Australian Marine Alliance SA submission to Department of Environment, Water and Natural Resources Regarding the Current Proposed Zoning

Arrangements for the SA Marine Parks Network

Copyright 2010

Table of Contents

Foreword - The State Of World Fisheries Ray Hilborn .............2 Opening Statement.... 7 Brief Report on the Marine Parks Process.. .. 12 A Common-sense Cost Effective Approach to Implementing (Re-Categorising Existing) Marine Parks/Reserves in South Australia.21 The Cost of Impacting On Fisheries...28 Conclusion30 References31

Foreword

Ray Hilborn The state of world Fisheries As spoken by Ray Hilborn in a video speech: The world view perception status of fisheries and impact on marine ecosystems. In the 19 century there was concern about fisheries. Gastron 1900 the fisheries are not exhaustible but in a rapid and continual process of exhaustion he said that the rate that sea fishes multiply and grow even in favourable season is exceed in the rate of capture. The science of understanding the impacts of fishing developed all through the beginning of the 19 hundreds. By the 1950s what we call the modern science of fisheries management had pretty well been developed and ended up codified in a series of books was built around the concept of sustainable yields and maximum sustainable yield and the bio mass that produces maximum sustainable yield. In the 1970s and 1980s these concepts were written into law. Particularly the international Law of the Sea which solidified the concept of sustainable fishing and trying to manage the fisheries around the level that produces maximum sustained yield The world has always been a little more complicated than that , for instance John Gulland who was the best well known fisheries scientist 0f his era. He once sent me a quote which was the definition of the maximum sustainable yieldIts a quantity that has been shown by biologists not to exist, and by economists to be misleading if it did exist, in short it is the key to modern fisheries management. This theory was in place by the 1960s when countries were extending their jurisdictions out to 200nm, all of a sudden countries really started to think about managing there fisheries. Initial fisheries management was reactionary, you would wait until there was a problem; until yields were declining dramatically and fishers were complaining and then something might be done. Most fisheries in that era were open access there was no limitations, anyone who wanted to go fishing in a country would just go out and buy a licence for a hundred dollars. Countries started becoming proactive they started introducing licence limitation. Late 1970 early 1980s Australia and New Zealand were among the world leaders in this kind of fisheries management. Almost all countries are and modern developed countries were introducing something like modern fisheries management systems. In the 1990s a long series of papers of concern about the status of fisheries began to emerge. These papers had enormous public impact. The ones I am going to mention all got coverage in American Major Newspapers New York Times and several of them got front page coverage. The first one was actually a paper that I was one of the coauthors in 1993 authored by Don Ludwic who was a leader Author. We basically argued that fisheries inevitably ended up over exploited because we waited too long to begin management measures. In 1998 a very influential paper, perhaps the most influential paper in fisheries that has ever appeared came out published by Daniel Paully and several authors on the concept of Fishing down the marine Food chains. The basic idea of that paper was that fisheries began by catching the big valuable species and over time fished down the food chain. Ultimately all were going to end up with left in the Marine Ecosystems is jelly fish. Then another very high profile important paper came out in 2003 by Ron Myers and Boris Worm that looked at Japanese long line data catch rates and basically argues that all large fish of the ocean Tuna/Billfish had been depleted by 1980 to only 10% of their original biomass. This string of paper had a very significant impact on the 2

public, journalists and even most scientists perceptions about the state of fisheries. Almost every paper about fisheries begins with almost an obligate reservation of this litany of disaster. I might just read one, this came out in 2005 it was published in the journal nature and repeats what I would call the common excepted beliefs. Fishing in the oceans is no longer sustainable; worldwide we have failed to manage the ocean fisheries, in a few decades there may be no fisheries left to manage. So what should be done? Incessant hunting with increasing technological proficiency has decimated fish populations worldwide. Catches of large marine species such as swordfish and tuna have declined by 80% over the last 20 years- incidentally thats wrong they have actually increased by 10 times in the last 20 years but it is a good story. Northern cod historically a dietary main stay species once thought to be inexhaustible is all but commercially extinct in the western North Atlantic. In many areas bottom trawl has scoured the seabed clean. These are just a few examples of the long and miserable record of hunting the oceans. This world view is depicted quite dramatically in the recent movie the end of the line. Then in 2006 came the ultimate paper, this made the bbcs evening television news because it argued /claimed that all fish would be gone by 2048 if we didnt change our ways. This paper got enormous push back by the scientific community who works in fisheries that it was just silly. Many fisheries in the world are well managed, yes some places may continue to get worse yet some others get better. As a follow up to this paper lead author of the paper Boris Worm and I were on an American radio show and I discovered he was not this horrible monster and he seemed like a reasonable guy I had never met him before. We started talking and decided to put together a team representing the entire spectrum. From very green ecologists to people who work in hard-core fisheries management, we were going to try and understand why we had such differing perspectives about the status of fisheries. We got funding from the National Science Foundation with an initiative to meet four times and we put together a team of 21 people representing literally everyone imaginable. We produced a paper in July 2009 that summarised our work, Boris and I initially agreed on is to look for places where we could track could track the abundance of fish. Almost all the early work whether it was Worm 2003 paper that said all fish would be gone by 2048 or Paulys fishing down food chains used catch data that was assembled by the FAO (fisheries & Agriculture organisation). They assumed that the catch represented abundance. So if catch went down abundance went down. We said lets go back to places where we could actually track the abundance of fish. Either by surveys, scientifically designed surveys or through the complicated process of fisheries stock assessment. What we attempted to do was assemble as many surveys and stock assessments we could find for the entire world. In the end we ended up with the developed countries of the world, Europe, North America, Australia, New Zealand and a few other places. What we found was that through almost every ecosystem we looked at fishing pressure had been reducing in the recent past. The amount of fishing pressure was at levels that would produce in the long term maximum sustainable yield. So in other words fisheries management systems were working to reduce fishing pressure to get it to levels it should be. Some systems to me showed to me surprisingly rebuilding, one that surprised me was New England which had always been the whipping boy of American Fisheries and the biomass of large fish in New England has been growing quite dramatically in the last 20 years and the reasons are of dramatic reductions. Those catch reductions looked like collapsing stocks if you look at catch. When you look at abundance whether by survey or stock assessment, the abundance had been rebuilding. We also found that three areas Alaska, South Eastern Australia and New Zealand had never been systematically over fished. Some individual stocks in those areas had been overfished but as a whole ecosystems had managed to avoid overs fishing. Still we found that about two thirds of stocks were still below that targeted levels that would produce maximum sustained yield. Perhaps more interesting we found that about 15% of stocks we looked at were quite badly depleted that is perhaps below 10% of where they would be have been in the absence of fishing. When we looked across the range of cases and said well why are these fisheries that are 3

rebuilding doing so well. We basically found there is no magic bullet there is nothing simply, like ITQ or MPA that led to success. That in every case we found fisheries quality improving, it was because there was a strong central government that had been able to implement a whole range of techniques not just one thing but catch limits, effort limits, gear restrictions and a lot of closed areas, NOT MPA but temporary closed areas to protect spawning fish or to protect juveniles or something. The second big result I would say is that when you fish at a level that produces maximum sustained yield you reduce fish abundance by a lot, by the order of 60 70% and some species get depleted there is no way around that. If you want to catch fish there is going to be fewer fish in the ocean and given that most of the worlds fisheries involve some kind of mix of species, the less productive species will be overfished at times that you are maximising sustainable yield from all the stocks. You can moderate the ecosystem impacts to some extent by fishing a little less than what produces maximum sustained yield and by technological innovation but the idea that you can somehow catch fish and have everything in the ocean in good shape just does not seem to be possible. There is a trade of between ecosystems impacts and yield. If you want to have no environmental impact you cant fish, that is a simple fact of life. Fishing has received an enormous amount of criticism from the environmental groups and with particular emphasis on bottom trawling. As many people may be aware the Canadian chain loblaws stores have stopped selling hoki. This is due to pressure from environmental groups even though hoki has been certified by the Marine Stewardship Council as a well-managed fishery. Part of this is the hatred that environmental groups have with bottom trawling, quote from Greenpeace websiteEnormous bottom trawl nets are dragged along the seafloor catching all marine life and killing all habitats. They swallow and destroy everything in their path. And thats the kind of thing that has led to Loblaws stores not selling Hoki. The public is confused, back in January I was working with a college from the Frankford Zoological Society who directs there African program. He showed me the cover of Time magazine from November 2009; it had a picture of a Tuna bleeding. He said Tell me, should I stop eating fish? I really love sushi should I stop eating fish? so I said Well whats the alternative? He said Chicken, pork beef, there is no way I am becoming a vegetarian, my ancestors came out of the trees and worked their way through Africa and up the food chain over the last 3 million years, I would not want to dishonour them by becoming a vegetarian. This question prompted me to think about things I had seen recently. One was I was at a meeting on the convention on biodiversity and the FAO on the impacts of fishing and some people showed me a paper on the energy efficiency of different methods of producing food. I was surprised that fishing on average was more efficient than any form of producing meat. More efficient than chicken, pork or beef. Much more efficient than beef and a little more efficient than chicken.

I came across another paper on carbon footprints; again fishing had a lower carbon footprint than any other form of

producing meat which surprised me. So if you really think about it and start comparing impacts of fishing on the enviroment with the impacts of meat because if someone is not going to eat meat thats life, and the demands for both are growing quite dramatically around the world. So if greenpeace does not want people to eat hoki then that means more meat is going to be eaten, thats as clear as can be. So if you think about other comparative impacts fishing is amaziing in that it requires no water uses no pesticides uses no fertilizer uses no anti-biotics and does not cause any soil errosion. So on those measures of enviromental impacts fishing just has any form of agriculture beat by a mile!

The big criticism of fishing has been impacts on bio-diversity. If you look at the literature on the impacts of fishing there is quite an extensive literature, for instance people compare the abundance of fish inside a MPA to outside. What you find is there is more fish inside a MPA abundance outside is usually 50 70% and the diversity; that is the number of species in fished areas is about 30% lower than in unfished areas and these are the kinds of diversity impacts that the environmental groups worry about. Similarly if you compare trawled to un-trawled places you see roughly similar kinds of differences. On average abundance is 50 70% less and the species diversity is about 30 % less. Trawling is quite variable on soft sediments, on mud or sand there is almost no impact of trawling, on hard bottoms with a lot of epi-benthic flora and fauna the impacts can be 80 90% or even more. If you think about the standards we have in fisheries and the best international standards, the most common is the Marine Stewardship Council. I remember the first time I encountered the marine stewardship councils criteria was reviewing the West Australian Rock Lobster certification. I came across principle 2 of the marine stewardship council and it says fishing operations should allow for the maintenance of the structure productivity function and diversity of the ecosystem including habitat and the associated dependant and the ecologically related species on which the fishery depends. Now that is a pretty high standard! I remember at the time thinking wow farming would never stand up to that, it is very clear that no form of agriculture could possibly claim to maintain the structure and function of the ecosystem. Green groups are criticising farming as well and I understand that they have been particularly aggressive on the New Zealand dairy Industry, which has been expanding a lot but I do not hear them saying you should not drink milk! Or you should not eat meat! they will criticise the group, but somehow theyre saying you shouldnt eat Hoki or you shouldnt eat all sorts of a range of species. I think only about 3 % of New Zealands fish productions would qualify as something you should eat by the forest and birds List. So the question is: why are fisheries been held to a totally different standard. One simple number is that If you wanted to replace the worlds fish catch with animal protein produced by grazing which is essentially where much of the expansion of meat production is coming from you would need to cut down the entire rainforest of the world 22 times over, thats the biodiversity cost of getting rid of fishing. If you were to just ban trawling, thats the bad boy about of the worlds fish production is produced by trawling. So you would need 5 times the worlds rainforest to produce the fish equivalent produced by trawling. The point here is that if we consider the impacts of not eating fish on bio-diversity they are quite a bit higher than those of eating fish. One way to reduce impact is to not eat meat because meat takes a lot of land and causes a lot of 6

problems. If you compare fishing to farming, my wife used to be an organic vegetable farmer. She had five acres of vegetables. She had one hundred subscription customers she sold to the farmers markets she sold to restaurants. Organic farming in some sense is the greenest form of food production! BUT those 5 acres had been rainforest in the North West of the U.S.A. and I guarantee you there was NO remaining bio-diversity! It was completely transformed to something else. So I think a good case could be made that any form of fishing has less environmental impact than organic vegetable farming! The amount of land is not the same, the fact is fishing is one of the few forms of producing protein for food that largely leaves the ecosystems intact.

OPENING STATEMENT
The AMASA is grateful for the opportunity to submit a common sense forward thinking submission to the government in relation to zoning within South Australian Coastal waters Marine Parks. The AMASA does not support the governments current concept of marine parks or zoning in SA coastal waters. We say NO to the 19 marine parks, 81 sanctuary zones, 20 Restricted Access Zones, 56 Habitat protection zones, 29 general managed use zones and 49 Special Purpose Areas as listed below: Far West Coast Marine Park 1st may to 31st October Inclusive zoning = RAZ2, SPA-1, SPA3 and SPA4 1st November to 30th April inclusive= RAZ-1, SZ-1, SPA-1, SPA-2, HPZ1 SZ2 and SZ3 Nuyts Archipelago HPZ-1, SZ-1 GMUZ-1, HPZ-2, GMUZ-2, HPZ-3, SZ-2, HPZ-4, GMUZ3, HPZ-5, HPZ-6, SZ-6, HPZ-7, SZ-7, SZ-3, SZ-4, SZ-5 SZ-6, SPA-1, HPZ-8, GMUZ-4, SZ-9, SPA-5, SZ10 West Coast Bays Marine Park HPZ-1, SZ-1, SPA-2, RAZ-1, SZ-2, SZ-3, RAZ-2, HPZ-2, SZ-4, SZ-5, SZ-6, SZ-7, GMUZ-1, SZ-8, SZ-9, SPA-1 Investigator Marine Park SZ-1, HPZ-1, HPZ-2, GMUZ-1, HPZ-3, SZ-2, HPZ-4, GMUZ-2, HPZ-5, SZ-3, HPZ-6, GMUZ-3 Thorny Passage Marine Park SPA-1, HPZ-1, HPZ-2, HPZ-3, HPZ-4, HPZ-5, SZ-1, SZ-2, SZ-3, SZ-4, SZ-5, SZ-7, SPA-2, SPA-3, SPA-4 Sir Joseph Banks Group Marine Park HPZ-1, SZ-1, HPZ-2, GMUZ-1, SZ-2, SZ-3, GMUZ-3, SZ-4, SZ-5, GMUZ-4, GMUZ-2, RAZ-1 7

Neptune Islands Marine Park SZ-1, RAZ-1, RAZ-2, HPZ-1 Gambier Islands Group Marine Park HPZ-1 Franklin Harbor Marine Park SPA-1, SZ-1, SZ-2, SZ-3, HPZ-2, SZ-4, SZ-5, SPA-3, SPA-4, GMUZ-1, SPA-2, HPZ-1 Upper Spencer Gulf Marine Park SZ-1, SZ-2, SPA-1, HPZ-1, SZ-3, SZ-4, SPA-5, SZ-5, SPA-5, GMUZ-2, SPA-3, SPA-4, SZ-7, SPA-5, SZ-8, HPZ-2, SPA-5, HPZ3, SPA-5, SZ-9, SZ-10, SPA-2 Eastern Spencer Gulf Marine Park SZ-1, HPZ-1, GMUZ-1, SZ-2, SZ-3, HPZ-2, GMUZ-2 Southern Spencer Gulf Marine Park HPZ-1, SPA-1, HPZ-2, SZ-1, SZ-2, GMUZ-2, HPZ-3, RAZ-1 ALTHORPE ISLAND, RAZ-1 HAYSTACK ISLAND, RAZ-1 SEAL ISLAND Lower Yorke Peninsula Marine Park SZ-1, HPZ-1, SZ-2, SPA-3, SPA-1, GMUZ-1, SPA-2 Upper Gulf St Vincent Marine Park SZ-1, SPA-1, HPZ-1, SPA-2, GMUZ-1, SZ-3, SZ-2, SPA-3, RAZ-1, SZ-3 Encounter Marine Park GMUZ-1, SZ-1, SZ-2, HPZ-2, HPZ-4, HPZ-3, SPA-9, HPZ-1, SZ-3, SZ-4, GMUZ-3, SPA-1, SZ-5, GMUZ-2, GMUZ-4, HPZ-5, SPA-2, SZ-8, RAZ-1, SPA-3, GMUZ-5, SPA-4, SZ-9, SPA-5, SPA-7, SZ-10, SZ-11, RAZ-2, RAZ-3, GMUZ-6, RAZ-4, SPA-6, SZ6, SPA-10, SPA-11, SPA-12, HPZ-6, SPA-8, SZ-7, GMUZ-7 Western Kangaroo Island Marine Park SZ-1, SZ-2, HPZ-1, RAZ-1, RAZ-2, RAZ-2 (CASUARINS ISLETS), RAZ-3, HPZ-2 Southern Kangaroo Island Marine Park SZ-1, RAZ-1, HPZ-1, HPZ-2 Upper South East Marine Park SZ-1, HPZ-1, GMUZ-1, HPZ-2, SZ-2, SPA-2, HPZ-3, GMUZ-2, HPZ-4, SZ-3, SPA-1, Lower South East Marine Park SPA-1, HPZ-1, SZ-1, HPZ-2, GMUZ-1, GMUZ-2, HPZ-3, SZ-2, SPA-2 8

The Australian Marine Alliance asserts that the current government proposal: will result in a significant change in the way the South Australian coastline and marine environment will be managed, the huge unnecessarily impose of resources allocation which in turn will impact upon the commercial and recreational fishing sector across the state; has been progressed via an appalling and unsatisfactory process, with identified concerns regarding transparency and accountability1; has been presented to the communities and marine users under false pretences and a biased uninformed knowledge based. has not demonstrated how desired biodiversity conservation outcomes will be delivered through zoning the states network of marine parks; has failed to demonstrate what (if any benefits) will be achieved by zoning vast areas of our coastal waters without addressing the full suite of threats; has failed to provide sound scientific justification for zoning implementation and at what cost to community. has failed to deliver a firm marine parks management plan with a clear and costed strategy for compliance, monitoring, evaluation and research. has not presented any solid management plan of displaced effort or any costings associated with license, quota, or entitlement buyback scheme. The modelling of displaced effort for the governments current zoning proposal undertaken by SARDI2 has produced very poor and erroneous results, yet the data was still used. The Regional Impact Assessment (RIS) prepared by Econsearch 21 August 2012, appears to be a very broad document which has been designed, modelled, and written to support government political outcomes rather than a realistic assessment of the real impact that the Marine Park will have on the local communities and the state. Has been pushed onto communities by the government with a biased agenda influenced by environmental lobby groups. Countless errors and misleading information has been printed in government documentation.

The current government proposal gives no consideration to the current management arrangements and measures already in place within the marine environment of our state and country. These are: Australia is ranked second in the world for sustainable fisheries management Fisheries over the last ten years have been managed under an ESD (Ecologically sustainable development plan) where they dont just manage the fish species but also the habitats SA has already 3.1% of state waters under protection 3.This figure has since been identified to be under calculated by at least 3 %, given the other protection orders in place it is approximated to be around 6 to 8%. There has NOT been a single extinction of a marine fish or invertebrate in Australia 9

Wild harvest Fisheries production has the lowest carbon footprint of any food production in the world4 (see foreword) 75% of seafood is currently imported into Australia5 Australia is one of three countries to already meet its 2020 target for the protection of biodiversity 6. In 2011 the United Nations Environment Program (UNEP) calculated the entire area of the global MPAs was around 2.2 million square km, and that Australia had over 38% (840,000 square km) of this area. This was before the planned addition of 19 large marine parks in state waters in South Australia last year, not to mention the federal bioregional planning process. 840,000 + 2,396,216 = approx. 3,236,216 km2 of MPAs in Australia (both state and federal) marine parks. Australia will hold more MPAs than any other country in the world totalling 70.4%.7 Not only will we hold 70% of the total global MPAs we will hold more sanctuaries than the rest of the world combined! In the Janine Baker9 (2000) report commissioned by DENR she highlighted threats to the inshore marine ecosystems and biodiversity for SA as: The continued loss of habitat due to sewage and/or stormwater discharges, industrial developments, and degradation of reefs by sedimentation. Damage to reefs from boats, anchors and SCUBA diving activity Urban and rural waste as solids and chemical pollution heavy metal contamination by-catch and damage from trawling introduction of pests and diseases in ballast water aquaculture discharge Oil spills

Currently in SA waters; 100% of seagrass is protected 100% of Macro algae is protected All marine mammals such as dolphins, whales, seals, sea lions are protected Majority of seabirds both shore and migratory are under protection as well as their nesting areas under several ACTS and Treaties All Syngnathidae species (i.e. sea dragons, sea horses) and solenostomidae (ghost pipefish) are protected All intertidal reefs out to 2m in depth are protected Mangroves are protected under 3 ACTS and currently 56% of mangroves are currently in 7 existing aquatic reserves 10

Blue groper is protected and prohibited to be taken in Gulf St Vincent, Spencer Gulf, Investigator strait and backstairs passage all year round( etc. etc. could go on and on)

Federal Environment Minister, Tony Burke8, stated in a letter dated Jan 2011 that SA is required by the Commonwealth Government to have 10% under management NOT in strict Sanctuary or no take zones. South Australia waters are 100% under management through various ACTS, so SA has already exceeded its obligation. 3 recent Sanctuary zone audits in Australia revealed that when large sanctuary zones were implemented there were no clear benefits to the marine environment or to the communities. Benefits have only been proven overseas where fisheries management is poor or non-existent. The marine reserve network options submitted below by the Australian Marine Alliance SA would minimise all impacts on commercial fishing industry, the recreational fishing sector and communities but still significantly deliver on Australias international commitments to marine biodiversity conservation; The AMASA stress that we are strong supporters of marine conservation under the current care, control and management of PIRSA. We believe that to protected marine biodiversity in South Australian coastal waters we need to first address the already identified issue of pollution. A risk assessment completed for Gulf St Vincent clearly identified the threats to biodiversity are directly related to Government Infrastructure (EPA 2009 A RISK ASSESSMENT OF THREATS TO WATER QUALITY IN GULF ST VINCENT)

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Brief Report on the Marine Park Process under the guidance of the Department of Environment and Heritage
This report has been produced as a result of continued mistreatment of the rights of fishers and total disregard for due processes. In this report the aim is to describe how communities/fishers have not been heard and how coastal communities/fishers have been disregarded in the processes conducted by the Department of Environment within South Australia. Statements will show how little knowledge the Department has and how they should never have been chartered to carry out something which is quite clearly beyond their knowledge.

Outer Boundaries proclaimed on 23rd July 2009

Proclamation of the outer boundaries and prior events should be mentioned as it shows the attitude and the stealthy way in which DEWNR staff have conducted themselves. The first contact made for the outer boundaries fishers can report from the area of Lower Yorke Peninsula was at a meeting held at Minlaton in 2006. At this meeting DEWNR staff described the outer boundaries as being inconsequential to fishers and it was nothing to be concerned about. They briefly described that there may be Sanctuary Zones which would be small and would quite simply not have any effect on current activities. It was noted they quickly breezed over any zoning and it was undecided as to what was going to happen. Fishers left feeling confused as to what was going on but suspicious as DEWNR was entering their marine environment with a new set of rules. 2008 Fishers/ community members report DEWNR set up a tent on the foreshore located near the jetty at Port Victoria. One DEWNR staff member entered an establishment and conversed with the staff there. The staff mentioned/asked why DEWNR were here as the Government had already decided where the outer boundaries were going and communities/ fishers would have no say in what was happening?. Very Little community involvement and confusion IS apparent. Industry Involvement consultation committed under duress. (*refer constitution common law equity) Proclamation/change in law or ownership of anything previously owned or utilised by the common man/communities would need a referendum an election or a change in the constitution to become law. In 2009 the outer boundaries were proclaimed by the Government under the guise of not impacting and being quite simply put nothing to worry about. Industry involvement was committed under duress; there was little community involvement with poor/confused understanding. To the best of our knowledge the Government has acted in a manner that could be seen to be in breach of our rights under equity. This has not been an Industry/community initiative and has been forced upon the people of South Australia.

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No Consultation Period There has not been a consultation period as was promised.

DEWNR staff member describing the consultation period has not started. In a breifing at the Port Victoria town hall Denr Staff member David Pearce described that the consultation period would start after the Lag. http://www.youtube.com/watch?v=ICAR0IjAN4U Also Chris Thomas described a consultation process in a breifing with the MP 11 Action Group which was recorded after permission was granted by DEWNR staff. Chris said they would consult for at least 3 months as it was such a big issue for communities. DEWNR Documentation of the Marine Park Management Planning Process describes a Consultation process after the release of the Draft Management plan. This process has been changed to a review period . Leading up to the release of the Draft Management plans the public was led to believe there would be a consultation period. Consultation is meeting with people NOT expecting the general public to have to fight against governmental decision makers through writing an indepth submission which should meet certain criteria to which the decission maker has set the rules. Judge Jury & Excutioner! This is hardly democratic

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BIASED FORM

Please AGREE to the following by ticking the boxes. I am committed to the creation of Marine Parks in my local area, I am prepared to be an advocate for marine parks in my local community, I am committed to attending local meetings. This is quite blatant ! They were looking for community members who were going to help advocate for Marine Parks. If this is the case then it would hardly be an unbiased structured view. 14

BIAS MISTRUTHS written by DEWNR and placed on the South Australian Strategic Plan site (screenshot)

http://saplan.org.au/targets/69-lose-no-species This screeshot was originally taken from the above link (South Australian Strategic Plan Website). The above information has since been removed. It is quite clear the author has an opinion about the cause in decline of both the Australian Sealion and the Giant Cuttlefish. These comments are slanderious and shows DEWNRs opinion of fishing. 15

Rapid Assessments produced by DEWNR example of errors in information Environmental values that are represented in this zoning option between 10-19%: Cosema endangered macroalgae Rocky reef (0 to-10m) Soft bottom habitat (0 to -10m)

The statement made by DEWNR above is not correct, according to Karen Edyvanes research there is no macroalgae under threat, however it is protected under the Fisheries Act 1982 and the Vegetation Management Act 1990. MP13, quite obvious errors in the diagrams below in the rapid assessment, the depth data is incorrect. If you look at the unmapped areas 0- 10m then compare with the soft bottom habitat you will notice the are 0-10m runs out past the 30m contour. Quite obviously this is a serious error and makes the planning process flawed. Macroalgae (0 to -10m)

Macroalgae (-10 to -30m)

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Unmapped (0 to -10m)

Soft-bottom habitat (-10 to -30m)

The same has been repeated throughout the states marine park rapid assessments. The information is not correct.

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Propaganda produced by DEWNR pulling at the heart strings. (Preserve habitats of our unique species as well as the recreation and livelihood of those who use the sea.) How could we possibly say this is not about fisheries management?

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DEWNR staff misinforming http://www.youtube.com/watch?v=rawRpn1RxHk&list=UUPNl9NbqFafUq3TS0hqYGvA&index=1&feature=plcp This YouTube video shows a member of staff from DEWNR misinforming the public. The Video was recorded on January 9th 2011.

00:03

00:03

http://www.environment.sa.gov.au/files/259a3fa6-b648-48bb-83d2-9e6700be1472/mp11-factsheet.pdf The above link opens up a DEWNR document which was produced on November 12th 2010. In the document it clearly states The State Government has not adopted an arbitrary percentage target for the size of sanctuary zones. Instead, it remains open to the advice of the community as to how to best design the marine parks network to protect and conserve marine biodiversity and marine habitats in a manner that accords with the objects of the Marine Parks Act 2007. This was backed by Tony Burkes letter in response to Gary Morgans question on the AICHI BIODIVERSITY TARGETS adopted by Australia; Tony Burke clearly states the targets are aspirational and not binding on Australia. Why were DEWNR staffs informing the public they are OBLIGATIONAL!!!

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00:19 traditionally our oceans have been open slather. This is not correct and quite obviously fisheries management 00:35 A lot of species are in decline. Identifying that fishing is a threat. 00:40 Commitment to put 10% of every jurisdiction around the world in a sanctuary zone. Wrong 01:05 happening in commonwealth and State waters. Identifying a commitment that does not exist. 01:12 commitment has been made at an International level which has led to a state commitment as well and the writing of the legislation to create the marine parks. Quite clearly DEWNR are making it sound like we have little choice in this matter. 01:57 its a preventative approach, adopted by the government seen as responsible stewardship of the ocean. 02:26 the current science recommends 10% of our oceans be locked away you are safeguarding your marine resource. Fisheries management, there is no science

The video goes for 17 minutes it is full of misinformation. Throughout the state DEWNR staff have been saying they have a huge amount of scientific Data to back up claims that Marine Parks are a solution to a precautionary principle created problem. This is simply not true in fact one of the Scientist enlisted by DEWNR to be part of the scientific working group DR. Hugh Kirkman (Director at marine science and ecology, seagrass ecologist) has written a peer reviewed paper. This paper states:- the design principles were again used for zoning purposes but modifications to them and others were needed. Some problems,

lack of scientific information on biodiversity and marine habitats, have been resolved, the latter by invoking the Precautionary Principle.
including protests from user interest groups and a The application of these methodological approaches and the lessons learned are extremely applicable to the East Asian Seas. So no scientific backing to Marine Parks, this is why the invoking of the precautionary principle has been essential to push this broken agenda. DEWNR staff have always maintained they had mountains of science now we learn that was a lie!

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SUBMISSION DETAILING A COMMONSENSE COST EFFECTIVE APPROACH TO IMPLEMENTING (RE-CATAGORISING EXISTING) MARINE PARKS/RESERVE SYSTEMS IN SOUTH AUSTRALIA

WE MEET ALL TARGETS BEYOND FEDERAL OBLIGATIONS States and Territories are under no obligation to implement a marine park system.

Darkened wording are quotations taken from the COP 10 Decision Strategic Plan for Biodiversity 20112020 AND THE AICHI BIODIVERSITY TARGETS http://www.cbd.int/decision/cop/?id=12268
Strategic goal C. Improve the status of biodiversity by safeguarding ecosystems, species and genetic diversity Target 11:By 2020, at least 17 per cent of terrestrial and inland water areas, and 10 per cent of coastal and marine areas, especially areas of particular importance for biodiversity and ecosystem services, are conserved through effectively and equitably managed, ecologically representative and well-connected systems of protected areas and other effective area-based conservation measures, and integrated into the wider landscapes and seascapes. Dr. Gary Morgan had this confirmed from Minister T. Burke that all targets were aspirational and NOT binding on Australia! Target 15:By 2020, ecosystem resilience and the contribution of biodiversity to carbon stocks has been enhanced, through conservation and restoration, including restoration of at least 15 per cent of degraded ecosystems, thereby contributing to climate change mitigation and adaptation and to combating desertification. i.e. Metro Adelaide is a perfect example of GOVERNMENT infrastructure impacting on the seagrass beds. The denuding of Adelaides coastlines is due to high nutrient water and stormwater runoff. Target 8:By 2020, pollution, including from excess nutrients, has been brought to levels that are not detrimental to ecosystem function and biodiversity. The Government is not adhering to the agreement. Even if the states and Territories were obliged to meet targets set by the UN treaty we would not have to proclaim MPAs or change anything under our current management system being enforced by PIRSA/EPA/DEWNR. Quite simply if the state would like to come in line with the ICUN park system all that is required is to re-categorise our current systems and laws. Using the below areas and also adding an approximate of the inshore rocky reef it is our belief there is 8% of state or coastal waters already protected. This is in comparison to Victoria and or New South Wales a much greater percentage. However if you were to compare them per population South Australia has already by far an enormously inequitable comparison.

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PROPOSED MARINE PARKS State VIC population 5,603,100.00 % of classification water NO FISH 5.30% c. area in mtrs2 541,289 mtrs per head of population 0.096605272

NSW

7,272,800.00

NO FISH

6.00%

528,120

0.072615774

SA

1,650,600.00 1,650,600.00

NO FISH Total proclaimed

6.00% 44.00%

3,601,920 2.182188295 26,414,080 16.00271416

WA

2,410,600.00

NO FISH

2.50%

2,893,500 1.200323571

EXISTING AQUATIC RESERVES & PROTECTION WITHIN SA % of c. State population classification water area in mtrs2 SA 1,650,600.00 VARIOUS 8.00%

mtrs per head of population

4,802,560 2.909584394

At a glance the proposed marine NO take zones are double that of other comparative states. To bring things into perspective we could do away with all aquatic reserves and closures keeping the Great Australian Bight. We would actually have around the same share per head according to South Australias population as Victoria and Western Australia and more than New South Wales. Hardly seems equitable to implement additional on top of our existing zoning.

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Fisheries Ministerial powers Fisheries Minister may close a fishery or area if deemed to be under threat or in risk of collapse or an area being harmed. The Minister has the power to control any fishery and its practices under the Fisheries Management Act as he or she sees fit. Re categorising current areas of protection to align with IUCN Area (km2) 7 15 10 21 30 3 <1 435 2 4 5 13 3 <1 <1 2 34 11 593 % State IUCN Waters Category <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 1 II II II VI VI VI (part II) II II Ia VI (part II) Ia VI VI Ia VI VI II II

AQUATIC RESERVE (Fisheries Management Act 2007) Aldinga Reef American River Bales Beach Barker Inlet - St. Kilda Blanche Harbour - Douglas Bank Coobowie Bay Goose Island Great Australian Bight Point Labatt Port Noarlunga Reef Seal Bay St. Kilda - Chapman Creek Troubridge Hill West Island (Prohibited Zone) West Island (Aquatic Reserve) Whyalla Cowled's landing Area 1 Whyalla Cowled's landing Area 2 Yatala Harbour TOTAL AQUATIC RESERVES

SANCTUARY (Adelaide Dolphin Sanctuary Act 2005) Adelaide Dolphin Sanctuary

Area (km2) 118

% State IUCN Waters Category <1 VI

NPWSA RESERVE (National Parks and Wildlife Act 1972) (Marine component only) Acraman Creek CP Althorpe Islands CP

Area (km2)

% State IUCN Waters Category

3 1

<1 <1

III III 23

Avoid Bay Islands CP Baudin CP Bird Islands CP Cap Island CP Cape Bouguer WA Cape Gantheaume CP Cape Torrens CP Clinton CP Coffin Bay NP Coorong NP Deep Creek CP Douglas Point CP Eba Island CP Franklin Harbor CP Gambier Islands CP Goose Island CP Granite Island RP Great Australian Bight Marine NP Greenly Island CP Hallett Cove CP Innes NP Investigator Group CP Isles of St. Francis CP Lesueur CP Leven Beach CP Lincoln NP Lipson Island CP Little Dip CP Memory Cove WA Mount Dutton Bay CP Munyaroo CR Neptune Islands CP Newland Head CP Nullarbor NP Nuyts Archipelago CP Nuyts Reef CP Olive Island CP Pelican Lagoon CP Piccaninnie Ponds CP Pigface Island CP Point Davenport CP Point Labatt CP Port Gawler CP Ravine des Casoars WA Rocky Island (North) CP Rocky Island (South) CP Seal Bay CP

<1 <1 3 <1 3 <1 <1 1 15 234 1 <1 1 7 1 <1 <1 1232 1 <1 <1 3 2 <1 1 13 <1 1 6 <1 17 142 1 48 46 <1 <1 <1 2 <1 1 <1 4 <1 <1 <1 2

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 2 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1

VI III VI VI Ib VI VI III III III VI VI III VI VI II VI VI VI VI VI VI VI III VI VI III VI Ib VI VI VI VI VI VI III VI II III VI VI Ia VI Ib VI VI II 24

Sinclair Island CP Sir Joseph Banks Group CP The Pages CP Torrens Island CP Troubridge Island CP Tumby Island CP ` Vivonne Bay CP Waldegrave Islands CP Western River CP Whidbey Isles CP Winninowie CP Wittelbee CP Total NPWSA Marine Component

<1 465 70 3 3 <1 3 <1 1 1 1 37 <1 2375

<1 1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 4

VI VI VI VI VI VI VI VI VI VI VI VI III

Inshore Net Fishing Closure Legislation Due to closures implemented on the inshore net fishery in 2005 there is currently only 1% of South Australias state waters available for netters to work. In 1993 the taking of Snapper with a net was legislated as illegal.

Inshore Netfishing Closure Designated areas throughout State Waters including being restricted to less than 5mtrs Total Area of restricted from

Area (km2)

% State IUCN Waters Category

59431.68

99

Native Vegetation Act 1991 Native vegetation means a plant or plants of a species indigenous to South Australia including a plant or plants growing in or under waters of the sea but does not include (a) a plant or part of a plant that is dead unless the plant, or part of the plant, is of a class declared by regulation to be included in this definition; or a plant intentionally sown or planted by a person unless the person was acting in compliance with a condition imposed by the Council under this Act or by the Native Vegetation Authority under the repealed Act, or with the order of a court under this Act or the repealed Act; or in pursuance of a proposal approved by the Council under Part 4 Division 2; or in compliance with a condition imposed by a Minister, statutory authority or prescribed person or body under the River Murray Act 2003; or 25

(b) (i) (ii) (iii) (A)

(B) (C)

the Water Resources Act 1997; or any other Act prescribed by the regulations for the purposes of this paragraph; waters of the sea includes any water that is subject to the ebb and flow of the tide

NATIVE VEGITATION ACT 1991 South Australian State legistlated waters protected under the "native Vegitation Act 1991" Total Area under State Durisdiction

Area (km2)

% State IUCN Waters Category

60282

100

Intertidal Reefs Intertidal reefs fully protected in SA A closure for the taking of all benthic (bottom dwelling) organisms from intertidal rocky reef areas applies to all coastal waters in South Australia. Intertidal reefs are those rocky areas of our coastline extending up to the high tide mark. This closure means that it is illegal to remove any bottom dwelling organisms, including abalone from any intertidal rocky reef in South Australia out to a depth of two metres. The closure only relates to rocky reefs and therefore does not include sand or beach areas. To protect these areas, it is an offence to remove bottom dwelling organisms from all intertidal rocky reef areas from the high tide line to a depth of two metres throughout South Australia. Government of South Australia Primary Industries and Resources August 2005. Area (km2) 5716 % State IUCN Waters Category ? ?

INTER-TIDAL REEF PROTECTED UNDER Total Area protected under inter tidal protection out to 2 mtrs in depth on rocky reef

The length of South Australias coastline is measured at the mean high water (MHW) and extends over a distance of around 5716 kilometres; a large percentage of South Australias coastline is made up of Rocky Reef. The exact percentage is unknown. Fisheries management Act 2007 71Taking, injuring etc aquatic mammals and protected species prohibited (1) (a) (b) A person must not Take an aquatic mammal or aquatic resource of a protected species; or Injure, damage or otherwise harm an aquatic mammal or aquatic resource of a protected species.

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Fisheries management Act 2007 Taking, injuring etc aquatic mammals and protected species prohibited Total Area under State Durisdiction

Area (km2)

% State IUCN Waters Category

60282

100

Parks and wildlife act 1972 Marine mammal means a seal or sea lion (order Pinnipedia) or a dolphin or whale (order Cetacea); protected animal means (a) (b) (c) (d) any mammal, bird or reptile indigenous to Australia; or any migratory mammal, bird or reptile that periodically or occasionally migrates to, and lives in, Australia; or any animal of a species referred to in Schedule 7, 8 or 9; or any animal of a species declared by regulation to be a species of protected animals,

but does not include animals of the species referred to in Schedule 10 or any animals declared by regulation to be unprotected; Division 2Restrictions upon the taking of protected animals 51Taking of protected animals etc (1) Subject to this Part, a person must not take a protected animal or the eggs of a protected animal.

Maximum penalty: In the case of a marine mammal$100 000 or imprisonment for 2 years

National Parks & Wildlife Act 1972 All species indigenous to Australia unless otherwise specified in Schedule 10 or any animals declared by regulation to be unprotected Total Area under State Durisdiction IUCN Protected Areas Categories

Area (km2)

% State IUCN Waters Category

60282

100

Category Ia Strict nature reserve: protected area managed mainly for science Category Ib Wilderness area: protected area managed mainly for wilderness protection Category II National park: protected area managed mainly for ecosystem conservation and recreation Category III Natural monument or feature: protected area managed for conservation of specific natural features 27

Category IV Habitat/species management area: protected area managed mainly for conservation through management intervention Category V Protected landscape/seascape: protected area managed mainly for landscape/seascape conservation and recreation Category VI Protected area with sustainable use of natural resources: protected area managed mainly for the sustainable use of natural ecosystems

The cost of impacting on Fisheries

Humans consume protein: if we impact on fisheries protein must be produced in some other way. Wild caught fish is the most ecologically environmentally friendly cost effective manner to produce protein. No fertiliser poison pesticide or antibiotics, bio-diversity may be in an altered state it is NOT destroyed. Fishers dont clear land like other forms of farming. The most ecologically friendly form of farming (organic) has a bigger impact on the worlds biodiversity than fishing. More imported unsustainably caught or poorly produced fish from other countries in the world is hardly a solution to this quandary. Whilst Australia restricts itself by selfishly neglecting the obligation to utilise our economic exclusion zone other countries around the world will see it as a boon. We risk their environment and their biodiversity by forcing them to produce product for us to eat. Will Australia bring in laws to force all product imported to have a Marine Stewardship tick of sustainability? Or boycott countries that are not locking up vast areas of ocean in the name of conservation? Australia's fishing zone is the third largest in the world, covering 11 million square kilometres, yet Australia is only the 52nd largest producer in terms of volume. Locking up areas of ocean puts Australias national security at risk. It is not our god given right to lock away vast areas of ocean the Law of the Sea treaty means we must utilise the resource. Quite simply use it or lose it, UNCLOS was designed for resource management, locking up sections of oceans is not management it is shutting the gate. This treaty could allow other countries to argue the fact that Australia is underutilising its resource therefore they could petition to utilise Australia would have one vote to argue against loss of our EEZ, one vote out of one hundred and sixty! Would other countrys vote with us?

If we are to look at mother earth as one ecosystem instead of humans interpreting it as segments then Australia is in fact underutilising our EEZ. Australia has an obligation to rest of the world to utilise and produce a high quality product using our sustainable fishing practices. We as a nation have an obligation to the environment and humanity to help feed the worlds population. Australia is 52nd as far as production is concerned and 3rd as far as the size of 28

our Economic Exclusion Zone. By underutilising we threaten the very thing we are suggesting we protect the environment. Other countries use poor or no fisheries management.

2007-2008 Australia became a net importer of fisheries products, both in terms of volume and in terms of value. We are not only underutilising we are not providing enough food to feed our own population.

Land clearing for other forms of primary production

Salinity in South Australia is a problem in all principal agricultural areas, with 370000 hectares of land and wetlands impacted. At current rates, this is expected to increase by 60% by 2050.[12] It is expected to cost the state around $47million per year in lost agricultural profit, and is expected to taint more than 20% of ground water to levels above those safe for human consumption.[9] http://en.wikipedia.org/wiki/Salinity_in_Australia#South_Australia The State of the Environment Report, 2001, prepared by independent researchers for the federal government, concluded that the condition of the environment and environmental management in Australia had worsened since the previous report in 1996. Of particular relevance to wildlife conservation, the report indicated that many processessuch as salinity, changing hydrological conditions, land clearing, fragmentation of ecosystems, poor management of the coastal environment, and invasive speciespose major problems for protecting Australia's biodiversity.[177] http://en.wikipedia.org/wiki/Fauna_of_Australia

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CONCLUSION
There have been three Audits conducted, Victoria, Western Australia & New South Wales. The Auditor Generals findings found in Victoria it cost one million dollars to implement each sanctuary zone and they could find No clear benefits. Western Australias department of environments own Audit on Jurien Bay Marine Park found no clear benefits after 10 years and they have large No Take areas. Why would South Australia want to go down the path of self-imposing restrictions on fisheries? No species of fish has become extinct from fishing, our current systems of 100% management of both the fisheries and simultaneously through EPBC is the best system of management in the world. All of the Marine Environment from the water itself to the plants and animals that dwell in the ocean are already protected; any development terrestrial or oceanic must first be approved through government. In a study financed by the EPA the threats to biodiversity were not fishing, it was actually government infrastructure which had the biggest impacts. With our growing populations cost to the Health of our populous is paramount. Through impacting on small country townships where particularly our younger generation fish from beaches etc will have profound effects on the behaviour of adults and youngsters. In a study Identifying the health and well-being benefits of recreational fishing Prof A. McManus, Dr W. Hunt, J. Storey, J. White. http://cessh.curtin.edu.au/local/docs/RecFishinglr.pdf it found With clear evidence supporting physical activity and a healthy diet high in seafood as beneficial to health and the prevention of chronic conditions (McManus and Newton 2011; McManus. A., White. J. et al. 2011; Newton and McManus 2011), it is both logical and intuitive that recreational fishing could offer substantial health benefits. Reforming the cultural behaviour by impacting on traditional fishing practices is in our opinion a breach in the constitutional rights of Australian citizens. Under equity the Government would be neglecting by showing a total disregard for both commercial and recreational fishers by taking ownership and legislating boundaries and new laws. Such practice is against our constitutional rights! In conclusion it is the belief of the AMA that the South Australian State government should: Remove all outer boundaries. Re-categorise all existing protection orders Marine protected areas or reserves to come under the IUCN zoning scheme.

In doing so the State Government can avoid: Displacement of both commercial and recreational fishers Social economic impacts on small communities and the economics of the State

The cost of using this common-sense approach is in administration only; The State Government can save hundreds of millions of dollars. Current marine protected areas are already being policed by the Fisheries department there would be no additional policing fees. The current marine protected areas have community acceptance. The area of current mpas has been approximated to be between 6 to 8 % of the states coastal waters, more than Victoria. Seeking common-sense with an equitable outcome, Australian Marine Alliance SA Branch Written and collated by Wade Wheeler

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References
1. SA Select Committee Inquiry Into Marine Parks http://www.parliament.sa.gov.au/Committees/Pages/Committees.aspx?CTId=3&CId=263 2. Ward, T.M. and Burch, P. (2012) Revised Estimates of Historical Commercial Fishery Catches/Effort in Draft Sanctuary and Habitat Protection Zones in South Australias Marine Parks. Reprt To PIRSA Fisheries And Aquaculture. SARDI, Adelaide. SARDI publication no. F2011/000307-6. 3. Possingham, H.P., Noyce,T. and Stewart, R.R., 2003 Opportunity cost of an Ad Hoc Marine Reserve Design Decisions : An example of South Australia, Vol 253;25-38, 2003 Marine Ecology Press series, Published May 15th 2003 4. Stark, Walter (2011) MPAs A Useless Solution To A Non-Problem 5. http://www.sydneyfishmarket.com.au/LinkClick.aspx?fileticket=qV8leOPtKW8%3D&tabid=183 6. Dr Gary Morgan; Radio interview on Radio 5AA - October 2012 , Leon Byner, 5AA ;Tuesday, 9 October 2012 Jobs losses as a result of bans on fishing in proposed Marine Parks
7. http://www.environment.gov.au/coasts/mbp/temperateeast/consultation/submissions/pubs/0178nswgamefishingassociation.pdf

8. Tony Burke, 25th January, 2011 letter to Dr Gary Morgan regarding CBD Target 11 9. Baker J.L. and Bridgland, John, SA Dept. of Environment and Heritage, Coast and Marine Section Guide to Marine Protected Areas Adelaide; 2000

References Links http://en.wikipedia.org/wiki/Salinity_in_Australia#South_Australia http://en.wikipedia.org/wiki/Fauna_of_Australia http://www.cbd.int/decision/cop/?id=12268 http://cessh.curtin.edu.au/local/docs/RecFishinglr.pdf http://www.youtube.com/watch?v=ICAR0IjAN4U http://cessh.curtin.edu.au/local/docs/RecFishinglr.pdf http://www.environment.sa.gov.au/files/259a3fa6-b648-48bb-83d2-9e6700be1472/mp11-factsheet.pdf

Disclaimer Australian Marine Alliance SA would like to apologise if we have not provided all references, given opportunity if required we would happily aid in any form that the State Government should require. Copyright 2010 31