I am a resident of Esperance 6450.
I have opted to submit my submission via email because you have not allowed enough characters for me to respond via the online submission process and I feel that it is important that all points of my submission are explored.
My submission is based on the proposed Wudjari Marine Park Plan however the points that I am submitting cover the four proposed marine parks and should be considered against the four.
Whilst I am not completely against the idea of a Marine Park, I feel that this proposed plan has been slapped together with no supporting evidence or level headed planning into the zoning. Therefore I am opposed to this proposed Wudjari Marine Park Plan. Perhaps have the marine park with no sanctuary zones for starters. This will attract funding for research capabilities and allow appropriate time to study the area and place sanctuary zones in the appropriate places.
This document is written in tongue tie and seems like it has been purposely designed to trip the average person up and deter them from submitting feedback. Shame on the department for poor writing.
If you restrict commercial fishing in Australia too much, then seafood will simply be imported from elsewhere where there are limited or no fishing restrictions. This may protect Australian waters but not the world, which will defeat the purpose.
The south coast of Western Australia already has a small number of good weather and tidal condition days that allow for both boat and land fishing let alone the number of days that people have off work to be able to go. Let nature minimise human activity in this form. This is also evident in that there is no current and solid research (as per the documents references) on the animals in this area because scientist cannot get out to the islands frequently to undertake the research. However, the documents that you have referenced that I did take the time to read indicate that all species numbers are currently stable.
Conservation and protection rights are already in place on many species in the area. All local personnel respect and look after nature.
I am not a commercial fisherman but I do work in an office. I do not trash my office, I respect my workplace. I am confident that commercial fisherman do the same. It would not be in their interest to ruin the place that supports their livelihood.
I don’t understand the requirement of cultural zones under the sea. Where is the evidence to support the proposed cultural zones? It is not listed in the plan. I do not believe it is important to waste taxpayers money researching historical cultural sites under the sea. I have full respect and am willing to learn about locations that I may come across on land.
Proposed Kepa Kurl Sanctuary Zone includes Woody Island meaning no fishing will be allowed at Woody Island (except for the tiny area you have left at the jetty). There is only one tourist boat and only one tourist island in the whole archipelago and you want to turn it into a sanctuary? This will affect the Esperance Tourism Industry.
We don’t have the tourism industry over the sea like there is up north in places such as Exmouth and or QLD Great Barrier Reef. There are a couple of fishing charters, dive boat, Woody Island tour, helicopter tour, and 4×4 tour. Most of it is seasonal and not every day of the week. Places like Exmouth have 50 or so boats go out daily. Don’t assume Esperance is the same.
All larger companies that work on or near the water (Ports, shipping companies, mining and oil rig companies) are all required to have risk assessments and emergency plans etc in place
for incidents that may result in marine pollution whether they are in a marine park area or
not. In the past the Esperance Port has completed incident management drills with local emergency services to discuss potential incidents and how they would be managed. I know this for fact as I have been involved with them.
Further reading (of your referenced documents) suggests that the big threat to the south coast of WA is rising water temperatures as a result of global warming. This is not going to be changed with the input of the Marine Park.
There are already so many existing government agencies and regulations that are in place to ensure people care and respect the environment. The marine park does not change this. Work with what you have.
DPIRD – FRM Act – Fish limits – 98% of WA aquatic resources are currently being sustainably managed.
CALM Act and regulations require commercial businesses to have commercial operations licence
DoT and Dept. Planning Lands and Heritage are responsible for planning and developing coastal infrastructure.
Dept. Mines, Industry Regulation and Safety assesses approvals under the Mining Act and the Petroleum Act
Shire of Esperance.
There are already Commonwealth Marine Parks in place in the region.
Once the marine park is put into place it requires this community consultation process again if changes to any of the zones are required. Once a Class A marine park is in place it requires approval from both houses of parliament to make any changes. This sounds like a lengthy process.
There is no budget/ proposed budget with this document. How is the marine park going to affect taxpayers both for capex and opex? Is it going to provide more jobs to the region? If so, for anyone or just for Wudjari people?
The marine park covers 1000km of coastline from Bremer Bay to the South Australian border. Why has the marine park been targeted for a non labor seat area? What is the difference in marine are from Bremer Bay to Albany and beyond? Where is the evidence to support you choosing of a location for a marine park?
Referring back to the document
Page 7 Acknowledgements
Just says ‘many groups and individuals provided valuable input’ but what groups? Were the following groups given opportunity:
Commercial fisherman
Surfers
4 x 4 clubs
Motorbike clubs
Esperance Port Authority
Deep Sea Angling club
Land fishing club
Dive Shop and local divers
Woody Island Tours
The Jetty Group
Page 10 Management Plan
There are 12 dot points listed as main outcomes of which only one touches on the ecological benefits of a marine park. Is the proposal really in place for the right reasons or is this just to satisfy a political promise?
Page 10 Development Plan
As per page 7 – Suggests that advisory groups were consulted but what groups?
Page 11 – This plan recognises Wudjari Special Purpose zones that serve as focus areas of management related to different cultural areas – no restrictions on commercial and recreational fishing are proposed for these zones.
But will restrictions come into effect once the marine park is in place? Will we start getting charged to enter these places? Are there other restrictions aside from fishing? Why have these zones been chosen? Where is the evidence of them being special purpose zones?
Page 11 and 12 Why is the JMB only between ETNTAC and DBCA when DPIRD plays a massive role in all things fish and aquatic?
Page 14 – paragraph 3 ‘exact boundary is yet to be defined’. All boundaries need to allow for public consultation. There should be a second round of consultation after this first round to update on any changes that the public have spent the time addressing.
Page 14 – The proposed marine park includes intertidal areas to the high-water mark subject to adjacent terrestrial tenure and registration of an Indigenous Land Use Agreement with ETNTAC providing for native title consents in accordance with the Native Title Act 1993.
Page 17 – 4th paragraph
An indigenous land use agreement (ILUA) is being negotiated with the ETNTAC, pursuant to the native title act 1993, to provide for the native title consent to create the proposed marine park over the intertidal zone.
Where is all of this up to? How does this outcome affect the JMB?
Page 17 Joint Management – I would like to know more details about the Joint Management Plan. Who is looking after what? Who is funding what and where is funding coming from? Will more jobs be allocated to the existing departments in the Esperance region? Who will ensure the JMB groups remain responsible and report correctly?
Page 20 – Boodja is hanging on but is not as healthy as it should be. Some things are less healthy than others, and they need to be prioritised first.
What are the examples? Where is the science and evidence to back this up? Irrelevant statement.
Page 21 and 22 Access to Country
Only talks about Wudjari people. What about everyone else? What about DBCA access? What about locals and tourists and other indigenous people that are non-Wudjari?
Developing protocols should be provided to the community prior to the proposed marine park being approved. If there is a cultural location that should be treated with special behaviours then why hasn’t this come out before now? Why does this need to be part of a marine park? ETNTAC is already a working organisation.
All pages with information missing – 22, 23, 26, 85:
The performance measures, targets, and reporting should all be advised prior to the marine park being approved. I recommend reporting be annually for the first 3 years and then 3 yearly after that.
Page 23 talks about employment opportunities for Wudjari people only. Will other departments be given additional employment opportunities? Can anyone become a Wudjari Ranger?
Page 24 – I am happy to learn historical culture on the land. I think it is a waste of time and tax payers money learning historical culture that is under the sea. No body will be walking these parts ever again. The odd diver may come across locations but otherwise it will remain untouched.
As per Page 73 Maritime Heritage
Maritime heritage is protected under the Commonwealth Underwater Cultural Heritage Act 2018 and the State Maritime Archaeology Act 1973. The Western Australia Museum is responsible. Leave the responsibility with them and support them.
Page 24 – Special places that can be shared by Wudjari people are detailed in Appendix 2.
No they are not… perhaps table 1 on page 99? But even so, and in paragraph 3, where is the information and evidence that these are cultural special places? What has been found there? A lot of the management strategies on page 25 talk about auditing and locating these places so are they just made up for now?
Page 34 – Recently, several locations within the proposed marine park have been identified for green hydrogen projects and butty head has been identified as a potential port area? Where did this info come from? How does that marine park affect these projects? How do these projects affect the marine park? More info required. I would believe that any large projects would require a large amount of planning and consultation even without a marine park in place.
Page 34 – pressures – DBCA and the Shire already limit and monitor access to certain locations. Why does this need to be done again under yet another plan? Identify the locations and combine them into an existing ranger programs.
A lot of info is referenced to document SCRMPWG, 2010. This framework was to be reviewed after 10 years which meant it should have been reviewed in 2020. Why wasn’t it? Costs? Personnel? No info? If we can’t keep up with existing frameworks then why are we adding more?
Page 35
Potential sources or marine pollution:
Ships
Agriculture waste water
Dredging
Habitat degradation
These are all potential marine pollutions marine park or no marine park ad should already be managed by the rightful authorities. This is doubling up on existing plans. Each agency will already have risk assessments and emergency management plans in place.
Page 36 Sediment quality. Where is the research and evidence that estuaries ‘may’ have lower water or sediment quality? Vessel discharge and major pollution events are managed by DoT. They organise drills locally with emergency services and agency reps to go over incidents.
Page 37
Point 3 – Aren’t there already land management regulations that ensure land owners capture and contain their own water run off? I know I can’t let my drain water leak into my neighbours property.
Point 4 – Managed by DoT already.
Point 6 – We already have campaigns in place like clean up Australia day.
Points 9, 10, 11, 12 – How about apply for some funding to do this research first and then apply a marine park only if necessary?
Page 38
Migratory birds are already monitored through RAMSAR convention.
References Bancroft et al. 1997 and Hodgkin & Clark 1989 – Is this really the most recent data to be relating your information to?
Page 39
Which estuaries are in altered states? What evidence?
Current major pressure – adjacent land use – What are locations of interest?
Page 41 – No seagrass species are listed as threatened in WA.
Seagrass are protected throughout the state under the BC Act and the FRM Act.
Boat impacts are already limited by weather and tidal conditions.
New infrastructure requires major planning approvals.
Vessels are managed by DoT.
Why have you used sea grass as an excuse for sanctuary zones when it is in good condition?
Page 42 – Leeuwin and Capes current strongly influence the distribution of macroalgae. You can’t control this by implementing a marine park.
Page 46 – Filter feeders
Few species found in the marine park and not only local to this area. The threats are global issues not local issues.
Page 48 and 49 Invertebrates
You state they are generally in good condition but if you are so worried then talk to DPIRD about the bag limits.
Management strategy 9 investigate feasibility of restoration but you said at the top they were in good condition?
Page 50 and 51
Leafy sea dragons and White shark already protected. Responsibility of DPIRD.
You still state finfish are in good condition.
Page 52
Already the Tjaltjraak seabird monitoring program in place. Will this be duplicated or combined with the marine park plan?
Page 54
All seabird species and their eggs are protected under the state and federal government legislation to the 200nm economic exclusion zone.
Page 55 – I do agree with the protection of the Australian sealion given that it is an endangered species under the EPBC Act and the BC Act.
There are already exclusion zones in place.
After further reading, even of the most recent document Australian Sea Lion Monitoring Framework – background document by B Pitcher in 2018. It still doesn’t suggest there is a decline in numbers and that research of the animal is difficult due to remoteness in rough seas.
Page 58 – I do agree with the protection of the humpback whale given that it is a vulnerable species under the EPBC Act and conservation dependant under the BC Act (WA).
Page 61
Increasing number of visitors are arriving on cruise ships.
Yes but they have no means of transport so they will likely be on a formal tour or remain in the Esperance port area. Therefore this is irrelevant.
Page 72 ‘With an expected increase in commercial and recreational vessel…’ What is causing the increase? Are more boats being sold in the region? Is the Port getting bigger? The large ships that come into the Port have a direct path in and out.
Page 73 Maritime Heritage
Maritime heritage is protected under the Commonwealth Underwater Cultural Heritage Act 2018 and the State Maritime Archaeology Act 1973. The Western Australia Museum is responsible.
Page 84
Making country healthy and ensuring it remains healthy requires strong cultural governance.
I disagree, I love the country too. It does not require cultural governance. It just requires the right governance.
Page 96
Proposed Kepa Kurl Sanctuary Zone includes Woody Island meaning no fishing will be allowed at Woody Island. This will affect the Esperance Tourism Industry.
Page 97
Victoria Harbour beach to Hammer Head offshore sanctuary zone – what is the bioculture significance?
Page 99
Table 1
Why have these locations been identified as cultural zones? What evidence has been found? How can people believe these are historical cultural sites when the Mississippi Point/Rossiter Bay/Dunn Rocks doesn’t even have a cultural name and is still yet to be decided?
Page 105
Review of the JMB should be 5 years not 10 years, especially to start with.
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