DoC’s
Answers to Questions raised by option4
22 December 2003
option4 comment - The list
of questions that follow were produced by option4 to determine the
level of understanding and support for issues regarding marine reserves.
These questions were directed at members of the public who were
concerned enough to submit to the proposal put forward by DoC. option4
considered the process surrounding the Great Barrier Island proposal
to be inadequate so we commissioned our own study.
The inadequacy of the process is further proven by the actions of
DoC to publish an update on the marine reserve proposal on their
website (22 December 2003) and fail to notify those who had already
confirmed their interest in receiving email notification of any
new developments. The update was referred to in the DoC newsletter
emailed to the general DoC subscription list 38 days later. Not
all of those on the Barrrier email list were included in the newsletter
notification.
DoC’s original questionnaire consisted of eight questions,
we asked an additional 13 questions as copied below. In this document
DoC aims to dispel option4's misgivings, but fails. We have the
following to say in response to their comments.
Key: black text = DoC comment;
blue text = option4 comment
option4 provided a questionnaire about the GBI marine reserve proposal
on its website. About one-third of the comments that the Department
of Conservation (DOC) received on the proposal were on the option4
questionnaire.
In addition to the fields provided by DOC on its questionnaire,
the option4 form contained a number of additional questions formulated
by that group. The questions are listed below, with a response from
DOC.
It
was necessary for option4 to add more questions to DoC's form because
DoC's questions were loaded to solicit a favourable response. For
instance, rather than asking 'Do you support this
proposal?', DoC's question was vague: 'Do you support the principle
of a marine reserve somewhere on the north-east
coast of Great Barrier?'. A YES answer was then interpreted as support
for the proposal. Such misrepresentation has offended many.
1. Do you believe that a co-ordinated approach to marine
protection is required before this marine reserve proposal (if it
receives support from the public) goes forward as an application?
Government policy, as outlined in the New Zealand Biodiversity Strategy
2000, supports a strategy for establishing a network of areas that
protect marine biodiversity. Auckland Conservancy is currently working
on a strategy which aims to identify a network of areas that protect
marine biodiversity in the Hauraki Gulf. It is envisaged that key
stakeholders and the wider community will have input into the decision-making
processes for this strategy.
Instead
of giving good reasons, time and again DoC hides behind the Biodiversity
Strategy 2000, ignoring the fact that option4 and others seriously
question the validity of this strategy. Furthermore notice the word
currently. If it weren't for the constant pressure from
option4, DoC would still not be looking at an integrated strategy,
creating marine reserves here and there in a fragmented, piece-meal
manner. But even so, a truly integrated approach looks at the entire
situation from a wide angle, taking into account existing conservation
measures such as trawler bans, de-facto marine reserves and locally
managed marine parks. The tragedy of DoC is that it has no mandate
to consider such options. Instead it wields its one and only blunt
tool: complete and permanent closure.
However, such an approach may take some time. For example, a strategic
approach to marine protection that was undertaken in Victoria, Australia
took over ten years to complete and implement. In the absence of
a strategic approach, DOC must continue to follow government policy
and work towards the target of protecting ten percent of New Zealand’s
marine environment by 2010.
Again
reference to the Biodiversity Strategy, for better or for worse.
The point is that there exists no compelling reason for haste. Why
do it wrong now when we can do it right tomorrow? Why, we may ask,
did DoC not follow Victoria's example ten years ago? Furthermore,
the Marine Reserves Act spells out very clearly that marine reserves
are for scientific study, not for protecting biodiversity.
The proposed GBI marine reserve contains habitats not currently
represented in marine protected areas in New Zealand. It is therefore
likely that the north-east coast of GBI would fit into a network
of marine protected areas in the Hauraki Gulf.
Is
the certainty of likely good enough to cast a mistake in
concrete? Please notice how the network idea has reached
magical proportions, whereas no research to date has shown that
it has real value. Much ado is also made of a tiny estuary inside
the proposed marine reserve, which is too small to function ecologically
as one or to have a measurable influence on the surrounding area.
Mention is also made of deep reef areas which could be protected
by a simple trawler ban.
2. Are you concerned that DOC has no intention of arranging
public meetings in Auckland to consult with public?
DOC arranged a number of meetings about the Great Barrier Island
marine reserve proposal, including two public meetings held in Devonport
on 9 July 2003 and Auckland Central on 15 July 2003.
Pressured
by option4, DoC decided to hold two 'Drop-In' meetings that people
could attend. The fact remains that no public meetings were held
to help the vast majority of users of the proposed area, boaties
and fishermen, to vent their concerns.
Here is a barrister's personal experience of one of the Drop-In
meetings:
"I attended one of DOC's drop in meetings at the Marine Rescue
Centre last year. I asked whether it would be possible to
create a reserve but allow recreational fishing on a limited basis.
Their answer was no. I asked whether DOC had studied the impact
of recreational fishing on the proposed reserve area. Their
answer was no because it is not important. I then asked if
the impact of recreational fishing is not important then why ban
it. Their answer was they wanted to return the area to the
way it was before people arrived. I asked them what way was
that? Their answer was they need to put the reserve in place
to return it back to the way it was. I then suggested that
allowing some recreational fishing would not prevent them from achieving
that objective. They disagreed."
Do you think that opt-in meetings as held by DoC are acceptable
forms of consultation?
3. Have DOC advertised the process and distributed brochures
to your satisfaction? Is their process adequate?
Most marine reserve proposals involve both pre-statutory consultation
(occurs before a formal application is made) and statutory consultation
(occurs after a formal application has been made).
Pre-statutory consultation, including the production and release
of a discussion document or similar and seeking comments on it,
is not required under the Marine Reserves Act 1971. There is no
process specified under that Act for pre-statutory consultation.
However, experience has demonstrated that the pre-statutory consultation
assists in deciding whether to proceed with a statutory marine reserve
application and if so, what form the proposal might take. The pre-statutory
consultation stage does not represent a formal application, which
may or may not come at a later stage.
True.
The MRA71 does not spell out preconsultation, however, DoC's own
manual does. Note very carefully the words whether to proceed,
since the flowchart in DoC’s manual clearly states, to abandon
the project in the face of overwhelming adverse public reaction.
Yet DoC keeps pushing on, where it should have backed off indefinitely.
Game over! Continuing on, despite the adverse response to their
proposal amounts to harassment.
Statutory consultation occurs after a formal marine reserve application
has been notified under the Marine Reserves Act 1971. The notification
of a marine reserve application and consultation must follow the
requirements of the section 5 of the Act.
DOC is currently undertaking pre-statutory consultation about the
Great Barrier Island marine reserve proposal. A proposal document,
“A Marine Reserve for Great Barrier Island? – Your chance
to have a say, and questionnaire was released in March 2003.
Approximately 4,500 proposal documents and questionnaires were distributed
to 180 organisations, groups and clubs and approximately 600 individuals.
In addition, 6,500 copies were provided for distribution in the
NZ Professional Skipper and New Horizons magazines.
Pressured
by an unrealistic deadline, option4 created an electronic submission
form which was highly appreciated. It also duplicated the proposal
document on its website. Many of the documents were distributed
at personal cost to those interested, the Great Barrier Island Marine
Action Group distributed over 800 submissions alone.
Information about the proposal was also available on the department’s
website, at the department’s offices in Auckland, Warkworth
and GBI and its Auckland Visitors Centre. Articles appeared in a
number of newspapers and magazines, including the NZ Herald, regional
Auckland papers, Dominion-Post, Barrier Bulletin, Dive NZ, and Boating
NZ. Items also appeared on the following television programmes:
Breakfast, TV One News and TV 3 News.
Unfortunately,
the version of the proposal on DoC's website was Internet-unfriendly,
making documents hard to find while requiring unacceptably long
download times. The point is that we hope DoC has learnt a lesson,
and that good consultation is precisely what it says. It also means
listening. This includes consulting with people who use the area
as well as those who live there.
4. What is so unique that it/they require the complete protection
of a no take marine reserve in perpetuity?
The Marine Reserves Act 1971 does not specify that an area must
be unique to qualify for protection under a marine reserve.
Section 3 of the Marine Reserves Act states that the purpose of
the act is to preserve, as marine reserves for the scientific study
of marine life, areas of New Zealand that contain underwater scenery,
natural features or marine life, of such distinctive quality, or
so typical, or beautiful, or unique, that their continued preservation
is in the national interest.
There
is indeed an anomaly in this part of the MRA, because the words
unique and typical are mutually exclusive, and
taken together, unique or typical means any.
Some of the marine habitats on the north-east coast of Great Barrier,
such as the deep reefs which contain rare black coral and unusual
sponges, are both beautiful and distinctive. The Whangapoua Estuary
is distinctive because it is one of the most undisturbed and unmodified
estuaries in northern New Zealand. Habitats such as the inshore
and offshore sediment areas on the north-east coast of Great Barrier
Island are typical.
It
is sad that marine scientists employed or contracted by DoC have
not been able to recognise the massive environmental degradation
that has occurred in the designated area, and this despite their
many surveys. Even their remotely controlled camera survey of the
deep reefs, while showing black coral, sponges and other sessile
filterfeeders, also clearly showed how much these were affected
by sediment, bearing all the symptoms of serious degradation. It
no longer makes sense to protect such depleted habitats by area
closure since this does not take the threat of degradation away.
Only by saving the land can we save the sea!
Most marine reserves are usually established in perpetuity. Studies
at Leigh Marine Reserve, which is New Zealand’s oldest, have
shown continuing recovery towards the natural state even 25 years
after the marine reserve’s establishment. The benefits of
the reserve increase over time so there is little point in squandering
the benefits by opening the area to fishing.
The
reality is that even the Leigh Marine Reserve is degrading precipitously,
many species are absent, while researchers have done no evaluation
of this at all. In 1998 the crayfish fled from mud entering the
reserve. This reserve is not at all continuing recovery to the natural
state! We wonder why DoC keeps using this argument. Are they really
THAT blind?
5. Why have de-facto marine reserves not been studied or
proposed as marine reserves?
Note: this question has been answered on the assumption that the
term “de-facto marine reserve” refers to areas around
New Zealand that are closed to fishing and/or anchoring such as
cable protection zones. Correct
Approximately 165,000 hectares (0.03% of New Zealand’s Exclusive
Economic Zone) is made up of cable/pipeline areas that are closed
to fishing. Cable protection zones are not established for protecting
marine biodiversity, but may have the effect of doing so. If enforced
properly, cable protection zones can prevent most activity occurring
that may threaten biodiversity values, except for cable laying and
maintenance.
All
cable protection zones are located in the territorial seas around
NZ, an area 11x the size of all mainland marine reserves together
which amount to a mere 15,000ha! Add to this an almost equal area
in ammunition dumps, and the de-facto protected area becomes 20x.
It is false to relate this area to the total EEZ, which covers 430Mha,
as opposed to that of the territorial sea of 16Mha. Thus the de-facto
reserves make up a total of 2% of the territorial sea. More to the
point, these are areas that have enjoyed continuous protection for
over 40 years! Surely one wishes to promote these before all others?
Why is DoC not doing this? Why have they not been studied in the
past?
DOC has contracted the University of Auckland to undertake some
research to increase the understanding of what conservation outcomes
may accrue from areas with partial protection or other areas where
fishing is prohibited.
Our
persistence has had some result! It is sad that our prodding was
necessary before scientists condescended to look.
Areas that will be studied are Taranaki’s Nga Motu/Sugar Loaf
Islands Marine Protected Area and the Hauraki Gulf Cable Protection
Zone in Auckland. NIWA has conducted research on the effects on
the benthos (flora and fauna of the sea bottom) of the closed trawling
and dredging areas in the Hauraki Gulf.
There is no reason why some cable protection areas cannot be proposed
as marine reserves. However, they may already effectively protect
marine biodiversity.
The
point that fishermen make is that these areas should be counted
as such and included in the overarching strategic approach. Their
position is firmly: look at the whole and let us be part of all
decisions, before these are sprung upon us.
6. Why is fishing the ONLY threat?
Fishing is not the only threat. New Zealand’s marine environment
faces a number of other threats, including: sediment and nutrient
runoff, land and sea-based pollution, introduced marine pests, coastal
development etc.
However, fishing does have a major impact on the marine environment:
Fishing increases mortality and affects age distribution, age and
size at maturity, growth rates and other life history characteristics;
But
there is no conclusive evidence that this is harmful to biodiversity.
One beautiful aspect of biodiversity and evolution is that the environment
adapts. It adapts to being fished. Is this a bad thing? Should fishing
stop, it adapts back to the unfished situation. The natural environment
is flexible.
Fishing affects species composition in fished areas and therefore
changes the interactions among fished species and their prey;
True,
but this is only very minor compared to what we have done on land
where habitats were changed drastically and permanently (by burning),
and many species became extinct, particularly the large ones. Remember
that possums don't eat kelp!
Long-term fishing can lead to dominance by species with certain
life history characteristics such as early maturation; and
Fishing techniques such as bottom trawling and dredging can alter
marine habitats, therefore affecting the diversity of marine habitats
and the function of ecosystems.
True,
but everything is relative. Stop fishing for five years and the
environment rebounds to almost natural conditions. So the effect
of fishing is neither large, nor irreversible. However, long-term
degradation has much worse effects, causing changes that are not
easily reversible, while also negatively affecting fish stocks and
biodiversity.
The increasing pressure on New Zealand shores from fishing and collecting
has led to reduction in target species of shellfish and fish, the
loss or modification of habitats, major reductions of biomass and
changes in population structure including loss of large old individuals,
and the disturbance of food chains.
True,
but recovery is fast, unlike that of native forests that were burnt,
then farmed.
7. What scientific study can be undertaken in a marine reserve
that cannot be undertaken whilst fishing continues?
Marine reserves provide an opportunity to study natural, undisturbed
marine ecosystems. Scientific study looking at things like the size,
abundance and behaviour of fish with the impact of fishing removed
is undertaken in some of New Zealand’s marine reserves and
this research can obviously not take place whilst fishing continues.
Sadly,
this research is politically motivated to prove that marine
reserves work. It has been counter-productive, now that scientists
themselves are admitting that research into the effects of marine
reserves has been hopelessly inadequate. We concur. Study degradation
instead! Only by saving the land can we save the sea!
Scientific study in marine reserves contributes to knowledge of
natural and/or recovered marine ecosystems. For example, study in
marine reserves can:
Notice
the word can rather than will or have
Provide information on predator/prey relationships, interactions
between species, species recovery and ecosystems;
In
theory YES, but in practice this research is compounded by land-based
degradation.
Provide control sites for research and ecological benchmarks against
which to measure changes; and
Help us understand more natural systems where natural mortality
can be compared to fishing mortality.
Despite
the availability of 27 years of marine reserves and 50 years of
de-facto reserves, no studies have been done. Natural systems can
no longer be found along mainland's coasts. Degradation from land-based
pollution causes massive mortalities, including those from poisonous
plankton blooms. No comparative research has been done.
Specifically, study in marine reserves has shown us that:
Snapper and rock lobster are more abundant and larger inside the
Leigh Marine Reserve than outside (Source: Babcock et al, 1999);
Debunked.
Rocklobster walked out after large mud storms in winter 1998. Their
abundance dropped 85%!! The snapper occur in a snapper hotspot and
no comparable abundance has been found in any other marine reserve
here or elsewhere in the world. They have been counted using the
unscientific Baited Underwater Camera, which fails scientific principles.
Blue cod are larger inside the Long Island-Kokomohua Marine Reserve
than outside (Source: Davidson 2001); and
After
years of being protected, the blue cod are slightly larger and slightly
more abundant. This could have been achieved by other methods. Lately
they have been found to be declining.
Spill over of rock lobster around Leigh marine reserve and tagged
lobster made extended excursions to offshore sand-flats outside
the reserve (Source: Kelly, Scott, & MacDiarmid, 2002. The value
of spill over fishery for spiny lobsters around a marine reserve
in northern NZ. Coastal Management, 30:153-66 and Kelly, 1999. Marine
reserves & the spiny lobster, Jasus edwardsii. Unpublished PhD
thesis, University of Auckland, Auckland).
It
has also been shown that this did not affect the lobster fishery
nearby. The difference between fishing the line and fishing
outside is not detectable. But protection for scientific research
has protected the tagged rocklobsters.
Please note that for all the above studies, the areas outside the
reserves were of equal importance. Ideally, marine reserves should
allow us to study the natural situation but in practice, they have
been rather disappointing.
8. How does DOC intend to address displaced fishing effort
and the consequential decline in fishing success in the remaining
fishing grounds?
Effort displacement will be partially addressed by locating any
new marine reserves in sites so the impact on existing patterns
of use will be as little as possible.
If New Zealand achieves the ten percent marine protected area target
that has been set by the Government in the NZ Biodiversity Strategy
2000, there will still be 90 percent of New Zealand’s marine
environment available for fishing.
The
most important question, will these marine reserves work and
deliver on their expectations, has not been addressed. We have
16-17 coastal marine reserves and nearly all are degrading badly.
No evaluation has been done as to their efficacy and whether they
get better over time than worse and whether they do protect biodiversity.
We have no proof that coastal marine reserves are working, but we
have observational evidence that they are NOT. Yet DoC refuses to
evaluate all existing ones. Why should we repeat past mistakes?
Why should we steal the right of others for no benefit in return?
Why should we invoke real costs of over $100M annually and 500 people
on the dole, for no measurable benefit in return?
9. How do marine reserves contribute to improved fishing
success? Where is the evidence of those benefits?
The purpose of marine reserves is not fisheries management, or to
improve fishing success (see purpose of Marine Reserves Act 1971
in answer to question 4).
True.
Neither is it for protecting biodiversity.
Research shows that inside marine reserves species such as snapper
and rock lobster are present in greater numbers and are larger.
However, there is no conclusive evidence that shows marine reserves
contribute to improved fishing success outside reserves.
It is possible that there are benefits that accrue to fishing and
fisheries industries from marine reserves but these have yet to
be demonstrated conclusively. However, what we do know is:
Marine organisms move in and out of marine reserve areas freely,
thus potentially providing benefits to surrounding fished areas;
This
argument has officially been laid to rest. Resident species do not
move freely and migrant ones move into and through and out of protected
areas, which are of no consequence to them.
Spiny lobster were monitored in several marine reserves and it was
noted that for each year of protection there were increases of up
to nine percent egg production; and
Again
very naughty use of statistics. In the Leigh marine reserve, after
the massive crayfish walkout, there remained a puny 1.6x, which
equates to an increase of 60% in 27 years or 0.2% per year. Other
reserves do not fare much better, except for the first two years
after establishment after which populations level out, although
more crays become larger, which adds to egg production.
At Leigh Marine Reserve research has shown that CPUE (Catch Per
Unit Effort – yield and costs) for lobsters are just the same
adjacent to the marine reserve area as in nearby open fished areas.
This
proves that crayfish do not spill out. Fishing the line is of no
additional benefit, but scientists always forget to account for
the lost fishery inside the reserve. The total fishery benefit of
reserves is always negative (-90 to -100%).
Marine reserves provide supporting knowledge for the sustainable
management of fisheries.
After
27 years, no such research has been done here, and very little if
any overseas either.
10. What are the fisheries benefits that arise from the
declaration of a marine reserve? Where is the evidence of those
benefits?
See answer to question 9.
11. What cost/benefit analysis has been done to uphold the
claims of economic benefits from tourism etc?
The following research has been undertaken to determine the socio-economic
implications of establishing marine reserves including:
Cocklin, Chris and Flood, Sharon. 1992. The socio-economic implications
of establishing marine reserves. This report that was prepared for
Department of Conservation showed that cash injected into the local
economy by visitors to the Hahei marine reserve supplemented the
livelihood of local businesses.
In 1995, a survey by Wolfenden, Cram and Kirkwood of community reactions
to marine reserves was undertaken in four communities (Hahei, Cooks
Beach, Thompson Point and Onetangi Bay on Waiheke Island). Beliefs,
attitudes and knowledge regarding marine reserves were explored.
What
benefits were ascertained?
Risely, W. 2002. Impact, knowledge, opinion and usage: a ten year
assessment of Te Whanganui-A-Hei Marine Reserve.
What
costs and benefits have been measured?
Taylor, Nick and Buckenham, Brigid. 2003. Social impacts of marine
reserves in New Zealand. Science for Conservation 217. 58p.
The Rodney Economic Development Trust (NB – the trust is funded
by the Rodney District Council) undertook a study that showed the
Leigh marine reserve contributed $12.5 million per annum to the
Rodney district.
Auckland Conservancy undertakes visitor surveys of Leigh marine
reserve. The questions that are asked include: the activities visitors
undertook, visitor enjoyment/satisfaction of their visit, whether
visitors understood the rules of marine reserves, age and nationality
details, and how much money visitors spent on their visit (including
petrol, food, equipment hire etc).
Where
are these results?
DOC is currently undertaking a social science research project to
investigate what some communities think about the creation of a
marine reserve prior to its gazettal and how they viewed its establishment
after. The project will also examine any other benefits (aside from
biodiversity) that arise through the creation of a marine reserve
(i.e. economic benefits).
When
will DoC examine the actual biodiversity 'benefits'?
12. Where else in NZ other than Leigh do marine reserves
foster an eco-tourism economy?
The Marine Reserves Act 1971 does not require marine reserves to
be established to provide for eco-tourism. The Act states that the
public are to have right of entry into marine reserves and some
of New Zealand’s marine reserves attract people and, as a
result, eco-tourism operators have established (eg, Poor Knights
Islands Marine Reserve, Leigh Marine Reserve, Hahei Marine Reserve).
Eco-tourism
can be expected in those reserves that have clear water (diving,
glassbottom boat) and are easily accessible (schools). Very few
of our reserves satisfy these criteria.
13. Are the Leigh and Poor Knights examples supported by
any proper analysis, and how widely spread are the eco-tourism benefits
in Leigh and Tutukaka?
Please see answer to question 11.
Learn
More
For
a more thorough dissection of these responses go to https://www.seafriends.org.nz/issues/cons/myths8.htm
To
learn more about marine protection and the potential of marine reserves
in the right place for the right reasons go to https://www.seafriends.org.nz
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