EMP Submission
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EMP Submission
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1/6/05 Encounter Marine Park Draft Zoning
Plan Submissions C/O Coast and Marine Conservation
Branch Department of Environment and Heritage GPO Box 1047 Adelaide SA 5001 Dear Sir / Madam RE:
ENCOUNTER MARINE PARK DRAFT ZONING PLAN Our
Federation (SDFSA), as the peak body and on behalf of all recreational scuba
divers in South Australia, wishes to make a submission regarding the Encounter
Marine Park Draft Zoning Plan. Recreational scuba divers in South Australia
pursue a range of interests, including but not limited to marine life
appreciation on both natural and artificial reefs, wreck diving, and the
recreational take of rock lobster, abalone, scallops and shells. The SDFSA
represents all those interests and believes that sensible zoning through marine
protected areas (MPAs) has the potential to enhance each of these pursuits
without significantly detracting from any of them. The SDFSA also understands that most
diving experiences, for both current and future divers, are dependent on healthy
ecosystems and the maintenance of biodiversity and ecological processes, and is
therefore very supportive of the objectives of the MPA. We do have some general comments about
the MPA and specific comments about particular zones that we wish to be taken
into account when finalizing the zoning plan. General
Comments applicable to all zones: Permits: Many scuba divers are underwater
photographers & enter photo competitions that although small and
insignificant could be required to have a permit. Also, most scuba diving,
particularly by those who are members of clubs, are organised events by a group
of divers. It is difficult for divers to
understand and support the need for a permit to take a photograph or organise an
event. We are not aware of any such requirement in a land-based National Park.
It will be seen as an unnecessary impediment that will limit & complicate
the community access to a resource that we all have a right to visit free of
charge, and will undermine support that would otherwise be given for the Park. Many divers, for example, would
consider it bizarre that a commercial fisherman can trawl in a General Managed
Zone but that they would need a permit to take a photograph or to organise an
event in the same zone. Unfortunately, divers have had
some recent bad experiences with permits, through the Hobart Artificial Reef
permit system which we consider to be largely responsible for limited numbers
diving the wreck. If there must be a permit system
then at the very least the community must be able to apply online & for the
minority that don't have access to a computer, access to a convenient location
to apply personally, must be available 7 days a week. The SDFSA also wonders if DEH has
considered all aspects of the legal risk/exposure associated with a permit
system. If DEH wants to collect data, it
could produce a simple brief questionnaire to be completed at the boat ramp
& placed in a collection box, near the DEH MPA signage that it intends to
erect. This would be considerably cheaper to administer & much more
convenient for the end users. Other general comments We expect that the final plan will be
developed in such a way that:
Comments
on particular zones S1: The SDFSA is generally supportive
of this zone, particularly the protection of the reefs to the north of
Carrickalinga Creek. One of these reefs, immediately opposite the toilet block
in the South Bay car park appears to be right on the zone boundary 200m from the
shore and some clarity is needed as to whether it lies within or outside the
Sanctuary Zone. If the purpose of the 200m zone
between the shore and the Sanctuary Zone boundary is to allow beach fishing,
then it may be better to specify that as an allowable activity and maintain the
boundary to the shore, to avoid a situation where boat fishing activity is
squeezed into the 200m band, above a couple of reefs that have traditionally
been used by snorkellers and divers entering from the shore. Boat fishing
creates a number of potential hazards for divers. This area has not historically
sustained and is unlikely to sustain any significant recreational rock lobster
fishery given that the species is at the edge of its range and the level of
effort is relatively high due to the easy accessibility of many reefs from the
shore. However, this area does appear to have a significant amount of lobster
habitat and, given appropriate protection, it may well make a contribution to
the recreational fishery outside the Sanctuary Zone and provide an area where
divers can view an undisturbed lobster population. There are few areas within the Gulf
part of the draft proposal that include cliff areas with significant vertical
face and underhangs, yet there is such an area immediately outside the northern
boundary of the S1 zone, which should be included, especially if there is a
northwards contraction of the S1 zone in order to address the concerns of other
stakeholders. S2: The “Basis for Zoning”
document makes it clear that this zone is not specifically for the purpose of
biodiversity conservation, but rather for maintaining the existing regime
established under the Fisheries Act and Historic Shipwrecks Act. However, making
this area a Sanctuary Zone within the MPA will prevent activities such as the
feeding of fish or the use of underwater scooters. The SDFSA understands the need for
some areas where there is minimal impact on ecosystems and the species within
them, including their behaviour, but does not consider the Hobart wreck to be
such a site. If it is vital that the permitted activities be consistent across
all Sanctuary Zones, then this area should not be a Sanctuary Zone but a Special
Purpose (Recreational Diving) zone. S3: The SDFSA is generally supportive
of this Sanctuary Zone but wishes to point out that this area is one of several
destinations used by divers for a second or third dive after diving the HMAS
Hobart. Although the Sanctuary zone
and the Rapid Bay jetty will provide excellent locations for a naturalist dive,
many divers also seek a crayfish in this area. The SDFSA believes that the
Sanctuary Zones should be a range of sizes in order to learn, through
monitoring, more about the optimal size for Sanctuary Zones. However, the SDFSA
believes that this zone should either be as small as possible or should be
located as far south as possible to allow a “hunting” area and relieve the
pressure on the areas around Second Valley. Note: the SDFSA expresses some
surprise that the diversity of reef habitats and seagrass area in the vicinity
of Second Valley have not been included as a Sanctuary Zone (either with or
without jetty fishing), but does acknowledge that this area is subject to
significant threat from polluted outflow from the Parananacooka Creek and from
the northward movement of gravel originating from the mine at Rapid Bay. S4 & S5: The SDFSA is supportive
of these zones and pleased that the accessible areas from Fisheries Beach to
Blowhole Creek beach have been left out of a Sanctuary Zone, but that there is
still significant area within a Sanctuary Zone. The SDFSA understands the need
for the area between S4 and S5 to provide sheltered water for boating. However,
rather than having a large sanctuary zone at Rapid Head, the SDFSA would prefer
crayfishing to be prohibited in this area between the Sanctuary Zones, thus
creating a long, continuous “Sanctuary” for crayfish that would allow
studies, similar to those of Edgar & Barrett at Maria Island, to be
undertaken. This area should be a special purpose zone for Commercial and
Charter Fishing only to ensure that catch and effort data on all reef associated
species. Zoning at The Pages The SDFSA is supportive of SOME of
this area being zoned with restricted access and sanctuary zones but prefers to
leave further comment about the zoning around The Pages to individuals and
clubs. S13: The SDFSA is very supportive of
the protection of large parts of the cliff habitat east of Penneshaw but asks
that the Government take into account the need for access to the full range of
diving experiences within this area. It is not unusual for divers to undertake
boat dives on this coast departing from Cape Jervis, and significantly greater
distances would need to be travelled in order to make a dive in similar habitat
to the Sanctuary Zone as proposed. S7, S8 The SDFSA is surprised that the reef
adjacent to the bluff and to the southeast of the jetty and nearby rocks has not
been included within the Sanctuary zone, given the diversity and number of
outstanding features of this area, and the high level of support given by divers
who completed an earlier survey on suitable no-take zones. We understand the
desire to maximise support for the MPA by minimising impact on shore-based
recreational fishers, but would prefer that the curved area around the Bluff be
included, but traded off by excluding some part of the Whalebone reef (S8) from
the Sanctuary Zone. Yours
faithfully Steve
Reynolds Secretary Scuba
Divers Federation of SA |
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