THE nation's independent heritage body has warned the Abbott Government the strategic assessment of the Great Barrier Reef could fail to prevent further decline of the reef, without major changes.

In a submission to the reef strategic assessment, the Australian Heritage Council has raised serious doubts the concerns of the World Heritage Committee were "capable of being met" under present management.

"Our significant concern is that while the assessment shows the serious decline in many attributes, the program does not provide assurance that these concerns will be reversed," the submission reads.

Council chairwoman, Professor Carmen Lawrence, said while the "basic structure" of the strategic assessment was good, it had not outlined enough action to prevent continued decline of the reef.

She told APN Newsdesk that the efforts outlined to address the problems the reef faced was "simply not commensurate with the size of the problem".

The council's submission casts doubt on the government's claims last year that the assessment would result in a "halt and reverse" of the decline of the reef, and whether a "net benefit policy" can actually be achieved.

Prof Lawrence said one of the key problems was the "lack of clarity" outlined in the assessment on when action should actually be taken.

"Even if you're monitoring the decline of the reef, what determines when you act?" she said.

"It hasn't really looked at integrating that monitoring to ensure a response is taken when the deterioration gets to a certain point.

"In particular, there is a large failure in the assessment to really examine the cumulative impacts of one development after another."

Prof Lawrence's comments follow the government's recent approvals of the Abbot Point dredging project, Clive Palmer's Waratah Coal mine, Gina Rinehart's Kevin's Corner project and a fourth LNG facility on Curtis Island - all of which could threaten the World Heritage-listing of the reef.

While the council acknowledged the roles of climate change, crown of thorns starfish and sediment run-off among other issues, it said "additional concerns were raised about the "effects of dredge spoil disposal within the reef".

"It is noted that the assessment report identifies incomplete modelling of dispersal of sea-dumped dredged material that has probably led to an underestimate of the extent and duration of such impacts," the submission reads.

"This further strengthens concern about these coastal and inshore developments.

"The fact that inshore reefs in the southern section of the Great Barrier Reef are in very poor condition adds to the concern."

Prof Lawrence said the damage also caused to the southern part of the reef "should give instruction - the same sorts of problems will be repeated in undeveloped areas".

"The lack of key criteria to say when things have gone too far, and when to back off from approving more developments is critical," she said.

The council also warned that the "record of declining condition" of the reef raised doubts that the World Heritage Committee's concerns could be met without "a change to the present management".

Prof Lawrence said changes needed included better resources and management practices across the board, with not enough staff and resources available to meet the challenge.

"I don't think they do have enough staff, I think they're overwhelmed by the scale of the problem here," she said.

"You can't expect the best outcome when the people doing the work don't have the necessary resources to do it."

The government reported to UNESCO on its latest actions to protect the reef earlier this month.

Releasing the report, Mr Hunt said at the time the reef's outstanding universal value remained "largely intact" and the report showed "substantial progress and commitment" responding to UNESCO concerns.

The World Heritage Committee will decide in June whether the Commonwealth's action to date will prevent the reef being placed on a World Heritage Sites "in danger" list.