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Australian Office:
PO Box 439 Avalon
NSW 2107
Australia
+612 9973 1728
[email protected]
www.hsi.org.au
Head Office:
2100 L Street, NW
Washington, DC
20037
USA
301-258-3010
Fax: 301-258-3082
[email protected]
Officers
Wayne Pacelle
President
Andrew N. Rowan,
Ph.D.
Vice President
G. Thomas Waite III
Treasurer
Australian Office
Michael Kennedy,
Director
Verna Simpson,
Director
Australian Board
Peter Woolley
Jean Irwin
Elizabeth Willis-Smith
Patricia Forkan
Dr. Andrew Rowan
Michael Kennedy
Verna Simpson
Department of Sustainability, Environment, Water, Population and Communities
MBP submissions – Temperate East
Reply Paid 787
Canberra ACT 2601
By email to: [email protected]
15 February 2012
Dear Sir / Madam
Re: Temperate East Commonwealth marine reserves network proposal
Humane Society International (HSI), the world’s largest conservation and animal welfare organisation,
welcomes the opportunity to provide the following submission on behalf of 11 million supporters
worldwide, and 40,000 Australian supporters. HSI has been an active stakeholder in the marine
bioregional planning process that is currently underway. HSI recognise and support the Government’s
policy commitment at the 2010 federal election to implement a nationally representative network of
marine reserves by 2012.
The Temperate East Marine Region off eastern Australia provides critical habitat for humpback whales,
critically endangered species such as the grey nurse shark, threatened fish like the black cod and
deepwater sharks, and unique subtropical corals. The combination of tropical and temperate seas, deep
oceans, canyons, islands, seamounts and reefs ensures that there is ocean life found nowhere else.
And yet less than one per cent of the Temperate East Marine Region is currently protected from threats
such as fishing-related habitat damage, bycatch, overfishing, and mining and oil and gas exploration
and production.
th
On 11 November 2011 the Australian Government proposed a network of marine reserves including a
number of marine sanctuaries for the Commonwealth waters of the Temperate East Marine Region.
The proposed Temperate East marine reserve network covers only 25 per cent of the region. This
compares unfavourably with that proposed for the Coral Sea Marine Reserve (100 per cent of the
region), the South-west Marine Region (42 per cent of the region) and the North-west Marine Region
(33 per cent of the region). Only four per cent of the Temperate East Marine Region is proposed for
Marine National Park Zone protection. This again contrasts with the Coral Sea (51 per cent), the Southwest (22 per cent) and the north-west (12 per cent of the region)
Not one new reserve is proposed for the continental shelf (the high-level protection in the Cod Grounds
and Solitary Islands marine reserves already exists), and the proposed marine sanctuaries (or Marine
National Park Zone) cover zero per cent of the continental shelf.
HSI therefore believes that the reserve network needs to be expanded and its protection levels (and
particularly Marine National Park Zones) increased in area to ensure that the significant and diverse
features and habitats of the Temperate East Marine Region are better represented and protected. The
increases should be designed to make the Temperate East Marine Region network comparable to the
networks proposed for the South-west and North-west marine regions. Our comments that follow aim to
further elaborate on these points.
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Protect underwater icons
The proposed marine sanctuaries provide inadequate or no protection for the ten underwater icons of
the Temperate East, as shown in Figure 1. This must be rectified in the final marine reserve network for
the Temperate East.
Figure 1 – Marine sanctuaries proposed by the Australian Government for the Temperate East
planning region, overlaid with the zone of importance and underwater icons.
Protect all nine key ecological features
The draft plan identifies eight key ecological features with special conservation values, however it fails
to include the majority of the continental shelf as a ninth key ecological feature. Only shelf rocky reefs
and continental slope canyons off the edge of the shelf have been identified as key ecological features.
The continental shelf was identified as an important ecosystem in Brewer, D.T et al (2007), Ecosystems
of the East Marine Planning Region, a CSIRO report to the then Department of Environment and Water
1
Resources . Also identified as important in that report were the Lord Howe Plateau and the Caledonia
Basin, both found between Lord Howe and Norfolk islands. By leaving these three systems out of the
key ecological features, they have also been largely left out of the proposed Commonwealth marine
reserve network in the draft marine reserve proposal for the Temperate East.
The absence of the continental shelf from the list of key ecological features ignores the critical
importance it has to ocean life and the commercial and recreational fishing and tourism dependent on it.
This must be rectified in the final marine reserve proposal, with the continental shelf recognised as a
key ecological feature and protected over a larger area within the marine reserve network that includes
Marine National Park Zones.
The proposed marine sanctuaries also provide inadequate or no protection for the eight identified key
ecological features for the Temperate East. Middleton Reef is contained within an existing marine
sanctuary (Elizabeth Reef remains outside marine sanctuaries), but no additional protection is proposed
for this key ecological feature (Table 1). The proposed marine sanctuaries provide some protection for
the Lord Howe Seamount Chain, Norfolk Ridge and Tasmantid Seamount Chains and no protection for
1
Brewer, D.T., Flynn, A., Skewes, T.D., Corfield, J., Pearson, B., Alowa, J., and Young, J. W. (2007). Ecosystems of the
East Marine Planning Region. Report to Department of Environment and Water Resources. CSIRO, Cleveland. 150 pg.
2
the four remaining key ecological features (Table 1). This must be rectified in the final marine reserve
network.
Table 1 – Level of inclusion of key ecological features as defined by SEWPaC for the Temperate
East planning region.
Proposed
Existing
marine
marine
sanctuaries sanctuaries
Key Ecological Features
Canyons on the Eastern Continental Slope
0%
0%
Elizabeth and Middleton Reefs
0%
45%
Lord Howe Seamount Chain
6%
18%
Norfolk Ridge
20%
0%
Shelf Rocky Reefs
0%
0%
Tasman Front and Eddy Field
0%
0%
Tasmantid Seamount Chain
20%
0%
Upwelling off Fraser Island
0%
0%
Protect biologically important areas
Of the 161 biologically important areas mapped within the Temperate East planning region for 37
ecologically significant species, 160 fail to meet minimum scientific benchmarks for protection. For
example, no protection has been provided to the feeding grounds for little penguins that extend into the
Temperate East planning region (Table 2). One biologically important area (feeding grounds for black
noddy’s breeding at Lord Howe) has more than 30% of its extent within existing and proposed marine
sanctuaries within the Temperate East planning region.
Table 2 - Level of inclusion of biologically important areas as
Temperate East planning region.
Proposed marine
Common Name
sanctuaries
Antipodean albatross
0.1%
Black noddy
8%
Black petrel
4%
Black-browed albatross
0%
Black-winged petrel
9%
Campbell albatross
0%
Coastal (indo-pacific) bottlenose dolphin
0%
Common Noddy
7%
Flesh-footed shearwater
2%
Great-winged petrel
2%
Green Turtle
0%
Grey nurse shark
0%
Grey ternlet
8%
Humpback whale
0%
Indian yellow-nosed albatross
0%
Indo-pacific humpback dolphin
0%
Kermadec petrel
9%
Little penguin
0%
Little Shearwater
8%
Loggerhead Turtle
0%
Masked Booby
8%
Northern giant petrel
0%
Providence petrel
8%
Red-tailed tropicbird
8%
Short-tailed shearwater
0%
Sooty shearwater
0%
Sooty tern
8%
Southern giant petrel
0%
Wandering albatross
0%
defined by SEWPaC for the
Existing marine
Sanctuaries
0%
5%
0.2%
0%
1%
0%
0%
1%
0.2%
0.3%
0%
0%
1%
0%
0%
0%
1%
0%
1%
0%
1%
0%
1%
1%
0%
0%
1%
0%
0%
3
Wedge-tailed shearwater
White shark
White tern
White-bellied storm petrel
White-capped albatross
White-faced storm petrel
White-necked petrel
Wilson's storm petrel
3%
0%
10%
15%
0%
0%
0%
0%
0.5%
0%
2%
2%
0%
0%
0%
0%
Establish a Comprehensive, Adequate and Representative network
In 2009 Australian experts in marine conservation science provided a guidance statement to the
Commonwealth Government that contained advice on how a comprehensive, adequate and
representative network of marine sanctuaries could be established. There is a significant difference
between this advice and the draft proposals for the Temperate East.
The proposals do not establish the comprehensive, adequate and representative network of marine
sanctuaries required to protect marine life. Specifically:
a. Of the 11 bioregions of the Temperate East planning region, eight contain no proposed marine
sanctuaries.
b. Overall, the median representation of features important for the conservation of biodiversity
within the Temperate East planning region is 0%.
c. The marine sanctuaries proposed fail to form an interconnected network, with marine life
protected within each proposed marine sanctuary likely to face major connectivity issues.
The marine sanctuaries proposed in the draft plan for the Temperate East Marine Region are therefore
not comprehensive, adequate, or representative. Substantial improvement would be needed to satisfy
the primary goal set by all Australian governments in 1998 of establishing a national system of marine
sanctuaries to protect Australia’s unique marine life.
Identify and protect against all five major threats
Four major threats are identified in the draft plan, however one major additional threat has been omitted
- mining and oil and gas exploration and production. Based on the current marine reserve proposal,
mining and oil and gas exploration and production would be allowed in 68 per cent of the proposed
marine reserve network. These uses are permitted in the Multiple Use and Special Purpose zones,
2
which constitutes 252,387 km or 68 per cent of the proposed reserve network. None of the
Commonwealth shelf waters are zoned for protection from mining.
The Montara and Deepwater Horizon disasters exposed the risks to ocean life from the industry.
Damage to seabed habitats, pollution of surrounding waters by chemicals and oil spills, and noise
pollution from the industrial operations and seismic testing are all potential impacts of the industry on
the region’s conservation values. This impacts on the critical habitats of threatened marine species both
directly – through damage to seabeds as well as indirectly, driving marine life away from critical habitats
due to increase in ocean noise, both of which threaten the future of those species.
Mining and oil and gas exploration and production should be removed from the list of allowable uses in
the marine reserve network due to the risk the industry poses for ocean life. This would then be
consistent with the proposed zoning in the Coral Sea Commonwealth Marine Reserve, which is in the
northern part of the broader East Marine Region.
Build connectivity
The boundaries of the proposed marine reserves in Commonwealth waters should be linked to those in
nearby NSW state waters. Protection in Commonwealth waters can build on the successful
conservation of coastal areas, building connectivity, increasing resilience and maximising conservation
outcomes across jurisdictions. For many threatened marine species, these connections are vital as they
act as critical habitats in the form of migratory routes.
Commit sufficient budgetary resources
The Federal Government must commit sufficient budgetary resources to the establishment and
management of the reserve network, including the transitional funding needed for those commercial
fishers affected by the changes in protection and management. There is currently no Federal
Government budget commitment for any of the marine reserve networks proposed in its bioregional
4
marine planning process. This has significantly lowered the ambition of the government in terms of the
area and level of protection, which in turn has strongly influenced the design of the proposals by
SEWPaC.
Ensure that conservation of marine life is the primary objective
The primary objective in establishing the network should be the conservation of marine life but this has
been relegated to secondary status by the way in which the design goals and principles and selection
criteria have been established. HSI understands that the aim in the Temperate East Marine Region has
been to avoid fished areas and potential oil and gas exploration and production to minimise socioeconomic impacts. These impacts cannot assumed to be negative, as there is plenty of evidence here
and overseas that protection of the marine environment from such impacts can have positive social and
economic effects.
Most commercial and recreational fishing is concentrated on the continental shelf, the place where
much of the region’s diversity of ocean life is found. The current proposals keep open 95 per cent of the
Temperate East Marine Region to recreational, charter and game fishers. Without giving protection to
fished areas, the necessary recovery of marine life in the region will be undermined. The Temperate
East marine reserve proposal must therefore ensure marine life is protected as the primary objective.
Specific comments on the proposed reserves
Each of the nine reserves proposed for the network require improvement, either in terms of increasing
their overall size or the coverage of Marine National Park Zones within them.
Only the boundary of one of the proposed Multiple Use Zone reserves, Hunter, includes the shelf, while
the western boundaries of two others, Clarence and Jervis, stop at the shelf edge. In contrast, the Areas
for Further Assessment released by the Government in 2010 included extensive areas of shelf
suggesting it believed there were significant conservation values worthy of consideration for protection.
The proposed Marine National Park Zones do not include five of the nine key ecological features for the
region (Canyons on the Eastern Continental Slope, Shelf Rocky Reefs, Tasman Front and Eddy Field
Upwelling off Fraser Island and Elizabeth Reef). The remaining four (Middleton Reef, Lord Howe
Seamount Chain, Norfolk Ridge and Tasmantid Seamount Chain) would gain some Marine National
Park Zone protection.
Shelf rocky reefs, which are critical habitat for many species, one of the region’s ecological features and
a regional priority in the draft marine plan, are largely excluded from the reserve network, as noted
earlier.
Recommendations for new marine reserves in the network
A marine reserve should be created in south-east Queensland to protect the Fraser Shelf, Canyon and
Upwelling, as well as rocky reefs, feeding grounds for humpback whales and critical habitat for
loggerhead turtles. It is also an important spawning area for temperate small pelagic fish such as
sardines, round herrings and Australian anchovies, and significant for juvenile and adult white sharks.
Creating a reserve here would connect protected coastal waters, home to dugongs and migratory
shorebirds, to deeper ocean environments, including the iconic eastern seamounts. This area is
described in the draft plan as an important conservation value and as a regional priority, and was
previously identified by the Government as having significant natural values when the Areas for Further
Assessment were released in 2010.
A new marine reserve should be created in the Tweed-Cape Byron area that would include Tweed
Canyon, (only shelf-commencing canyon in the region) and Richmond Canyon, and offshore reefs of
Windarra Banks and Nine Mile. The mixing of tropical and subtropical waters, large canyons, and
features associated with the Eastern Australian Current combine to create an extremely significant area.
Seasonal currents off Cape Byron and the Tweed Canyon result in high numbers of fish and
invertebrates, attracting seabirds and predatory fish. Reef features such as the world-renowned
Windarra Banks dive site provide critical habitat for the critically endangered grey nurse shark. This new
reserve’s western boundary should connect with the NSW Cape Byron Marine Park to more effectively
protect this highly productive habitat and assist estuary-breeding fish such as mangrove jack to access
feeding areas in offshore reefs.
Conclusion
The Temperate East marine reserve network has the potential to provide significant protection for the
5
regions key ecological features, threatened species and the critical habitats on which they rely.
However in order to provide this protection, the marine reserve network must be expanded and its
protection levels increased to ensure that the significant and diverse habitats of the region are better
represented and protected. Marine National Park Zones, based on mounting scientific evidence, are
the best way to protect and recover ocean life in the region and ensure that nature conservation and the
maintenance of ecological integrity are the primary goals for establishing the network. Amending the
proposed Temperate East marine reserve network will ensure that Government objectives can be met
for the benefit of our marine life.
Yours sincerely
Alexia Wellbelove
Senior Program Manager
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