Fraser Island Defenders Organization FIDO, “The Watchdog of Fraser Island”, aims to ensure the wisest use of Fraser Island's natural resources.

FIDO Submission on Northern Section Proposed Great Sandy Marine Park

The Queensland Government is proposing a marine park discussion paper.

The following letter is FIDO's Comments:

Fraser Island Defenders Organization PO Box 71, GLADESVILLE, NSW 1675 Telephone (02) 9817 4660 - Fax (02) 9816 1642 FIDO - The Watchdog of Fraser Island Aims to ensure the wisest use of Fraser Island's natural resources

26th June, 2002

Environmental Protection Agency,
Parks and Forests Planning,
Great Sandy Marine Park,
PO Box 155,
BRISBANE, ALBERT STREET, QLD 4002

FIDO Submission on Northern Section Proposed Great Sandy Marine Park

The Fraser Island Defenders Organization (FIDO) welcomes the proposal to establish a Marine Park over the waters of the Great Sandy Region.

FIDO is an organization with a long history of strongly advocating the protection of the outstanding natural values of Fraser Island and the Great Sandy Region. A short history of FIDO is included in an educational supplement produced to coincide with FIDO's 30th birthday and 100th issue of MOONBI.

For some time years it has been a major concern of FIDO that insufficient has been done to address the plethora of urgent marine issues surrounding Fraser Island. This is perhaps best epitomized by the failure to consider the impact of the Toyota Fishing Expo at Orchid Beach on the marine environment although the World Heritage area extends 500 metres seaward on all sides of Fraser Island.

There are several unresolved disputes over the rights of fishers in the Great Sandy Region. Toyota wants to continue its deplorable exploitation of this World Heritage site for its commercial purposes. The commercial fishers want unfettered access for the motor vehicles to all parts of the Fraser Island coast even beaches closed to all other Fraser Island users. Amateur anglers claim that commercial fishers are over-exploiting the resource and are walking roughshod over other Fraser Island stakeholders. Meanwhile the Queensland Government is concerned as the general overall depletion of the whole fishery in the Great Sandy Region and have belatedly started to apply some restrictions on at least the tailor fishery.

This submission wishes to address the issues in two levels:
A. On a geographical level addressing specific sites within the proposed Marine Park, and
B. On an issues level relating to specific topics which need to be addressed within the zoning and Management Plan for the Marine Park.

A. Geographical Issues:

The area is most appropriate: This organization applauds the selection of the boundaries for this Marine Park. We especially applaud the decision to extend the Marine Park much further than the 500 metres from Fraser Island as included on the World Heritage List. It should be noted that this Organization thought that the marine areas of Hervey Bay were so special that we had proposed to include it in the Great Sandy Region World Heritage area which we first described in 1984. Our position was vindicated by the Fitzgerald Commission of Inquiry into Fraser Island and the Great Sandy Region in 1990-91. We always envisaged the area linking to the Great Barrier Reef Marine Park.

We like the inclusion of and linking of the Hervey Bay and Woongarra Marine Parks and their incorporation in this Greater Marine Park. While we welcomed these parks we always considered that they were inadequate to protect the very significant natural values which extend well outside these areas. The fact that there are now more clearly defined natural boundaries rather than a straight line is also welcome.

We are particularly happy that it will incorporate a number of the existing Fisheries Habitat Reserves and the whole of the defined Ramsar Site in the Great Sandy Strait. However we will be most disappointed and critical if it does not at least improve on the existing protection given to this area.

We also believe there needs to be more attention given to the protection of the biodiversity of the marine areas surrounding Fraser Island included those areas which are part of the World Heritage site. We believe that the Environmental Protection Agency has been derelict in its obligation by abdicating its responsibility under the Nature Conservation Act by abdicating all responsibility in this area to the Department of Primary Industries to monitor and control all fishing activities below the high water mark surrounding Fraser Island. The fact that the impact on the marine biodiversity of the Fraser Island Fishing Expo does even rate a mention in the reports prepared by the Environmental Protection Agency is loud testimony to this serious omission.

1. Breaksea Spit: Our only concern about the boundaries is that it may have overlooked Breaksea Spit. Breaksea Spit is of great significance to the natural values of the Great Sandy Region and an important fish habitat. It is believed to be very significant spawning area for Tailor fish. We believe that should therefore be included in the boundaries in its entirety although we understand that the State jurisdiction may not cover beyond the three nautical miles. However we would flag the natural resources of the Breaksea Spit area as deserving greater protection than they currently receive.
2. Platypus Bay: (The current Hervey Bay Marine Park): The areas of Platypus Bay previously covered by the Hervey Bay Marine Park also require better management. Seasonal closure during the whale watching season is good but that seems to be the only effective zoning regulation in existence and the significance of the area requires much more management. Four issues have been overlooked in the management of this Marine Park.
   1. Its significance as a breeding ground for loggerhead turtles;
   2. The importance of the reef system off Rooneys Point; and
   3. The high incidence of cigatatura inducing algae; and
   4. The need to integrate the management of the Marine Park with the management of the Great Sandy Region National Park which lies on the adjacent shore.
   1. Turtles: In personal communication we have been advised that all of the courtship for the endangered loggerhead turtles in the south-west Pacific occurs in October and November around Rooneys Point. This was discussed in "Discovering Fraser Island and Cooloola" by the writer in 1998. The 1984 World Heritage nomination for the marine areas of Hervey Bay also prepared by the writer made the following observations on the turtles:

      Hervey Bay is one of the major feeding grounds for loggerheads in eastern Australia. Almost all courtship and mating of loggerhead turtles occurs in Hervey Bay near Rooneys Point.

      Mon Repos is the second largest loggerhead turtle rookery in the South Pacific after Wreck Island. Due to its proximity to Bundaberg, it has become one of the most thoroughly studied nesting beaches in the world. It has an international reputation as a major loggerhead turtle rookery, supporting a nesting population of about 300 - 400 females annually. Green turtles and the indigenous flatback nest there in lesser numbers. The rare and endangered leathery turtles have also been recorded as having nested at Mon Repos.

      While the animals don't necessarily nest there after mating this is where they assemble for their orgy of mating prior to dispersing to preferred nesting sites at Mon Repos and elsewhere. Turtles caught in the Gulf of Carpentaria have had to swim at a rate in excess of 80 kilometres per day to make this mating rendezvous. It seems justifiable therefore if the closed season for netting and other forms of commercial fishing in the area of Platypus Bay extending to Sandy Cape should be closed from the start of this mating season. The increasing significance of the northern end of Fraser Island as a turtle rookery seems to justify the extension of this closed season from the start of the turtle mating until mid February. Since the closures for the whale watching season conclude virtually as the turtle mating starts, this would have the Platypus Bay to Sandy Cape area closed from August until March.
   2. The Rooney Point Reef system: The writer noted in the 1984 World Heritage Nomination that Rooneys Point was of special significance: Rare colonies of vernetid gastropods (sedentary marine snails) have been discovered at Rooneys Point. The gastropod colonies which could be more than 100 years old, are a series of brown domes lying in a shallow sand depression. Although large reef conglomerations of these creatures are common in other parts of the world, they are unusual in Australia. Normally they are found only in intertidal areas. The remote, rarely visited subtidal reef in the Great Sandy Region lies in about 30 metres of water north-west of Rooney Point. This occurrence in such deep water is considered exceptional. They are affected by strong tidal currents. FIDO believes that there insufficient protection has been given to this phenomenon. Fortunately the inaccessibility of this site affords some protection but we believe that recognition and zoning is needed to more definitely protect this site.
   3. Cigatatura: The high prevalence of cigatatura amongst mackerel caught in Hervey Bay has resulted in an Australia wide total ban on the sale of all mackerel caught in Hervey Bay. It appears that the cigatatura is a result of a build up of toxins from a natural algae which is most prevalent around Wathumba Creek and the shores of Platypus Bay. Thus there is already a ban on some commercial fishing within the Marine Park,. This organization believes that this is added justification for selecting the area which is currently in the Hervey Bay Marine Park a "No-take" zone for all fishing.
   4. Management of Fraser Island: There has recently been a total closure of the western shores of Fraser Island from Wathumba Creek to the Sandy Cape Lighthouse to all vehicular traffic except for commercial fishers and management vehicles. This closure in accordance with the 1994 Management Plan is well justified. However the current exemption for commercial fishers is only justified on the fact that there is commercial fishing occurring in the northern part of Fraser Island. Given the coincidence of the above factors, it is this organizations view that all shore based commercial fishing should end in the Platypus Bay area. It is also the area most remote from the main communities surrounding Hervey Bay. Playtpus Bay is the epicentre of cigatatura occurrence in Hervey Bay. It is so important for whales that there are already seasonal restrictions there. Given its importance for sea turtles it is our submission that the seasonal restrictions need to be extended further to protect turtles. In addition to the other marine values identified at Rooneys Point, there are significant cultural values associated with the two visits of Matthew Flinders, the wreck of the Panama, the death of Yankee Jack Piggott and the Sandy Cape Lighthouse. This area was the territory of a separate Aboriginal grouping described by the Hon Serena Lovell and others. Therefore for all of the above reasons this is the area of open water where highest priority should be given to establishing a no-take zone within Hervey Bay proper.
3. Great Sandy Strait: The richest most biodiverse part of the Great Sandy Region Marine Park id clearly the Great Sandy Strait - Tin Can Bay section. This is testified by the number of overlapping protection titles afforded to it. The Ramsar inscription should justify the highest level of protection. Likewise the Fisheries Habitat Reserves are testimony to the rich biological significance and attempts to protect this rich habitat. Overlaying that is also the Dugong protection zone. Notwithstanding all of this recognition of the outstanding biological significance there has been very inadequate protection given to this area where commercial fishing is becoming increasingly aggressive in exploiting this rich natural resource as has recently been reported to this organization by a local observer who has advised as follows:

   Unfortunately, despite the RAMSAR accreditation, successive Queensland governments have refused to exclude commercial fishers and crabbers from the area. And, now the marine ecology is currently under threat due to plundering by commercial fishers/crabbers.

   Despite a pot limit of 50 pots, every professional crabber in the Great Sandy Strait has more than 75 pots (one has over 100) constantly in the area catching crabs. Most crabs are female. Crabbers have personally told me that there are so few male crabs left they cannot make a living out of only 50 pots (the legal maximum). In this area, Queensland Fisheries has never ever sent a team of assessors to check the number of pots being used by any crabber.

   Despite not being allowed to enter the mangrove fringed creeks entering the Great Sandy Strait, smaller beam trawlers nevertheless enter the creeks and drag their nets along the entire creek beds. The trawlers use prawn nets - a very small sized net. These nets not only drag up every living fish, the debris that forms habitat protection for small fish is also dragged in. The fishing boats go to more open waters and sort through their catch, discarding anything that cannot be sold (including undersized fish). Don't say it doesn't happen I've witnessed the trawlers in the creeks doing the trawling. Deckhands tell me that up to 80% of the catch is returned to the water - DEAD.

   Many commercial fishers/crabbers admit that they are going beyond catch limits when possible because they believe the fish/crab stocks are on the verge of collapse. At the moment, many are actively lobbying the State Government to buy back the fishing licences. But there seems to be a reluctance to buy back licences as it will set a precedent for other over-fished areas.

   Because of the richness and significance of Great Sandy Strait FIDO recommends that all of Great Sandy Strait be excluded to all commercial fishing and crabbing operations and that all of the existing Fisheries Habitat Reserves all be designated as "no take zones" even for recreational fishers.

   * A NO TAKE area for Great Sandy Strait : FIDO recommends that all of Great Sandy Strait be excluded to all commercial fishing and crabbing operations and that all of the existing Fisheries Habitat Reserves all be designated as "no take zones" even for recreational fishers. This would virtually establish something equivalent to a Marine National Park as occurs in the Great Barrier Reef.
4. The Eastern seaboard area: The extension of the Marine Park 3 nautical miles to the east of Fraser Island and Cooloola is long overdue. The inshore areas are most important for recreational fishing based on Fraser Island. There has been significant overexploitation of some of this fishery, particularly the Tailor Fishery. We attach a copy of our submission to the Queensland Fisheries Service on this issue. Most of our comments apply to the eastern seaboard area. In addition we have identified the following as being particularly in need of better protection and better management.
   • Indian Head - Waddy Point area: We urge that the seasonal closure of this area to all fishery be extended from 15 July to 15 October. We also believe that the existing boundaries of the closed area are not far enough apart. We suggest that the boundaries be at least one kilometre south of Indian Head and one kilometre north of Waddy Point.
   • We referred to Breaksea Spit above. We believe that this area also needs to be considered for seasonal closure.
   • Off-shore small boat based fishing: Coincidental with the decline of the Fraser Island shore based fishery has been a rapid growth in the volume of small boat based fishing off-shore from Fraser Island. Both commercial and recreational fishers are engaged in this practice. This has rapidly increased since boats began to be launched in the lee of Waddy Point. This practice only began in the late 1970s because prior to that it was almost impossible to get boat trailers north of Middle Rocks. Much of this small boat based fishing occurs within the 3 mile boundary. Some reefs are being heavily targetted by these boats.
   • Wolf Rock: FIDO is also aware of the small boats launched from the lee of Double Island Point or Inskip Point to exploit the fishery at Wolf Rock, Wolf Rock needs special zoning. In addition to the above Some trawling from trawlers based in Tin Can Bay also occurs within the 3 mile zone. It is FIDO's concern that this fishery is already being depleted before the level of sustainability has been established. FIDO believes that with the inclusion of this offshore area there needs to be closer monitoring of the take from this area. It is also FIDO's submission that in preparing any management and zoning plans for this area the Precautionary Principle should prevail.
5. Western Hervey Bay: The final part of the area to be addressed is the western and southern part of Hervey Bay. This includes the Woongarra Marine Park but it is also the areas where most of the human population is based in settlement from Urangan to Moore Park. It is also an area where there are a number of significant environmental threats arising from the mainland based land uses and some recent proposals for marine developments including aquaculture ventures and a coal loader. Due to the arc of population centres in this zone we accept that this area should most appropriately zoned to allow recreation fishing as long as this does not degrade the values of the Fisheries Habitat Reserves in this area nor the dugong protection zone. * Woongarra Marine Park: FIDO has recognized the significance of the Woongarra Coast since 1984 when we first proposed that Mon Repos and the marine environment of Hervey Bay be included in the World Heritage area for which we prepared a draft nomination in 1984. The Woongarra Marine Park certainly contains such outstanding natural values that it deserves to be declared as a Marine National Park where all marine life is protected. . FIDO is concerned at the very significant environmental impacts which may arise from the proposed oyster aquaculture venture off Woodgate and the possible coal loader at Coonaar on the marine environment of Hervey Bay. Again we urge that these projects be approached with the Precautionary principle uppermost in mind.

B. Management Issues:

Many of the management issue have been addressed in the above discussion of the geographical areas. We also need to emphasize that we support the remarks relating to the various natural marine values included in the Discussion Paper. The following remarks should therefore be regarded as supplementary to the above.

(1) "No Take" areas: It will be noted that FIDO has identified three significant "no take" areas. These are the existing two Marine Parks and the Fisheries Habitat Reserves. FIDO supports the widely held view that there needs to be 10% of the total marine area set aside as "No Take" areas. This accords with the general principle of sustainability that all governments should aim to establish 10% of the marine areas as "No Take" zones in the interests of biological sustainability. The area nominated by FIDO may slightly exceed the 10% but we believe that this is well justified. The Great Barrier Reef Marine Park started off with what GBRMPA now acknowledges to be a clear deficiency of "No take" area. However increasing this to 10% now is proving much more difficult to achieve and is only marginally moving upwards by incremental expansion of some of the existing areas. FIDO urges that the Great Sandy Region Marine Park not be crippled by the lack of adequate "No Take" areas. We have given a strong rationale to justify each of the areas we have identified being designated as "No Take" zones.

(2) Dugong and sea grass: We believe that the physical protection of the dugong from physical harm from boat strikes and trawlers is most desirable. However, the disastrous loss of a huge part of the Hervey Bay dugong population about a decade ago (then estimated at about 2000) was not due to dugong drowning or physical harm but to the death of the sea grass which was attributable to increased turbidity in Hervey Bay. Thus while we recognize the importance of dugong and the significance of Hervey Bay the maintenance of a healthy dugong population largely depends on land management issues on the catchments flowing into Hervey Bay. This needs to be recognized in the management issues.

(3) Maintaining Environmental Flow: As well as bringing negative impacts such as increased turbidity and some damaging pollutants some water flowing into the marine environment has very beneficial effects on marine productivity. This was recognized by FIDO when it published an Educational Backgrounder on the necessity for maintaining the environmental flow from the natural streams of Fraser Island into Hervey Bay. FIDO would urge that the Marine Park recognize and underline the importance of the environmental flow of the streams from Fraser Island into Hervey Bay.

(4) Over exploitation of fish stocks: This has already been addressed above in part. However the creation of more Marine National Park within the Great Sandy Marine Park will address many of these concerns. However, FIDO remains most concerned at some special events such as the Fraser Island Fishing Expo which encourages some massive and concentrated fishing effort in this World Heritage area. FIDO regards the marine biodiversity as a very significant part of the World Heritage area which has been sadly overlooked in the existing Great Sandy Region Management Plan . We regard the initiative of developing a Marine Park to incorporate all of the marine zone within the World Heritage site as very positive. However it will not be effective unless it takes action to ensure that all fishing is sustainable and takes positive steps to achieve that objective.

(5) Shark netting: For many years we have been concerned about the impact of shark netting on larger marine creatures. During the1970s the author studied the statistics of the by-catches in these shark nets. The number of sharks, dugong, dolphins, rays, turtles caught was appalling. He has not seen data since 1978 but the downward trend on the number of animals caught in these nets indicate that they are reducing populations of the larger marine animals. As well shark nets being placed off Rainbow Beach there are still line drums in the Woongarra Marine Park. If this Marine Park is to offer credible protection as foreshadowed when the Environment Minister, Dean Wells, announced the establishment of this Marine Park, it will need to address the issues of trying to purge the whole area of sharks and in the process offer more than lip service to the most commendable objective of protecting the endangered grey nurse shark as well as other shark species in this region.

In conclusion we emphasize that we welcome the establishment of a larger Marine Park over the northern part of the Great Sandy Region. However our welcome is based on the anticipation that it will provide significantly greater protection of the outstanding biodiversity than the area is currently receiving. The rich natural resources of this region deserve much better management than they have hitherto received from the Queensland Government .

Yours sincerely

John Sinclair,
Honorary Project Officer.

Attachments:
History of FIDO
FIDO's Submission on Proposed Tailor Regulations
Maintaining Fraser Island's Environmental Flow