Submission on the Draft Policy on Fish Aggregating Devices and Artificial Reefs

We recommend that the Draft Policy make explicit that an exception to the prohibition on the deployment of Artificial reefs exists beyond the exceptions set out in paragraph 13 of the Draft Policy
In our view, the exception to the general prohibition on the deployment of artificial reefs should be clarified to explicitly allow artificial reefs to be deployed for:
• small-scale research purposes;
• habitat restoration practices; and
• management tool to prevent natural habitat overfishing and to restore depleted populations due to habitat loss and fishing pressures on natural habitats.
We recommend that under the artificial reef deployment policy, any consideration of whether an artificial reef project application falls within an exemption category evaluates the artificial reef’s impact on the surrounding environment, as well as the chances of success for the artificial reef to achieve its set conservation and management goals.
• The Draft Policy is based on research that does not take into account the most recent research advances in the field of Green Marine Engineering, Conservation and Habitat Restoration
In Section 3, we provide a summary of the most recent advances in this research field that may assist the Great Barrier Reef Park Authority in further examining the suitability of the Draft Policy.
• The Definition of ‘Artificial reef’ is too broad and could be tailored to prevent unintentional chilling effect on research that may support stronger environmental outcomes for the Great Barrier Reef