Dr Bruce Pease made this submission on 11 November 2015 to the NSW Government arguing against proposals to permanently remove sanctuary zone protection for parts of Celito and Fiona Beaches within the Port Stephens-Great Lakes Marine Park (PSGLMP).
He made the submission in his capacity as representative (executive member) of EcoNetwork-Port Stephens and the Marine Parks Association on the PSGLMP Advisory Committee.
As a retired Fisheries Scientist with over 20 years experience conducting fisheries research within the NSW Department of Fisheries, I believe that I have a good scientific understanding of the marine habitats and fisheries of NSW. As a resident of Port Stephens and a surfer, diver, recreational fisher and cruising yachtsman, I have an intense personal interest in marine conservation.
The proposal to permanently remove sanctuary zone protection for parts of Celito and Fiona Beaches within the PSGLMP is clearly illogical and totally unacceptable.
In the following discussion the Marine Estate Expert Knowledge Panel Ocean Beaches and Headlands Assessment Report will be referred to as “the Assessment report” and the Beaches and Headlands ecological report as “the Ecological report”. The Assessment report states that “NSW marine parks aim to conserve marine biodiversity, maintain ecological processes and provide for sustainable uses of the marine environment.” The stated order infers that primary aims are conservation of marine biodiversity and maintenance of ecological processes, while sustainable uses (such as recreational fishing) are of secondary importance.
We agree with this order of priority, which also aligns with the Australian Marine Science Association’s position statement on marine protected areas, which gives the highest functional priority to: “protect biodiversity and ecosystem function, including the processes on which biodiversity depends.” In other words, the primary function of marine parks is to conserve and protect the natural environment, with particular regard to biodiversity.
A key part of the management strategy for establishing the PSGLMP in 2005 was to protect the biodiversity within approximately 20% of each representative habitat type within the marine park boundary using a system of totally protected sanctuary zones based primarily on the Precautionary Principle.
This process was publicly transparent and all key sectors of the community were consulted extensively over a period of several years.
The political proclamation of a Recreational Fishing Amnesty in all ocean beach and headland sanctuaries within all coastal marine parks in NSW (including the PSGLMP) was suddenly announced by the Minister for Primary Industries as an item tacked to the bottom of a 2012 Media Release announcing that the Government supported all recommendations of the 2011 Scientific Audit of NSW Marine Parks..
However, none of the recommendations from this audit said anything about the need for a recreational fishing amnesty in any of the sanctuary zones within any marine park in NSW.
The Minister justified this Amnesty based on a minor comment about the relative lack of scientific data in the ocean beach and headland habitats that was buried in the extensive audit recommendations.
In 2013, almost a year after announcing the recreational fishing amnesty, the NSW Marine Estate Management Authority (MEMA) released the Assessment report on risk analysis of recreational fishing in all ocean beach and rocky headland sanctuary/amnesty zones using methodology developed from surveys conducted by consultants (Social values technical report and Economic technical report ).
However, none of the methodology surveys were conducted in the PSGLMP. The risk analysis in the Assessment report is based on public opinion surveys and the opinion of the “Expert” panel and resulted in the finding that the “Economic risks to fishers if fishing is not allowed” in the Celito and Fiona Beach sanctuary/amnesty zones are “low”.
In 2014, two years after the recreational fishing amnesty was announced, a media release announced the Cabinet decision to retain 10 of the amnesty zones (including Celito and Fiona Beaches) and return 20 of them to sanctuary zone status, again based on a statement that: “The audit found that information was lacking with respect to some no-take zones, including ocean beaches.”
After this final political proclamation, the Ecological report was released in 2015. There is some very interesting information in the Ecological report that was not stated and probably not used in any of the previous MEMA reports.
Table 5.5 shows that Celito and Fiona Beach sanctuary/amnesty zones comprise half of the combined shoreline length of all the original ocean beach sanctuary zones in the PSGLMP. However, the following statement was attached to the discussion of ecological assessment in each of the ocean beach sanctuary/amnesty zones in the PSGLMP: “No research has been undertaken in the intertidal and subtidal habitats included in this assessment.”
The Ecological report also reveals that the most recent survey of Australian recreational fishing effort and catch in 2003 showed that recreational fishing effort in ocean beaches in the PSGLMP is relatively high: “Within NSW 65% of fishing events and 64% of fisher hours occurred on ocean beaches and 31% of fishing events and 34% of fisher hours occurred on rocky headlands. Mid north coast and Hunter regions had the largest proportion of fishing events and fisher hours of NSW on ocean beaches whereas the south coast had the largest proportion of events and fisher hours on rocky headlands in NSW (Figure 3.1).”
However, “There have been few studies on the ecological effects of marine shore-based recreational fishing globally and none in NSW.” “In a different context, such as reviews of marine park zoning arrangements, it will be important to consider more fully the relative impacts from recreational fishing on marine biodiversity.” We also learn that: “A study by Smith et al. (2008) found fishing related litter to be the most prevalent form of litter on the coastline between Yamba and South West Rocks in northern NSW.
The ecological effects of lost recreational fishing gear from shore-based fishers include entanglement of shorebirds (Ferris and Ferris 2004) and marine reptiles by fishing line leading to injury or death, ingestion of sinkers and lures by shore-birds mistaken for prey or from foraging, entanglement around subtidal or intertidal biotic habitats, such as sponges or algae leading to damage or severance of structures.”
In summary, we are told that MEMA is proposing to reduce the area of ocean beach sanctuary zone, the management zone that directly addresses the primary aim of marine biodiversity conservation in marine parks, by 50% in the PSGLMP based on the following information:
– we know relatively little about the marine ecology and biodiversity in this habitat, 2) we know that recreational fishing effort is relatively high in this habitat, 3) we know virtually nothing about the ecological impacts of recreational fishing in this habitat other than it removes fish and leaves ecologically dangerous litter that is listed as a Key Threatening Process for threatened marine species in NSW, and 4) risk analysis based on limited public opinion surveys and the opinion of an “expert” panel found that “Economic risks to fishers if fishing is not allowed” would be “low”.
– This proposal is being made before there is a comprehensive review of the management plan for PSGLMP rather than as part of an integrated management review process. Re-zoning these sanctuary zone areas now, will set an unjustified precedent for allowing recreational fishing in sanctuary zones prior to full implementation of the review process for management of Marine Parks in NSW. There is no scientific, logical or common-sense justification for permanently removing the fully protected, sanctuary status from the Celito and Fiona Beach sanctuary zones at this time.
Submitted 4/10/2015 by Dr. Bruce Pease, representing EcoNetwork-Port Stephens Inc. and Marine Parks Association