GREAT BARRIER REEF COASTAL ZONE STRATEGIC ASSESSMENT
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MileS Yeates Sinclair Knight Merz T +61 7 3026 7100 E: MYeates@globalskm.com ABN 37 001 024 095 32 Cordelia Street, (PO Box 3848) South Brisbane QLD 4101 Australia www.globalskm.com COPYRIGHT: The concepts and information contained in this document are the property of Sinclair Knight Merz Pty Ltd (SKM). Use or copying of this document in whole or in part without the written permission of SKM constitutes an infringement of copyright.
table of contents:
Limitation Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1.2 Scope of work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
1.3 Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
1.4 Structure of this report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
2. Consistency with the Terms of Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
2.1 Overview of the Terms of Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
2.2 Purpose and description of the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
2.3 MNES affected by the Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
2.4 Promoting ecologically sustainable development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
2.5 Adaptive management: addressing uncertainty and managing risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
2.6 Auditing, reporting, review, modification or abandonment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2.7 Further work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3. Structure of Reports and Cohesiveness of Presentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.2 Intergovernmental management arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.3 Goals and objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.4 Presentation and cohesiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
4. Breadth and Depth of Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
4.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
4.2 Assumptions and gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
4.3 Comprehensiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
4.4 Protected areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
4.5 Forward Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
4.6 Gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5. Technical Accuracy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.2 Strengths . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.3 Areas for improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
5.4 Assessment results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
6. Validity of Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
6.1 Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
6.2 Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
7. Conclusions and Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
7.1 Summary of conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
7.2 Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
8. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
Appendix A. Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45Limitation Statement
The sole purpose of this report and the associated SKM has prepared this report in accordance with
services performed by Sinclair Knight Merz the usual care and thoroughness of the consulting
(“SKM”) is to complete an independent review profession, for the sole purpose described
of the Great Barrier Reef Coastal Zone Strategic above and by reference to applicable standards,
Assessment in accordance with the scope of guidelines, procedures and practices at the date
services set out in the contract between SKM and of issue of this report. For the reasons outlined,
the Department of the Environment (“Client”). however, no other warranty or guarantee, whether
That scope of services, as described in this expressed or implied, is made as to the data,
independent review report, was developed with observations and findings expressed in this report,
the Client. to the extent permitted by law.
SKM prepared this report from information This report should be read in full and no excerpts
sourced from the Client and additional material are to be taken as representative of the findings.
available in the public domain at the time or No responsibility is accepted by SKM for use of
times outlined in this report. The passage of any part of this report in any other context. This
time, manifestation of latent conditions or report has been prepared on behalf of, and for the
impacts of future events may require further use of, SKM’s Client, and is subject to, and issued
examination of the project and subsequent data in accordance with, the provisions of the contract
analysis, and re-evaluation of the data, findings, between SKM and the Client. SKM accepts no
observations and conclusions expressed in this liability or responsibility whatsoever for, or in
report. SKM reviewed a ‘draft in progress’ version respect of, any use of, or reliance upon, this report
of the Strategic Assessment reports, dated by any third party.
13 September 2013. This version may differ
significantly from subsequent reports published for
public comment.
2Executive summary
Background Appendices. SKM utilised experienced staff in
The Great Barrier Reef is recognised globally the areas of marine park management, coastal
as an iconic natural asset, comprising almost planning, marine science, impact assessment,
3,000 reefs, which form one of the largest, most strategic program management and environmental
complex and diverse ecosystems on the planet. assessments under the EPBC Act. The SKM review
Management of the reef ecosystem as a multiple- team worked independently of the Queensland
use marine park and world heritage area is being Government when conducting the review.
increasingly challenged by a range of complex
SKM made an assessment of the Strategic
factors, many of which have their origin outside of
Assessment’s consistency with its Terms of
the marine park’s boundaries.
Reference, structure and cohesiveness of
The Australian and Queensland governments are presentation, breadth and depth, technical
undertaking a Strategic Assessment of the Great accuracy and the validity of conclusions drawn.
Barrier Reef World Heritage Area and adjacent Comments have been presented in this report
coastal zone, with the Queensland Government on the adequacy of the Strategic Assessment in
leading the relevant coastal zone components addition to recommendations for improvement
and the Great Barrier Reef Marine Park Authority of the documents in subsequent versions. It
leading the marine components. The Strategic is anticipated that the independent review, or
Assessment will help identify, plan for and part thereof, will form an appendix to the final
manage the unique values of the Great Barrier assessment report, once completed.
Reef, and is being carried out under Part 10
Results
of the Environment Protection and Biodiversity
Overall, the draft Strategic Assessment was
Conservation Act 1999 (EPBC Act).
found to be a good presentation of a large body
Sinclair Knight Merz (SKM) was engaged by the of information. The reports are generally well
Commonwealth Department of Sustainability, written and will be consistent with the Terms of
Environment, Water, Populations and Communities Reference if key gaps identified in this review
(SEWPaC, now Department of the Environment) to are addressed in subsequent revisions. Strengths
complete an independent review of the draft Great of the Strategic Assessment are its relatively
Barrier Reef Coastal Zone Strategic Assessment concise format suitable for a wide audience, use
(version dated 13/09/13). This report outlines the of spatial mapping tools, analysis of terrestrial
findings of the independent review. ecological values and detailed consideration of the
linkages between land-based activities and the
Methods
environmental health of the reef ecosystems.
SKM established a review team to assess the
draft Strategic Assessment, which was comprised Suggestions for improvement of the documents
of a Program Report, Assessment Report and have been identified which may further assist
4in enhancing the presentation and to increase Breadth and Depth of Assessment
the depth and coverage of the assessment. The large geographic scale of the assessment
These include placing greater emphasis on the required a synthesis of the most important issues
assessment of outcomes rather than processes for detailed analysis and the development of
when considering the adequacy of the existing a method of simplification in the assessment
Program and Forward Commitments, conducting approach. The majority of issues were described
a more detailed assessment of ecological and assessed in a balanced and rigorous
processes, focussing on managing for resilience fashion, with a particular focus on development
and expanding some aspects of the Program assessment and the protection of terrestrial
description to include the regulation of activities ecology values. Further analysis of land uses and
such as fisheries, agriculture and aquaculture. their regulation in moderately disturbed areas
would have added value, particularly due to the
Structure and Cohesiveness of the Reports
significance of water quality issues for the future
The reports were found to be cohesive in their
of the Great Barrier Reef. Further description
presentation and structure, particularly in light of
and assessment was expected in relation to
the large amount of material and the magnitude of
port development and dredging, aquaculture
the Strategic Assessment task. The complexities
and fisheries management, which are all given
associated with the intergovernmental
limited attention in the reports. It is recommended
management arrangements for the Great Barrier
that the assessment of cumulative impacts is
Reef were well described, and articulated an
expanded, with a particular focus on port and
improving alignment in the future management
coastal development and the influence of severe
of Matters of National Environmental Significance
weather events. A more detailed description of
(MNES), through converging approaches to
the magnitude and adequacy of protected area
mapping environmental values and considering
management activities would also add value to the
environmental offsets. SKM considers that the
analysis. The application of methods to select key
objectives of the Strategic Assessment were not
listed species on the basis of regularly triggering
clearly defined, and constrained the synthesis
development assessments does not appear to
of key findings into a collection of strong
have produced a geographic representation of
conclusions. Some recommendations to improve
species across the Great Barrier Reef Coastal
the readability of the Assessment results through
Zone.
minor changes to the structure and layout have
been made. The frequent use of tables, figures
and cross references to aid interpretation of the
reports was highly regarded.
5 Independent Review of the Great Barrier Reef Coastal Zone Strategic AssessmentTechnical Accuracy managing for resilience in response to ocean
In general, the results derived from the application acidification and climate change. Collectively,
of the assessment methods were evidence-based the future management commitments do not
and justified by the information presented in the appear sufficient to halt the declining condition
reports. The Assessment communicates that the of MNES and to maintain all of the natural
condition of the Great Barrier Reef is in decline, heritage values described in the world heritage
and that existing management measures have listing criteria for the Great Barrier Reef. In this
generally been only partially effective at reversing context, further justification of the objectives,
this trend. Discussion of the effectiveness of perceived benefits and resources to be allocated
management measures appears to be more to Forward Commitments would provide more
favourable than the assessment results appear information to make an informed judgement on
to warrant. In this context, further justification the appropriateness of these measures.
of the likely effectiveness of future management
Conclusions and Recommendations
commitments in protecting MNES and reversing
The draft documents reviewed by SKM address
the ongoing decline in condition is recommended.
the majority of the requirements of the Terms of
The documents identify that the existing Program
Reference, and with further improvement, will
has some weaknesses in the management of
provide complete consistency with the Terms of
cumulative impacts and environmental offsets.
Reference. The documents therefore represent
Further text is required to strengthen the
significant progress in the preparation of a
description of these aspects of management
comprehensive and detailed Strategic Assessment
and how they will be improved in the future.
of the Great Barrier Reef Coastal Zone. They
Amendments to the Program description are
focus on the strengths of the existing Queensland
also recommended as some relevant legislative
Program, which was not designed explicitly for
functions and planning reforms have not been
the purpose of protecting MNES. In this context,
mentioned or are incorrectly described.
proposed actions to further align the State and
Validity of Conclusions Commonwealth management frameworks and to
There is strong focus on the management of focus on water quality issues are appropriate and
water quality issues arising from runoff within the will be critical to the success of the Program’s
catchment as a means of protecting MNES of the implementation. Further work is required to fill
Great Barrier Reef and mitigating the impacts of information gaps, focussing on Program outcomes
sediment, nutrient and pesticide discharges. This rather than inputs and processes, and to define
is appropriate and consistent with management of future management actions on the basis of an
the environment at a landscape scale. assessment of what will be required to halt the
declining values of the Great Barrier Reef World
Issues relevant to the 25 year time frame of
Heritage Area.
the Program receive less attention, such as
61. Introduction
1.1 Background together produce reports covering the terrestrial
The Great Barrier Reef is recognised globally and marine areas of the Great Barrier Reef.
as an iconic natural asset, comprising almost
There is a high degree of public interest in the
3,000 reefs, which form one of the largest, most
management of the Great Barrier Reef, both within
complex and diverse ecosystems on the planet.
Australia and internationally. The United Nations
More than 900 islands are located throughout the
Educational, Scientific and Cultural Organisation
Great Barrier Reef, covering a distance of 2,300
(UNESCO) World Heritage Committee, in its final
kilometres across shallow estuarine areas to deep
reactive monitoring mission report in June 2012,
oceanic waters.
called for a halt to new port developments outside
Management of the reef ecosystem as a multiple- of the existing major port areas on the Great
use marine park and world heritage area is being Barrier Reef until the completion of the Strategic
increasingly challenged by several threats, many Assessment (UNESCO 2012). The mission report
of which have their origin outside of the marine also made several references to the Strategic
park’s boundaries. These include climate change, Assessment as making an important contribution
ocean acidification, catchment runoff comprising to the long term conservation of the Great Barrier
sediment, nutrients and pesticides, disease and Reef.
pest outbreaks, ports and shipping, recreation
The Queensland Government has recently
and tourism, fishing and coastal development.
developed the coastal zone Strategic Assessment
While the Great Barrier Reef remains one of the
to an initial draft stage. This includes a Program
healthiest coral reef ecosystems on the planet, its
Report (Queensland Government 2013a),
condition and resilience have declined in recent
which describes the Queensland Government’s
decades as a result of such pressures (GBRMPA
coastal management, planning and development
2009).
assessment framework, and a Strategic
The Australian and Queensland governments Assessment Report (Queensland Government
are undertaking a Strategic Assessment of the 2013b), which contains an assessment of
Great Barrier Reef World Heritage Area and the Program’s effectiveness in managing and
adjacent coastal zone, with the Queensland protecting the Matters of National Environmental
Government leading the relevant coastal zone Significance (MNES) of the Great Barrier Reef
components and the Great Barrier Reef Marine Coastal Zone. Several appendices to the
Park Authority (GBRMPA) leading the marine Assessment Report have also been prepared.
components. The Strategic Assessment will help
The purpose of the coastal zone Strategic
identify, plan for and manage the unique values
Assessment is described in Sub-Chapter
of the Great Barrier Reef, and is being carried out
1.3 of the Assessment Report. The Strategic
under Part 10 of the Environment Protection and
Assessment is a broad systems and landscape
Biodiversity Conservation Act 1999 (EPBC Act).
scale assessment of Queensland’s policies, plans
The Queensland Government and the GBRMPA will
8or programs that relate to the management and The independent review is an important step in
protection of Matters of National Environmental determining whether the Strategic Assessment
Significance (MNES), including Outstanding has satisfied its Terms of Reference and assessed
Universal Value (OUV). The Strategic Assessment and described the existing and future risks to the
will help identify, plan for and manage existing and Great Barrier Reef and how they will be managed.
emerging risks to ensure ongoing protection and
The review considered electronic versions of the
management of the unique environmental values
Draft Program Report, Draft Strategic Assessment
of the Great Barrier Reef World Heritage Area and
Report and Draft Appendices. These were provided
adjacent coastal zone. This will be achieved by
to SKM by SEWPaC on 13 September 2013.
ensuring that:
The documents were marked “Draft in Progress
• the existing management arrangements for – version current as at 13/09/2013”. Although
MNES in and adjacent to the Great Barrier Reef largely complete, the documents included a small
World Heritage Area are adequate. number of incomplete sections, primarily ‘Gaps
and Improvements’ sections of the Assessment
• planning, development and land management
Report (Sub-Chapters 7.6.4.5, 7.10.2.1,
in the Great Barrier Reef Coastal Zone avoids,
7.10.3.1). Some sections of the Appendices were
mitigates or offsets significant direct, indirect
missing or were difficult to locate in the absence
and cumulative impacts on MNES.
of a Table of Contents for the Appendices. SKM
The Strategic Assessment forms part of Australia’s understands that the documents are being
response to the World Heritage Committee’s refined by the Queensland Government while the
concerns regarding the impact of development on independent review is being conducted.
the Great Barrier Reef World Heritage Area.
1.3 Methods
SKM established a review team to assess the draft
1.2 Scope of work
Strategic Assessment, utilising staff experienced in
Sinclair Knight Merz (SKM) was engaged by the
the areas of protected area management, coastal
Commonwealth Department of Sustainability,
planning, marine science, impact assessment,
Environment, Water, Populations and Communities
strategic program management and assessments
(SEWPaC, now Department of the Environment),
under the EPBC Act. The method adopted for
to complete an independent review of the
the review was agreed with SEWPaC prior to
draft Great Barrier Reef Coastal Zone Strategic
the project commencing, and is summarised as
Assessment. This report outlines the findings of
follows:
the independent review.
• A project inception meeting was held
Terms of Reference (Queensland Government
to confirm project objectives, methods,
2012) for the Strategic Assessment were finalised
communication channels and timeframes.
in 2012, following a public consultation process.
Among the 377 public submissions received, • A briefing was given by the Queensland
the carrying out of an independent review of the Government approximately one week prior to
Strategic Assessment was the most commonly receipt of the draft documents. It provided SKM
raised issue. Accordingly, SEWPaC engaged SKM with background on the approach to the
to complete an independent review of the draft Strategic Assessment and on the approach that
Strategic Assessment, prior to release for public had been taken to developing the documents.
comment in late 2013.
9 Independent Review of the Great Barrier Reef Coastal Zone Strategic Assessment• The Program Report, Assessment Report and Weekly progress reports were provided to the
Appendices were reviewed, with an Department of the Environment during the review
assessment made of their: process. Given that the documents were in a draft
stage and still under revision at the time of the
1. consistency with the Terms of Reference.
review, SKM did not provide feedback on editorial
2. structure and cohesiveness of presentation .
or formatting issues in the documents provided.
- SKM considered whether the information
was appropriately structured, presented 1.4 Structure of this report
in a clear, concise and well-written This report has been structured to meet two
manner, and whether the goals and objectives of the review process:
objectives of the assessment were feasible,
• Conduct an independent, critical review of the
well-defined and targeted towards the
Strategic Assessment documents, and describe
material issues.
their adequacy in meeting the objectives of the
3. breadth and depth - SKM considered
Strategic Assessment.
whether the coverage of the assessment
was adequate, and whether issues had • Provide recommendations on how the draft
been addressed in sufficient depth, or been documents can be improved.
overlooked.
4. technical accuracy - SKM also considered The findings of the independent review are
whether uncertainty had been adequately presented in two parts, consistent with these
characterised and whether any conflict in objectives. The main body of the report presents
the available information had been the findings of the independent review, by
recorded and assessed. evaluating:
5. conclusions - to determine whether they
• the consistency of the Strategic Assessment
were evidence-based, valid and
with the terms of reference (Section 2),
comprehensive. The change process
assumed in the Strategic Assessment was • its structure and cohesiveness (Section 3),
tested for feasibility, and the presentation
of the implications of the Strategic • its breadth and depth (Section 4),
Assessment was reviewed. • the accuracy of technical aspects (Section 5),
• Conclusions from the review were drawn, and
and areas requiring further work were • the validity of conclusions (Section 6).
identified. Recommendations on improving the
Strategic Assessment have been made and are SKM’s conclusions and recommendations are
presented in this report. described in Section 7. A detailed list of comments
and recommended actions to improve the
The SKM review team worked independently of Strategic Assessment documents is provided in
the Queensland Government and did not directly Appendix A. These recommendations will assist
interact with it during the review process. In the Queensland Government and Commonwealth
addition to reviewing the Strategic Assessment Department of the Environment in finalising the
documents, SKM referred to other relevant reports for-public-comment and final versions of the
and literature available in the public domain. Strategic Assessment.
102. Consistency with the
Terms of Reference
2.1 Overview of the Terms of Reference have been addressed in more detail than others,
The Terms of Reference for the Strategic which is to be expected given the scale of the
Assessment (Queensland Government 2012) assessment and the variety of issues requiring
provide a description of the geographic extent consideration. In general, the Queensland
of the Great Barrier Reef Coastal Zone, provide Government has provided adequate coverage of
background information and context for the the issues stated in the Terms of Reference, with
Strategic Assessment and prescribe the matters several exceptions, where further detail would
to be addressed in the Program description and strengthen the assessment and coverage of
assessment. A description of the scope of the issues.
Strategic Assessment is provided in Sub-Chapter
2.2 Purpose and description of
1.4 of the Program Report, with a summary of
the Program
The Program Report describes the purpose of
The Strategic Assessment has a close alignment with the the Queensland management framework for
requirements outlined in the Terms of Reference. Tables the coastal zone of the Great Barrier Reef, and
and figures within the documents refer directly to relevant defines the geographic area to which the Strategic
sections of the Terms of Reference to provide clarification Assessment applies. Legislation, plans, policies
of where key requirements have been addressed. The and other material that comprise the Program are
reports are focussed on the strengths of the Queensland described, including commitments to strengthen
Program, with detailed assessments of terrestrial ecological the Program or implement new management
matters and development assessment controls. Gaps exist actions in the future. Some sections
in the description of some Outstanding Universal Values, of the Program Report have gaps or inaccuracies
including natural beauty and aesthetics, which are not in the description of the legislative framework
identified by the Protected Matters Search Tools applied in the and the jurisdiction of some Departments in
assessment. implementation. The Program description was
also focussed towards the assessment of
A greater focus on adaptive management for resilience in development, and further expansion to include
response to climate change, ocean acidification and declining more detail on the management of other
water quality would enhance consistency with the Terms of activities is recommended.
Reference.
2.3 MNES affected by the Program
The Strategic Assessment comprehensively
describes the spatial distribution and condition of
how the Terms of Reference have been addressed the vast majority of MNES through the application
provided in Figure 3.3-1 of the Assessment of mapping tools. This provides a foundation for
Report and in Appendix D. the assessment of impacts on MNES of activities
within the Great Barrier Reef Coastal Zone and
Some components of the Terms of Reference
12adjacent catchment. The condition and trend in role of birds in seed dispersal. Considering only
MNES are also explained, and referenced to the aspects of OUV that are explicitly identified as
data sources. The identification of priority areas MNES prevents the Strategic Assessment from
for conservation has only been given a brief and fully meeting the Terms of Reference requirement
general consideration in the reports, and further to “provide sufficient information to allow an
detail would improve consistency with the Terms understanding of the connectivity between MNES
of Reference. including OUV”.
The Terms of Reference state that the Strategic The description of the distribution, significance
Assessment must “describe the current condition and management of indigenous cultural values of
of OUV against the retrospective statement of the Great Barrier Reef could be further expanded
OUV which describes the state of the Great to provide greater recognition of the role played
Barrier Reef World Heritage Area (GBRWHA) by indigenous people in the management of
at the time of listing”. The condition of some their traditional lands and sea-country. While
aspects of OUV is not considered in any detail by it is recognised that the four world heritage
the Strategic Assessment. Examples include the listing criteria for the Great Barrier Reef relate
Great Barrier Reef’s superlative natural beauty, to natural heritage, some further description of
including above the water (listing criterion vii), and the cultural landscapes and heritage values of
representation of the processes of geological and the Great Barrier Reef and their management
geomorphological evolution (criterion viii), coastal by traditional owners would seem warranted
processes and the role of birds in processes such given the depth and breadth of the Strategic
as seed dispersal (criterion ix). This appears to be Assessment and the limited description provided
because these aspects of OUV, though implicitly in the draft documents. The statement of OUV for
MNES, are not explicitly identified as MNES using the Great Barrier Reef acknowledges the “strong
tools such as the Protected Matters Search Tool, ongoing links between Aboriginal and Torres Strait
and have not been considered in the Strategic Islanders and their sea-country”, and this could
Assessment. For example, the Pied Imperial be more prominently reflected in some sections of
Pigeon (Ducula bicolor) is a listed marine species the Strategic Assessment documents.
Existing and emerging risks to the Great Barrier
Reef associated with climate change are not
discussed to the level of detail expected to be
consistent with the Terms of Reference (Section
2.2-g). Although it is recognised that actions to
mitigate or reduce climate change are outside
the scope of the report, increasing the resilience
of the Great Barrier Reef is a common theme in
many chapters, and adapting to climate change is
a key challenge for future management. Further
discussion of such matters would be appropriate,
particularly in light of the 25 year timeframe of
but is not a listed threatened or migratory species
the Program. The absence of detailed discussion
identified by the Protected Matters Search Tool.
suggests that the Program does not currently
As a result, it is not addressed in the Strategic
address the issue of managing for increased
Assessment despite it being specifically referred
resilience in response to climate change.
to in the statement of OUV in relation to the
13 Independent Review of the Great Barrier Reef Coastal Zone Strategic Assessment2.4 Promoting ecologically principle is noted as being enshrined in the
sustainable development Sustainable Planning Act 2009, but further
It is not clear how the principles of ecologically explanation would be helpful on how it is applied.
sustainable development (ESD) are applied in the Greater focus on long-term or forward looking
Program. The discussion of ESD is insufficient. measures, which are encapsulated in the first
One of the principles ‘improved valuation, pricing ESD principle (see page 321 of the Assessment
and incentive measures’ has been misinterpreted. Report) is recommended. Much of the coastal
The principle includes the following key aspects: development and infrastructure within the Great
polluter-pays, environmental factors should be Barrier Reef Coastal Zone (especially ports) will
included in the valuing of assets and services, have a design life spanning decades.
costs should reflect the full life cycle of goods
and structures, and financial or market incentives
2.5 Adaptive management: addressing
for developing effective solutions with a positive
uncertainty and managing risk
impact are available. It is not clear how the
The adaptive management section of the Terms
examples mentioned in the text (page 323) reflect
of Reference appears to have only been partially
or apply this principle.
addressed. While there are broad descriptions
The two other ESD principles (decision-making in the Strategic Assessment of plans to adapt
processes integrate both long and short term management to address risk and uncertainty,
considerations, and the precautionary principle) this section is lacking in detail and should be
are not addressed in detail. The precautionary strengthened. The description of uncertainties in
14scientific understanding could be further explained 2.7 Further work
for key management issues such as crown-of- The draft reports reviewed by SKM meet the
thorns starfish (COTS) outbreaks, the tolerance majority of the requirements of the Terms of
of coral reefs to sediment, nutrient and pesticide Reference. In order to be completely consistent
discharges and adaptation of the reef ecosystem with the Terms of Reference, a broader coverage
to climate change. of the following issues is required:
2.6 Auditing, reporting, review, • Description of OUV not identified by the
modification or abandonment Protected Matters Search Tool.
Descriptions of how the Program will be
• Better recognition of the strong ongoing links
administered in the future are relatively brief
between Aboriginal and Torres Strait Islanders
and described primarily within Sub-Chapter 9.8
and the management of their traditional lands
of the Assessment Report. A statutory review
and sea-country within the Great Barrier Reef
process applied to all regulatory mechanisms
Coastal Zone.
in Queensland is referenced. The commitment
to continue working with the Commonwealth • Further explanation on how the principles of
Government on joint management arrangements is ESD are applied under the Program.
also reaffirmed.
• More detailed description of adaptive
management actions and of scientific
uncertainty in our understanding of the Great
Barrier Reef.
• Further details on the proposed administrative
arrangements for the Program, including a
description of the likely circumstances that
may result in modification or abandonment
of the Program, and the parties responsible for
reviewing and/or auditing the Program.
15 Independent Review of the Great Barrier Reef Coastal Zone Strategic Assessment3. Structure of Reports
and Cohesiveness of
Presentation
3.1 Introduction 3.2 Intergovernmental management
The Strategic Assessment is the result of work arrangements
by a variety of Queensland and Commonwealth One of the first challenges faced in the Strategic
government agencies. This section examines Assessment is to describe the intergovernmental
whether the content of the reports is appropriately management arrangements in place for the Great
structured, and whether information is presented Barrier Reef. These arrangements are relatively
in a clear, concise and well written manner. The complex, as illustrated in Figure 6 (page 20) of the
cohesiveness, or degree to which sections of the Program Report, but are described in a relatively
Strategic Assessment fit together logically is also simple and concise manner that is well suited to a
described, particularly in relation to the objectives general audience. The selection of demonstration
cases across a broad range of management
activities provides significant benefit in describing
The Strategic Assessment presents a large body of
how the Program is applied in practice and how
information. The reports are generally well written,
interaction between State, Commonwealth and
concise and effective in articulating key messages. SKM
Local government agencies is achieved.
found the reports to be cohesive in their presentation
and structure, particularly in light of the large volume of The implications of the Strategic Assessment for
information presented. The frequent use of tables, figures the management of future development within
and cross references has assisted in the explanation of the Great Barrier Reef Coastal Zone by the
complex concepts for a broad audience. Queensland and Commonwealth governments
could be more clearly defined. In accordance
Clear and measurable objectives for the Strategic
with Part 10 of the EPBC Act, Sub-Chapter
Assessment should be outlined, and used as a basis
2.8 of the Program Report indicates that
for assessing the effectiveness of the existing Program.
under an endorsed Strategic Assessment, “the
Further explanation is recommended on how the Program
Commonwealth Environment Minister can approve
components comprising Foundational Management,
certain classes of actions, avoiding the need for
Strengthened Management and Forward Commitments will
proponents to submit individual proposals for
be of a sufficient scale and magnitude to provide for the long
further environmental assessment under national
term protection of the Great Barrier Reef.
law”. The Program Report does not clearly specify
activities that could be considered by the Minister
to be actions or classes of action to which this
exemption would apply should the Strategic
being feasible, well-defined and targeted towards
Assessment be endorsed. If any such actions are
the material issues affecting the Great Barrier
to be proposed, details should be clearly specified
Reef. Some recommendations for improvement
in the Program Report, as should details of how
of the documents have been identified which will
the Program will manage potential impacts on
further assist in enhancing the presentation for a
MNES. The term ‘accreditation’ appears to have
wide audience and to build technical rigour.
been incorrectly applied to the endorsement
16process for the Program, and further explanation 3.4 Presentation and cohesiveness
of the accreditation or endorsement process is In general, the reports are well presented and
recommended. flow logically. The description of the Program is
relatively concise and limits the information and
3.3 Goals and objectives
analysis to the material issues. The Queensland
The objectives of the Strategic Assessment
Government appears to have achieved a balance
are not well defined, which makes it difficult to
between detail and readability in most chapters.
evaluate the effectiveness of the Program Report
Some aspects of the Program description
and Assessment Report overall. Sub-Chapter 1.3
require further detail, and the ‘Strengthened
of the Assessment Report is titled ‘Objectives
Management’ and ‘Forward Commitments’
and Purpose of the Strategic Assessment’, but
sections would be stronger if they were related
provides only a high level description of the
to future environmental targets. Cross references
Strategic Assessment’s purpose and benefits. A
between the Program Report and Assessment
series of specific and measurable objectives in
Report, where present, assist the reader to link
this section would improve understanding of the
these documents. The inclusion of further cross
aims of the assessment and assist in determining
references in future revisions would improve
the effectiveness of the Strategic Assessment
readability. Figures and tables are generally used
overall.
effectively. The coloured visual summary tables
Examples of some possible objectives include: effectively present the assessment results for
condition, trend and management effectiveness.
• Conduct an assessment of the protection
afforded to MNES of the Great Barrier Reef The Program Report refers to the ‘World Heritage
Coastal Zone by the legislation, polices and Committee’s recommendations’ in several sections
management framework of the Queensland without providing a description of the background
Program. or context. There appears to be a level of assumed
knowledge of the history of the World Heritage
• Assess the current condition and trend of MNES Committee’s consideration of management of
within the Great Barrier Reef Coastal Zone, and the Great Barrier Reef. The inclusion of a brief
determine what level of additional management description of the background in the introductory
actions would be necessary to maintain world sections of the Program Report would enhance
heritage values in the long term (25 years). readability and the cohesiveness of presentation.
• Describe a series of new Strengthened The Strategic Assessment refers to the future
Management initiatives and Forward development of a Long-term Sustainability Plan
Commitments to address gaps identified in the for the Great Barrier Reef, which is a key step
protection of MNES by the existing Queensland in the process of improved joint management
Program. by the State and Commonwealth. The intended
development of this plan allows important
management challenges to be addressed in the
future rather than within the Strategic Assessment
itself. It is therefore important that the Long-
17 Independent Review of the Great Barrier Reef Coastal Zone Strategic Assessmentterm Sustainability Plan is outcome-focussed for future management of the Great Barrier Reef
and follows through on the commitments in reflect historical legacies rather than current
the Strategic Assessment. Further clarification activities. Declines in the condition of the Great
of the purpose, objectives and likely content of Barrier Reef in recent decades have been driven
the Long-term Sustainability Plan would provide by historical clearing across vast areas of the
important context for the reader on future actions catchment and activities operating at a broad
that will be guided by the findings of the Strategic spatial scale. This is perhaps one of the strongest
Assessment. messages from the Strategic Assessment, and
is important in setting directions and priorities
The Program and Assessment reports describe a
for future management. The scale and diversity
Great Barrier Reef that is under significant threat
of threats to the Great Barrier Reef will require
from a diverse range of activities. The focus on
a sustained management response to halt the
water quality, and in particular links between land
declining condition of the Great Barrier Reef.
management and environmental health of the
adjacent marine environment, are appropriate Summary tables used in the assessment of
and backed by science. Most environmental condition, trend and effectiveness are useful,
values of the Great Barrier Reef Coastal Zone are especially the colour coding which is an effective
described to be in either ‘good’ or ‘poor’ condition, visual cue. An additional table presenting a
with values that underpin MNES including OUV summary of all assessment ratings would be
having deteriorated over the past 5 years. Such useful to provide a visual overview of the Strategic
trends have occurred despite the existence Assessment’s findings. Summary assessment
of dedicated management programs, which tables are currently spread across three separate
have been assessed to be relatively successful chapters, and within different sections of each
(‘partially effective’ or ‘effective’). This apparent chapter, making it difficult for the reader to gain a
conflict between the assessment of effectiveness complete picture of condition and trend across all
and declining trends warrants further discussion of the MNES and OUV.
and explanation. The results are a sign that the
Recommendations to improve the readability
existing management actions and/or resources
and interpretation of concepts in the reports
allocated for management are not sufficient
are provided in Appendix A. These relate to the
to achieve the management objectives, even
purpose and layout of some figures, increasing the
if they have been implemented successfully.
number of cross references between the Program
Further discussion of the adequacy of existing
and Assessment reports (which are helpful where
management actions including resourcing, is
they are present), and providing more information
warranted. Links to discussions of the adequacy of
about matters such as the “accreditation process”
future management commitments would also be
described for the Program under the EPBC Act.
helpful in this context.
The reports will provide a structured and cohesive
The current condition and declining trends of the presentation with further amendment to improve
Great Barrier Reef also raise concerns about the confidence that management actions will be
time scales over which a sustained improvement sufficient to address the declining condition of the
could be expected. Many of the key challenges Great Barrier Reef.
184. Breadth and
Depth of Assessment
4.1 Introduction focussed the assessment on MNES. However, the
This section evaluates the breadth and depth Queensland Program was not established with
of the Strategic Assessment, focussing on the MNES in mind, and thus the assessment method
coverage of key issues affecting the Great Barrier has faced a significant challenge in evaluating the
Reef Coastal Zone and the level of detail applied protection afforded to a range of environmental
to the assessment. The comprehensiveness of values that are not specifically defined or targeted
the assessment is discussed and any areas that by the Program legislation. This has made the
have been overlooked or require more detailed assessment task complex, in the context that any
assessment have been identified. protection afforded to MNES has been largely
coincidental, rather than specifically targeted by
There are many potential methods that could have
Queensland’s legislative framework.
been chosen to complete a Strategic Assessment
at the scale of the Great Barrier Reef. Utilising A Queensland planning framework that is more
the process specified under the EPBC Act has compatible with Commonwealth legislation is
proposed in the Program Report. This will involve
explicit consideration of MNES and is indicative of
The Strategic Assessment has addressed significant
improved collaboration between the Queensland
challenges associated with evaluating the effectiveness
and Commonwealth governments. MNES would
of the Queensland Program, which was not designed
appear to be mutually accepted by the State and
to specifically consider MNES. There is a detailed focus
Commonwealth governments as a key feature
on the links between land-based activities and the
of the future management considerations for
environmental health of the adjacent marine environment,
the Great Barrier Reef, which is a significant
which is a strength of the assessment. The rigorous
step forward in the process of aligning joint
analysis of water quality issues and the spatial distribution
management responsibilities. This is illustrated in
of terrestrial ecological values are of a high quality and
several sections of the report, such as in Figure
targeted towards the material issues.
12 of the Program Report where an extract
The description of port development and related activities of the draft State Planning Policy released for
such as dredging and shipping would benefit from further consultation in April 2013 is shown, with specific
detail. Additional information on land use in disturbed areas reference to MNES.
and the management of national parks is also recommended,
Differing Queensland and Commonwealth
to justify the assumptions of ecological integrity and
government approaches to management of the
effectiveness of management across the protected area
Great Barrier Reef are highlighted in the reports.
estate. There is limited evidence that the Program, including
Examples include the techniques used to map
its Forward Commitments, will be sufficient to reverse the
environmental values, approaches to the listing
decline in the condition of the Great Barrier Reef and provide
of threatened species and the application of
for its long-term protection. Further evidence and discussion is
environmental offset policies to major projects.
therefore recommended to provide a stronger evidence base to
The reports identify these inconsistencies and
support the conclusions of the Strategic Assessment.
19 Independent Review of the Great Barrier Reef Coastal Zone Strategic Assessmentmany of the Forward Commitments are associated of dredged material at sea is overly simplified
with further aligning management between the and does not refer to the National Assessment
Queensland and Commonwealth governments. Guidelines for Dredging, which is the basis upon
which applications for dredging and material
4.2 Assumptions and gaps
placement are generally assessed (see page 168
The Strategic Assessment has a strong focus
of Assessment Report). Given the degree to which
on urban and infrastructure development,
expanded port proposals have shaped the public’s
which is reflected in the planning and
interest in the Strategic Assessment, and the
legislative instruments discussed. Coastal
nature of the Terms of Reference, a more detailed
planning mechanisms which are not focussed
description and assessment of these activities is
on infrastructure projects are given limited
recommended.
discussion and recognition in the documents. The
regulation of fisheries, aquaculture operations The description of the Queensland Government’s
and agriculture, for example, are given limited commitment to limit future port developments
consideration. The reports would benefit from to the existing port limits until 2022 should
an expansion in the discussion of ecological be explained in more detail, as readers may
processes, as this is generally limited to a small incorrectly interpret this as meaning that no new
number of issues such as the linkages between port expansion projects will occur during this
nitrogen discharges and outbreaks of the COTS. period. Significant expansion of port capacity
to accommodate new shipping berths could
More detail on port development was expected,
occur within the existing port limits at many
particularly in light of the World Heritage
port locations. The majority of concerns raised
Committee’s concerns about port expansions
regarding port expansions on the Great Barrier
throughout the Great Barrier Reef Coastal Zone.
Reef have occurred in response to proposals to
Port development and associated activities
increase capacity within existing port limits. Also,
such as shipping and dredging are given limited
the Program life is stated to be 25 years, which
description and assessment within the documents.
is longer than the currency of the 2022 port
The potential impacts of port development
commitment.
are correctly described as being local in
geographic scale, although such descriptions The Assessment Report makes an assumption
do not acknowledge the broader spatial scale of that Queensland regional ecosystems are
shipping activities and the cumulative impacts a surrogate for Commonwealth Threatened
of multiple ports along the coast. While port Ecological Communities (TECs). While TECs are
development activities are subject to detailed often based on regional ecosystems, the Strategic
management processes under the approval Assessment does not recognise that condition
framework described in the Program, there is thresholds such as patch size, canopy species
little justification provided for the assessment of and the level of weed infestation must be met for
risks relating to these activities in the documents. a regional ecosystem to form the TEC, for the two
Discussion on port developments is also TECs which have the majority of their distribution
disjointed, in some areas referring to the recently withinin the Great Barrier Reef Coastal Zone.
released draft Queensland Ports Strategy without Such matters should be clarified in the method
summarising and analysing the material issues description and addressed where possible in the
for the Strategic Assessment. The description of interpretation of results.
the management of dredging and the disposal
20The Strategic Assessment would benefit from a have produced a geographic representation of
discussion regarding the process to select the species that would be logically expected. The
key species to be assessed in the report. In Sub- key species considered in the assessment are
Chapter 3.5 of the Strategic Assessment report, largely concentrated in the northern parts of the
it is stated that those EPBC Act listed species Great Barrier Reef Coastal Zone. The southern
parts of the Great Barrier Reef Coastal Zone,
where significant development occurs, are poorly
represented in the distributions of these 11
species (e.g. only two of the species listed in Table
3.5-1 – ‘Key threatened species and ecological
communities in the Great Barrier Reef Coastal
Zone’ are found in the two southern natural
resource management (NRM) regions, Fitzroy and
Burnett Mary). This apparent discrepancy between
the assessment method and its application
in practice warrants further clarification and
discussion. The selection of listed species could
be more representative of the entire Great Barrier
Reef Coastal Zone if NRM regions were used to
provide a framework to check that the species
that are not regularly triggered for development chosen for assessment are distributed relatively
assessments under the EPBC Act were removed evenly.
from the list of species to be assessed. This
Sub-Chapter 5.2.2.3 of the Program Report
reduced the number of species to be considered
describes that proposed guideline for MNES in
from 162 to 50 species. No rationale for this
the Queensland Planning System. This is a good
approach was provided, and the method appears
initiative and has potential to clarify expectations
to invalidly assume that key risks for listed
about MNES in a Queensland context.
species are only associated with development.
Consideration could be given to expanding the
However, development is only one of the many
coverage of the guideline from State Development
sources of pressure on listed species and further
Areas and regional planning, to include mining,
justification of the approach would aid the reader
agriculture, development and other activities that
in understanding its validity. The description of the
generate non-point source impacts to the Great
process to identify threatened species could be
Barrier Reef.
strengthened with a definition of what is meant
by the phrase “not regularly triggered” in relation 4.3 Comprehensiveness
to development assessments used to identify The detailed examination and assessment of
species. the influence of land-based activities on the
marine environment is a feature of the Strategic
The application of methods to select key listed
Assessment. Management of marine protected
species on the basis of regularly triggering
areas is often constrained by legislation and
development assessments does not appear to
21 Independent Review of the Great Barrier Reef Coastal Zone Strategic AssessmentYou can also read