The Chief Executive
Department of Environment and Natural Resources
GPO Box 1047
Adelaide SA 5001
Dear Chief Executive:
I am writing at the advice of the Committee of Scientific Advisors and on behalf of the Board of Governors of the Society for Marine Mammalogy to comment on the South Australian Government’s proposed multiple use marine park in the waters of the Great Australian Bight.
The Society for Marine Mammalogy is a professional scientific organization whose members conduct research on marine mammals internationally. The Society currently includes approximately 1,400 marine science professionals and students living and working around the world.
We are encouraged with the steps that your government has taken already to protect the calving grounds of the southern right whale and the coastal waters close to the colonies of Australian sea lions in the Great Australian Bight. The Committee of Scientific Advisors to the Board of Governors of the Society is concerned, however, that the provisions of the conservation zone and right whale and sea lion sanctuaries, as proposed, may not be adequate to provide effective protection as intended. While we understand the limitation of the South Australian government’s jurisdiction, the 3 nautical mile extent of the proposed conservation zone and right whale sanctuary and the proposed 1 nautical mile wide sea lion sanctuary zones may not afford sufficient protection from human activities occurring just outside the proposed protected areas (e.g., commercial fishing, recreation, resource development, etc.). In addition, although right whales may reside in this area for only 6 months of the year (May through November), it would be important to conserve right whale habitats year round to avoid changes that could render these areas undesirable for breeding and calf rearing when the whales are in residence.
Marine protected areas need to offer effective protection from activities that may disadvantage affected species and/or prove disruptive to their essential resources. This is not to say that the creation of marine protected areas may not be compatible with other human activities.
As noted in your proposal, sanctioned activities, such as public recreation, recreational and some commercial fishing, can be allowed so long as they are regulated so as not to jeopardize the integrity of the habitat or disadvantage the species that depend on those habitats.
In our view, scientific advice, based on biological, social, and economic considerations, should be an integral part of the planning and development process. This advice must identify critical uncertainties as well as established facts, and inform managers, developers, and the public of the potential consequences of alternatives before development begins. For example, establishing 3 and 1 nautical mile limits to the boundaries of the whale and sea lion sanctuary zones may be legally consistent with the limits of your jurisdiction. Such zones may, however, be ineffectual with regard to the biological needs of right whales and sea lions. To be effective, the proposed limits of such a protection zone should have as their basis the biological needs of the affected species, and consider the extent and timing of their seasonal movements. Responsible authorities should then develop an implementation plan that can be accommodated within the scope of the relevant legal mandates.
In addition to establishing a protected area, it is essential that research and monitoring programs are implemented to see that all aspects of the protected area are fully implemented as envisaged, and to allow detection and analysis of any unforeseen changes in the affected species status or their habitats. In this way, potentially detrimental actions may be identified and avoided before problems arise. In summary, the Board of Governors of the Society for Marine Mammalogy encourages you to: reconsider the proposed boundaries of the Great Australian Bight Marine Park based on the actual habitat needs of the right whales and sea lions to provide effective protection, including consideration of year-round measures; develop and implement research and monitoring programs to evaluate the effectiveness of the park to protect these species; and, pursue discussions with your Federal Government toward expanding the marine park to include the adjoining Commonwealth waters to be managed in a complementary manner.
Jeanette A. Thomas, Ph.D.
Dr. Peter Bridgewater
Australian Nature Conservation Agency
GPO Box 636
Canberra, A.C.T. 2601
Mr. David Hall
Director of Fisheries
GPO Box 1625
Adelaide, S.A. 5001