Heard Island and McDonald Islands Marine Reserve proposed proclamation and proposal to prepare a draft management plan

I fully support the expansion of the Heard Island and McDonald Island marine reserve, but it must protect areas of high conservation value, not lower value deep sea areas. Industrial fishing, wether it is bottom trawling, long lining or any other method, should not take precedence over protecting high value conservation areas. In fact, industrial fishing has no place in a marine reserve at all. The current design shows that fishing has been prioritised over conservation. The Australian Government must ensure that such unique and critical areas of biodiversity are fully protected and complete no take zones.

The current design is based on a principal of quantity not quality. Huge swathes of low conservation deepwater areas are protected, but do little to protect biodiversity simply beacause it isnt as present in deep water. In an effort to appease industrial fisheries, there is extremely poor representation of the depth ranges and benthic features between around 750m to 2,500m which are the depths where Patagonian toothfish are generally caught. This must be addressed and changed. I would strongly support a marine reserve expansion that fully protects key conservation features including the William’s ridge complex, southern canyons, Gunnari ridge and western plateau.

I would strongly support a marine reserve expansion that fully protects key conservation features including the William’s ridge complex, southern canyons, Gunnari ridge and western plateau. These are the areas that harbour critical biodiversity that the current design has completely overlooked. As a world heritage area, the concept that industrial longliners can set kilometres of longlines with thousands of hooks in this area is outdated. It becomes even more outdated when the fishery targets a deep water fish, on which scientific data is lacking, and is then sold as a luxury item. This doesn't and should not fulfil any criteria of sustainability or good practice. Australia can take the lead globally on Antarctic and Sub Antarctic conservation, and ensure that the natural values are protected and not sacrificed at the behest of the fishing industry.

My key recommendation is that the marine reserve expansion proposal must be changed to include full protection for key conservation features including the William’s ridge complex, southern canyons, Gunnari ridge and western plateau, with industrial fishing fully excluded from the marine reserve and these key conservation areas. There is enough scientific doubt and lack of understanding surrounding the impacts of industrial fishing in these critical areas, as well as the impacts on the target species of Patagonian toothfish and other icefish, to warrant the cessation of industrial fishing, be that longline fishing or trawling, in the highlighted key conservation areas.

As a matter of principle, the Australian Government should enshrine the concept of conservation being the only priority in a marine park and reserve. Industrial fisheries should have no place inside any of Australia's marine protected areas. Global evidence has shown that if fishing activity is excluded entirely from a marine park, then fish stocks in the region, both inside and outside the marine reserve improve. It is completely at odds with the goals and intentions of a marine park. reserve or protected area, to allow extractive industries to operate within its boundaries.

The Australian government must provide strong support and budget to ensure that, once the key conservation areas have been protected and fishing is excluded, that no illegal fishing takes place in the marine reserve.