The Chief Executive
Department of Environment and Natural Resources
GPO Box 1047
Adelaide SA 5001
Australia

Dear Chief Executive:

I am writing at the advice of the Committee of Scientific
Advisors and on behalf of the Board of Governors of the Society
for Marine Mammalogy to comment on the South Australian
Government's proposed multiple use marine park in the waters of
the Great Australian Bight.  

The Society for Marine Mammalogy is a professional scientific
organization whose members conduct research on marine mammals
internationally.  The Society currently includes approximately
1,400 marine science professionals and students living and
working around the world.

We are encouraged with the steps that your government has taken
already to protect the calving grounds of the southern right
whale and the coastal waters close to the colonies of Australian
sea lions in the Great Australian Bight.   The Committee of
Scientific Advisors to the Board of Governors of the Society is
concerned, however, that the provisions of the conservation zone
and right whale and sea lion sanctuaries, as proposed, may not be
adequate to provide effective protection as intended.  While we
understand the limitation of the South Australian government's
jurisdiction, the 3 nautical mile extent of the proposed
conservation zone and right whale sanctuary and the proposed 1
nautical mile wide sea lion sanctuary zones may not afford
sufficient protection from human activities occurring just
outside the proposed protected areas (e.g., commercial fishing,
recreation, resource development, etc.).  In addition, although
right  whales may reside in this area for only 6 months of the
year (May through November), it would be important to conserve
right whale habitats year round to avoid changes that could
render these areas undesirable for breeding and calf rearing when
the whales are in residence.

Marine protected areas need to offer effective protection from
activities that may disadvantage affected species and/or prove
disruptive to their essential resources.  This is not to say that
the creation of marine protected areas may not be compatible with
other human activities.  

As noted in your proposal, sanctioned activities, such as public
recreation, recreational and some commercial fishing, can be
allowed so long as they are regulated so as not to jeopardize the
integrity of the habitat or disadvantage the species that depend
on those habitats.

In our view, scientific advice, based on biological, social, and
economic considerations, should be an integral part of the
planning and development process.  This advice must identify
critical uncertainties as well as established facts, and inform
managers, developers, and the public of the potential
consequences of alternatives before development begins.  For
example, establishing 3 and 1 nautical mile limits to the
boundaries of the whale and sea lion sanctuary zones may be
legally consistent with the limits of your jurisdiction.  Such
zones may, however, be ineffectual with regard to the biological
needs of right whales and sea lions.  To be effective, the
proposed limits of such a protection zone should have as their
basis the biological needs of the affected species, and consider
the extent and timing of their seasonal movements.  Responsible
authorities should then develop an implementation plan that can
be accommodated within the scope of the relevant legal mandates.

In addition to establishing a protected area, it is essential
that research and monitoring programs are implemented to see that
all aspects of the protected area are fully implemented as
envisaged, and to allow detection and analysis of any unforseen
changes in the affected species status or their habitats.  In
this way, potentially detrimental actions may be identified and
avoided before problems arise.
 
In summary, the Board of Governors of the Society for Marine
Mammalogy encourages you to: reconsider the proposed boundaries
of the Great Australian Bight Marine Park based on the actual
habitat needs of the right whales and sea lions to provide
effective protection, including consideration of  year-round
measures; develop and implement research and monitoring programs
to evaluate the effectiveness of the park to protect these
species; and, pursue discussions with your Federal Government
toward expanding the marine park to include the adjoining
Commonwealth waters to be managed in a complementary manner .


Yours sincerely,


Jeanette A. Thomas, Ph.D.
President


cc: 

Dr. Peter Bridgewater
Chief Executive
Australian Nature Conservation Agency
GPO Box 636
Canberra, A.C.T.  2601
Australia

Mr. David Hall
Director of Fisheries
GPO Box 1625
Adelaide, S.A.  5001
Australia