Australian Office: PO Box 439 Avalon NSW 2107 Australia +612 9973 1728 admin@hsi.org.au www.hsi.org.au Head Office: 2100 L Street, NW Washington, DC 20037 USA 301-258-3010 Fax: 301-258-3082 hsi@hsihsus.org Officers Wayne Pacelle President Andrew N. Rowan, Ph.D. Vice President G. Thomas Waite III Treasurer Australian Office Michael Kennedy, Director Verna Simpson, Director Australian Board Peter Woolley Jean Irwin Elizabeth Willis-Smith Patricia Forkan Dr. Andrew Rowan Michael Kennedy Verna Simpson Department of Sustainability, Environment, Water, Population and Communities MBP submissions - Coral Sea Reply Paid 787 Canberra ACT 2601 By email to: Submissions.CoralSea@environment.gov.au 15 February 2012 Dear Sir or Madam Re: Coral Sea Commonwealth marine reserve proposal Humane Society International (HSI), the world s largest conservation and animal welfare organisation, welcomes the opportunity to provide the following submission on behalf of 11 million supporters worldwide, and 40,000 Australian supporters. HSI has been an active stakeholder in the marine bioregional planning process that is currently underway, and in the Coral Sea region has been actively working as part of the Protect Our Coral Sea alliance. Our goal is the establishment of a large, world-class, highly protected marine park in the Coral Sea that will provide a safe haven for marine life and recognise its historic significance. HSI recognise and support the Government s policy commitment at the 2010 federal election to implement a nationally representative network of marine reserves by 2012. Lying adjacent and seaward of the Great Barrier Reef, in a remote oceanic environment, the iconic Coral Sea is separated from the Great Barrier Reef by an area of deep water known as the Queensland Trough, protected from effects of coastal influences such as urban run-off and pollution. Due to this location, it has largely avoided the destructive fate of other coral reefs worldwide, including the closely related Great Barrier Reef. On 25 th November 2011 the Australian Government published the proposed network of marine reserves for the Coral Sea. This submission sets out HSI s views on these proposals. HSI welcomes certain aspects of the current marine reserve proposal, including: 1. That the outer boundary is 989,842 km 2. 2. That the entire area is to be protected from demersal trawling, gillnetting, demersal longlining, and mining, including petroleum exploration and development. 3. That three quarters of the area (approximately 730,000 km2) is proposed for protection from pelagic longline fishing, a gear type that is associated with a high level of mortality of nontarget species. 4. The proposal of a large Marine National Park Zone in the eastern Coral Sea that adds approximately 490,000 km 2 of no-take protection to the two existing reserves. This new area includes the Mellish and Kenn reef systems and an area of national historic significance, where three U.S. warships from the Battle of the Coral Sea are located. These aspects provide a solid framework on which to build an internationally acclaimed conservation success. However, the Coral Sea marine reserve proposal leaves out the majority of species-rich coral reefs and critical habitat sites for tuna and marlin. Critical habitats for turtles, whales and sharks are also proposed to remain open to fishing. Many of the jewels in the crown of the Coral Sea remain unprotected as they lie in the western half: only two of about 25 unprotected 1
reefs are given a high level of protection. By extending the proposed marine national park to include the western half of the Coral Sea, the Coral Sea marine reserve could include all the reefs, cays and seamounts in the proposed reserve and most of Australia s largest trough system (the Queensland and Townsville Troughs) in one very large, highly protected area, creating the world s single largest marine national park. Our submission sets out further information on each of these points. Increase protection for Coral Reefs The majority of coral reefs are critical habitats forming breeding and feeding sites for a whole host of marine life such as pelagic fish, migrating cetaceans and marine turtles, and seasonally returning seabirds. One such example is Osprey Reef, considered one of the world s top 10 shark dive sites. Although coral reefs make up less than 1% of the Coral Sea s area, global biodiversity patterns would suggest they host the majority of the Coral Sea s marine species. The extent of the proposed Marine National Park Zone is very disappointing. The marine reserve proposal plans to keep 22 reefs open to various forms of commercial fishing and 23 reefs open to commercial charter fishing. The proposed exposure of more than 90% of the Coral Sea s unprotected coral reefs to continued fishing is by far the most serious weakness of the marine reserve proposal and risks a perverse outcome where the most diverse and dynamic habitats of the Coral Sea are relegated to continued and, most likely, poorly regulated exploitation. The unique assemblages of species on the reefs of the Coral Sea make them highly distinctive from the reefs of the Great Barrier Reef. In addition, the low level of connectivity between the reefs of the Coral Sea makes each individual coral reef highly distinctive from every other reef in the proposed reserve. This means that a representative approach to protection will not work in the Coral Sea. 219 (65%) of the Coral Sea species included on the IUCN Red List of Threatened Species are corals, directly reliant on shallow water habitat, which are left largely unprotected in the proposed reserve 1. Other IUCN Red Listed species likely to use the Coral Sea s reefs and associated cays and islets as critical habitat include 24 species of seabirds, 5 species of marine turtles, and several species of fish, including the Humphead Maori wrasse which was last year listed as Endangered on the IUCN Red List. The proposed Coral Sea Marine Reserve will not afford these species adequate protection since less than 10% of the Coral Sea s reefs fall within the proposed Marine National Park zone. The government should extend marine national park protection over all the reefs of the Coral Sea - both emergent reefs on plateaux and reefs atop seamounts - in recognition of the highly distinctive characteristics of each coral reef and the extent of threatened species occurring in these critical habitats. Increase Protection for Critical Habitats Under the current proposal the only known spawning site in the world for black marlin will still be available for recreational and charter fishing. Globally vulnerable bigeye tuna; and near threatened yellowfin tuna will continue to be caught commercially in a large area of the proposed Coral Sea Marine Reserve. These spawning aggregations or critical habitats occur in the Townsville Trough and Queensland Trough, which comprise Australia s largest trough system. These major trough systems should be included within the Marine National Park Zone. The marine reserve proposal allows most sub-sectors of the Coral Sea Fishery, as well as commercial charter fishing and private recreational fishing to continue throughout this biologically important trough system. The government should remove all commercial charter and private recreational fishing from the entire trough system in order to protect these critical habitats. Protect Underwater Volcanoes The underwater volcanoes in the southern Coral Sea are a globally significant hotspot for top ocean predators such as sharks, tuna and marlin. Under the existing proposal they will remain open to longline fishing and various other forms of fishing. All the underwater volcanoes and their associated reefs should be included in the Marine National Park Zone. 1 Ceccarelli, D. M. (2011) Australia s Coral Sea: A Biophysical Profile. 2
Protect Submarine Canyons and other Amazing Formations The Coral Sea is an iconic marine environment with a diversity of habitats, ranging from sand cays to cavernous basins over 4000m deep. It is the interconnected and near intact habitats that make the Coral Sea special yet the proposed Coral Sea Marine Reserve fails to adequately protect these features as one integrated ecosystem. Canyons and knolls in the deeper reaches of the Queensland Trough are known to host unique cold-water coral assemblages of high conservation significance. Geological features of the Townsville Trough, western Queensland Plateau and most of the Marion Plateau fall outside the highly protected national park zone in the current proposal. This should be rectified in the final plan. At a time when there is so little known about the diversity and vulnerability of the Coral Sea this ocean treasure is deserving of protection provided within the Marine National Park Zone. Simplify the Overly Complex Zoning The use of three zones types - the Habitat Protection Zones, the Special Purpose Zone, and the Multiple Use Zone in addition to the fourth Marine National Park Zone is overly complex for such a remote offshore area. The design of such a complex zoning plan risks creating expensive and unnecessary difficulties and serious ongoing management challenges, undermining the potential benefits of the marine reserve. The government should embrace the least expensive zoning option, which is also the most protective and precautionary conservation option, namely the establishment of one very large highly protected Marine National Park Zone. Increase protection in the Southern Coral Sea The continuation of pelagic longline fishing in the southern Coral Sea, which is considered a global biodiversity hot spot for apex predators, is a serious weakness of the Marine Reserve proposal. The Eastern Tuna and Billfish Fishery (ETBF) targets species of global conservation concern, at least four of which are included in the IUCN Redlist (bigeye tuna (Vulnerable); and yellowfin tuna, albacore tuna and striped marlin (Near Threatened)). The longline fishery also captures a wide range of non-target species such as leatherback turtles and sharks. Species listed as protected under the Environment Protection and Biodiversity Conservation Act 1999 such as leatherback and loggerhead turtles, would remain at risk of capture by longline fishing gear inside the marine reserve. The southern Coral Sea includes critical habitats such as the Frederick, Wreck and Cato Seamounts, and emergent reefs such as Marion and Saumarez, which function as important feeding grounds for pelagic species. According to longline fishermen who operate in the region, tuna and billfish species follow predictable movements through the southern Coral Sea, around the reefs, seamounts and troughs. The retention of longlining in the southern Coral Sea would result in fish protected in the northern, eastern and western sections of the reserve being captured in the south, going some way to cancel out the benefits of protection elsewhere in the reserve. The government should protect the entire proposed Coral Sea Marine Reserve from pelagic longline fishing in a Marine National Park Zone, creating a globally significant safe haven for pelagic species that are under intense pressure elsewhere in the Pacific. Provide Protection from All Commercial Fishing The zoning system proposes to retain four out of five of the sub-sectors of the Coral Sea Fishery: line and fish trap/pot; marine aquarium; sea cucumber; and trochus and tropical rock lobster. It is unclear why fish trap/pot is retained, given the plan proposes to remove all other demersal fishing. The level of active effort in this fishery is very low and consequently the commercial value is very low, yet the area that remains open to this fishery is vast: 49% of the proposed Marine Reserve (excluding Marion Reef). At a time when countries around the world are severely restricting or even banning shark fishing, the Marine Reserve proposal allows for the continuation of shark fishing in 49% of the proposed Coral Sea Marine Reserve by failing to ban line permits. This could lead to the export of shark fins from the world s largest marine park. We find that to be unacceptable, and we recommend that all targeted shark fishing or that results in the incidental capture of sharks and all commercial trade in shark fins be prohibited in the proposed marine park. The marine aquarium sub-sector, which is comprised of only two permits, has dominated the Coral Sea Fishery in recent years. The ecological consequences of the removal of large numbers of 3
individual fish, such as the commercially targeted and Endangered Humphead Maori wrasse, from these remote and highly individual reefs for use in aquariums are unknown. Therefore, in accordance with the application of the precautionary principle, we recommend that the entire marine aquarium fishery be closed in the proposed Marine Reserve. Under Queensland regulations, the two aquarium permit holders have access to the GBRMP, from where they obtain most of their income. The most cost-effective and ecologically sound way forward is for the Government to protect the entire Coral Sea reserve from commercial fishing in a Marine National Park Zone. This would have very minimal socio-economic impact, since most permits in the Coral Sea Fishery are not active and create a globally significant safe haven for marine life. Provide Protection from Commercial Charter Fishing and Private Recreational Fishing Commercial charter fishing in the Coral Sea is an opportunistic activity for a small number of charter operators. According to the Queensland Fisheries, there were only 307 days fished by licenced charter vessels in 2010. Private recreational fishing in the Coral Sea is extremely limited relative to the Great Barrier Reef Marine Park. No government agencies, fishing groups or research institutions hold quantitative data on the full extent of the different types of recreational fishing in the Coral Sea. It is well known amongst key stakeholder groups, however, that most anglers who visit the area do so by charter vessel hire. It can be assumed that a very small number of individual boat owners, who own ocean-going boats, visit the area occasionally. Information from the NSW national Game Fish Tagging Program shows the extent of game fishing in the Coral Sea compared to the GBRMP. Over a 20 year period (1989 2009) north of 24 30, 99.2% of tagged and reported game fish (mostly black marlin) were from the GBRMP and 0.8% from the Coral Sea. The Coral Sea is an aspirational destination for a very small number of game fishers. Closing it to this type of fishing will thus likely result in very little current economic change for those interested in engaging in it, but potentially huge conservation benefits for the Coral Sea environment. In recognition of the very low socio-economic value of the Coral Sea to charter and private recreational fishers relative to the GBRMP, and taking account of the potential impact of sustained recreational fishing on the unique and fragile reef systems in the Coral Sea, the critical habitats and the threatened marine species that rely on them, commercial charter and private recreational fishing should be excluded from the Coral Sea Marine Reserve. Extend Protection along the Entire EEZ Boundary The governments of France and New Caledonia are considering management options for the Coral Sea in French waters. These options could include a marine reserve, possibly a highly protected reserve. In order to enhance the prospects of a large highly protected area in the French waters of the Coral Sea, where a no-take highly protected area could be mirrored by both countries, we recommend that the Marine National Park Zone extend all the way along the boundary of Australia s Exclusive Economic Zone (EEZ) with France, between Australia and New Caledonia. Conclusion The Coral Sea is one of the least impacted tropical marine ecosystems on Earth. Unlike so many other locations in the Pacific, the large pelagic species that dominate this region (tuna, billfish and sharks) have not yet been severely depleted. There is a chance now to protect what remains after decades of fishing pressure, and to enable this precious ecosystem to recover its former diversity. To achieve this, all commercial, commercial charter and private recreational fishing should be removed from the proposed marine reserve in order to effectively protect this globally significant natural asset and create a large Marine National Park Zone. Given peer-reviewed research that shows that a single, large, no-take marine reserve would be the most cost-effective to manage and enforce, such a decision would make both ecological and economic sense. A decision not to protect the most important components of the Coral Sea, most notably the coral reef systems themselves, the underwater features of the Coral Sea and the critical habitats they provide for our marine life, would undermine the long-term success of the reserve, by choosing short-term local commercial benefits over long-term conservation benefits. The Coral Sea Commonwealth Marine Reserve has the potential to be the world s best example of a large, effectively protected marine ecosystem. The opportunity to make such an important 4
decision comes only once in a lifetime. It is rare for a government to have the opportunity to make such a globally significant decision. It offers the chance to leave a lasting environmental legacy for future generations at a time when numerous threats and their cumulative impacts on our marine life will otherwise undermine and degrade this essential and precious system. We urge the government to increase its level of ambition and create the world s largest marine national park, next to the Great Barrier Reef. This would make an unparalleled contribution to global ocean conservation, and cement Australia s role as the world s international leader in marine protection. Yours sincerely Alexia Wellbelove Senior Program Manager 5