From 30% Protection to 100% Ocean Stewardship

Submission to the Australian Marine Parks Management Plan Review

From 30% Protection to 100% Ocean Stewardship

Healthy Oceans • Sustainable Seafood • Nourished People • Resilient Communities

30 September 2026 Seafood Consumers Association Ltd Download Full Submission (PDF)

Executive Summary

Seafood Consumers Association Ltd (SCA) supports effective protection of Australia's marine biodiversity and recognises the important role that well-designed marine protected areas can play in conserving vulnerable habitats, biodiversity and ecosystem functions.

However, SCA submits that the success of Australian marine policy should not be measured principally by the percentage of ocean enclosed within marine park boundaries.

Australia already has approximately 52% of its waters within marine protected areas, with around 24% in highly protected no-take zones. The Australian Government has committed to increasing highly protected marine areas to 30% by 2030.

At the same time, Australia's newly released Sustainable Ocean Plan commits the nation to the sustainable management of 100% of Australia's ocean.

SCA believes these two objectives must be considered together.

How do we ensure that 100% of Australia's ocean is healthy, resilient, productive and sustainably managed?

Protect what needs protecting.
Manage what can be sustainably used.
Restore what has been degraded.
Measure outcomes across 100% of Australia's ocean.

Marine protected areas are an important management instrument. They should not, however, become a substitute for effective fisheries management, pollution control, climate adaptation, habitat restoration, biosecurity, monitoring, enforcement and management of the land-based activities that ultimately affect marine ecosystems.


Principal Recommendations

1
100% Ocean Stewardship

Adopt 100% Ocean Stewardship as the overarching national objective, with marine protected areas forming one component of a wider management system.

2
Conservation Value–Threat–Response Test

Require an evidence-based test before significant additional spatial restrictions are imposed.

3
Measurable Ecological Objectives

Establish baselines and regular public reporting against stated objectives for marine parks.

4
Assess Displacement

Model where fishing effort moves and its consequences for fuel use, emissions, safety, other habitats and fisheries before final zoning decisions.

5
Seafood Supply & Substitution Assessment

Assess likely import substitution and associated environmental and consumer consequences where restrictions reduce Australian seafood production.

6
Food & Nutrition Security

Integrate food and nutrition security into marine policy, recognising wild-capture fishing as harvesting a renewable biological resource for food.

7
Catchment-to-Coast Management

Recognise that pollution, PFAS, plastics, pesticides and sediment do not recognise marine park boundaries.

8
Climate-Adaptive Marine Management

Include dynamic and seasonal management where ecological values and species distributions are changing.

9
National Blue Habitat Restoration

Create a restoration program covering mangroves, seagrasses, saltmarshes, oyster and mussel reefs, kelp and other productive marine habitats.

10
2030 Capability & 2050 Vision

Establish a 2030 milestone for tools, data and governance to manage 100% of Australia's ocean, with 2050 as the intergenerational vision.


SCA's Interest

SCA is an independent Australian not-for-profit charity representing the interests of seafood consumers. SCA also participates in international networks concerned with aquatic foods, responsible seafood and fisheries transparency, including membership of the Aquatic Blue Food Coalition and the Conservation Alliance for Seafood Solutions, and Affiliate status with the Coalition for Fisheries Transparency.

What marine-management arrangements will best protect Australia's marine environment while ensuring present and future Australians continue to benefit from healthy, sustainable and nutritious aquatic foods?


From 30% Protection to 100% Stewardship

Australia's 30 by 30 commitment aligns with Target 3 of the Kunming-Montreal Global Biodiversity Framework. SCA notes that the same framework includes Target 10, which calls for fisheries and aquaculture to be managed sustainably in ways that support biodiversity, resilience, long-term productivity and food security.

30% highly protected must sit inside 100% effectively managed.

Marine parks should complement, rather than substitute for: effective fisheries management; pollution prevention; habitat restoration; climate adaptation; invasive-species and biosecurity management; scientific monitoring; enforcement; Indigenous stewardship; sustainable aquaculture; international fisheries cooperation; and consumer and food-security policy.


Conservation Value – Threat – Response

SCA recommends that significant proposed zoning changes be accompanied by a transparent three-stage assessment:

  • What is the conservation value? Identify precisely the species, habitat, ecological process or other value requiring protection.
  • What is the demonstrated threat? Identify the activities actually placing that value at risk and quantify their contribution where possible.
  • What is the most effective response? Determine whether permanent spatial exclusion is necessary or whether another intervention would achieve the objective with fewer unintended consequences.

Displacement Must Be Measured

When fishing activity is excluded from an area, it does not necessarily disappear. It may move. Potential consequences include:

  • Concentration of fishing pressure elsewhere
  • Displacement onto different habitats
  • Longer steaming distances and increased fuel consumption
  • Increased emissions and higher operating costs
  • Vessel-safety implications
  • Congestion in remaining fishing grounds
  • Impacts on regional ports and communities

Historical catch inside a proposed closure is not the same as the economic or ecological impact of closing it.


The Missing Question: What Replaces the Seafood?

If Australian seafood production falls while consumer demand remains, the lost product must be replaced. A 2026 James Cook University-led review reports that about 65% of Australian seafood consumption is met through imports and warns that heavy import reliance can shift environmental and socioeconomic costs to producing nations.

Research led by Duncan Leadbitter, with Ray Hilborn and international co-authors, estimates that replacing all animal protein currently supplied by marine capture fisheries with livestock and poultry could require almost 5 million square kilometres of additional agricultural land. Extinction risk per million tonnes of animal protein produced is about 2.6 times higher for agriculture than for marine capture fisheries.

Marine conservation should not be considered successful if environmental impacts have simply disappeared from Australia's map and reappeared in another nation's waters.


Seafood Is Food

Wild-capture fishing is the harvesting of a renewable biological resource for food. Its long-term productivity depends upon maintaining functioning marine ecosystems and keeping harvest within scientifically sustainable limits.

A productive sustainable fishery and a healthy marine environment should therefore not automatically be treated as competing objectives. Properly managed, each depends upon the other.

Australian consumers who do not have the equipment, physical capacity, knowledge, time or geographic opportunity to catch fish themselves depend upon commercial fisheries to access Australia's wild seafood resources. A recreational fisher accesses the resource with a fishing line. A non-fishing consumer accesses it through the seafood counter. Both are Australians.


Catchment to Coast — The Ocean Begins on Land

Marine parks cannot prevent every threat to marine ecosystems. A boundary cannot stop PFAS, agricultural nutrients, pesticides, urban stormwater, sediment, plastics, heavy metals, wastewater, introduced species, ocean warming or acidification.

SCA recommends greater integration between catchment management, rivers, estuaries, coastal waters and offshore marine management.


Climate-Ready Marine Management

Climate change is altering ocean temperatures, currents, species distributions, productivity, habitats, spawning behaviour and ecosystem relationships.

Fixed ecological values may require fixed protection. Dynamic ecological risks may require dynamic management.


Restore the Ocean — Don't Only Restrict Its Use

SCA recommends creation of a National Blue Habitat and Fisheries Restoration Program covering mangroves, seagrass meadows, saltmarsh, oyster reefs, mussel reefs, kelp and other important fish habitats.

These ecosystems provide multiple benefits including nursery and breeding habitat, biodiversity, water filtration, nutrient cycling, shoreline protection, climate resilience, carbon sequestration, fisheries productivity, regional employment, First Nations economic opportunities and sustainable seafood production.

Australia should measure not only how much ocean it restricts, but how much marine habitat it rebuilds.


Commercial Fishers Are Also Part of Australia's Marine Capability

Commercial fishers should not be viewed only as users of marine resources. They are also observers of changing ocean conditions, potential contributors to scientific data, experienced mariners, regional employers, food producers and sources of local ecological knowledge.

SCA is an Affiliate of the Coalition for Fisheries Transparency, which supports the Global Charter for Fisheries Transparency. In June 2026, sixteen governments adopted the Mombasa Declaration on Fisheries Transparency. This provides a useful principle: spatial protection and fisheries transparency should be complementary components of ocean stewardship.


First Nations and Co-Management

SCA supports meaningful First Nations participation in marine governance. Australia should continue developing management arrangements appropriate to Sea Country that incorporate traditional ecological knowledge, Indigenous governance, ranger programs, research, monitoring, restoration and economic participation.


Australia Needs an Aquatic Food Strategy

Australia's seafood policy is fragmented across fisheries, aquaculture, environment, trade, health, food standards and biosecurity portfolios. Yet Australians experience these systems together — at the seafood counter and on the plate.

SCA believes Australia requires an explicit Aquatic Food Strategy integrated with the Sustainable Ocean Plan, covering sustainable wild fisheries, responsible aquaculture, seafood imports, national consumption, nutrition, affordability, regional employment, climate resilience, trade, traceability, food safety and environmental performance.


2030 Capability — 2050 Vision

2030

Build the tools, data, institutions and management systems to steward 100% of Australia's ocean effectively.

2050

Deliver the intergenerational vision — a healthy, productive, resilient, secure, inclusive, transparent and nourishing ocean.

By 2050 Australia should aspire to an ocean that is:

Healthy

Biodiversity and ecosystem function maintained; degraded habitats actively restored.

Productive

Sustainable fisheries and aquaculture provide food, employment and economic opportunity.

Resilient

Management responds to climate change, extreme events, pollution and emerging threats.

Secure

Australia maintains knowledge, presence, monitoring and governance across its marine jurisdiction.

Inclusive

First Nations peoples, consumers, fishers, scientists and communities participate meaningfully.

Transparent

Australians can understand where seafood comes from and how marine-management decisions perform.

Nourishing

Aquatic foods contribute meaningfully to Australian health and food security.


A National Ocean Scorecard

SCA recommends development of a publicly accessible Australian Ocean Stewardship Scorecard reporting indicators including ecosystem condition, stock sustainability, threatened-species trends, habitat restoration, water quality, pollution trends, marine heatwave impacts, IUU activity, seafood production, aquaculture, imports, consumption, affordability, nutritional contribution, regional employment, fisheries transparency, traceability, monitoring coverage, First Nations participation and marine park performance.


Conclusion

SCA supports the Australian Government's ambition to protect Australia's marine environment. But Australia should aspire to something larger than achieving a percentage target.

The Government's Sustainable Ocean Plan now provides the basis for that larger ambition: sustainable management of 100% of Australia's ocean. Marine protected areas should form part of that framework — not substitute for it.

Protect what needs protecting.
Manage what can be sustainably used.
Restore what has been degraded.
Measure outcomes across 100% of Australia's ocean.

The ultimate measure of success should not be the number of square kilometres coloured differently on a marine map. It should be the condition of the ocean and the benefits it continues to provide to Australians.

Hon Prof Roy D Palmer (MBA)
CEO, Seafood Consumers Association Ltd
“26 Million Voices. One Seafood Future.”