A proliferation of marine protected areas around the world, including Europe and Southeast Asia, is evidence of a growing global concern for the marine environment and its living resources. While marine protected areas in Europe on a wider scale have generally been considered a tool for either nature conservation or a technical measure in management of fisheries, overall management objectives of marine protected areas in Southeast Asian countries have varied more significantly between countries and sites due to differences in societal needs and opportunities, spatial scales, environmental conditions and varying threats. These differences have resulted in different approaches to marine protected area development and management.

Management of the Northern European marine environment and its living resources is highly sectoral and largely determined by central directives and policies stemming from the European Union, such as the Habitats Directive and the Common Fisheries Policy. This paper however, will touch upon an ongoing evolution within the European Union from a strictly sectoral approach to marine protected areas and marine management, towards a more integrated, ecosystem approach to management of fisheries and the marine environment.

In Southeast Asia, marine protected area development is usually determined by individual governments, municipalities and coastal communities, based upon specific needs and settings. Examples of such marine protected areas in Vietnam and the Philippines will be described, including their underlying institutional frameworks and objectives such as tourism, management of artisanal fisheries, etc.

Examples of differences and similarities between Northern European and Southeast Asian marine protected areas will be presented and areas in which regions might learn from one another identified. For instance, where Southeast Asian protected areas have addressed the inevitable interdependency between healthy ecosystems and sustainable coastal fisheries for decades, marine protected areas in Northern Europe usually address either large scale management of stocks of individual fish species or nature conservation. Tourism has long been an overarching driving force in marine protected area implementation in SE Asia, while in Northern Europe especially this has only had little influence on overall objectives pertaining to the marine environment.

## Introduction

In the following, underlying objectives and frameworks for establishment of marine protected areas (MPAs) are described for the European and Southeast Asian (SE Asian) settings. In describing European conditions, special focus is placed on Denmark, which is a member of the European Union (EU). Although there are many common traits between European countries, their use and management of MPAs varies widely, especially between southern countries and their northern counterparts. For the purpose of this paper, “European” refers to Northern European coastal states that are members of the EU. The Philippines and Vietnam provide representative case study MPAs for the SE Asian setting.

## European MPAs

### The EU Natura 2000 network

Protection of marine areas in Northern European countries has often originated from the need to protect seals for example and especially sea birds that, during migrations, spend varying amounts of time resting or breeding in coastal areas. As a result, a large number of nature reserves do exist in the coastal areas of northern Europe. However, as the goals, objectives and resulting management in many European countries (mainly outside of the Mediterranean Sea) usually have not directly addressed neither conservation of marine biodiversity nor management of fish populations, it is difficult to count these areas as MPAs, however broadly MPAs might be defined. In the case of Denmark, until fairly recently only very few, small national nature reserves have existed for which the purpose of establishment was to conserve marine biodiversity and/or fish populations.

It was not until the introduction by the European Union of the Habitats Directive in 1992 (Anon, 1992) that EU member states were put under the obligation to designate and protect marine sites purely for the sake of the conservation of marine biodiversity. As a consequence, it has by any account become the main driver for MPA designation in European seas (PROTECT, 2006). The legally binding Habitats Directive is the means through which the EU aims to meet its obligations as a signatory of the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention). It requires member states to take measures, by 2015, to maintain or restore a predefined set of natural habitats and wild species at a so-called “favourable conservation status”; i.e. introducing robust protection for those habitats and species of European importance. Sites for protection under the Habitats Directive are termed Special Areas of Conservation (SACs ), and are identified and designated by member states for subsequent approval by the EU Commission. Among the habitats listed in Annex I of the directive are reefs and submerged sandbanks, while Annex II lists a large number of marine species. However, only a small number of (threatened) fish species are included among these; commercially important fish species are not included.

The Habitats Directive and the Birds Directive (Anon, 1979), the latter introduced in 1979 coincidentally taking over the RAMSAR Convention as the main driver for bird protection in EU member states), together make up the legal foundation for a Europe-wide set of terrestrial and marine protected sites named the Natura 2000 network. Most coastal EU member states have at present designated SAC's in coastal waters, while most have yet to designate sites in offshore areas within their Exclusive Economic Zones (200 nautical miles where geography permits). No member state had in autumn 2008 finalised management plans to ensure protection of habitats and species in SAC's, albeit the deadline to do so is in 2009.

### The EU Common Fisheries Policy

All fishing activity taking place in European offshore waters is regulated through the EU's Common Fisheries Policy (CFP). It is thus the responsibility of the CFP, based on survey data collected by member states in coordinated international survey frameworks, to sustainably manage fish populations and regulate their exploitation through an ecosystem based approach to fisheries management (PROTECT, 2006). In addition to the setting of catch limits for respective commercial species, the CFP is responsible for development and implementation of technical measures such as MPAs (which in fisheries terms are usually referred to as fisheries closures, boxes, etc.). Such closed areas have been implemented for a number of reasons, most commonly as a means to protect spawning or nursery areas and, more recently, to protect sensitive habitats such as deep water coral reefs from lasting damage caused by fishing. CFP closures for management of fish species have so far had only limited success (PROTECT, 2006), while the relative simplicity of managing static habitats such as deep sea corals may hold more promise for achievement of conservation objectives.

### Sectoral policies and MPAs

MPAs in EU waters are thus driven heavily by overarching, legally binding sectoral directives and policies such as the Habitats and Birds Directives and the Common Fisheries Policy. As a consequence of such a sectoral division of the management of the marine environment, a number of management dilemmas and divergences relating to the implementation of MPAs have in recent years become more and more apparent. For instance, nature conservation MPAs (Natura, 2000) are designated by environmental authorities of individual member states; but if fishing is affected, the site's management plan must be approved by EU fisheries authorities. In addition, the Natura 2000 MPA network does not take into account commercial fish species, even in cases where Natura 2000 habitats are in fact also important habitats for commercial fish (stone reefs, sandbanks, etc). As a result, there are two separate, parallel processes that are simultaneously dealing with marine closures to protect different components of the marine environment creating problems where integrated; synergetic and ecosystem based solutions would inevitably be far more fruitful for the achievement of overarching goals.

That said, a new European Maritime Policy (with a Marine Strategy Directive (Anon, 2005) as the “environmental pillar”) aims at adopting an integrated approach towards management of Europe's seas and oceans in order to develop synergies between sectoral policies (transport, environment, research, fisheries etc). In addition, through current developments and management measures implemented through the European Common Fisheries Policy, one can detect a steadily increasing focus on the environmental impacts of fisheries on sensitive species and habitats. This is happening together with a coincidental current rise in the general awareness among European citizens and consumers regarding overfishing of species, destructive fishing methods etc.

### Southeast Asian MPAs

Southeast Asia has long been world famous for its rich and highly significant marine biodiversity. The region is host to more than one third of the world's coral reefs and includes critical habitats for many endangered marine species (Fortes et al., 2003). However, many of SE Asia's coastal ecosystems have for decades been heavily impacted by overfishing, destructive fishing practices, coastal development, tourism, pollution, erosion and many other anthropogenic impacts unfortunately. In addition, global climatic change and periodic warming of waters in the region have taken their toll on coral reef health.

Many SE Asian countries have made efforts to protect marine biodiversity in their respective waters, including the implementation of MPAs. As the SE Asian nations are not politically organised in a strictly formalised union with common policies such as the European Union, the rate of and standards for MPA implementation are determined by individual countries. Alternatively, a Regional Action Plan (2002–2012) was introduced by the South East Asia Marine Working Group of the World Commission on Protected Areas (WCPA SEA Marine) to improve and coordinate implementation and management of MPAs in SE Asia. The Action Plan is based on an ecosystem approach and is a framework to coordinate, guide and implement existing and new plans of action for the development of a network of MPAs throughout SE Asia by 2012, seeking to promote conservation of biodiversity, sustainable fisheries, sustainable nature-based tourism and integrated coastal management in the region. The Regional Action Plan identifies five high priority issues for actions in the management of MPAs: planning and design, adaptive management, coordination and enforcement, community awareness and development and sustainable financing (Fortes et al., 2003).

Effectiveness of the management of MPAs in most SE Asian countries has generally been poor and only few MPAs have achieved or are achieving their management objectives. 74% of SE Asian MPAs are unmanaged or only poorly managed (UP-MSI et al., 2002). In Vietnam, for instance, the current institutional, policy and legal framework for protected areas in Vietnam is still incomplete, particularly in relation to MPAs (UNDP-GEF 2006). A number of underlying reasons for the lack of success of MPAs in SE Asia have been described by Cheung et al. (UP-MSI et al., 2002). For instance, the mandate for the planning and management of MPAs in many SE Asian countries lies within forestry or environment authorities, which are traditionally the authority for terrestrial nature reserves and national parks. The legal framework and personnel capacity of these departments are inadequate or inappropriate to tackle marine environmental issues (UP-MSI et al., 2002). SE Asian MPAs that are managed by fisheries authorities, who may in some cases have more knowledge of and experience with marine resource management, are often hampered by the fact that these authorities do not have jurisdiction over the terrestrial areas adjacent to MPAs; negative impacts from terrestrial activities such as deforestation and coastal development are often difficult to control (UP-MSI et al., 2002). Furthermore, unclear mechanisms for coordination among government agencies, lack of MPA planning and legal frameworks and limited human and financial resources also contribute to the inadequate MPA management. Enforcement issues also constitute a great obstacle in achieving success for MPAs in the Philippines. Destructive fishing methods such as blast and cyanide fishing are still widespread in many parts of the country and control of such practices is often hindered by both corruption and an overall lack of resources for patrolling and enforcement (there have been cases where incarcerations have deliberately been avoided due to lack of funding for food for prisoners) (Dalby and Sørensen, 2002).

### SE Asian approaches

Cheung et al. (UP-MSI et al., 2002) note that due to the different cultures, traditions, land and marine tenure systems, management capabilities and the very nature of threats imposed upon the marine environment, the strategies for planning and management of MPAs vary widely from country to country, and even among MPAs in a given country. Currently, there are many different approaches to MPA management from top-down, government-dominated approaches to grassroots level, community-based management, depending on parameters at the local level (UP-MSI et al., 2002). Regardless of the means, measures or short term objectives, an overarching aim of achieving healthy coastal ecosystems that can continue to provide subsistence and food for coastal communities is nonetheless ubiquitous in MPA strategies in the Philippines (e.g. White et al., 2005) and other SE Asian countries. In many cases (e.g. Russ et al., 2003), this is also evident when observing the number of MPAs that have been established (White et al., 2007) based on expected spillover effects, i.e. the export and migration of larval, juvenile and adult fishes from within MPAs to surrounding areas.

In many SE Asian countries, donors and international NGOs play a key role in conservation and MPA development and management (e.g. White et al., 2007). In Vietnam, for instance, three current, large MPA projects are driven by donors and NGOs, providing different, tailored MPA management frameworks. The Hon Mun MPA Pilot project, the first MPA of Vietnam, was funded by the Danish International Development Agency (Danida) and the Global Environmental Facility through the World Bank and implemented by the World Conservation Union (IUCN). The project aimed to establish conservation measures for marine biodiversity at Nha Trang Bay, build capacity for protected area management and promote sustainable livelihoods for local communities through alternative income generation activities. The second MPA, Cu Lao Cham, funded by Danida, supported sustainable livelihoods of local communities in and around the MPA based on sound natural resource management and more diversified income generation. Con Dao MPA, funded by Danida, WWF and Conservation Trust Fund, focuses especially on the issue of sustainable tourism as a sustainable financing mechanism for marine biodiversity conservation.

Success of many coastal MPAs in SEA is highly dependent on the involvement and support of local communities and relevant stakeholders. This lesson can be learned from the involvement of local communities in MPA planning and implementation processes in Vietnam, for example. To facilitate conservation activities in villages fronting the Nha Trang Bay MPA, where 86% of households are directly dependent on fishing and aquaculture for subsistence (Ho et al., 2005), MPA Committees were established in all villages with regular meetings providing the opportunity for each committee to highlight key issues of common concern, identify and recommend solutions, and to conduct education and awareness raising activities. Each Village MPA Committee included representative groups and persons such as village leaders, women unions, youth unions, fishermen's unions, etc. (Nguyen, 2007).

In addition, MPA development in SE Asia is often connected with development of coastal tourism, e.g. with the charging of entrance fees from visitors to the MPA from adjacent diving resorts. These fees contribute to the covering of MPA costs and support the economy of local communities to which the coastal waters traditionally belong. Currently, the Nha Trang Bay MPA in Vietnam is collecting fees from tourists entering the MPA as a sustainable financing strategy for their daily operational expenses such as enforcement, education and other activities (Nguyen, 2007). For instance, fees for swimmers and divers around Hon Mun Island collected from 2006 was VND 660 million (US$41,200) and from 2007 was VND 686 million (US$42,800). In Apo Island in the Philippines, besides fees collected for snorkelling and scuba diving, other fees are also collected such as a lodging fee for overnight visitors, fees for camping, filming, mooring and anchoring (Dalby and Sørensen, 2002). Another Philippine MPA, the small Gilutongan marine sanctuary, has become a popular excursion for tourists from nearby Cebu City and Mactan Island (White et al., 2007). The success of both the Apo Island and Gilutongan MPAs contributes greatly to the incentive of other nearshore communities to protect marine biodiversity, and this message has been disseminated throughout the Philippines. In addition, local communities adjacent to SE Asian MPAs benefit from tourism which is attracted to or generated by MPAs that teem with healthy corals and fish populations, through employment in the tourist resorts, sales of t-shirts, handicrafts and other souvenirs and the shuttling of tourists to and from islands as in the case of Apo Island in the Philippines and Nha Trang Bay MPA in Vietnam. Such livelihood strategies are often developed to create incentives for MPA establishment among coastal communities and ensure successful management and enforcement through the provision of economically viable alternatives to fishing and other activities that contribute to the degradation of coastal ecosystems.

### MPAs in Europe and SE Asia: differences and similarities

It is apparent that there are fundamental differences between MPA development and management in Europe and SE Asia. The majority of these differences may be attributed to the overall political frameworks of the respective regions. The European Union acknowledges, at least in principle, the interconnectedness of marine species and habitats and the importance of coherence in both terrestrial and marine protected area networks to conserve biodiversity in Europe as a region. The centralised nature of the EU allows for the setting of common guidelines, standards and time frames for the establishment of MPAs in the waters of all coastal member states as stated in relevant directives. The key factor, however, is the fact that the directives are legally binding; if member states fail to designate sites appropriately and develop management plans that ensure a “favourable conservation status”, member states may be brought before the European Court. The current situation in SE Asia, where such legally binding regional agreements are not in place, does not to the same degree push governments to establish and, ultimately, ensure permanent protection for marine biodiversity. Solutions based on “soft law” risk the same unfortunate fate as other non-binding agreements have met in the past. It has become clear that the most sustainable strategy for development of MPAs in SE Asia is one in which MPAs are “owned” by those coastal communities that are dependent upon the marine resources in question. In the Philippines, Dalby and Sørensen (2002) examined a set of MPAs developed under different legal and management regimes. It was clear that community based strategies were the most sustainable and that in most cases a set of many small, community based (and owned) MPAs had much better chances of achieving overall conservation and resource management goals than large, nationally implemented MPAs.

NGOs play an important role in the development of MPAs. The role of NGOs, however, is very different in SE Asia and in Europe. In Denmark, for instance, the role of NGOs on the national level regarding MPAs is mostly limited to providing both input to and pressure on government agencies in the development of strategies and designation of sites and formulation of management plans for the Natura 2000 network. Much political lobbying is also focused on influencing central decisions made in Brussels on an overall EU policy level. European NGOs are thus not a crucial factor in the establishment of MPAs in general, since “top-down” EU directives dictate member states to do so. In cases where activities are expropriated as a result of MPAs, economic compensation usually eliminates the need for e.g. alternative livelihood strategies. A relatively lesser direct dependence of coastal communities on nearby marine resources for subsistence in Europe also means a lower risk of encroachment and poaching in MPAs, in turn reducing needs for increased enforcement. It can therefore be argued that community support is not a crucial factor for long term success of MPAs in Northern Europe. In SE Asia, many successful community based MPAs have seen the light of day due to the hard work of NGOs, in some cases contracted by national governments, and the corresponding activities pertaining to the raising of environmental awareness, alternative livelihood strategies, community monitoring of MPA performance, etc.

In SE Asia, MPAs are often driven by expected gains for local communities through the attraction of tourism and tourism revenue to a given site (e.g. user fees, sale of products, employment, etc.). Although such similar cases are common in the Mediterranean, in Northern Europe tourism is not usually a driving force for MPA establishment.

## Conclusions

It is apparent that SE Asian and European MPAs have both differences and similarities. MPAs are established in both regions as a means to mitigate a strikingly similar set of impacts on the marine environment. In the majority of cases European and SE Asian MPAs also share the same burden of being managed through highly sectoral institutional frameworks; management is the official responsibility of either fisheries or environmental authorities. However, where MPA establishment and implementation in SE Asia and Europe differ most substantially, and as a consequence where Europe perhaps can learn the most from SE Asia, is in the fundamental acceptance that healthy coastal fisheries can only be achieved if the ecosystem as a whole is in good condition. Where the majority of MPAs in Europe in policy and practice are established to either protect sensitive habitats and species or manage commercial fish populations, MPAs in SE Asia tend to consider the ecosystem as a whole. The aims of achieving high quality, resilient marine habitats and healthy fish populations intuitively go hand in hand, regardless of which government agency is responsible for individual components of the ecosystem. Fortunately, this seems to be the direction in which Europe is heading.

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