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Saturday, 8 September 2012

Commonwealth Marine Reserves submission DRAFT



Submission To Hon. Tony Burke MP, Minister for Sustainability, Environment, Water, Population and Communities


Commonwealth Marine Reserves Proclamation Comments
Department of Sustainability, Environment, Water, Population and Communities



Dear Minister,
Thank you for the opportunity to make a submission on the final Commonwealth Marine Reserves Network proposal.


I CANNOT and will not support this proposal to proclaim the final Commonwealth Marine Reserve Network, it is totally unacceptable and nothing but an elaborate anti-fishing campaign.

The model

The model of marine parks proposed to be introduced is the CAR model of marine parks. 

Comprehensiveness: The NRSMPA will include the full range of ecosystems
recognised at an appropriate scale within and across each bioregion.

Adequacy: The NRSMPA will have the required level of reservation to ensure the
ecological viability and integrity of populations, species and communities.

Representativeness: Those marine areas that are selected for inclusion in MPAs
should reasonably reflect the biotic diversity of the marine ecosystems from which they
derive.

The principle of this model is to select areas with each type of biodiversity of an adequate size that is a true representation of type of ecosystem, remove the treat these areas face, to act as an insurance policy should something happen to all the other areas, and so these areas can better handle the threats we cant control.

This model was chosen not because it is the best model to provide a safe guard to our ocean habitats but because it was the one that would have had the best chance of winning over the public and the hardest for opponents to fight.

I encourage anyone interested to read  “The long and winding road: The development of a comprehensive, adequate and representative system of highly protected marine protected areas in Victoria, Australia  Geoff Wescott”

http://seawaste.uwc.ac.za/archive/MPA%20Aus.pdf


This document explains why the CAR models was chosen, as well as the strategy to get the CAR model of marine parks implemented all across our country. This approach that has been taken proves the premeditation and intent to deprive the Australian Public of any chance to oppose or appeal, and thus in clear breach of the consultation process required.

Quote
“There are clear benefits for pursuing an ‘‘all or none’’ strategy for creating a CAR system of MPAs. Of the many attempts made in Victoria to obtain a highly protected MPA system it was the most comprehensive and most ambitious that proved successful, i.e. One which was for all ‘‘no-take’’ reserves and was for an entire suite, or system, of MPAs in one declaration.
The previous modest attempts at gaining one MPA ‘‘here’’ and a little later another MPA ‘‘there’’ meant that each and every proposal was weakened (either by a decrease in the degree of protection, or a decrease in area) before declaration. Historically the area by area (incremental) approach meant that there was little statewide support for a localised proposal but those opposed to MPA declaration were able to focus all their statewide and local resources to oppose each proposed MPA in turn, i.e. each proposal was ‘‘picked off’’ and weakened. By proposing an entire suite of MPAs simultaneously statewide support was garnered for the MPAs but the opposition now had to work against a whole range of proposals simultaneously. The better organised state-based conservation organisation were able to carry a central campaign direct to the parliament, politicians and decision makers based in the capital city , Melbourne, where over 75% of the state populations lives. Conversely the ‘anti’ campaign became fragmented when confronted with 24 MPA ‘‘battlefronts’’ simultaneously.
Also the argument of the ‘‘thin end of the wedge’’ was not as easy to carry in a CAR system proposal. Whilst when a single reserve was proposed in a local area opponents could argue that their favourite fishing spot was to be removed and the MPA was to cover say 15–20% of their local area—hence making ‘‘scare’’ tactics easier—it was impossible to argue that a reserve system that covered 5% of the sate (and no piers, jetties or heavily frequented beach fishing locations) leaving 95% of coastal waters available for fishing was a threat to the existence of recreational and commercial fishing. A 5% reservation could not be portrayed ‘‘as locking up the state’s waters’’.


The threats

So then we must ask ourselves what are the current threats our marine environment faces, and
what activities are not threats, there has been a lot of discussion in the media about “extractive activities” and they have been portrayed as a great threat to our marine life, and recreational fishing has been included as an extractive activity.
Recreational fishing takes in a wide range of activities, everything from catch and kill to catch and release fishing, with modern fishing gear it’s possible to be very selective in not only what species you target but what you to choose to kill for food should you wish.
 
We have had the Minister for the Sustainability, Environment, Water, Population and Communities the Hon Tony Burke, come out publicly a number of times stating that this proposal will have no impact on recreational anglers, as well as advocates from these marine parks stating the same.


Professor Terry Hughes, Director of the Australian Research Council Centre for Excellence for Coral Reef Studies, at James Cook University, is one of the authors of the scientists' statement. February 16, 2012
“At the moment there's almost no recreational fishing taking place within the Coral Sea, so we think it's not a good idea to encourage the development of widespread recreational fishing that's based on catch and release technologies.”

Pew's Coral Sea Campaign director Imogen Zethoven 30th Sep 2009

“In the Coral Sea there is actually VERY LITTLE recreational fishing and what we're finding is that the level of pushback (by Australian anglers) is disproportionate to the actual level of fishing that occurs there”

“And in fact when fishermen realise that the area we are proposing is very far offshore and they NEVER GO THERE then it's not an issue for them. So we are talking about a very SMALL impact and a very large community benefit that would last forever.”

Cairns and Far North Environment Centre marine campaigner Steve Ryan said


"A lot of these areas are beyond the continental shelf so most people don’t visit these remote reef system"

So if these statements are correct then recreational fishing cannot be viewed as a threat to these areas, and the question needs to be asked what are the current threats to these areas.

Recently we have had 2 ships with engine troubles, that if not for pure luck would have run aground on this precious area, vessels MV Vega Fynen on the 26th October 2011 and ID Integrity on 20th May 2011, have we all forgotten how close we came in  April 2010 when the Shen Neng ran aground on the GBR causing widespread damage to the reef.

http://asopa.typepad.com/asopa_people/2011/10/hmas-broome-averts-maritime-disaster-in-coral-sea.html


http://www.abc.net.au/news/2012-05-19/stricken-ship-narrowly-misses-reef/4021460

http://www.abc.net.au/news/2010-04-13/reef-damage-from-carrier-stretches-3km/393854

This marine park proposal does nothing to even reduce these incidents.

Then we have the advocates poster child
the whale plastered all over billboards and web pages.

( Frantzis 1998; Jepson et al. 2003). The International Whaling Commission’s Scientific Committee noted “there is now compelling evidence implicating military sonar as a direct impact on beaked whales in particular”(IWC 2004). Even a U.S. Navy-commissioned report stated that “the evidence of sonar causation [of whale beachings] is, in our opinion, completely convincing.” (Levine et al. 2004) Often whales show bleeding around their brain, in their ears, in other structures to do with hearing, and in other organs of their body (e.g. NOAA and U.S. Navy 2001; Fernandez et al. 2005). Mass strandings of certain types of whale increased dramatically after 1961 when more powerful naval sonars began to be used (Friedman 1989).

One scientist reported that 1/3 of all stranded cetaceans they necropsies had some form of auditory damage

Research shows that whales avoid sounds with a source level of about 120 dB (Richardson et al., 1995, Green et al., 1998) There are sound sources in the ocean that produce noise levels much higher than 120 dB:

1) Air guns used for oil exploration & geophysical research (216-230 dB)
2) Underwater construction
3) Explosives
4) Military sonars
5) Large ships
6) Acoustic harassment devices

These very loud underwater sounds may cause various adverse effects on marine mammals including:

1) Masking social communications used to find mates or identify predators
2) Temporary and permanent hearing loss or impairment
3) Displacement from preferred habitat
4) Disruption of feeding, breeding, nursing and communication
5) Stranding’s
6) Death and serious injury from haemorrhaging and tissue trauma

Public and scientific concern about underwater noise pollution has grown over the last decade after a series of mass mortalities of cetaceans associated with the use of mid-frequency active sonar in coastal areas.

The British Defence Research Agency reports that fish exposed to Low Frequency Active Sonar above 160 dB suffered:

1) Internal injuries
2) Eye haemorrhaging
3) Auditory damage
4) Fifty-seven precent of brown trout died after exposure to levels above 170 dB.

Here is what the WWF has to say on shipping and whales.
“Ship strikes are to blame for 90% of North Atlantic right whale deaths for which the cause is known (excluding deaths from natural causes such as old age). However, they are only one of the whale species directly threatened by shipping”

This marine park proposal does nothing to even reduce these incidents, Recreational fishing has absolutely no impact on whales.

Black Marlin, With the help of recreational anglers, scientist have confirmed with DNA testing that the Black Marlin the spawn in the Coral Sea are a separate group to the Black marlin of other areas, so the claim that Black Marlin numbers are declining globally is irrelevant, our Black Marlin don’t breed with other Black Marlin from areas like the Indian Ocean or South China Sea.

The Black Marlin fishery in the Coral sea is primarily a catch and release fishery, Between October and December, game boats criss‐cross the reef front in hope of hooking a giant black marlin. These can reach 700 kg in weight and achieve speeds near 130 km/h, making them one of the ocean's most prized game fish. Although the game boats have killed many black marlins in the past, today’s recreational fishing ethics result in the release of the vast majority of the fish they catch. In fact, the scientists took advantage of this catch‐and‐release practice to assist their research.

The habitat inside the GBR may hold the key. Juvenile black marlin can be found inside the GBR lagoon year round, indicating that it is a prime nursery area,” the researchers say.

“The lagoon likely has just the right combination of water temperature and prey availability to optimize the survival of the young marlin. Marlin are voracious predators right from hatching, and the ample supply of spawning coral reef fishes provides a rich diet of tiny fish for the marlin to eat,” Dr Domeier adds.

http://www.protectourcoralsea.org.au/media/transfer/doc/mcsi_marlin_gbr_13mar12.pdf

This area within the GBR marine parks has been as you call it protected for years under the same rules as this marine park proposal is attempting to impose on the Coral Sea, yet it has done little to protect this area, and anyone concerned about truly protecting our marine environment and the species that live within it should ask why? Before attempting to propose the same “protection” in other areas.

"Intense wet-season rainfall in January 2005 caused rivers in the Mackay–Whitsunday region of Queensland, Australia, to produce large discharges to the Great Barrier Reef (GBR) lagoon. The regional land use is dominated by sugarcane cultivation, beef grazing and urban uses. The high nutrient (nitrogen and phosphorus) fluxes from these land uses via river runoff produced a massive phytoplankton bloom in the GBR lagoon, which, after 9 days, had spread 150 km offshore."

"In high flow events, most of the rivers of north-eastern Queensland flow fresh to the mouth and estuarine processes take place on the continental shelf rather than in a traditional estuary (Devlin and Brodie 2005)"


http://www-public.jcu.edu.au/public/groups/everyone/documents/journal_article/jcuprd1_059685.pdf



The Science

Professor Terry Hughes, Director of the Australian Research Council Centre for Excellence for Coral Reef Studies, at James Cook University, is one of the authors of the scientists' statement. February 16, 2012 from a document signed by 300 scientist.
“At the moment there's almost no recreational fishing taking place within the Coral Sea, so we think it's not a good idea to encourage the development of widespread recreational fishing that's based on catch and release technologies.”

Marine scientist don’t think it’s a good idea to encourage catch and release fishing, marine scientist only know what they know about the species they study due to catch and release fishing, most of the time this tool vital to their research is provided to them free of charge and entirely at the cost of the recreational angler, for a scientist to say that we don’t want to encourage catch and release fishing is a political statement and not a scientific on and cannot be viewed in any other way, but this just goes to show how this anti-fishing campaign is working and even influencing our marine scientist that are all vying for the millions of dollars handed out in the of grants from our government and not only our environmental charities but international environmental charities.
Osprey Reef has been included in this marine park proposal as a highly protected area, a no fishing area. How and why? A scientific study that was used to justify including Osprey Reef as one of the highly protected areas, conducted a satellite shark tagging program to monitor the movements of sharks on a few reefs in the area, they found that the shark population around Osprey Reef unlike other reefs didn’t not move far from the reef, where on other reefs the sharks would disappear from the area for months at a time and some never to return the sharks at Osprey Reef, would rarely stray any distance from the monitored area. So it was used to justify giving this area a highly protected status as if the sharks stayed locally then they would be less likely to venture to unprotected waters, this by protecting this area it would greatly effective at protecting the sharks of the area.
But what the study also found was that the reason that these sharks at Osprey Reef don’t venture far from this reef is because shark feeding activities conducted on the reef have modified their behaviour, they have also modified the biodiversity, with the reef holding a larger population of sharks then other similar reefs, as well as completely changing the biomass and assemblage of the prey species of the reef.
Recreational fishing in this area does not target the shark species found here, and its only lightly fished, yet fishing has been banned yet the shark feeding that has already had an impact is allowed to remain, further more due to shark feeding this area is no longer a true representation of the biodiversity of an area like this thus does not comply with the principles of the CAR system.
Again this goes to highlight that this is nothing but an anti-fishing campaign with the science being used to justify the position, if you read the full research you cannot find any other conclusion that what is threatening the area is organised shark dives, and not fishing.

The Advocates

So again what are the threats to our marine environment?

Pew's Coral Sea Campaign director Imogen Zethoven 30th Sep 2009

What do mean by "fully protected"?

"No fishing, no oil and gas exploration - extractive activities would be prohibited. But of course COMMERCIAL SHIPPING would be permitted as well as tourism, yachting, and NAVAL ACTIVITIES. "

Not a single one of Australia’s environmental groups mentioned anything else apart from fishing as a threat to these marine areas,
in there first round submissions, when clearly the science and their own science mind you clear paints a different picture, this cannot be looked at anything  but an elaborate anti-fishing campaign.

Here is a scientific report looking at the Maria Island reserve in Tasmania, they tried to show that an increase number of lobsters resulted in a decrease number of the sea urchin showing a healthier ecosystem, but what they also found was that there was a huge decrease in the abalone numbers as well, to the point that they are now worried about its numbers. This shows that while removing fishing will see an increased numbers of the targeted species, and let’s face it we don’t need a report to tell us that, but it will also have an effect on the prey of the targeted species, some species may benefit while others will suffer. It just happens that most of the species that have been shown to be in need of protection are the very prey of the species we target, and if they disappear then no matter how many lines they draw on the map it will be all over.

“Changes within the remote Maria Island MPA(the largest) relative to references sites have increased in the abundance of lobster and susceptible fish (Latridopsis frosteri), increase in the mean size of rock lobster and a decrease in the abundance of prey species such as urchins and abalone
At Maria Island there was also a 30% decline in the abundance of common urchins within the reserve, which may be the first Tasmanian evidence of  cascading ecosystem effect related to protection from fishing, Abalone numbers were also observed to decline sharply in the period sampled. This change was interesting in that one possible explanation was an inverse relationship between predators (lobsters) and the prey (abalone). If shown to be correct this finding is likely to have significant consequences for the integrated, ecosystem based management of these two “species.”



Here in Victoria we have just recently had an audit on the Environmental Management of Marine Protected Areas by the Auditor-General, 2nd March 2011. Here are some high lights
"Parks Victoria could not demonstrate that it is effectively managing MPAs or that it is being effective or efficient in protecting marine biodiversity within MPAs. This is largely because dedicated funding for managing MPAs has been used for other activities. This has contributed to a lack of dedicated marine staffing and expertise, and a consequent lack of demonstrable activity to achieve management plan objectives. While dedicated funding for marine-related activities has not been used as intended, management and reporting systems within Parks Victoria are such that it is not possible to determine where these funds were applied."

"DSE is responsible for state marine environmental policy. However, it has not developed a policy to direct management of the marine environment—one that encompasses all marine areas, integrates well across catchments and coastal areas, and enables consistent planning across both MPAs and other marine waters to achieve agreed outcomes.
Shortcomings exist with planning at the state level. While Parks Victoria had developed a plan for marine national parks and sanctuaries—Victoria’s System of Marine National Parks and Sanctuaries: Management Strategy 2003–2010—it had neither fully implemented nor evaluated it before it expired in 2010"

http://www.audit.vic.gov.au/reports__publications/reports_by_year/2010-11/20110302_marine_parks.aspx

“Furthermore, the Auditor-General found $34 million of the $38 million the Labor Government provided to Parks Victoria for the management of marine protected areas could not be reliably accounted for.”

although I completely understand that this is a state issue and not a federal one, it goes to highlight the fundamental drive of or environmental charities and our governments with this need to lock users out of areas then instead of looking after those areas, fight for more areas to be locked up.


The detrimental effect of this proposal

THE US-based anti-fishing organisation Pew has admitted it pressured the Australian Government to lock anglers out of vast areas of the Coral Sea but would not take the same action in American waters because it would harm the US economy and disadvantage local fishermen.

http://www.fishingworld.com.au/news/pew-admits-it-targeted-australia-for-lockouts-left-us-alone

A USA tuna purse-seine fleet just recently agrees to pay Pacific Island countries over USD$600 million dollars to catch in-excess of 4 times Australia’s total fish production on the other side of your marine park line, this is a fishery that will now be closed to Australian Commercial fishers, you have closed down one of the best regulated fishing industries in the world and handed it over to one of the world’s worst.

To claim that these marine parks will have little effect on commercial and recreational fishing is complete false. Yes currently the commercial sector is responsible for extracting an Estimated catch (2009–10) of 4 tonnes excluding the Aquarium Sector, this is a drop in the ocean on what the industry could grow to in the future, going by the figures that the USA fleet has played, these marine parks have created a situation where Australian commercial fishers that operate under on of the best managed frameworks in the world are no looking gat the option of setting up overseas in countries that have little or no fishing regulations.
Marine Parks were developed for 3rd world countries with little or no management plans. Of course they have worked in areas where open slather and destructive fishing practises are employed, Australia has 100% management of it marine environment and the industry is totally self-sufficient, relies on no government grants and  pays its way for research, it is almost unique in the world, where they have to compete with fishers of other countries that have very highly subsidised fishing industries, Australia has the 3rd largest economic exclusion zone yet we are 52nd in the world as far as production is concerned. Fishing is the most environmentally friendly form of protein production known to man, it would stand on top when compared to other forms of food production, on a carbon and water footprint, on sustainability and its miles ahead on lack of environmental impacts.






This report from Living Planet index, by the WWF, clearly shows that these protection areas are not the silver bullet we are lead to believe, it clearly shows that while we have seen a steady increase of global protection areas, we have also seen a decline in species.
we need to protect the entire marine system, from the start of our catchment to the distant reef and deep water marine environments, with a unified approach and selecting small areas that someone says are of high value will offer little if any protection, until we change the gauge of success of conservation from how much area we have locked up to how the species are actually doing we will not achieve anything, we need to start by looking at the start of the food chain and not the end of the food chain, this approach of locking at what we have left and dividing that up between the sectors, needs to move to evaluating what we perceive we will need in the future amongst  all groups and start putting in measures in place  to ensure there is enough resources for everyone in the future, and these marine parks are not the way for Australia were we have the political will and economy to do more than the minimum we ask of third world countries. According to this report by WWF
Just 0.8% of Australia’s marine species are considered threatened, compare that to the others, and out of this O.8%, not one is a species targeted by anglers, in fact the only species to have become extinct are fresh water species that live in our national parks rivers, 20.2% of our mammals, 6% or our Birds, 5% of our Reptiles and 13.7% of our Amphibians are considered to be under threat. And yet we keep hearing that we need to do to our oceans what we have done to our terrestrial environment. In Australia we currently have 1/3( by size) of the world’s marine protected areas already, lets manage what we have properly before imposing locking out users from new areas.


Conclusion

As I mentioned above Minister Burke as well as the advocates for these marine parks all say that recreational anglers will not be affected by this proposal, if this is correct and looking at the other restrictions then nothing has been done to this area to claim it is somehow protected, protected from what? Either anglers of today or anglers of tomorrow will be effected by this proposal or very little has been done, if one was to agree with the propaganda that fishing is somehow a threat, yet at the same time this preoccupation with an anti-fishing campaign has seen that the issues that do threaten these areas have been completely overlooked by everyone, I have yet to see a detailed report on what the real threat these areas face today, not from third world countries that have no fisheries management, not from island areas that have a population of 50 people, not from a report that is tittles “how fishing effects…. (insert whatever you want)……” , but a reel report from our own area that have no pre conceived,  conceptions of the outcome. We keep hearing about this precautionary principle but how is banning an activity that everyone agrees is not a current threat and ignoring the threats the area faces today precautionary in any way shape or form?


This proposal can only be viewed as an anti-fishing stance by our government, as it panders to minority groups and international groups like PEW, with the potential to significantly impact on future generations, while offering little in the way of protection for our marine environment, and the current government can only be viewed as hostile to anglers interest.
How can you claim that this is in any way protection for the area, removing an activity that is practised on a very small scale in the area, yet ignoring the activities like commercial shipping and naval activities that if anything will increase in the area in the future?

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