and turtle breeding colonies in Australia - they receive no protection from mining development in this plan. Seabirds forage over a large area around the islands and any mining accidents would be particularly devastating to this important colony.
By leaving the north section of the Kimberley Marine Park without a MNPZ, the Government is missing an important opportunity to enhance the conservation outcome of this park – the WA Government has placed a MNPZ equivalent in the adjacent North Kimberley Marine park, over Long Reef and the East Holothuria Reef. The Holothuria Banks in the federal park is important for flatback turtles and should also be protected with a MNPZ.
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● Regarding the 80 Mile and Roebuck Marine Parks – as well as their ecological values, these parks are critical to the Pearling industry, are both adjacent to Ramsar-listed wetlands of international importance and host migrating humpback whales – a species recovering from the threat of extinction and increasingly important to the Kimberley’s $68m tourism industry. As well as established impacts on cetaceans, new evidence suggests that seismic testing can kill pearl oyster larvae and any decline in water quality will be devastating to the economically important Kimberley pearling industry.
North-west marine region Recommendations
1. We strongly reject the proposed removal of MNPZs in the Kimberley, Argo-Rowley, Gascoyne and Dampier Marine Parks;
2. We reject the proposed trawling zone close to the Rowley Shoals in the Argo Rowley Terrace Marine Park, and recommend the protection of Rowley Shoals from mining by the establishment of Habitat Protection Zones (HPZs);
3. With respect of the Kimberley Marine Park, we recommend:- ● the replacement of the proposed HPZ for Adele Island with a MNPZ, ● the upgrading of the Multiple Use Zone around the Lacepede Islands to a higher level zoning, ● the upgrading of the MUZ throughout the Kimberley marine park to either HPZ or Special Purpose Zone (mining exclusion); ● the establishment of a new large MNPZ in the north section of the Kimberley Marine Park to match the protection declared by the WA Government in state waters in the adjacent ‘Great Kimberley Marine Parks network’. This would protect globally significant values including the Holothuria Banks – an important breeding area for flatback turtles and tourism.
4. We recommend that adequately placed and sized MNPZs be placed in the 6 marine parks that do not currently have any MNPZ protection – Roebuck, 80 Mile Beach, Montebello, Shark Bay, Ningaloo and Carnarvon Canyon, so that the management arrangements for the NW marine region marine parks meet CSIRO recommendations for each marine park to contain at least one MNPZ;
5. We recommend that as well as appropriately placed MNPZs that do not displace pearling operations, that the remainder of the 80 Mile Beach and Roebuck Marine Parks are made Special Purpose (mining exclusion) Zones;
6. We seek an increase in protection for the Ningaloo Marine Park by matching the protection provided in the adjacent WA state waters marine park (which has a network of IUCN II zones) with matching zoning in Commonwealth waters - as has been proposed for the boundary between the Coral Sea Marine Park and the Great Barrier Reef Marine Park.
The North region’s marine parks – issues and recommendations The North region – the world’s last remaining pristine tropical coastline - includes the warm, and shallow waters of the Timor and Arafura seas, a world biodiversity hot spot where the continental shelf is at its widest, and species travel freely from Australian up to Papua New Guinea and into Asia.
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The North region is host to some of Australia’s most plentiful reef fish stocks, a diverse range of shark species and a variety of marine mammals - including the illusive dugong. The North region is home to all seven species of marine turtles, which nest on the sandy beaches of the outer islands, and head to deeper waters to feed. Australia’s very own species of dolphin, the Australian Snubfin dolphin, also calls the North home. Affectionately known as ‘snubby’ this dolphin seeks refuge in the calmer shallow waters of North feasting on local barramundi stocks.
● Regarding high level MNPZ protection in the North region – we are very concerned that the government is proposing to reduce MNPZ protection across the 8 parks in the region by 57% - leaving only 1% of the region in high level protection - when the Review and the science is clear that there should be more, not less.
More specifically – we are concerned that over half of the marine parks in the North region (Joseph Bonaparte, Arafura, Arnhem, Limmen and Wessel Marine Parks) do not have a MNPZ – despite the CSIRO recommendation that each marine park have at least one MNPZ.
● Regarding West Cape York Marine Park – we are concerned with the Government’s proposal to reduce the size of the Marine National Park zone by over 4600km2 and split this zone into two isolated MNPZ. This reduction in MNPZ is the largest proposed in the North region, equivalent to twice the area of the ACT, and much larger than reductions proposed by the Government’s own review. The Marine National Park zone has been re-zoned as Habitat Protection Zone, a zone which still allows trawling, longlining and hand collection. A Government commissioned ABARES report shows that these changes to West Cape York Marine Park will decrease the potential displacement by just $141,200.
We are also concerned about the removal of the Multiple Use Zone adjacent to QLD coastal waters - a change which opens the area within the Marine Park to gillnetting. Gillnetting has been designated as a destructive fishing technique by two Government reviews and is particularly dangerous for local populations of dugong and marine turtles including those at Crab island- the world’s largest nesting population of flatback turtles.
● Regarding Gulf of Carpentaria Marine Park – we are concerned about the Government’s proposal to reduce the size of the MNPZ in the Gulf of Carpentaria Marine Park, from 7400km2 to 3600km2, moving much of the remaining MNPZ further offshore. The removal of protection for high value shelf habitat adjacent to the Wellesley Islands will compromise the protection of this biodiversity hotspot - and important nesting site for the endangered hawksbill turtle, the vulnerable olive ridley turtle as well as a known biologically important area for coastal dolphins. This is an area where the Traditional Owners declared one of Australia’s first marine Indigenous Protected Areas/IPAs – over the Wellesley Islands. This speaks to the opportunity to enhance the conservation and cultural outcomes that a well zoned federal marine park in the southern Gulf should deliver. Further, the Review’s advice to the Federal Government recommended increasing the size of this Marine National Park Zone to provide additional protection for this important ecosystem which is representative of several Key Ecological Features including the Gulf’s famous submerged coral reefs.
● Regarding Wessel Marine Park - we are concerned about the Government’s proposal to remove the MNPZ from the Wessel Marine Park. The Wessel Islands are known for their high level of endemism, a hotspot which supports a range of pelagic fish such as sharks, snapper, tuna and mackerel, as well as variety of unique sponge and coral communities. As recommended by the Government’s own review this Marine National Park should be increased in size, to provide additional protection for this unique area.
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● Regarding Oceanic Shoals Marine Park – we are concerned about the new Special Purpose Zone (trawling) that has been created within the Oceanic Shoals Marine Park. This new zone will open a large area of the Carbonate bank and terrace systems of the Van Diemen Rise to gillnets, and demersal trawling which would not have been permitted if they remained as Multiple Use Zones. Both gear types are of great concern to the NT community – consistently rallied against by recreational fishers, the general public and commercial fishers who use more sustainable gear types in this fishery. As a result of this concern, the NT Demersal Fishery’s WTO accreditation remains under review. Further, these fishing techniques have been deemed incompatible with the aims of marine parks, by the Government’s fishing gear review, and have the ability for further impact on already stressed reef fish stocks. The NT state government has already acknowledged the fragility of the reef fish stocks in the area, bringing in special Reef Fish Protection zones. Large offshore marine parks which protect these important fish stocks are required to complement these Reef Fish Protection Zones.
● Regarding Arafura Marine Park – we are concerned about the Government’s proposal to introduce a large Special Purpose Zone (Trawl) into this marine park allowing the use of bottom trawling over the unique tributary canyons. These canyons support a diversity of large predatory fish, endangered sawfish, marine turtle and whale sharks, species that may be significantly affected by increased destructive fishing techniques. The lack of Marine National Park zone within this Marine Park is also concerning. The Government’s own expert science panel highlighted the importance of all marine parks having at least one Marine National Park zone. The Arafura Marine Park is one of four Marine Parks in the North without a Marine National Park zone.
● Regarding Limmen Marine Park – we are concerned with the continued lack of a Marine National Park zone within the Limmen Marine Park – an iconic marine area off the Top End and one of only two areas in the Northern Territory waters to be a marine park. The Government’s own Review recommended the addition of a Marine National Park zone in the North-west of the Limmen Marine Park, to compliment the Northern Territory marine park and provide additional protection for threatened dugong populations which feed around the labyrinth of shoals and sand banks in these shallow waters. It is representative of the near- pristine Gulf of Carpentaria Key Ecological Feature. It is important to also note here that the federal and Territory waters of the Limmen Marine Park are at risk from seabed mining (the moratorium runs out in 2018) and continued attempts to barge iron ore through the park, as a cheaper option than land transport to Port Darwin – something which the Traditional Owners and Amateur Fishermens Association of the NT (AFANT) have been very public in their concern over.
● Regarding Joseph Bonaparte Gulf Marine Park and Arnhem Marine Parks – we are concerned with the continued lack of Marine National Park zone within the Joseph Bonaparte Gulf and Arnhem Marine Park. The Government’s own expert science panel highlighted the importance of all marine parks having at least one Marine National Park zone. The Joseph Bonaparte Gulf and Arnhem Marine Parks are two of four Marine Parks in the North region without a Marine National Park zone.
Specifically, a Marine National Park Zone in the Joseph Bonaparte Marine Park would satisfy the Government’s long-standing commitment to create a Marine National Park Zone within the Anson Beagle, Cambridge-Bonaparte and Bonaparte Gulf bioregions. (source: ANZECC TFMPA 1998. Guidelines for Establishing the National Representative System of
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Marine Protected Areas. Australian and New Zealand Environment and Conservation Council, Task Force on Marine Protected Areas. Environment Australia, Canberra). It would also provide the first ever protection within Marine National Park Zones of the feeding habitats for endangered green turtles within the Bonaparte Gulf and the inter-nesting habitats of one the world’s largest populations of flatback turtles nesting at Cape Dommet.
● With respect of Arnhem Marine Park – a Marine National Park Zone in the Arnhem Marine Reserve is recommended by the CSIRO and would satisfy the Government’s long standing commitment to create a Marine National Park Zone within the Arnhem-Wessel bioregion (source: ANZECC TFMPA 1998). It would provide protection for known feeding grounds of a number of migratory seabirds nesting in Boucat Bay (Crested Tern/ Roseate Tern, Bridled Tern) and for Flatback turtles known to nest on the Cobourg peninsula and feed in these waters. Further, there are currently no oil and gas rights in the park – so a Special Purpose Zone (mining exclusion) should be declared as a complementary measure to a MNPZ.
North marine region Recommendations
1. We reject the large loss of Marine National Park zone in the North region – which reduces the coverage in the region to 1%. This ignores the Government’s own Review, which recommended it be increased by 10% and CSIRO advice which recommends that each marine park include at least one MNPZ.
2. We support the two increases of MNPZ - ● in the Oceanic Shoals Marine Park; and ● the increase in protection around the north Wellesley Islands within the Gulf of Carpentaria Marine Park (notwithstanding the large loss of MPNZ in that park overall).
3. We reject the draft management plans where the Marine National Park zones are reduced or removed entirely, ie:- ● in the West Cape York Marine Park- where the Marine National Park has been reduced by over half; ● in the Wessel Marine Park, where the Marine National Park Zones has been removed entirely; ● In the Gulf of Carpentaria Marine Park where the Marine National Park over the high value shelf habitats have been removed and replaced by lower value deeper habitats. The overall size of this MNPZ has decreased by over 60% of it’s original size.
3. We recommend that the following increase in MNPZ be made:- ● Introduction of a new MNPZ in the western half of the Limmen Bight Marine Park, as suggested by the Government’s own Review. This would complement the Northern Territory waters marine park, providing much needed protection to the shallow waters of Limmen Bight. ● Marine National Park Zones in those marine parks without any, being the Arafura, Arnhem and Joseph Bonaparte Gulf Marine Parks as well as reinstatement in those parks where the Government proposes to remove them altogether – Wessel and Limmen Marine Parks.
4. Mining - We support the Draft’s proposal to put in place no mining ‘Habitat Protection Zones’ in the West Cape York, Oceanic Shoals, Limmen and Wessel Marine Parks. These P a g e 26 | 27
zones do not go far enough though, still permitting mining infrastructure and pipelines to be constructed. Further, we recommend that the other key coastal communities adjacent to commonwealth marine parks be given protection from mining – at Tiwi Islands (the Oceanic Shoals Marine Park), Port Keats and Wyndham (the Joseph Bonaparte Gulf Marine Park), Maningrida (the Arnhem Marine Park), and Minjilang (the Arafura Marine Park).
In closing, we bring to your attention two reports by the Centre for Conservation Geography, which provide more detailed analysis on the proposed zoning in the draft management plans, and a separate analysis on the statements by Parks Australia in support of their zoning proposals - that the draft plans would protect the same number of conservation features as before, but with a smaller effect on users. Both these reports constitute part of our submission, and are appended.
We also recommend that in addressing the concerns in our submission, Parks Australia use the Scientific Principles for Design of Marine Protected Areas in Australia: A Guidance Statement, produced by the University of Queensland in consultation with 40 scientists, which provides clear science based guidance on design principles and criteria for the implementation of Australia’s National Representative System of Marine Protected Areas. The Statement is appended here.
Thank you for the opportunity to make this submission. We believe that final zoning outcomes are possible which address the legitimate concerns of affected fishers whilst not foreclosing on the significant tourism opportunities for regional communities, nor the contribution that science-based marine parks make to a sound marine management regime for Australia.
Michelle Grady, The Pew Charitable Trusts and on behalf of:
Adele Pedder, the Australian Marine Conservation Society Christabel Mitchell, Save Our Marine Life
APPENDIX 1 The Ecology Centre, The University of Queensland (2009) ‘Scientific Principles for Design of Marine Protected Areas in Australia: A Guidance Statement’. 29pp.
APPENDIX 2 Centre for Conservation Geography (2017) ‘The new management plans for Australia’s marine parks: Centre for Conservation Geography Critique’.
APPENDIX 3 Centre for Conservation Geography (2017) ‘Do the Australian Government’s proposed new management plans protect an equal number of conservation features?’
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