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Management Plan Submission Guide

NSW Mainland Marine Park Network DRAFT Management Plan 2021-2031 – Submission Guide

Key points to assist with responses

Submissions close 31 January 2022 at 5pm.

EcoNetwork recommends that you draft your own response based on the following points plus any personal observations you would like to reflect on.  The page numbers refer to pages in EcoNetwork’s draft submission document available here.

The Draft Management Plan (DMP), as it currently stands, is unlikely to achieve any improvement in the management of the NSW marine parks network over the coming 10 years.  It does not recognise or integrate recent research results and ignores well-established and accepted world best practice for marine parks. In fact, in its current form, it is more likely to undermine conservation gains made over the past 10 – 15 years. 

Here’s are some pointers that may assist with your submission:

  1. The plan needs to be accountable and include standard management tools with measurable objectives, goals, milestones, key performance indicators and time lines to assess the success or failure of the planned management action over time. Otherwise the plan is merely aspirational.
  1. It should set specific goals to be achieved over the coming 10 years.  For example, the percentage cover of sanctuary zones to be gained over the duration of the plan and how that will be achieved.  This should reflect world’s best practice which recommends approximately 30 % of NSW waters be protected by sanctuary zonessee previous page.
  1. It should include indicative budgets, staffing levels and resources required to achieve the proposed goals so as to assess the aspirations of the plan against the reality of available funding and resources.
  1. Chapters and paragraphs should be numbered to facilitate the review and access of the plan for implementation.
  1. It should follow the guidelines provided through the legislation (page 6) which states that the primary purpose of marine parks is to ‘conserve biological diversity and maintain ecosystem functionality and integrity‘ and that marine parks should be managed in ‘a manner consistent with Ecologically Sustainable Development Goals.’  These elements alone underpin sound conservation management. Currently the DMP gives these principles lip service but does not follow them.
  2. It should focus on development and delivery of effective sanctuary zones (page 8) recognised as providing the most effective conservation outcomes.  Read more about sanctuary zones here.
  1. It should follow world’s best practice in marine parks management.  This includes the application of the CAR principles (Comprehensive, Adequate and Representative) across the entire marine parks network.  The DMP states that CAR will only be considered as a guideline for existing sanctuary zones and where appropriate to address specific threats (page 11).
  1. It should follow the scientific advice given in the two authoritative technical papers that the government commissioned that review the results of scientific1 and socio-economic2 research on marine parks since 2012 (page 8).
  1. The threats and risks process is largely based on anecdotal evidence and lacks the scientific rigour required to judge the success or failure of proposed management actions.  There is insufficient evidence to set management goals through this process and effectively prioritise the threats and risks. An action that enhances socio-economic or cultural values may represent a threat to biological and ecosystem integrity and should be addressed accordingly – currently they are not.
  1. There is a general misconception that marine parks are fisheries management tools.  They are not. (page 13). The DMP acknowledges marine parks and fisheries management have different objectives and that ‘even well managed fisheries have substantial impacts on ecosystem integrity‘.  While there is clearly some overlap, one is aimed at extraction the other at conservation requiring a different skill set and approach.  So why do marine parks fall under the management of DPI Fisheries and the DMP prepared by DPI Fisheries managers? DPI Fisheries is listed as lead agency in as many as 109 of the 152 actions and is partnered in most of the others. Our view is that Marine Parks should operate under the Department of Environment.
  1. Win-win, trade-offs, quadruple bottom lines (page 11) are not appropriate policies for managing marine parks – suggests more of a marketing plan than a management plan.  This approach appears to be an attempt to circumvent rigorous science and establish a simplistic approach to managing marine parks.
  1. There should be a clear pathway of how to maximise broader partnerships and community engagement in the management of marine parks (page 16). The DMP states that ‘Early and effective engagement with community, partnerships, collaboration are critical to effective marine parks management’ (DMP page 18).  Yet the major partnerships identified in the Actions section (DMP p48 – 80) are predominantly those with strong associations with the commercial fishing and seafood industry. In many cases these partners have limited knowledge of marine parks while marine science institutions, educators and community groups with relevant expertise have not been included.
  1. Despite acknowledgment of traditional owners in the DMP, it offers no clear pathway to ensure appropriate engagement of traditional owners in marine park management.  Traditional owners are poorly represented in the Actions programme (6 mentions from 152 Actions). The technical paper prepared by BDO EconSearch proposes opportunities for indigenous engagement in monitoring and evaluation and suggests identifying how to access, incorporate and manage culturally-owned and informed data that would be useful in developing community participation and acceptance.2

To submit your own comments, or using this proforma response we have prepared, you will need to log on to NSW Marine Park Engagement to answer their survey.

This process will guide (and limit) your responses but there is a section you can upload a pre-prepared submission within the survey. 

EcoNetwork’s opinion is that the ‘yoursay’ survey method for this review document is inappropriate as it forces simple responses to complex issues. There is no right or wrong answer and results are unlikely to influence decision-makers. So please supplement this by attaching your own comments.

If this online system is too complex, you can post your submission to: Draft Marine Parks Network Management Plan, NSW Marine Estate Management Authority, Locked Bag 1 Nelson Bay NSW 2315.

REMEMBER: Submissions close at 11:55pm on 31 January, 2022.


1Evaluation of the performance of NSW Marine Protected Areas; biological and ecological parameters, August 2020.

2Social, Cultural and Economic Science Technical Paper for NSW Marine Protected Areas, Prepared by BDO EconSearch, 2021.

Published: 11 Jan 2022