Particularly Sensitive Sea Area: Great Barrier Reef and Torres Strait

Background: PSSA framework under Resolution A.982(24)

A Particularly Sensitive Sea Area (PSSA) is an area that, in accordance with the IMO Guidelines for Identification and Designation of Particularly Sensitive Sea Areas adopted by the Assembly as Resolution A.982(24) on 1 December 2005, has been recognised by IMO as needing special protection through action by IMO because of its significance for recognised ecological, socio-economic or scientific reasons, and which may be vulnerable to damage by international shipping activities. Resolution A.982(24) replaced the earlier Guidelines first adopted as Assembly Resolution A.720(17) of 6 November 1991 and revised in Resolution A.927(22) of 29 November 2001. The 2005 Guidelines remain the operative instrument and are administered by the Marine Environment Protection Committee (MEPC) in cooperation with the Maritime Safety Committee (MSC) where the proposed Associated Protective Measures fall under the SOLAS Convention.

The PSSA concept arose from the experience of the early 1980s when the Great Barrier Reef was identified as facing rising risk from increasing through-traffic of bulk carriers, tankers and chemical carriers and from the realisation that the existing MARPOL special-area regime, while protective of certain discharges, did not address the underlying risk of grounding, collision or operational error in confined waters. The Australian delegation to MEPC 25 in November 1987 first formally proposed the creation of a designation that would package together protective measures under different IMO conventions for an ecologically vulnerable area. The proposal matured through MEPC 26 to MEPC 29 and crystallised in the original PSSA Guidelines of 1991.

A PSSA differs in scope and legal basis from a MARPOL Special Area. A Special Area is a geographically defined sea area where special discharge requirements apply under one of the MARPOL annexes (Annex I, II, IV, V or VI), and the protection is solely under MARPOL. A PSSA, by contrast, is a designation that triggers a package of Associated Protective Measures which may draw on SOLAS Chapter V (ships’ routeing, ship reporting), MARPOL annexes, the Convention on the International Regulations for Preventing Collisions at Sea, 1972 (COLREG), or other IMO instruments. The two regimes can overlap and frequently do, with the GBR being both a PSSA under MEPC.44(30) as extended and a Special Area under Annex IV sewage and Annex V garbage.

Four ecological / scientific / socio-economic criteria

Resolution A.982(24) sets out three categories of criteria for the identification of an area as a PSSA: ecological, social, cultural and economic, and scientific and educational. In practice the literature speaks of four operative criterion families that an applicant coastal state typically demonstrates to MEPC.

The first family is ecological criteria. These include uniqueness or rarity, critical habitat, dependency, representativeness, diversity, productivity, spawning or breeding grounds, naturalness, integrity, fragility and bio-geographic importance. The Great Barrier Reef satisfies essentially every one of these criteria, comprising over 2,900 individual reefs, 600 continental islands, 300 coral cays and 150 inshore mangrove islands stretching over 2,300 km along the north-east coast of Australia, the largest coral reef system in the world, with over 400 species of hard coral, 1,500 species of fish, 4,000 species of mollusc and 240 species of bird.

The second family is social, cultural and economic criteria. These cover social or economic dependency, human dependency, cultural heritage, recreation and tourism. The Reef supports a tourism industry valued at over AUD 6 billion per year, a commercial fishery, traditional Indigenous hunting and cultural practices by Aboriginal and Torres Strait Islander peoples whose connection to sea country in the area is continuous and dates back at least 60,000 years, and a recreational fishery and boating sector serving the populations of Queensland and the Torres Strait.

The third family is scientific and educational criteria. These include research value, baseline and monitoring studies, education and reference value. The Reef has been the subject of continuous scientific investigation by the Australian Institute of Marine Science, the Great Barrier Reef Marine Park Authority, James Cook University, the CSIRO, and a global network of climate-change and coral-bleaching monitoring stations.

The fourth family, often treated as a fourth criterion in textbooks though formally a sub-set of ecological criteria, is vulnerability to damage from international shipping activities. Resolution A.982(24) is explicit that a PSSA must be at risk specifically from international shipping. The applicant state demonstrates this through traffic statistics, casualty history, vessel-type analysis, hazardous cargo flows, and projected growth. The original 1990 Australian submission documented an annual through-traffic of about 2,500 commercial vessel transits, an average of more than five known reef contacts per year between 1985 and 1989, and projected continuing growth in chemical and bulk carrier traffic out of the ports of Hay Point, Gladstone and Townsville.

IMO designation process and Associated Protective Measures (APMs)

A PSSA is designated by IMO through a two-stage process under Resolution A.982(24). The first stage is the proposal by one or more coastal states. The proposal sets out the boundaries of the area, the ecological, socio-economic and scientific basis for designation, evidence of vulnerability to international shipping, and the proposed Associated Protective Measures. APMs must be measures that IMO has the legal competence to adopt, must be the least burdensome practicable, and must be supported by an analysis of the impact on international shipping. The proposal is submitted to MEPC.

The second stage is MEPC review and adoption. MEPC considers the proposal at one or more sessions, normally requiring a Technical Group to review the supporting documentation. Where the APMs include ships’ routeing or ship reporting measures requiring adoption under SOLAS Chapter V, the Maritime Safety Committee considers and adopts those APMs in parallel under its routeing and reporting machinery. MEPC adopts a resolution designating the PSSA “in principle” or “with full effect” once the APMs are also adopted by MSC, ensuring the protective package enters force as a coherent whole.

The Associated Protective Measures of a PSSA can be drawn from several IMO instruments. The principal categories are routeing measures under SOLAS V/10 (areas to be avoided, two-way routes, traffic separation schemes, deep-water routes, recommended tracks, no-anchoring areas, precautionary areas), ship reporting systems under SOLAS V/11 (mandatory or recommendatory), pilotage requirements (recommendatory by IMO; compulsory enforcement is a matter for the coastal state under UNCLOS), MARPOL Special Area discharge restrictions, and other measures including vessel-traffic services, equipment requirements and operational controls.

The total number of designated PSSAs has grown steadily from the original Great Barrier Reef in 1990 to seventeen as at 2025, including the Sabana-Camagüey Archipelago (Cuba), the Malpelo Island (Colombia), the Florida Keys (United States), the Wadden Sea (Denmark, Germany, Netherlands), Paracas (Peru), the Western European Waters, the Canary Islands (Spain), the Galapagos Archipelago (Ecuador), the Baltic Sea Area (excluding Russian waters), the Papahānaumokuākea Marine National Monument (United States), the Strait of Bonifacio (France, Italy), the Saba Bank (Netherlands), the Tubbataha Reefs Natural Park (Philippines), the Jomard Entrance (Papua New Guinea) and the North-Western Hawaiian Islands.

GBR PSSA original 1990 designation (MEPC.44(30))

The Great Barrier Reef was designated a PSSA by Resolution MEPC.44(30) adopted on 16 November 1990. The resolution recorded that the Great Barrier Reef Region was an area of recognised ecological significance, the largest coral reef system in the world, an area of major scientific value, and an area whose ecological balance was vulnerable to damage from shipping. The designation covered the entire Great Barrier Reef Region from the Cape York Peninsula in the north to the area south of Lady Elliot Island at approximately 24 30’ S in the south, broadly coterminous with the Great Barrier Reef Marine Park boundaries declared by the Australian Parliament under the Great Barrier Reef Marine Park Act 1975.

The 1990 designation was accompanied by Associated Protective Measures comprising recommended pilotage in the Inner Route between Cape York and Cairns, the Hydrographers Passage off Mackay, and Whitsunday Passage; an area-to-be-avoided around the Hydrographers Passage approaches; the existing Great Barrier Reef and Torres Strait two-way routes adopted under SOLAS V; and a discharge prohibition area under MARPOL Annex I, Annex II and the then-developing Annex IV and Annex V regimes. The Australian Federal Parliament gave the recommended pilotage immediate compulsory effect by amendments to the Navigation Act 1912 commencing 1 October 1991, with full enforcement from 1 January 1992. The amendment placed Australia among the first IMO Member States to use national legislation to convert IMO-recommended pilotage into a compulsory regime, an approach that has since become the standard model for PSSA enforcement worldwide.

The 1990 designation was the proof of concept for the entire PSSA framework. It demonstrated that a coastal state could secure a comprehensive, IMO-recognised package of protective measures for an ecologically sensitive area while remaining consistent with the freedom-of-navigation principles of the United Nations Convention on the Law of the Sea (UNCLOS) of 1982 to which Australia is a party.

2005 extension to Torres Strait (MEPC.133(53))

The Torres Strait, a narrow body of water between Cape York Peninsula and the southern coast of Papua New Guinea, was added to the GBR PSSA by Resolution MEPC.133(53) adopted on 22 July 2005. The Torres Strait is a confined and shallow international shipping route, with depths in places less than 12 m and dotted with reefs, islets and tidal rips. About 3,500 vessel transits occur each year, mostly bulk carriers and tankers loading at Australian east-coast ports and proceeding to the Indian Ocean and Asia through the Torres Strait, the alternative being the much longer route around the south of Australia.

The Torres Strait extension was a joint proposal by Australia and Papua New Guinea, both coastal states under UNCLOS to the strait. The associated protective measure adopted with the extension was the IMO recommendation that pilotage be applied through the Torres Strait, the Great North-East Channel and the Hydrographers Passage. Australia translated the recommendation into compulsory national pilotage with effect from 6 October 2006 by amendment to the Navigation Act 1912, extending the existing GBR Inner Route compulsory regime northwards into the Torres Strait. The compulsory regime applies to all vessels of 70 m or more in length, and to all loaded oil tankers, chemical tankers and gas carriers irrespective of length.

The 2005 extension was contentious in IMO. Several flag states, principally Singapore and the United States, voiced concerns at the precedent of converting an IMO recommendation into a compulsory pilotage requirement in an international strait used for international navigation. The Legal Committee of IMO considered the issue at LEG 91 in April 2006 and recorded a divergence of views between Australia and Papua New Guinea on the one hand, who maintained that the compulsory regime was a permissible exercise of coastal-state jurisdiction, and the United States and Singapore on the other, who maintained that compulsory pilotage in a strait used for international navigation was inconsistent with the transit-passage regime of UNCLOS Part III. The matter has not been pressed to dispute settlement, and the compulsory regime has been continuously enforced by AMSA since 2006 with very high compliance.

APM 1: Compulsory pilotage in the Inner Route

The first and most operationally significant Associated Protective Measure of the GBR PSSA is compulsory coastal pilotage in three defined geographic areas:

• The Inner Route between Cairns and Cape York, a distance of approximately 470 nautical miles between latitudes approximately 17 S and 11 S.
• Hydrographers Passage, a deep-water passage through the Reef off Mackay, used by very large bulk carriers loading at Hay Point and Dalrymple Bay.
• The Torres Strait, the Great North-East Channel and the approaches, added by MEPC.133(53) in 2005.

The compulsory regime is administered by AMSA under the Navigation Act 2012 (which replaced the 1912 Act). Pilots are licensed by AMSA, organised through two pilotage companies (Australian Reef Pilots and Torres Pilots), and trained, examined and audited under the AMSA Coastal Pilotage Standards. Pilot allocation is by AMSA-administered roster.

The threshold for compulsory pilotage is vessels of 70 m or more length overall, plus all loaded tankers, chemical carriers and gas carriers of any length. The fee for a typical Inner Route transit between Cairns and Cape York is approximately AUD 18,000 in 2024 to 2025 dollars, comprising the pilot’s fee, transport to and from the vessel, and a contribution to the compulsory pilotage administration. The fee for the Torres Strait or Hydrographers Passage segments is additional.

The compulsory pilotage regime has produced a sustained reduction in casualty rates. AMSA statistics show an average of about 0.4 reportable casualties per 1,000 transits in the post-2006 period compared to over 5 per 1,000 transits in the pre-1991 period. Casualties that have occurred have generally been associated with cases where the master continued the passage in defiance of pilot advice or in circumstances where the pilot had been put under undue commercial pressure.

APM 2: Two-way “Reef” route system

The second APM is the two-way “Reef” route system, originally adopted by IMO as a recommended route under Resolution A.572(14) and converted to a SOLAS Chapter V routeing measure under Resolution MSC.52(66). The two-way route is a designated track through the Inner Route and the Torres Strait, with separation between northbound and southbound traffic where the channel width permits, and convergence to a single shared track where it does not.

The two-way route serves three purposes. The first is collision avoidance through traffic management in confined waters. The second is the routing of traffic away from the most ecologically sensitive sub-areas of the Reef, including the principal coral spawning sites and the green and hawksbill turtle nesting beaches. The third is the simplification of the pilot’s task by providing a known, charted, IMO-recognised track that can be used as the operational reference for pilotage.

The two-way route is shown on Australian Hydrographic Office charts AUS 825, AUS 826 and AUS 827 and on the corresponding ENC cells. Compliance with the two-way route is mandatory for vessels using the GBR Inner Route under SOLAS V/10 as implemented in the Marine Orders 2012. Departure from the route is permitted only in cases of force majeure, mechanical breakdown or pilot direction. AMSA’s Maritime Operations Centre at Canberra monitors compliance through Automatic Identification System (AIS) data and through REEFREP reports.

APM 3: REEFREP ship reporting system

The third APM is REEFREP, the Great Barrier Reef and Torres Strait Vessel Traffic Service ship reporting system. REEFREP was developed by AMSA in the early 1990s, made operational in stages from 1996, and recognised by IMO as a mandatory ship reporting system under SOLAS V/11 by Resolution MSC.52(66) on 30 May 1996, with the Torres Strait extension recognised by Resolution MSC.171(79) on 9 December 2004.

REEFREP applies to all vessels of 50 m or more length overall, all vessels carrying hazardous cargo, all vessels engaged in towing where the tow plus tug exceeds 150 m, and all vessels not under command or restricted in their ability to manoeuvre. Reports are made to the AMSA Reef VTS centre at Hay Point, Queensland, on VHF channels 2, 5 and 22 or by HF and Inmarsat-C. The principal report types are:

• Position report on entering the REEFREP area.
• Final report on departing the area.
• Deviation report when a vessel departs from the two-way route.
• Defect or incident report on any equipment failure or near-miss.
• 12-hour position report at noon and midnight UTC for vessels remaining in the area.

The REEFREP area extends from latitude 22 S south of the Whitsundays to latitude 9 S in the Torres Strait, and from the Australian coast to the seaward edge of the Great Barrier Reef. The 12-nautical-mile offshore boundary referred to in some literature is the offshore edge of the Australian territorial sea south of latitude 22 S and is the geographic reference for REEFREP coverage in that southern segment.

REEFREP is operationally supported by Vessel Traffic Service personnel at Hay Point who maintain real-time situational awareness of all reporting vessels, issue advisories on traffic, weather and reef sightings, and coordinate with the licensed pilot on board each vessel.

APM 4: IMO-mandated reporting structure

The fourth APM is the IMO-mandated mandatory ship reporting structure under SOLAS V/11 that gives REEFREP its international legal status. The distinction between APM 3 and APM 4 is that APM 3 is the operational system and APM 4 is the legal status under SOLAS V/11.

Under SOLAS V/11 a Contracting Government may submit a proposal to MEPC and MSC for the establishment of a mandatory ship reporting system. The proposal must demonstrate the need for the system, set out its geographic boundaries and reporting requirements, and demonstrate that the system is consistent with international law. Australia first submitted its proposal for REEFREP to NAV 41 in 1995, with adoption by MSC.52(66) on 30 May 1996 and entry into force on 1 July 1997. The Torres Strait extension was added by MSC.171(79) on 9 December 2004 with entry into force on 1 July 2006.

The IMO-mandated character of REEFREP means that all flag states whose vessels enter the REEFREP area are obliged under SOLAS V/11 to ensure that their vessels comply with the reporting requirements, regardless of whether the vessel itself transits Australian internal waters. AMSA has the right to enforce non-compliance through the flag state and through port-state control inspections at the next Australian port of call.

GBR Marine Park Authority management plan

The Great Barrier Reef Marine Park Authority (GBRMPA) is a statutory authority of the Australian Government established under the Great Barrier Reef Marine Park Act 1975 with responsibility for the long-term protection and conservation of the GBR Marine Park, an area of approximately 344,400 km that overlaps with most of the GBR PSSA. GBRMPA operates a Zoning Plan adopted in 2003 and reviewed every ten years, dividing the Marine Park into general use, habitat protection, conservation park, buffer, scientific research, marine national park, preservation and Commonwealth island zones with progressively stricter restrictions on extractive and shipping activities.

GBRMPA cooperates with AMSA under a Memorandum of Understanding first signed in 1996 and regularly renewed. AMSA is the lead agency for shipping safety, casualty response and pollution preparedness; GBRMPA is the lead agency for environmental management, restoration and monitoring; the Australian Hydrographic Office is the lead for charting and the Bureau of Meteorology for weather and oceanographic data. The Reef HQ centre at Townsville and the Reef 2050 Long-Term Sustainability Plan provide the long-term programmatic framework within which the PSSA APMs are operated.

MEPC.221(63) chemical-tanker through-routing

In February 2012 MEPC adopted Resolution MEPC.221(63) which extended specific protective measures within the GBR PSSA addressing chemical-tanker through-routing. The resolution recorded the increasing volume of chemical-tanker traffic transiting the Reef bound for and from chemical terminals at Brisbane, Gladstone and Townsville, and adopted recommendations that chemical tankers carrying noxious liquid substances of MARPOL Annex II Categories X and Y use the Hydrographers Passage in preference to the Inner Route where possible, that they carry an enhanced level of SOPEP and corresponding chemical-tanker emergency planning documentation, and that they hold a current Certificate of Fitness under the IBC Code or the BCH Code as applicable.

These measures are sometimes characterised as “Adopted but not yet in force” because the recommendation under MEPC.221(63) interacts with the IBC Code Certificate of Fitness regime through MEPC and MSC parallel adoption channels and with national chemical-tanker carriage rules under the Australian Marine Orders. Operationally, AMSA has applied the MEPC.221(63) recommendations through Marine Orders since 2013, and major chemical-tanker operators have aligned their routing to the recommendations.

Torres Strait shared-pilotage agreement with PNG

The Torres Strait is bounded to the south by the Australian Cape York Peninsula and to the north by the south coast of Papua New Guinea. The two coastal states share UNCLOS rights and obligations in the strait under the Torres Strait Treaty of 1978, which established the maritime boundary, defined a Protected Zone for the protection of the traditional way of life of the Torres Strait Islander and Papuan coastal peoples, and provided for cooperation on environmental management.

The PSSA extension by MEPC.133(53) was a joint Australia-PNG submission to IMO. The compulsory pilotage that Australia legislated from 6 October 2006 applies in Australian internal waters and the Australian-administered area of the Protected Zone. PNG legislated parallel arrangements under its Pilotage Act, recognising AMSA-licensed pilots as competent under PNG law for the Torres Strait segment and providing for cost-recovery between the two administrations. AMSA and the PNG National Maritime Safety Authority (NMSA) operate a shared roster of pilots and a shared cost-recovery arrangement that ensures continuity of pilotage across the maritime boundary.

The Jomard Entrance, a separate PSSA designated in 2016 by Resolution MEPC.282(70) at the request of Papua New Guinea covering the eastern approaches to the Torres Strait through the Louisiade Archipelago, complements the Torres Strait segment of the GBR PSSA by extending protective ship reporting and recommended pilotage to the wider eastern PNG region.

SOLAS V/22 ships’ routeing interaction

SOLAS Chapter V Regulation 22 covers navigation bridge visibility and general routeing references; the underlying ships’ routeing instrument is SOLAS V/10 read with Resolution A.572(14) and its successors. The GBR two-way “Reef” route, the GBR area-to-be-avoided (ATBA) around the offshore reefs of the Marine Park, and the Hydrographers Passage routeing measures are all SOLAS V/10 measures, given operational effect through publication in the IMO Ships’ Routeing publication, in Australian Hydrographic Office charts, and in ECDIS ENC cells.

Compliance with SOLAS V/10 routeing measures is a condition of SOLAS compliance for all flag states, enforceable by port-state control under the Tokyo MOU and the Paris MOU. The interaction with the GBR PSSA is that the routeing measures are simultaneously SOLAS V routeing measures and APMs of the PSSA, ensuring a double layer of legal protection.

Annex IV/V special-area status

The Great Barrier Reef and the Torres Strait are designated Special Areas under both MARPOL Annex IV sewage and MARPOL Annex V garbage. The Annex V Special Area for the GBR was designated by Resolution MEPC.118(52) on 15 October 2004 and entered into force on 1 January 2005. The Annex IV Special Area was designated by Resolution MEPC.200(62) on 15 July 2011 and entered into force on 1 January 2013, with the discharge prohibition taking effect for ships built before 2013 in 2018.

The Special Area regime overlays the PSSA regime to deliver an integrated discharge-prohibition framework. Under Annex V no garbage of any category may be discharged into the sea inside the Marine Park except for food wastes that have been comminuted to less than 25 mm and are discharged at least 12 nm from the nearest land or reef. Under Annex IV no untreated sewage may be discharged inside the Marine Park, and treated sewage may be discharged only when the ship is proceeding at not less than 4 knots and from an approved sewage treatment plant. The Special Area regime is enforced by AMSA through port-state control, by GBRMPA through Marine Park enforcement, and by the Queensland and Northern Territory Water Police.

There is no Emission Control Area declared for the Great Barrier Reef under MARPOL Annex VI. Australia has not submitted a proposal to MEPC for an ECA covering the GBR, and the area is therefore subject only to the global 0.50% sulphur cap under Annex VI Regulation 14. The question of whether to seek ECA designation has been canvassed in Australian government consultations, with the principal arguments being the additional protection for coral reefs from acid deposition and black-carbon settlement on coral surfaces, against which is set the cost of ECA-compliance fuel for the Australian east-coast trade.

Historical incidents: Doric Chariot, Oceanic Pioneer, Shen Neng 1

The grounding history of the GBR PSSA includes several major incidents that have shaped the development of the protective regime.

The Oceanic Pioneer grounding in May 2000 involved a Liberian-flagged bulk carrier that grounded on a reef in the Torres Strait north of Booby Island after a navigation error by the bridge team in deteriorating weather. The vessel was refloated without major hull damage or pollution, but the case prompted the Australian government to accelerate work on the Torres Strait PSSA extension that became MEPC.133(53) in 2005.

The Doric Chariot grounding on 29 July 2002 involved a Hong Kong-flagged bulk carrier that ran aground on Piper Reef near Cape York while transiting the Inner Route under compulsory pilotage. The vessel was refloated five days later and the ATSB investigation found that the master had countermanded the pilot’s advice on a course change, resulting in the vessel running directly onto the reef. The case led to a tightening of the AMSA Coastal Pilotage Standards and to a clarification of the pilot’s authority under the Navigation Act amendments of 2003.

The Shen Neng 1 grounding on 3 April 2010 was the most consequential GBR PSSA incident in financial and ecological terms. The Shen Neng 1, a Chinese-flagged bulk carrier loaded with 65,000 tonnes of coal at Gladstone, ran aground on Douglas Shoal in the Capricorn-Bunker Group at full speed of about 12 knots after the chief mate failed to alter course at a planned waypoint. The vessel was refloated nine days later after extensive lightering. The grounding caused damage to a coral reef area of about 400,000 m, the largest single ship-source coral damage event recorded in the GBR. The salvage cost was approximately AUD 39.4 million, recovered from the shipowner and its P&I club through litigation by the Australian Government concluded in 2016. The reef restoration cost was estimated at a further AUD 20 million spread over a decade. The Shen Neng 1 case led to a review of the Capricorn-Bunker traffic-routing arrangements and reinforced the case for the MEPC.221(63) chemical and bulk-tanker through-routing recommendations.

UNESCO World Heritage status

The Great Barrier Reef was inscribed on the UNESCO World Heritage List under cultural and natural heritage criteria (vii), (viii), (ix) and (x) on 26 October 1981, eight years before the IMO PSSA designation. The World Heritage inscription covers an area of approximately 348,000 km, broadly coterminous with the GBR Marine Park and the GBR PSSA. The inscription recognises the Reef as the world’s most extensive coral reef ecosystem, of outstanding universal value, of exceptional natural beauty, of exceptional ongoing geological and biological evolutionary processes, and of exceptional habitat significance for the conservation of biological diversity.

The World Heritage status creates parallel obligations under the World Heritage Convention 1972 that complement the IMO PSSA APMs. Australia is required to report periodically to the World Heritage Committee on the state of conservation of the property, including shipping-related impacts. The World Heritage Committee has on several occasions considered placing the GBR on the World Heritage in Danger list, most recently in 2021 when a draft decision to that effect was deferred at the 44th session in Fuzhou pending an Australian state-of-conservation report. The Australian government has consistently treated maintenance of the World Heritage status as a primary policy driver for shipping management in the area, and the strength of the GBR PSSA regime is in part a response to that policy driver.

AMSA enforcement and cost-recovery

The Australian Maritime Safety Authority (AMSA) is the lead agency for the GBR PSSA. AMSA is responsible for the licensing of coastal pilots, the operation of the REEFREP VTS centre at Hay Point, the publication and updating of the routeing measures in cooperation with the Australian Hydrographic Office, the conduct of port-state control inspections at Australian east-coast ports for compliance with PSSA requirements, the investigation of incidents in cooperation with the Australian Transport Safety Bureau (ATSB) under independent statutory powers, and the cost-recovery of pilotage and VTS services from industry.

The AMSA cost-recovery framework is governed by the Australian Government Cost Recovery Guidelines and the AMSA-specific levies under the Marine Navigation Levy and the Protection of the Sea Levy. The Marine Navigation Levy funds AMSA’s navigation aids, search and rescue, and safety regulatory functions. The Protection of the Sea Levy funds the National Plan for Maritime Environmental Emergencies and the GBR-specific environmental protection arrangements. The pilotage fees are paid directly by the shipowner to the licensed pilotage company; AMSA recovers its administrative costs through a separate per-transit levy.

AMSA enforcement in cases of non-compliance is graduated. The first response is normally a warning issued through the master or the flag state. Persistent non-compliance is referred for prosecution under the Navigation Act 2012 or the Protection of the Sea (Prevention of Pollution from Ships) Act 1983, with maximum penalties for corporations of up to AUD 11 million for the most serious environmental offences. AMSA also has the power to detain a vessel and refuse port entry in cases of serious or repeated non-compliance.

Commercial impacts: pilot fees, route divergence, certificates

The GBR PSSA imposes measurable commercial impacts on through-trade. The principal cost categories are pilotage fees, route-divergence steaming time, and chemical-tanker certification.

The pilot fee for a typical Inner Route transit between Cairns and Cape York averages AUD 18,000 in 2024 to 2025 dollars, with the Hydrographers Passage and Torres Strait segments adding further fees on a per-transit basis. The fee is largely fixed regardless of vessel size since it reflects the pilot’s time on board (typically 36 to 48 hours for an Inner Route transit) plus transport, accommodation and the AMSA administrative levy.

The route-divergence cost is the additional steaming time that results from the obligation to follow the two-way “Reef” route rather than the rhumb-line track that would be optimal for a vessel proceeding from a Queensland port to the Indian Ocean. For a typical Inner Route transit the additional steaming time is approximately 12 hours, equivalent to a fuel-cost increment of about AUD 12,000 to AUD 18,000 at 2024 to 2025 bunker prices for a Capesize bulk carrier.

The chemical-tanker certification cost is the requirement under the IBC Code and MEPC.221(63) for an enhanced Certificate of Fitness covering carriage of MARPOL Annex II Categories X and Y noxious liquid substances. The certificate is issued by the flag state administration or by a recognised classification society at the time of survey, and the marginal cost of compliance is generally bundled into the IBC Code certification cycle.

The total commercial impact for a typical chemical-tanker through-transit of the GBR PSSA is estimated at AUD 30,000 to AUD 45,000 per transit, equivalent to about USD 0.40 to USD 0.60 per tonne of cargo for a Handy-size product carrier. The impact is small in relation to the value of the cargo and to the value-at-risk in the event of a casualty, and is universally accepted by industry as a reasonable cost of operating in the area. The 2024 contingency arrangements for bunker C, heavy fuel oil and intermediate fuel oils carried as cargo, sometimes informally referenced as the “Sea Empress” arrangements after the 1996 UK casualty that prompted the original international debate, comprise enhanced SOPEP equivalents, mandatory fully-laden tug-escort within Hydrographers Passage and the southern entrance of the Torres Strait, and pre-arrival notification to AMSA at least 96 hours before entry to the REEFREP area.

Formula, assumptions, and limits

Formula

The total commercial cost of a single PSSA transit can be approximated as:

where $F_{\text{pilot}}$ is the pilot fee per transit, $T_{\text{div}}$ is the additional steaming time in hours, $F_{\text{bunker}}$ is the bunker fuel price per tonne, $Q_{\text{fuel}}$ is the hourly fuel consumption in tonnes per hour, $L_{\text{levy}}$ is the AMSA administrative levy and Protection of the Sea Levy contribution per transit, and $C_{\text{cert}}$ is the amortised cost of any GBR-specific certification.

Derivation

The four cost components capture the principal direct economic impacts of the GBR PSSA. The pilot fee is set under the AMSA Coastal Pilotage Standards and the licensed-pilotage-company tariffs. The route-divergence steaming time is derived from the geometric difference between the rhumb-line track and the two-way route, computed for a typical transit of 470 nm at typical service speeds of 13 to 15 knots. The AMSA levies are gazetted annually under the Marine Navigation Levy Regulations 2012 and the Protection of the Sea (Shipping Levy) Act 1981. The certification cost is amortised over the IBC Code or BCH Code certification cycle for chemical tankers.

Assumptions

The cost model assumes a vessel of standard service speed (13 to 15 knots), a single one-way transit between Cairns and Cape York or equivalent, and 2024 to 2025 bunker prices in the range USD 600 to USD 700 per tonne of VLSFO. It assumes the vessel is fitted with all standard navigation equipment including a working ECDIS, AIS, GMDSS, and operational SOPEP and shipboard marine pollution emergency planning documentation. It assumes the vessel is fully classed with a recognised classification society and holds all standard MARPOL and SOLAS certificates.

Worked example

Consider a 75,000 dwt Panamax bulk carrier loading coal at Hay Point and bound for Yokohama through the Torres Strait. The pilot fee for the Hydrographers Passage and Inner Route segments combined is AUD 22,000. The route-divergence steaming time is approximately 14 hours. The hourly fuel consumption at service speed is approximately 1.6 tonnes per hour, and the bunker price is USD 650 per tonne (AUD 980 per tonne at 0.66 AUD per USD). The fuel-cost increment is therefore $14 \times 1.6 \times 980 = 21{,}952$ AUD, rounded to AUD 22,000. The AMSA levy is approximately AUD 2,000 per transit. The total commercial impact is approximately AUD 46,000 per transit. For a cargo of 75,000 tonnes the unit impact is approximately AUD 0.61 per tonne or USD 0.40 per tonne.

Edge cases and limits

The cost model breaks down for vessels that elect to bypass the GBR PSSA entirely by routing south of Tasmania. The bypass distance is approximately 1,500 nm additional, equivalent to about 5 days additional steaming and AUD 200,000 in fuel for a Capesize. The bypass is therefore economically unattractive except in special cases where the vessel is denied entry to the PSSA on safety or environmental grounds.

The model also breaks down for very small vessels below the 70 m threshold for compulsory pilotage. These vessels pay no pilot fee but are still subject to REEFREP reporting if they exceed 50 m, to the routeing measures under SOLAS V/10, and to the Annex IV/V Special Area discharge restrictions. Their commercial impact is dominated by the routing rather than the pilotage costs.

The model assumes normal weather and traffic conditions. In tropical-cyclone season (November to April) the pilot fee is increased by an extreme-weather surcharge of up to 50% in cases of forced delay, and the route-divergence steaming time can be doubled. The 2024 contingency arrangements add a tug-escort cost of approximately AUD 60,000 per transit for laden bunker C carriers and similar carriers of persistent oils.

Regulatory basis

The regulatory basis for the GBR PSSA APMs is set out in the following instruments. IMO Resolution A.982(24) establishes the PSSA Guidelines. Resolution MEPC.44(30) and MEPC.133(53) designate the GBR and the Torres Strait extension. Resolution MSC.52(66) establishes REEFREP under SOLAS V/11. Resolution MEPC.221(63) extends protection for chemical-tanker through-routing. The Australian Navigation Act 2012 and the Protection of the Sea (Prevention of Pollution from Ships) Act 1983 implement the regime in Australian law. The Great Barrier Reef Marine Park Act 1975 provides the environmental management framework for GBRMPA. The Torres Strait Treaty 1978 provides the bilateral framework with PNG.

Common errors

Common errors in operational interpretation of the GBR PSSA include treating the compulsory pilotage threshold as 50 m rather than 70 m for length-only categories, omitting the loaded-tanker any-length exception, failing to make the 12-hour position reports to REEFREP, departing from the two-way route in non-emergency circumstances, treating the Annex V Special Area food-waste 12 nm requirement as applying only to non-comminuted food waste rather than to all food waste discharged at sea, and failing to recognise that REEFREP is mandatory under SOLAS V/11 for all vessels in the area regardless of port of call. AMSA publishes regular guidance on these points through its Marine Notices.

See also

• MARPOL Convention
• MARPOL Annex I oil pollution prevention
• Regulation 37 SOPEP
• MARPOL Annex III harmful substances in packaged form
• MARPOL Annex IV sewage
• MARPOL Annex V garbage
• MARPOL Annex VI air pollution
• Calculator catalogue

References

1. International Maritime Organization, Resolution A.982(24), Revised Guidelines for the Identification and Designation of Particularly Sensitive Sea Areas, adopted 1 December 2005.
2. International Maritime Organization, Resolution MEPC.44(30), Identification of the Great Barrier Reef as a Particularly Sensitive Area, adopted 16 November 1990.
3. International Maritime Organization, Resolution MEPC.133(53), Designation of the Torres Strait as an Extension of the Great Barrier Reef Particularly Sensitive Sea Area, adopted 22 July 2005.
4. International Maritime Organization, Resolution MEPC.221(63), Designation of Certain Areas of the Great Barrier Reef Particularly Sensitive Sea Area, adopted 2 March 2012.
5. International Maritime Organization, Resolution MSC.52(66), Mandatory Ship Reporting Systems, adopted 30 May 1996.
6. International Maritime Organization, Resolution MSC.171(79), Amendments to Existing Mandatory Ship Reporting Systems, adopted 9 December 2004.
7. Australian Maritime Safety Authority, Coastal Pilotage Standards, latest revision.
8. Australian Maritime Safety Authority, Marine Notices on REEFREP and GBR PSSA compliance.
9. Great Barrier Reef Marine Park Authority, Zoning Plan 2003 and Reef 2050 Long-Term Sustainability Plan.
10. Australian Transport Safety Bureau, Independent Investigation into the Grounding of the Bulk Carrier Shen Neng 1, Report MO-2010-003.
11. UNESCO World Heritage Centre, Great Barrier Reef property file 154.
12. Torres Strait Treaty between Australia and Papua New Guinea, 18 December 1978.

Related calculators

• Great Circle vs Rhumb - Distance Comparison
• Great-Circle Vertex
• LNG Tank - Secondary Barrier Requirement
• Coating - LNG Tank Secondary Barrier
• GMDSS - Sea Area Coverage Check
• SOLAS IV/9 - Sea area A2
• SOLAS IV/8 - Sea area A1
• SOLAS IV/11 - Sea area A4

Related formulas

• Great Circle vs Rhumb - Distance Comparison
• Great-Circle Vertex
• LNG Tank - Secondary Barrier Requirement
• Coating - LNG Tank Secondary Barrier
• GMDSS - Sea Area Coverage Check
• SOLAS IV/9 - Sea area A2
• SOLAS IV/8 - Sea area A1
• SOLAS IV/11 - Sea area A4
• Great-Circle Distance (Haversine)