The Marine Reserves Bill is currently under consideration. We are also awaiting the release of the Government's Marine Protected Areas Strategy. The policy and legislative framework for such a large reserve appears muddled and confused.

The size and location of the proposed reserve will undoubtedly adversely affect the existing use by our members. For 19 years there has been an annual Grumpys Game Fish tournament based in Port Fitzroy with   a second introduced over the last 12 years called the Fitzroy one base. This attracts visitors and supports the fragile Barrier economy. The area proposed for the reserve is fished by our members trolling lures on the surface, in water depths between 80 and 150 metres, from late December through April. Many of these vessels would have been out of sight of your land based observations reported in the application document.

This proposal unreasonably excluded our members who troll on the surface and have no affect whatever on the benthic environment, or any species resident in the reserve. Method restrictions under the Fisheries Act would be quite adequate for the protection of all the species and ecosystems the department lists in the application.

The application contains no justification for closing this area to sport fishing vessels targeting highly migratory marlin and tuna by surface trolling. The applicant has made no assessment of the adverse impact of closing an area this size will have on fishers targeting marlin and tuna.

The purpose for creating a marine reserve under the 1971 Act is preserving an area for scientific study.

The justification for a reserve of this size on scientific grounds is extremely frail. The "science" is purely speculative, and the proposal document is misleading and contradictory. The depth of water in most of the proposed area excludes most non destructive sampling methods and those that are available are extraordinarily expensive (ROV, submarine).

Will DOC be funding scientific research in the area if a reserve is established? What is the likely annual budget?

The applicant claims " the proposed marine reserve would completely protect a range of both distinctive and typical marine habitats and species assemblages " (Page 33) when in effect all it does is stop people fishing there. This is totally misleading. It should be the applicants duty to provide adequate and unbiased information, especially when the applicant is also the advisor to the Minister and the recipient of considerable public funding. This statement implies that fishing is the only threat to the marine habitats in the area.   Much larger threats from invasive species, toxic algal blooms or pollution from a major shipping accident will not be reduced by marine reserve status.   

The supposed "benefits" of the reserve are highly contentious.

•  How will it help safeguard against environmental degradation?

•  How will it restore kelp forests?

•  How will it increase the range of fish types? Rare species will still be rare. Which "vulnerable" species will flourish, and by what are they threatened?

•  How will it act as a breeding area and boost populations outside the reserve?

•  Many fish in marine reserves do not exhibit natural behavior in the presence of divers.

Most of the species for which our members fish are currently managed by one of the best fisheries management systems in the world; one that has achieved international recognition. Our organization has invested considerable effort in participating in this system. We strongly disagree with the continual statements from DoC to the effect that existing management frameworks are inadequate, thus justifying the use of marine reserves as management tools. Marine reserves are not fisheries management tools and should not be promoted as such, either by direct statement or implication, in order to sway public opinion.

The entire marine environment in territorial waters is already managed to some degree. Whereby fisheries legislation (QMS, method restriction); transport legislation (shipping lanes, cable zones); defense legislation (defense areas), mining legislation etc. Very large applications such as this do not integrate well with existing rights and management.

The size and location of the proposed reserve means that is will be unenforceable. Most of it will be out of sight of land, and DoC has no resources to patrol such an area.

We will make further submissions in the event that the Department of Conservation decides to proceed with this application and seeks concurrence from the Minister of Fisheries.