MP Submission (Final Public)

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  • 7/31/2019 MP Submission (Final Public)




    SA Marine parks submissions

    Department of Environment,

    Water and Natural Resources (DEWNR)Reply Paid 1047

    Adelaide SA 5001

    Email:[email protected]

    Phone: 1800 006 120


    Scott Jansons





    Submission for the final draft proposals of SA

    Marine parks

    1. Introduction

    2. Terrestrial National Parks Vs Marine Sanctuaries

    3. Shifting the burden of Food Production

    4. Involvement of Conservation Charities

    5. Community ownership of Marine Parks and Sanctuaries

    6. Zoning reference

    7. Conclusion

    mailto:[email protected]:[email protected]:[email protected]
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    1. Introduction

    My name is Scott Jansons, I am interested in the Marine Parks planning process,

    because fishing is my recreation as well as my profession. I agree that there is a need

    for conservation in our marine environment, and there are threats that need to be

    addressed. So we can hand to the next generation a healthy marine environment.My comments come from my self, and based on 21 years recreational

    experience, 15 years commercial experience, and 4 years of experience as an educator

    of basic Marine Biology and Marine Conservation, in the Education Departments

    Aquatic Programme.

    2. Terrestrial National Parks Vs Marine Sanctuaries

    Throughout the process I have heard the line, We do not hunt in our National

    Parks, so why would we fish in our Marine Sanctuaries. To your average Joe urbanite,this sounds like no brain common sense. But what goes lacking in translation is the

    actual need for terrestrial parks to protect Bio Diversity, and especially the threat which

    creates that need.

    When average Joe hears that line, they will most probably associate Hunting as

    the primary threat to biodiversity. However this simply isnt the case, it is a secondary

    threat. The biggest cause of loss of bio-diversity in Australia is land/natural habitat

    clearing for the purpose of modern agriculture.

    To support my statement here is a satellite photo of Yorke Peninsula.

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    Before European settlement, this area would have been %100 Natural habitat,

    from which indigenous Australians harvested food in a sustainable manner.

    Clearly apparent in this photo is the amount of land/natural Habitat cleared for

    the purpose of cropping. %95 is totally cleared evident by the light green. What is not

    so clear is area that has not been cleared however the natural habitat has been affectedby grazing of foreign species; at a guess this would be about %3.

    The remaining %2 is National Park which only leaves an extremely small

    pocket which provides a natural ecosystem for native species to exists, now in a perfect

    world it is arguable that if managed properly it would be possible to harvest sustain ably

    from this remaining %2. However there is a secondary less visible threat being feral

    carnivores namely Cats and Foxes, as well as other introduced species like mice, rats

    and rabbits. So once this offset is taken into account there is too much pressure on

    species already and leaves no room for sustainable harvest.

    So Im sorry to say, this line used by DEH/DENR/DEWNR is false and

    misleading. And to use it to gain support from you average Joe public is plain and

    simple treating them with contempt.

    3. Shifting the Burden of Food Production

    I would like to bring to your attention this from Ray Hilborn in a speech about

    the state of the worlds fisheries:

    If you think about the standards we have in fisheries and the best internationalstandards, 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 productivityfunction 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. :- Ray Hilborn

    Now it is no secret that the world is facing a food security crisis in the near future,

    this will undoubtedly put extra pressures on bio diversity. It is incomprehensible why any self

    respecting scientist would want to displace a proven sustainable method of food production,

    which has a minimal impact on the ecosystem. When to offset this reduction you are only

    increasing the true threats to the same ecosystem you are claiming to protect. To me this is

    only going to accelerate and exacerbate the impact of true threats. I will refer you to the

    following table.

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    Now in this table there are 4 separate threats to the marine environment that will

    be increased by offsetting capture fisheries with a terrestrial equivalent one of which is

    a compounded threat. I will run through them below.

    - Reduced fresh water flows, we only need to look at the problems the River

    Murray has faced in last decade to realise how damaging it is to remove fresh water

    flows from an ecosystem. The removal of brackish water from the Coorong changed the

    ecosystem dramatically, not to mention patterns of species like Mulloway which rely on

    these flows as part of their breeding cycle.

    - Fertilizer in runoff creates a nutrient rich environment, which allows algae

    (slime) to flourish, this smothers natural seagrasses preventing them from

    photosynthesising and effectively kills of the grasses which are important habitat for

    many other species.

    - Pesticides are basically poison, and enter the marine environment via runoff.

    - Greenhouse gases contribute to climate change, climate change alters the marine

    environment.One simple number is that If you wanted to replace the worlds fish catch withanimal 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. :-Ray Hilborn

    - Clearing natural habitat not only reduces the ability to offset greenhouse gases

    but also contributes to bio-diversity loss of terrestrial species.

    I would also like to refer you to diagram 1 & 2 below, to show you that a

    reduction in production under our well managed fisheries also has the problem where

    we may be contributing to the loss of Marine Bio-diversity elsewhere in the world. (Out

    of site out of mind, Hey???)

    4. Involvement of Conservation Charities

    It is my belief there is distortion of the true support for Marine Parks. Sure there is a

    certain level of support amongst fishers for sanctuary zones. But that support isnt for

    the large scale closures as the department proposes/proposed. And the support amongst

    the general public is questionable due to the lack of understanding that exists, enhanced

    greatly by a concerted effort by conservation charities misleading them into thinking

    our fish stocks are in a state of extreme depletion and fishing practises extremely

    destructive as they are in much of the world, as they are continuously bombarded with

    through the media.

    What this subliminal messaging, largely sponsored by Green NGOs fails toconvey in the case of our state and federal Marine Park push is the fact that Australia is

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    a net importer of seafood. Much of this seafood comes from places where the marine

    ecosystem is threatened by overfishing and destructive fishing practises.

    Rarely if ever does this media campaign ever highlight the successful

    management of fisheries in this country or promote the fact that much is done to reduce

    the overall impact on environment, through the refinement of fishing techniques and

    equipment. They prefer to dwell on the doom and gloom, as it better suits their side ofthe argument.

    Below is two diagrams they would never show in their campaign, it highlights

    our imports of seafood may be contributing to threatening bio-diversity elsewhere in the

    world. This is something that may or probably will be exacerbated by the reducing of

    seafood production in Australia, to allow for large Marine Sanctuaries.

    Diagram 1

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    Diagram 2

    Here is another classic example on the federal level

    Now that there is a picture of a Whale, they are far more vulnerable to ship

    strike from merchant vessels than they are interaction with fishing practises in the area

    stated on the sign. So are we banning shipping traffic through marine sanctuaries in the

    Coral Sea or elsewhere in Australia for that matter?

    If the government was fair dinkum about this so called support, they would

    publicise the results of surveys conducted to gain the quoted levels. And be transparent

    about the sorts of questions included in the surveys. Why hell you could ask a loaded

    question like Do you think looking after our Marine Environment is important and

    you would probably get a %100 Yes answer, but this doesnt mean that people

    necessarily are saying they support the proposed marine parks. Or even the sampling

    area can distort the results, my understanding is a regional sample of fishers was taken

    at Wallaroo, now they are going to have a totally different view than say somewhere

    like Kangaroo Island. What Im trying to get at is surveys are only accurate or useful if

    they are unbiased. I do not trust that this is the case with this project.

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    It is clear and apparent by this photo that the government is over estimating the

    level of support they have for the current plans. Kangaroo Island is an isolated

    population, so it is unlikely there are many blow-ins in this photo. Estimates are that

    around 20 25 percent of the population of KI turned out to show their rejection to the

    current plans.

    Community ownership of the sanctuaries is imperative to their success, it is my

    opinion and the opinion of many I have talked to that the department does not have

    much community support for its plans.

    5. Community ownership of Marine Parks and Sanctuaries.

    One of the concepts was the involvement of the community in the design of

    Marine Parks & Sanctuaries. This would increase the community ownership which

    would assist to minimise the management costs. It would also minimise displacedactivities and maximise potential benefits from activities like education and eco-

    tourism, helping to make the project cost effective.

    After watching the process unfold I dont belive this happened, I see it not as a

    problem caused by lack of involvement from the community, but I see it as a flawed

    project design on behalf of DEH/DENR/DEWNR.

    The project was run with overbearing control by the department, appeared to

    have predetermined outcomes and lacked transparency, thus creating conflict between


    The department did not bring to the process an effective framework to allow full

    community involvement to design an efficient outcome. What the department bought to

    the process was a computer programme and process with predetermined outcomes thatlimited community involvement to a bare minimum to tick the boxes saying the

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    community was consulted with. And despite the public outcry, the department and

    government failed to put a moratorium on the process using money already spent and

    time already taken by the department as their pathetic excuse.

    To achieve full community acceptance and ownership it is my belief

    communities should have full control of the design of the sanctuaries, and the

    departments responsibility would be to provide the right tools for the job, then andonly then would the process be one of transparency and efficiency.

    Below I will list what I belive would have been the right tools for the job which

    the department should have provided to communities to assist them to design efficient


    * Measurable Goals

    DEH/DENR/DEWNR bought a plan to the table was a plan that had no

    accountability. By banning fishers from areas will help to protect bio-diversity from

    unrelated things like climate change or habitat destruction from pollution.

    Such an aim makes it impossible to measure success or failures of sanctuaries, and

    when time comes to assess the performance of the zones the conclusion will be loadedand predetermined, the science is disgustingly bias, to the point it can hardly be called


    The only goal bought to the community, and the measurability is the amount and size of

    no take zones implemented.

    We have been sold spill over as a benefit which has occurred elsewhere in the world

    with little to no fisheries management, but spill over from sanctuaries here is

    unmeasurable as it would most probably come from historic fisheries management

    decisions rather than created by sanctuaries as proposed. I have read nothing which

    states how differences in bio-diversity/biomass will be distinguished between the two

    jurisdictions involved in managing the same resource.

    * Specific Science

    - This area is unique or important because?

    - Fishing is a threat to bio-diversity in this area because?

    - Fishing is a threat to this species because?

    Sure, much irrelevant science was put on the table from overseas, and interstate

    grown from bias research previously addressed under the measurable goals section.

    Very little if any specific local science that is up to date was presented to

    communities to inform the design process for most zones, highlighting fishing is a key

    threat to bio-diversity in those areas. And most of the science that was put forward is

    addressed under our fisheries management regimes already.

    * A realistic starting point

    To me a realistic starting point would be a blank map, then the high value areas

    supported by specific science could be pin pointed on this map and boundaries could

    then be formulated with the SAMPIT data used as a reference as well as input for

    potential eco-tourism opportunities.

    Instead what we saw was the department come to the process with a computer

    programme with a predetermined result, and it is all to clear this programme failed to

    address SAMPIT data. I can only surmise the reason for this is because it was an

    information gathering tool which was used to deliberately target fishing grounds and

    not as described a tool to avoid fishing grounds.

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    * The best and most knowledgeable community members for the job.

    Right from the start of the community consultation it was clear and apparent

    how bias the process was going to be. The LAG nomination form came out excluding

    those who were smart enough not to sign a blank check.

    Please agree to the following by ticking the boxes.[ ] I am committed to creation of Marine Parks in my local area.

    [ ] I am prepared to be an advocate for Marine parks in my local area.

    [ ] I am committed to attending meetings in my local area.

    You say well those questions are fair enough, until you stop and consider the

    department did not clarify exactly what marine parks were going to be until July/August

    2012. Many of the most knowledgeable people about the marine environment in their

    local area are fishers, both recreational and commercial asking them to commit to and

    advocate for something as vague as the Marine Park plans were in March 2009 is


    Effectively what people were committing to and advocating for was actuallyassisting the department to damage the livelihoods, employment, recreation and

    economies of regional towns. No self respecting member of these communities would

    have a bar of signing up to that. Even more painful is conservationists criticising LAG

    members for backing the community interests rather than the Conservationist/DEWNR

    agenda of abundant and massive MPAs. As the following screenshot from the SAplan

    site shows.

    It was for this reason I didnt bother nominating for a seat on the LAG, even

    though I thought my 14years experience in the marine environment, including teaching

    basic marine biology to thousands of school children, may have been of value.

    * A staggered implementation of zones.

    Now considering that Australia already meets its obligations in regards toprotection and management of our Marine ecosystem. There was absolutely no need to

    come in and implement all of the sanctuaries in one hit at the same time across the

    entire state. And to tell you the truth it seems ridiculous to do it in this manner. The

    pros of implementing sanctuaries in a staggered manner far out way the cons of doing

    it in one foul swoop. It would be far more conducive to gaining public support for the

    Sanctuaries, in my opinion. Below I will list what I would consider the advantages of a

    staggered implementation of Sanctuary zones.

    - It would allow for fisheries management science to be recalibrated in a far more

    accurate manner, to factor in the effect of sanctuaries. This is extremely important on

    both sides of the scale. On one side there is a need to prevent overfishing fromoccurring, which is possible if the science used to calculate the displaced effort and

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    therefore the effort reduction needed is erroneous. As this link highlights:-


    And on the other side of the scale, it is important to achieve minimal displacement of

    effort to reduce the impact the on economies of regional areas. One of the advertised

    benefits of the zones is spill over, hypothetically if this does occur displacement shouldbe reduced. Its a common sense approach, when you run a hot bath you dont go and

    jump straight into it, you test with your toe first to make sure it isnt going to burn you.

    - Areas of high importance to biodiversity are less likely to be missed. What

    happens when a few years down the track scientists discover an area that was missed by

    the zones proposed? There would be riots! It would make the department look

    incompetent, and destroy any credibility the department has left. If you read this written

    by - DR. Hugh Kirkman (DEWNR Scientific Working Group)

    Some problems, including protests from user interest groups and a lack of scientific

    information on biodiversity and marine habitats, have been resolved, the latter by

    invoking the Precautionary Principle.

    Now you can not tell me after reading this there is %100 certainty involved in the finaldraft proposals?

    - Community involvement, I for one am a person who had an interest in

    numerous Marine Parks, considering my extensive intellectual property acquired while

    working in several sectors of the commercial industry. Therefore have a vested interest

    in many of the parks. I can remember at the stage of LAG #4 attending the MP 11 & 12

    meeting at Minlaton, returning home after this meeting at 1am and starting work at

    6am, it was physically impossible to do the same to attend the MP13 meeting at

    Edithburgh the following day. And then the most appalling act happened at LAG#5,

    where the public gallery was removed from the meeting before zoning was discussed.

    * A proper framework for community engagement

    The process proved that the government did not create an appropriate

    framework for proper community engagement. The most successful and efficient way

    of contributing to the process was created by the communities themselves, being action

    groups. MP 11 was a perfect example where they formulated their own design which

    was taken to the LAG for approval. This reduced the demand on the LAG and

    maximised community involvement. It is my opinion that the majority of action groups

    were formed too late in the process to work effectively and efficiency to aid in the

    planning. This is a problem as I see it where the department did not provide a proper

    framework for the process.

    6. Zoning referenceI do not support the governments current concept of marine parks orzoning in SA coastal waters. I say NO to the 19 marine parks, 81

    sanctuary zones, 20 Restricted Access Zones, 56 Habitat protection

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    zones, 29 general managed use zones and 49 Special PurposeAreas as listed below:

    Far West Coast Marine Park1st may to 31st October Inclusive zoning = RAZ2, SPA-1, SPA3 andSPA4

    1st November to 30th April inclusive= RAZ-1, SZ-1, SPA-1, SPA-2,HPZ1 SZ2 and SZ3Nuyts ArchipelagoHPZ-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, SZ10West Coast Bays Marine ParkHPZ-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-1Investigator Marine ParkSZ-1, HPZ-1, HPZ-2, GMUZ-1, HPZ-3, SZ-2, HPZ-4, GMUZ-2, HPZ-5, SZ-

    3, HPZ-6, GMUZ-3Thorny Passage Marine ParkSPA-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-4Sir Joseph Banks Group Marine ParkHPZ-1, SZ-1, HPZ-2, GMUZ-1, SZ-2, SZ-3, GMUZ-3, SZ-4, SZ-5, GMUZ-4, GMUZ-2, RAZ-1Neptune Islands Marine ParkSZ-1, RAZ-1, RAZ-2, HPZ-1Gambier Islands Group Marine Park

    HPZ-1Franklin Harbor Marine ParkSPA-1, SZ-1, SZ-2, SZ-3, HPZ-2, SZ-4, SZ-5, SPA-3, SPA-4, GMUZ-1,SPA-2, HPZ-1Upper Spencer Gulf Marine ParkSZ-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, HPZ-3, SPA-5, SZ-9,SZ-10, SPA-2Eastern Spencer Gulf Marine ParkSZ-1, HPZ-1, GMUZ-1, SZ-2, SZ-3, HPZ-2, GMUZ-2Southern Spencer Gulf Marine Park

    HPZ-1, SPA-1, HPZ-2, SZ-1, SZ-2, GMUZ-2, HPZ-3, RAZ-1 ALTHORPEISLAND, RAZ-1 HAYSTACK ISLAND, RAZ-1 SEAL ISLANDLower Yorke Peninsula Marine ParkSZ-1, HPZ-1, SZ-2, SPA-3, SPA-1, GMUZ-1, SPA-2Upper Gulf St Vincent Marine ParkSZ-1, SPA-1, HPZ-1, SPA-2, GMUZ-1, SZ-3, SZ-2, SPA-3, RAZ-1, SZ-3Encounter Marine ParkGMUZ-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, SZ-6, SPA-10, SPA-11, SPA-12, HPZ-6, SPA-8, SZ-7, GMUZ-7Western Kangaroo Island Marine Park

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    SZ-1, SZ-2, HPZ-1, RAZ-1, RAZ-2, RAZ-2 (CASUARINS ISLETS), RAZ-3,HPZ-2Southern Kangaroo Island Marine ParkSZ-1, RAZ-1, HPZ-1, HPZ-2Upper 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 ParkSPA-1, HPZ-1, SZ-1, HPZ-2, GMUZ-1, GMUZ-2, HPZ-3, SZ-2, SPA-2

    7. ConclusionI do not agree with the current proposals as I do not belive there is a

    good balance. I belive the current proposals are far too damaging toregional communities of South Australia.

    I also take the view that the proposals encroach too much into thefield of Fisheries management, which is already managed under ESD

    principals. And I do not belive the plans go far enough toward addressingtrue threats to the Marine Environment for example Pollution, InvasiveSpecies, Oil Spills etc.

    The community consultation has not been run well by thedepartment, and as I see it far to bias to be acceptable as a balancedapproach.You need to do far better than that!!!

    Thanks for your time.