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Paterson Inlet Marine Reserve Proposal Submission
CRA8
Management Committee
21
October 2003
This submission is made by
the CRA8 Management Committee Inc (the Committee). This organisation
is a fully constituted and incorporated society that is recognised
as the commercial stakeholder organisation representing the interests
of the commercial rock lobster industry in the southern South Island.
The Process
The Committee is very uneasy
that the process for the proposal of this marine reserve has been
drawn out over a long period. Undoubtedly this reflects the range
of opinions held relating to this proposal. Of concern is that information
used in the original proposal has not been updated or reinvestigated
between the promotion of the proposal in 1995 and the signing of
the application during 2002. Indeed the questionnaire circulated
with the discussion document titled "Paterson Inlet: A Protection
Plan and Marine Reserve" was required to be completed by March 30
1993. The last substantial round of submissions was held in 1995
with 64% objecting to the proposal at that time. It is not possible
for the Department of Conservation to provide substantive recent
figures to illustrate the level of support.
To further compound this
is the introduction of regulations during 1994 following the acceptance
of a fisheries management plan for Paterson Inlet. This resulted
in major changes to the use of the fisheries resource within the
Inlet.
The amount of literature
that is now available regarding the value of marine reserves had
not been developed or published during the 1990's. An example of
this is the general public assumption that marine reserves are a
fisheries management tool and enhance fishing opportunities outside
the boundaries of the reserve. A number of recently published articles
refute this and the Department of Conservation now avoid using this
as a selling point when advocating for the establishment of marine
reserves.
The Committee believes that
it is unsound to rely on the results of "old" questionnaires
and surveys of which in turn the respondents relied on "old" information
to formulate their responses.
Protection of
Paterson Inlet and the Establishment of a Marine Reserve
Currently there is a suite
of legislation that affords protection to the marine environment.
Marine reserves should only be considered as one of the tools within
this suite. It should be an end measure – all other options
should be considered first and only then should the establishment
of a marine reserve be proposed.
The Marine Reserves
Act 1971 provides for two main purposes for marine reserves:
The preservation of areas
.. 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:
and
The preservation of those
areas for scientific study of marine life.
Threats to Paterson Inlet
are ill defined and ambiguous as the legislative controls now in
place have mitigated them. This has meant that the Inlet is undisturbed
in many areas with little risk to any marine populations including
the benthic communities of brachiopods, tubeworms and algal meadows
that are identified as being special and requiring protection.
Involvement
of Tangata Whenua
Throughout the process local
iwi have been involved only in a capacity that would further their
own aims and ambitions for management of the balance of Paterson
Inlet. Their support for the establishment of a marine reserve has
nothing to do with the objectives of the Marine Reserves Act 1971
but rather to glean support for the establishment of a mataitai
reserve (originally iwi promoted establishment of a taiapure) over
the balance of the area. Their support is entirely one of " we will
scratch your back if you scratch ours".
Existing
Usage
1. Recreational
Fishing
According to 1993 questionnaire
referred to above, the largest single group of users of Paterson
Inlet are recreational fishers. This is unlikely to have changed
as advances in boat design - particularly alloy and aluminium –
and the large increase in SCUBA diving, has resulted in more people
now being involved in marine fishing and diving.
The marine areas surrounding
Native and Ulva Islands and the southern coast of the Inlet are
used extensively by recreational fishers and any displacement of
this effort will have detrimental results. Page 20 of the marine
reserve application document states "the proposed area includes
favoured diving locations around Native and Ulva Islands. Although
some favoured fishing spots are included in the proposed reserve,
the degree of disruption to traditional fishing patterns is not
thought to be extensive." This is a spurious and highly generalised
comment that is designed to gloss over the reality of the situation.
There is absolutely no evidence to support this comment in fact
a survey of favoured fishing spots would totally refute it.
As with any environment,
all areas are not equal. The areas identified are popular for recreational
fishers for one reason: they have habitat that is conducive to supporting
an abundance of fish species. A study of the blue cod population
of Paterson Inlet carried out by NIWA has shown that there is very
little movement of fish either into or out of the Inlet. There is
no reason to believe that other species do not behave similarly.
It is a closed system. Therefore the displacement of fishing
effort from areas of high abundance and effort to remaining areas
will have a major effect on the relative abundance of targeted species
within the Inlet and will have implications relating to the sustainability
of these species.
Another important fact is
that weather and sea conditions within the Inlet are highly variable.
It is susceptible to westerly winds and often conditions change
very quickly. Most fishers depart from Golden Bay, Watercress or
Thule and can reach the areas surrounding Native and Ulva Islands
quickly. These islands provide shelter for fishers from the prevailing
conditions. To remove these areas would force fishers to travel
further and could potentially create a safety issue for small boats
when conditions change.
The alternative option for
some is to anchor in a sheltered area. Sydney Cove currently provides
this but the establishment of a marine reserve will prohibit this
activity.
2. Scientific
Study
Scientific study is carried
out within the Inlet and has been on many occasions in the past.
The quality and state of the biodiversity of the marine environment
within the Inlet is well recognised. This proves that the existence
of a marine reserve is not required
3. Other Recreational
Use
Paterson Inlet is used for
a range of other recreational activities, many of which involve
the marine environment. These activities are established and provided
for. A marine reserve will not enhance this situation.
The approved plan provides
for a reserve in three distinct parts. This means that a number
of posts and markers are going to be required to sufficiently mark
the various boundaries. These markers will have an adverse effect
on the amenity values of the area.
Compliance
As referred to above, a range
of markers would be required to establish the boundaries of the
three distinct areas. The separate areas will cause confusion as
to what is within and what is not within the boundaries. It will
be very difficult to enforce due to the level of complexity and
that many visitors are unfamiliar with Paterson Inlet.
The Negative Impacts
of a Marine Reserve on Surrounding Areas
The Department of Conservation
regularly quote figures relating to the number of visitors to marine
reserves established in the North Island and advocate that the establishment
of reserves results in an influx of extra visitors. The effects
on Paterson Inlet should be considered within this scenario.
This increase in activity will increase the risks to the very area
that is proposed to be fully protected. Adverse effects that may
occur include: pollution of the sea and adjoining land; risks of
oil spills; increased number of boats in the area; increase in noise;
non compliance with legislation; effects on the natural behaviour
of birds and marine mammals in the area; effects on the marine populations;
and loss of enjoyment by other users of Paterson Inlet.
Summary
The Committee submits that
concurrence should not be granted to the establishment of the Paterson
Inlet marine reserve for the following reasons:
- The proposal relies on data and literature that is out of date
and therefore cannot reflect the current support or opposition
to the establishment of a marine reserve. Without this it is not
possible for the Minister of Fisheries to consider whether the
marine reserve will be contrary to the public interest.
- The approval for the establishment of three marine reserves
was signed by the then Minister of Conservation on the eve of
her retirement from that position. This was a swansong
that was influenced by and reflected her personal beliefs, and
was not a product of a sound decision-making process. It must
therefore be contrary to the public interest.
- The role of iwi in the process has been entirely self-serving.
The Minister of Fisheries would need to consider whether this
approach of iwi is contrary to public interest.
- The closure of some of the most popular fishing areas will displace
the effort and have the adverse effect of increasing the pressure
on fishstocks in the remaining areas, thus interfering with sustainability.
- The closure of areas that provide shelter to fishers could potentially
result in safety issues arising as fishers have to travel further
from launching areas. This has an adverse effect on existing usage.
- There is little threat to the features and marine communities
that are identified as requiring special protection. Current legislation
has mitigated any perceived risks and affords ongoing protection
to the marine biodiversity within Paterson Inlet.
- Recreational activities will not be enhanced by the establishment
of a marine reserve. The range of recreational activities are
already well established and provided for. More restrictions will
unduly interfere with and adversely affect some of these activities
without any additional values accruing.
- There is no evidence that the proposed area is unprotected or
on the brink of some sort of environmental disaster that it requires
marine reserve status.
- A marine reserve that has three distinct areas will cause confusion
and will be very difficult to enforce. This is contrary to the
public interest.
- An increase in activities around the marine reserve area will
unduly interfere with and negatively affect other users of Paterson
Inlet.
- An increase in activities around the marine reserve may have
a negative impact on the existing marine biodiversity and amenity
values. This is contrary to the public interest.
- A marine reserve is not required to encourage scientific study
within Paterson Inlet as it already occurs without the existence
of a marine reserve. Therefore the establishment of a reserve
for this purpose (which is the purpose of the Marine Reserves
Act), with the resultant interference to current users but no
additional benefits, must be contrary to the public interest.
Malcolm Lawson
Chief Executive Officer
CRA8 Management Committee
Inc.
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