CAFNEC Submission to the proposed amendments to the. Plan of Management

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1 Management Cairns CAFNEC Submission to the proposed amendments to the Cairns Area Plan of Management Please accept this submission on Behalf of the Cairns and Far North Environment Centre. Regards 19 March 2007 Steve Ryan Campaigner PART A 1. Increased flexibility for 365-day tour operators primarily conducting charter fishing All 365-day operators receive daily access to the Planning Area itself, with a maximum of 50 days anchoring access per year to each Location. Some 365-day operators who primarily conduct single-day fishing charters have advised the GBRMPA that a combination of recent management changes (for example, the Queensland Coral Reef Fin Fish Management Plan and the Great Barrier Reef Marine Park Zoning Plan) together with the existing 50-day to a Location access limitation under this Plan, has led to decreased opportunities. The GBRMPA proposes that these operators have the opportunity to apply for daily access to the General Use (light blue) Zones, Habitat Protection (dark blue) Zones and Conservation Park (yellow) Zones (other than that part of the Conservation Park Zone that is included in a Public Appreciation Special Management Area). It is likely that only a small number of operators would be likely to fall into this category. Amending Instrument Reference p.26, subclause 1.20 (10) Do you support the proposed increased access to the Cairns Planning Area for this style of operation? The decision should be based upon whether access is permitted under the stipulation of the original GBRMP Zoning Plan. Furthermore, if there is spatial management data that suggests that those zones specified as being accessible for charter fishing also require limits placed on the amount of time that access is permitted for fishing activities, then there needs to be restrictions such as are in place (existing 50-day to a Location). The decision must be made with regard to the research informing the plan, not on operators wishes. If the Marine Park can not be seen to be fairly managed like this, then it may be necessary to employ other measures, such as the designation of more Green Zones. Cairns and Far North Environment Centre Inc. PO Box 323N, North Cairns, Qld Ph: (07) Fax: (07) Mob: Web:

2 2. Providing for extra moorings (as required) The Plan currently caps the number of moorings at each Location (refer to Schedule 6). The GBRMPA has been asked to consider allowing the installation of a heli-pontoon in the Cairns Area which would require the use of a mooring. Situations may also arise where additional moorings at a site may be of environmental benefit. It is proposed to allow up to 20 additional moorings in the Planning Area to be allocated as required. These moorings would be subject to the development of site plans (including public comment with all interest groups) and, if found to be appropriate, would be allocated via an Expression of Interest process. Amending Instrument Reference- p.21, subclause 1.16 (5) Do you support the proposed amendment to provide for up to 20 additional moorings in the Cairns Planning Area? There is a need for GBRMPA to come to a final decision on limits to growth regarding the usage of the reef. CAFNEC recognises that there is a current need for a number of new moorings, but does endorse the 20 proposed new moorings which seemingly matches the number of possible new operations under the existing PoM. Hence we recommend: A. Allocate only 10 moorings using a tiered approach to allocation: the heli-pontoon in the Ribbon Reef Sector (for safety and operational reasons); a maximum of 4 in the Ribbon Reef and Offshore Port Douglas Sectors; a maximum of 4 moorings in the Offshore Cairns and South Offshore Cairns Sector in locations where operators have options restricted for different aspect winds; and the remainder spread evenly across the other sectors. All allocations are to be subject to a transparent process of expressions of interest, public consultation and impact assessment considering how these integrate into the GBRMPA management aspirations for the World Heritage Area. ie as the agency managing the WHA, GBRMPA needs to be mindful of the need to preserve and improve the Area s natural heritage values. B. Instead of allocating additional moorings, GBRMPA should establish a system where-by existing moorings could be shared. C. For the recommended ten moorings, restrict the usage and install a management regime where the tackle is removed when usage is not permitted (other than for the medi-vac heli-pontoon). The time frame for which tackle is removed should be based on research suggesting what length of time it takes for the sites coral cover and co-inhabiting species to regenerate. D. Conduct an overall assessment of usage within the Cairns PoM and commit to an absolute upper-capped limit to the number of moorings on the Reef (which is not negotiable). 2

3 3. Increasing the maximum group size at Flynn Reef and Pellowe Reef Every location in the Cairns Area has been defined for low, moderate or intensive-use, and maximum group sizes apply to all users when visiting a Location (see Schedule 4). Flynn Reef and Pellowe Reef are both Moderate-Use Locations and currently have a maximum group size of 60 people. In 2004, a list of sites were selected (see Schedule 4) to allow up to 100 people if operating to a mooring. It is proposed to amend the Plan to allow operators to carry up to 100 people to Flynn Reef and Pellowe Reef if operating to a mooring. Amending Instrument Reference- p.49, Schedule 6A Do you support the proposed increase in group size to a mooring for Flynn Reef and Pellowe Reef? In relation to protected areas management there is research that supports the concentration of nature based recreation in certain areas as a method of containing and managing impacts. If there is an increase in the visitation numbers at Flynn and Pellowe Reefs this may simply increase the impacts across all the sites. Increasing the usage from Medium to Heavy usage allows for almost a doubling of the usage at those sites. A. Before the GBRMPA goes ahead with decisions such as these, they need to be able to provide the research as to what impacts occur when sites are upgraded from Medium to Heavy usage areas. Science (that is the present condition of the site and what it takes for coral colonies and associated species to regenerate) needs to determine the frequency and duration of use. B. Pellowe - heavier usage of this site would require an impact assessment to determine the present condition and to gain a better understanding of the impacts of upgrading to a Heavy Usage categorisation. C. The poor condition of Flynn Reef could suggest the need for a limited usage management regime to allow the site to rest and for coral to recover and recolonise. For example Medium to Heavy usage could be rotated over a rostered time frame as informed by research. D. If moorings for northerly winds are required, only open up those specific existing moorings for the time when northerlies dominate - not the whole reef. E. GBRMPA to consider the style of usage at these sites when determining the impacts of changing the usage (eg intro divers, poor swimmers/snorkellers) 3

4 4. Children under four to not be included in group size limits Currently children under four years of age are not being counted for the purposes of the Environmental Management Charge; that is they are free of charge. The Tourism Industry has requested that for administrative purposes, children under four also don t get counted when calculating group sizes. Amending Instrument Reference- p.31, subclause 2.1 Do you support that children under four years of age not be included when calculating group sizes? Children under the age of four generate minimal revenue for GBRMPA or operators. They also have a very low usage capacity of the reef. It is fair not to include them in calculating group sizes. 5. Rewrite of part 1 Part 1 of the Plan outlines the values, issues and management strategies for the Planning Area. It is proposed to amend the Plan by replacing Part 1 with an updated version that explains the intent and provision of the Plan and has been edited to update or remove out-of-date information. See the website ( for a copy of the proposed Part 1. Do you have any comments on the updated Part 1? No 6. Minor technical and grammatical amendments A number of minor technical and grammatical changes are proposed. These will not alter the existing intent of the Plan. The following minor amendments are proposed: Move cruise ship anchorages from the Plan to the Great Barrier Reef Marine Park Regulations Move the enforcement provisions relating to whales from the Plan to the Great Barrier Reef Marine Park Regulations The Policy on Whale and Dolphin Conservation in the Great Barrier Reef Marine Park is also being reviewed. 6.3 Clause 2.19 of the Plan prevents the Authority from granting a permit that is inconsistent with the Plan. Additional enforcement provisions relating to the Authority s ability to grant and convert permits are better placed in Part 1 of the Plan. 6.4 References to traditional inhabitants to be changed to Traditional Owners to be consistent with the Zoning Plan. 6.5 Remove clause 2.16 that refers to collecting and fishing in Lizard Island Locality 1 and replace it with a Special Management Area under the Great Barrier Reef Marine Park Regulations Move East Hope Island to a Group A Sensitive Location. East Hope Island was included as a Group B Sensitive Location to address transitional permitting arrangements. These have now been completed and East Hope Island can be returned to a Group A 4

5 Sensitive Location. 6.7 Update the datum of all geographic co-ordinates from AGD66 to GDA94 to comply with Commonwealth Government requirements. Where this causes a significant change to a boundary, for example a setting, the description of that setting will be adjusted to maintain the original intent. 6.8 Remove ambiguity regarding the need for cruise ships that are regional tour operations to book to access the Planning Area. Cruise ship operations with endorsements for 365-day access to the Planning Area will not need to book to access the Planning Area but will be required to book to access a cruise ship anchorage. 6.9 Move the map of the Planning Area to the Schedule. Update references from private moorings to permitted moorings. Insert Chinaman Reef into Schedule 4 as a Moderate Use Location in the Offshore Port Douglas Sector. This change was inadvertently omitted in a previous amendment. The definition of vessel length is to refer directly to the definition contained in the Great Barrier Reef Marine Park Act This will ensure that the definition remains consistent across the Marine Park. Activities in the Low Isles Locality a) Insert exclusions to Plan provisions for management and permitted research activities at Low Isles. As Low Isles is a Commonwealth Island, the provisions of the Plan apply to the island as well. It was not intended that the provisions of the Plan would capture activities associated with the residence and research station. b) Include hull cleaning as an activity that cannot be conducted (GBRMPA currently specify hull scraping and hull painting). Definitions in Schedule 9 have been updated to complement the redrafting of Part 1 and the datum conversion Do you have any comments on any of the above technical and grammatical amendments? No 5

6 PART B 7. Proposed changes at Upolu Cay The GBRMPA is considering allowing the permanent mooring of glass bottom boats at Upolu Cay for operational and safety reasons. Since 1992 Upolu Cay has been managed to be free of structures1. The objective of the No Structures Policy is to ensure that some areas of the Great Barrier Reef remain: 1 In a natural state, largely unaltered by human works 2 Free from structures and permanently-moored facilities, except for approved vessel moorings, approved management, research and monitoring facilities and approved navigational markers which are essential for the protection, wise use, understanding and enjoyment of the Marine Park. Allowing permanent mooring of glass bottom boats would not require an amendment to the Cairns Area Plan of Management, however, it would be a departure from the way in which Upolu Cay has been managed. The GBRMPA is therefore seeking feedback on the issue of whether glass bottom boats should be allowed to be permanently moored at Upolu Cay. View a map of the No Structure area at Upolu Cay. Do you support the permanent mooring of glass bottom boats at Upolu Cay? The area is already a heavy usage area by recreational users. Allowing permanent mooring of glass-bottom boats at Upolu Cay would degrade the visual amenity of the site and add to over crowding on busy days. Operators already have good access to the site and need to be mindful of others in relation to their operations. It could also increase the possibility of unmonitored pollution and for an accidental free-drifting boat to damage the reef. 6

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