South-east Marine Parks Network Draft Management Plan

Under Introduction in subsection Vision and Objectives it would be useful to add a statement at the beginning on what is the vision or purpose of the Australian government's marine parks such as "An area of sea especially dedicated to the protection and maintenance of biological diversity, and of natural and associated cultural resources, and managed through legal or other effective means", based on the internationally accepted IUCN protected area definitions. This should go before the statement on management that goes straight to the issue of balancing protection with use.

Under section 1.6 Changes from the previous management plan Zoning Design it would be useful to be more explicit on the changed status of areas for pelagic fishing access to be clear to the public on what IUCN categories have changed and why, not just what they will be going forward if this management plan is accepted.

In this introduction to the revised Management programs it would be useful to outline briefly each of the four management programs and their desired outcome.

Section 2.3.3 Social and economic benefits - this should be in alphabetic order so that it does not appear that any single benefit is considered greater than those following it.

Section 3.1 mentions Adaptive management approach referring to section 3.5 on Monitoring and evaluation yet this section does not provide any indication of what that would entail and how adaptive management could be implemented.

I am pleased to see the creation of new highly protected zones in areas of high conservation value, particularly in the previously under-represented continental shelf and slope. In terms of CAR principles it is excellent to see the addition of highly protected areas to four shelf bioregions that previously did not have any. It is also a good step forward to see significant increased protection for high conservation areas in upper slope habitats. This is an excellent outcome, but there is more required to achieve a fully represented system, and it would be useful to call this out in this plan so that we are all aware of where the government has achieved CAR and where there is less representation and therefore there may need to be additional management measures to ensure ecological sustainability.

A management plan for a network of marine parks should address connectivity and this issue is inadequately addressed in the current draft plan. There are proposed changes to allow pelagic fishing in areas previously protected in order to manage possible changes to the distribution of commercially exploited species, but not for ecological connectivity. The rationale for the changes in protection in Flinders MP and Murray MP are not adequately backed up by scientific evidence of the need for these changes. It would be useful for transparency of the decision-making to provide a more robust description of these changes given it is the first time Australia will have made such significant reversals of protection. I am not opposed to changing zoning to create a more efficient and effective marine park network, but it needs to be well explained. The current plan does not adequately explain these changes, backed up by scientific analysis that shows how any new measures will "compensate" for the losses. A more precautionary approach would be to fully establish a comprehensive, adequate and representative system of marine parks and to then use adaptive management to adjust management boundaries to test that fishery management is adequate to ensure the long term ecological sustainability of the system.

While the draft Management Plan is concerned with reviewing activities and zoning within the existing marine park boundaries in terms of connectivity of the entire NRSMPA it would be beneficial to highlight potential new marine protected areas for the future adjacent to Victorian state waters and in particular adjacent to Victoria’s marine parks that abut the Commonwealth marine area. For the most effective national marine reserve system it would be useful to project the addition of new Commonwealth marine protected areas adjacent to Victoria's Twelve Apostles MP and Wilsons Promontory MP, which could be considered in the future.

There are key ecological features that are not adequately represented in highly protected zones. The highly protected zone in the Tasman Fracture Marine Park needs to be expanded to include the West Tasmanian Canyons key ecological feature. The Commonwealth has already identified an upwelling east of Eden as a key ecological feature known for its high productivity and marine life. The East Gippsland Marine Park currently lacks adequate areas that are highly protected and the upwelling east of Eden should be declared a highly protected zone.

Both research and monitoring are mentioned throughout the plan there is insufficient detail to make substantive commentary on their adequacy to support the network of marine parks. While prescriptions for where research may not happen are clear, it is less clear how a comprehensive research program will be established to support effective management.

Table S1.2 is a good inclusion to document the range of natural values. There is mention that natural values criteria may be updated and new values added, but no detail on how this will be done. It would be useful to understand how this knowledge base will be expanded to cover habitats and species that are currently poorly understood. I would recommend adding in a section on poorly understood elements such as deep sea skates, so that it is clear these will be addressed in some way in the life of the plan.

The new conservation measures for Macquarie Island Marine Park are strongly endorsed.
The significant increase in protection for seamounts to the south and east of Tasmania is warranted given our knowledge base of their importance continues to grow. My understanding is the number of seamounts proposed to now be covered in highly protected zones is 24 (or about 33%). It would be useful to provide further information on the adequacy of this protection for the full range of values present.