The primary purpose of NSW marine parks, as stated in the Marine Estate Management Act 2014 (the Act), is ‘to conserve the biological diversity, and maintain ecosystem integrity and ecosystem function, of bioregions in the marine estate’.
In our shared view, the draft Plan fails to meet this statutory objective, and requires substantial revision to render it fit for purpose.
The described ‘new approach’ appears to represent a deliberate effort to shift the management of Marine Parks from the international norms for protected area management towards a resource management model. We regard this shift as wholly inappropriate and inconsistent with Australia’s international commitments for the conservation of biodiversity and natural systems.
The 2021 report by the Marine Estate Expert Knowledge Panel Evaluation of the performance of NSW Marine Protected Areas; biological and ecological parameters¹ stated that the success of marine parks should be measured by the primary purpose, and definitively found that highly protected areas (marine sanctuaries) are critical to that success. NSW’s provision of these highly – protected areas is under 7% of the entire marine estate – far below the level of protection that is required for marine ecosystems to withstand current and future pressures.
Simply put, without a major shift toward a science and evidence-based approach, and substantial increases to marine sanctuaries, the marine park network in NSW will fail in reaching its primary objective.
The draft Plan consistently describes ‘balancing’ values of the marine park across environmental, social, and economic incentives, completely undermining the philosophical and legally established purpose of NSW marine parks.
As described in the Act, secondary purposes of marine parks (to maintain social, cultural and economic values) are to be provided for only ‘where consistent with the primary purpose’. The draft Plan has failed to actualise this very important distinction: different criteria must apply for these small areas of the wider marine estate.
Unfortunately, even secondary purposes are unlikely to be met for the broader community of NSW, given the lack of transparency and accountability, and poor community engagement strategies displayed in both this consultation process and in the draft Plan itself. Community education and partnerships display a marked intent to promote, encourage and facilitate extractive use while stewardship, conservation and science are almost entirely absent. Persistent reference to Community Advisory Committees as ‘the voice of communities’ – both in the draft Plan and throughout the process – completely misrepresent the way these Committees have been set up and operate, particularly with regard to a high level of confidentiality imposed on Committee members that limited their ability to consult with stakeholders on this draft Plan.
In this submission we provide detailed comment on the draft Plan, as thoroughly as possible, in the sincere hope that the Department will correct course. NSW’s marine ecosystems are incredibly valuable – to NSW lifestyles, livelihoods, and for their own unique and inherent worth. The draft Plan must be urgently revised to protect them.
¹ Marine Estate Expert Knowledge Panel. Evaluation of the performance of NSW Marine Protected Areas; biological and ecological parameters. 37 (2020).
Image credit: Cath Leach