| |
Marine
Protected Areas Policy Submission
NZ
Big Game Fishing Council
28
February 2005
|
|
Dear Sir
Please accept this submission
from the New Zealand Big Game Fishing Council on the marine protected
areas - policy statement, principles and implementation.
Introduction
The NZBGFC represents more
than 33,000 current financial members from 60 clubs spread throughout
New Zealand. The NZBGFC has long been active in the conservation
and sustainable management of the species for which its members
fish, as well as with the conservation of important food species
for those fish. In recent years the NZBGFC has been very actively
involved with fisheries management processes in New Zealand, making
detailed submissions, attending numerous meetings with industry
and Government agencies, as well as international forums. We are
well informed on fisheries management, research and conservation
issues.
Our policy on marine reserves,
as previously stated, is that marine reserve status is only justified
where an area has been clearly identified as being so special or
unique that its preservation is clearly in the national interest.
For some time now NZBGFC
and other marine stakeholders have been asking for an integrated
and coordinated approach to the selection of marine reserve areas
and recognition of other types of area closure that prohibit fishing.
We have also supported the use of fisheries regulations as better
tools than marine reserves to provide additional protection where
necessary in some areas.
A
coordinated approach
What we would like to see
is the government agencies (DOC, MFish, MFE) and stakeholders pooling
their experience and resources into a single process for discussing
the location and level of protection required for particular marine
habitats. The objectives and principles should reflect the need
for a cooperative and balanced approach with stakeholders whose
rights are being affected and take account of the complexity and
lack of fixed boundaries in many ecosystems.
Recently we have seen a narrow focus
of Government agencies and the tendency towards impatience with,
and intolerance of, the priorities and perspectives of marine stakeholders.
The ad hoc scatter gun approach to marine reserve proposals and
applications has divided communities and brought into question some
of the tactics used by applicants. This should not continue.
Definition
of Marine Protected Area
The discussion document proposes
that the purpose of this policy, an MPA is defined as:
"an area of the
marine environment especially dedicated to or achieving the protection
and maintenance of biological diversity at the marine community,
habitat and ecosystem level".
It is our view that marine
ecosystems are usually very large. In the sea, habitats are rarely
precisely or critically restricted. Many free-swimming species have
huge ranges. Water currents carry the genetic material of sedentary
or territorial species over large distances, often hundreds of kilometres.
The same genetic community is likely to occur throughout a large
geographic range, occurring wherever substrate and water quality
are suitable. [1] In most
cases a single MPA will not be able to achieve " the protection
and maintenance of biological diversity at an ecosystem level"
It may be able to "contribute" to that goal but it is setting the
bar too high to say that an area should achieve protection on an
ecosystem scale in order to be defined as an MPA. Certainly, most
current marine reserves do not achieve protection on this scale
in our view.
We submit that the wording
of the MPA definition is changed. Possibly to: at the marine
community, habitat or ecosystem level.
There is also a need to define
"protection". We believe that some work has started on defining
a marine protection standard. This is an important step in the process
and must involve stakeholder input.
MPA
Generic Principles
NZBGFC questions the need
for an annual process to develop new national priorities that will
guide the regional MPA process each year (Principle 1). The purpose
of the MPA policy should be to provide a more strategic approach
with increased certainty of the long term plan for selection and
establishment of MPAs.
There is currently considerable
mistrust within the non-commercial fishing sector of the process
of selection and consultation over marine reserve proposals. We
submit that this new process must provide a greater level of certainty
over where and when new proposals for MPAs will be developed.
We submit that the principles
and description should make it clear that the national priorities
will help provide long-term continuity and consistency rather than
generating a change of course and a new wish list on an annual basis.
Principles 4 and 5 recognise
property rights (commercial groups) and obligations to Maori while
Principle 10 promised to " constructively engage groups with
an interest in marine biodiversity protection " (Largely
environmental groups). It appears to us that, yet again, the largest
section of the community directly affected by new MPAs is left out.
The public who fish or those who receive fresh fish from their extended
family, many of whom are Maori but are not represented TOKM or Maori
commercial interests, many of whom belong to and participate in
various environment or landcare groups, have entitlements and rights
also. We submit that the principles must include a statement that
the entitlements and views of existing recreational and sustenance
fishers will be recognised during the process of planning and implementing
MPAs.
Network
Principles
The type of the environmental
classification system chosen will determine the number and size
of marine ecosystems that "require" protection. We cannot support
the network principles without knowing what the classification system
is and scale of ecosystem separation as applied in New Zealand conditions.
We submit that groups representing
commercial and non-commercial fishers must participate in the selection
of the environmental classification system.
Site
and tool selection principles
Principle 1 reads:
Every MPA should be designated
on the basis of a clearly defined objective, which will be consistent
with the network priorities and the MPA principles.
Where a site is selected
for the purpose of biodiversity protection we would agree. We would
like the plan to make it clear that to maintain national consistency
some sites that have access closed for other reasons may also qualify
as an MPA. For example existing military zones may qualify as MPAs
as they prohibit fishing, anchoring and public access. A new marine
military zone should also be able to qualify as an MPA even if the
purpose and selection of that site is not based on MPA or network
principles.
We support site and tool
selection principle 5 which reads:
Adverse impacts on existing
users of the marine environment should be minimised in establishing
MPAs.
We have seen local communities
polarised and divided over the lack of compromise and judgement
applied under the existing marine reserve establishment process.
The Minister's recent decision to include the south ridge
at the Volkner rocks has left many of our members thinking that
if closing this world class recreational fishery is not considered
an adverse effect then anywhere in New Zealand that can be closed
to fishing by a marine reserve application.
MPA
Implementation Plan
We do not support the operational
plan as written. It is still based on separate MFish and DOC processes
under separate legislation and has almost no hope of providing an
integrated approach to MPAs.
The nature and extent of
MFish Stock Strategies (if that is what they will be called) has
not been finalised and is not well understood, at least by stakeholders.
However there is a low probability that stock strategies will result
in area closures for fisheries management purposes, especially in
multi species inshore fisheries. The DOC process will focus on "
site selection for marine reserves " under the legislation
they are responsible for. However, if the Marine Reserve Bill goes
ahead in its current form anyone will be able to propose a marine
reserve anywhere they like. It is certainly not clear how the implementation
plan will handle proposals from outside the MPA plan. What
does seem certain is that the DOC process proposed will not be able
to consider a full range of MPA tools only marine reserves because
it is "constrained by the legislation that it has the mandate to
deliver".
We submit that implementation
should be based around a joint MFish DOC process where the full
range of management tools can be considered for the sites identified
as potential MPAs.
The Expert Groups proposed
to determine the classification and selection of areas in the DOC
process would appear to have a very strong influence on the proposals
that go to the regional groups. It is essential that there
are some experts from stakeholder groups and NIWA with knowledge
of fisheries in all expert groups in this process.
It is essential that there
is a full inventory of areas that qualify as MPAs. We expect to
have input into the process of selecting MPA criteria.
We submit that if the 10%
MPA target is part of the MPA policy then it should apply to waters
within the 12 mile limit. If the Marine Reserves Bill is passed
then the proportion of coastal waters must remain at 10% with a
separate inventory and target for the EEZ. There is concern that
the MPA strategy and new legislation will see an explosion in marine
reserve applications over and above the current Government target.
MPAs will have a significant
effect on where our members can fish. We will make further submissions
as the process evolves.
Jeff Romeril
President NZBGFC
[1]
Guidelines for Marine Protected Areas. World Commission
on Protected Areas of IUCN – The World Conservation Union
TOP
|
