| TIRITIRI ACTION
GROUP
Tiritiri Action Group
PO Box 600
Whangaparaoa
25 March 2003
New Zealand Underwater Association
PO Box 875
Auckland
Copy to - The Mayor Rodney District Council
- The Minister of Fisheries
- The Minister of Conservation
- President NZ Recreational Fishing Council
- President NZ Big Game Fishing Council
- Chairman Option 4
Submission on Tiritiri Matangi Marine
Reserve
Draft proposal for public discussion
Executive Summary
a. Tiritiri Action Group (TAG) is not against the formation
of marine reserves but believe they should be part of a regional
and strategic national plan. We do not consider the NZ Biodiversity
Strategy a satisfactory plan to address marine reserves.
b. The formation of reserves should include those affected
in the earliest stages of planning so issues can be debated
and ownership of the solution becomes a community issue.
c. TAG does not support justification of the proposal by New
Zealand Underwater Association (NZUA). The proposal does not
conform to the purposes of section 3 of the 1971 Marine Reserves
Act.
d. There are serious safety, social and economic concerns
about the proposal.
e. There is currently more than 10% of the local coastline
under marine protection. The proposal places an additional
unfair burden of marine restrictions on the local population.
f. Biodiversity issues need further qualification of criteria
that need to be met.
g. Fisheries management arguments are not a plausible justification
for this reserve.
h. The area proposed has a sewage outlet.
i. Historical, geographical and cultural justifications are
questioned.
j. TAG is critical of the timings of release of the document
and early closure date for submissions. The subsequent extension
was poorly advised.
k. TAG is critical of mass submissions from national activist
group’s that can over ride majority community opinion
against the proposal.
l. The Minister of Fisheries is unlikely to concur as is required
under the Marine Reserve Act when recreational fishing rights
will be impinged. The proposal should wait until the completion
of the review of recreational rights and the government’s
Oceans Policy.
Introduction
1. Concerned members of the public formed the Tiritiri Action
Group (TAG) in January 2003 in response to the proposed reserve
by the NZUA released in December 2002. Weekly meetings were
held in the Hibiscus Coast Boating Club (HCBC) at Stanmore
Bay by key members with the sole purpose to help raise awareness
of the reserve proposal and co-ordinate opposition to it.
TAG are of the belief that there is insufficient public support
in the Rodney and surrounding districts for the proposal to
proceed to the formal application stage. This submission represents
the views of the committee of TAG and signed by the chairman.
It is the TAG committee’s case against the proposed
reserve. TAG has encouraged individuals to make their own
submissions.
2. TAG convened a meeting Tuesday 4th February of invited
members of various backgrounds to discuss the proposal. Raising
funds to place public newspaper adverts against the proposal,
print and distributed submission forms and staged a public
rally at the HCBC Thursday evening of 13th February. NZUA
was invited to attend and speak at the rally but declined
the invitation. TAG has also informed a number of national
and local organisations/clubs that may be affected should
the marine reserve proceed.
3. The TAG group has an elected committee of a chairman, treasurer
and secretary who have called for public support to further
the aim of the group. That aim is - the Tiritiri Marine reserve
should not proceed as proposed and further proposals should
wait until a co-ordinated national and regional plan of marine
protected areas is formulated.
There are a number of relevant facts that leads TAG to its
main aim. These are amplified as follows.
Marine Reserves Act 1971
4. The proposal has been written quoting the Marine Reserves
Act 1971 as the tool in which the reserve will be eventually
formed under. However we find in the justification very little
that conforms to the Act that would enable the proposal to
meet the requirements of this Act. Certainly marine biodiversity
and representative areas are not part of the purpose of the
current Marine Reserves Act, which are the prime reasons offered
by the applicant why the area chosen should be considered
for a reserve. In fact we find the selected area has little
in common with section 3 of the Act to justify its formation.
Current restrictions to fishing
5. The proposal quotes the Auckland Regional Council policy
statement of 10% goal of the coastal area being fully protected
marine reserves. Such policy places an unfair burden on the
residents and visitors who fish around Whangaparaoa Peninsula
and Tiritiri Matangi Island for recreation or sustenance.
Currently there is well in excess of 10% of the surrounding
area within the Rodney district already fully protected or
has no fishing allowed. These include the Long Bay and Cape
Rodney- Okakari Pt (Goat Island) Reserves, Tawharanui Marine
park, a number of cabled areas including the substantial international
telecommunications cabled area adjourning the proposed reserve
area, Naval Degaussing area and danger area when live firing
take place at Whangaparaoa Naval Range and disused explosive
dumping zone south of Tiritiri Island. The attached chart
highlights all the current no fishing areas in close proximity
to the NZUA proposed marine reserve.
6. In addition to this will be marine aquaculture management
areas presently under formation that will effectively rule
out the use of these areas for any recreational purpose. To
add to this the 10% target of areas in full marine reserve
protection would deny a substantial proportion of fishable
water to the residents and visitors to the region on top of
those areas closed to fishing for other reasons. Further if
the 10% was applied to the most productive fishing areas which
tends to be the targeted areas for reserves, then recreational
fishing becomes an activity exclusive to those who have suitable
boats and time to travel the distances required to reach a
productive area not restricted to recreational fishing.
Maritime safety
7. TAG submits there is a serious safety issue if the reserve
was to proceed. To remove the most accessible and productive
fishing area around Whangapararoa that has shelter from most
wind directions will tempt fishers to proceed further afield
in search of a catch. There are a high proportion of small
craft that frequently fish the proposed reserve area due to
the protection it offers craft in any prevailing wind and
sea condition along with accessibility and productivity. A
further safety concern is for the many groups and individuals
that would be attracted to the reserve who are not aware of
the risks to crossing the Whangaparaoa Passage in small craft.
While common sense and good seamanship should prevail there
will always be those tempted or caught out by conditions unsuitable
for their craft. Further demands on the marine search and
rescue service, whilst difficult to quantify, will inevitably
rise.
8. The immediate proximity of the large cabled area next
to the proposed marine reserve will result in more incidents
of recreational fishers attempting to anchor and fish in the
cabled area. The no fishing cabled area extends beyond easily
recognisable geographic features to assess position. Unless
boats are fitted with GPS plotters or anglers take considerable
time to fix their position with bearings they will be tempted
to inaccurately assess their position. This being encouraged
by wanting to stay as close as they can to the safety of land
shelter and the better fishing normally associated with seabed
features near land. While a prohibited activity and one that
is not condoned, a situation will occur if the marine reserve
proceeds that will promote more careless but unintentional
intrusions into cabled areas by both novice and experienced
fishers.
Social effects
9. Whangaparaoa and Orewa region has a high retired population
and many choose the area because of the availability of recreational
and sustenance fishing close to home and by the use of smaller
boats or surfcasting off rocks. The same argument applies
to families who chose to live in the area because of the easy
access to surrounding fishing and availability of work in
the commutable area. The proposed area for reserve status
is widely recognised as the most productive in the region
for fishing with easy access and distance from boat launching
facilities or beaches for light craft. To remove this area
will eliminate a prime motivation for many that moved into
the region.
10. The proposed marine reserve constitutes a huge threat
to the local population due to the limited income of the retired
and those fishing for sustenance purposes. For many the proposed
area is the only place they can source fresh fish at a price
they can afford. To deny those who choose to live in the area
an opportunity to gather food for themselves is a factor that
has not been considered in the NZUA proposal.
Economical factors
11. There will be economic factors that should be explored
before any decision is made on future reserves within the
region. A study commissioned by MFish (REC9801) into the economic
value of recreational fishing showed nationally that recreational
fishers spent 973 million dollars annually in recurring expenses
in the pursuit of just five popular recreational species –
Snapper, Kingfish, Rock Lobster, Blue cod and Kahawai. This
survey is widely regarded as conservative as it underestimated
the proportion of public that fish, based on the results of
a later survey REC9803 for MFish. The recurring expenses do
not include capital equipment costs such as boats, motors,
rods and reels, which while one off costs would substantially
add to the total.
12. Given the popularity of fishing for recreation within
the region then a substantial proportion of this annual expenditure
is spent within the region. While this could be broken down
pro-rata in terms of population, this also would be conservative.
Targeted research should be commissioned to get more relevant
data on the reduction in economic benefit within the region
if it is no longer an attractive place to fish.
Marine Biodiversity
13. Marine biodiversity is offered as prime justification
for this particular proposal. As said earlier this is not
consistent with the current Marine Reserves Act but in support
of this logic the NZ Biodiversity Strategy is offered. This
strategy is less conservative than the Auckland Regional Council
policy in that its action plan includes 10% of marine protected
areas rather than reserves by 2010. The plan does take into
consideration currently protected areas other than marine
reserves. As stated earlier the Rodney district has already
achieved this as a region. However there are some arguments
that need qualification.
14. TAG is not against the formation of reserves outright
or the pursuit of maintaining marine biodiversity. The formation
of reserves should be initiated by a fully explored and debated
action plan by all interested parties and not by various interest
groups with self appointed agendas to fulfil. These plans
by necessity would have to be regional in nature and able
to fit into a national plan to achieve the same. The Biodiversity
Strategy does address some of the issues but lacks a good
definition of what is an acceptable level of biodiversity.
This requires defining so that the impact of existing mobile
marine species has on the quality of biodiversity in that
area can be assessed. To not have this leaves the NZ Biodiversity
strategy open for abuse as justification for large tracks
of coastal waters to be locked up permanently in reserves.
Sanctuaries and Marine Reserves
15. TAG is opposed to the justification of having marine reserves
surrounding terrestrial sanctuaries such as Tiritiri. They
have no beneficial or detrimental effect on the rare and endangered
species on the Island. Access to the island can be effectively
controlled with current restrictions and will not be enhanced
by the protection of a surrounding marine reserve. If this
justification were accepted then the waters surrounding almost
all offshore islands would be targeted for marine reserves.
This is a situation that would be strongly opposed by the
fishing public.
Scientific research
16. TAG is not opposed to a suitable area being placed into
marine reserve on the grounds of scientific research. However
we find little to justify this proposal under these terms.
We ask what scientific research can be carried out in this
locality that is not presently available because of current
fishing practice or could not be accommodated in existing
reserves.
Local consensus
17. TAG submits that any area proposed for reserve status
should be with the consent of the majority of the local population
that utilises the proposed area. This proposal did not effectively
seek the endorsement or views of the local population before
NZUA and its supporters devoted considerable time and expense
to the project. Had it done so and received endorsement then
the reaction that it has now received against the proposed
reserve could have been considerably mitigated. It is highly
unlikely that the current proposal would have been endorsed
but suitable alternatives acceptable to majority may have
eventuated.
Representative Areas
18. TAG does not support the representative area concept proposed
by NZUA. There is no provision for this in the current Act.
Should the current Marine Reserve Bill eventually modify the
act to include representative areas, then we are confident
that suitable alternatives could be found without the need
to lock up large tracks of the best fishable waters found
near the Whangaparaoa Peninsula.
Fisheries management
19. NZ has one of the best management systems in the world
and using implied justification that fish stocks need reserve
protection for management reasons shows contempt for our present
system. Marine reserves for management reasons are a last
ditch system in countries where there is no or little proper
management of their stocks and subsequently face over fishing
both commercial and recreationally. In a balanced fishery
such as New Zealand’s stock recruitment is a function
of favourable ambient sea conditions. The influence of a number
of reserves in virgin state scattered around the region is
minimal. Some would say the difference would be negligible.
20. While undoubtedly local resident populations of some
fish will increase in number and size in a protected reserve
the benefits of this are questionable. Spillover is a conservationist
myth as all current reserves tend to attract fish into the
reserve and may deplete surrounding fishing areas. Scientific
supporters of the Poor Knight reserve openly claimed that
snapper stocks had increased 10 fold within a year of that
area being given full marine reserve status. While not critical
of the Poor Knights area as a reserve it is just plain fanciful
to believe that this was caused by natural growth within the
reserve, the majority of this increase was caused by attracting
fish into the reserve from other regions. Fishing near an
existing reserve in the hope of a productive catch is the
activity of a novice fisher and one that they soon learn is
a waste of time.
Sewage outlet
21. We note that two of the proposed three area options have
sewage out fall contained within it. The current marine reserve
bill will if passed in its present state deem these to be
inappropriate areas for reserve status.
Geographic features
22. Uniqueness of Tiritiri and Whangaparaoa geographical features.
Specifically the shore platforms around Tiritiri and the cliffs
and intertidal platforms around Whangaparaoa Peninsula. While
these may be unique features to the area we ask what danger
do they face that they need full marine reserve protection.
Recreational activities including fishing pose no risk to
these features. If subsequently an activity was identified
and agreed by local and national bodies that it posed a risk
to the area then this activity could be specifically excluded
within the at-risk area by use of regulations under the Fisheries
Act.
Historical features
23. Historical justifications have no support within the current
act. Even within the new marine reserves Bill sections supporting
historical areas as a justification for marine reserves are
tenuous and we await the outcome of the select committee to
see if these remain part of the Bill. We argue that the wreck
of the Royal Tar has limited historical value and is not threatened
by fishing activity.
Cultural issues
24. Issues of cultural significance in the marine environment
are best left to Iwi to pursue with the numerous tools they
have at their disposal for each issue. To pre-empt that a
marine reserve status for this area serves Iwi best is an
injustice to them and bound to invite criticism, but we will
leave this for local Iwi to contest.
Timings
25. TAG formally complained by letter to NZUA at the timings
of the release and discussion period of this proposal. To
release this just prior to the nationally recognised holiday
period of the traditional Christmas holidays is viewed with
suspicion as to its intent. The letter dated 10th February
2003 asked for an extension due to insufficient notice and
useful period of dissemination of information and adequate
time to respond. With three days to go before submissions
closed we were advised by phone that this had been extended
to the 31st March. Earlier advice of the extension would have
been appreciated, as it appears that at this informal stage
this should have been easy to grant.
26. It subsequently became known to TAG that an internal
memo within NZUA membership and to NZ Forest and Bird Society
that the decision to extent the submission deadline had been
made by the 17th of February. The fact we were not also advised
at the same time having announced ourselves in a previous
letter and invited NZUA to participate in a public meeting
is poor administrative handling and also viewed with suspicion.
With the contempt we have apparently be shown we have grave
doubts that a logical decision regarding the analysing of
the submissions is likely.
Environmental groups
27. TAG is critical of practices that encourage mass submissions
by recognised national conservation organisations with little
connection to the area concerned. The Whangaparaoa and Orewa
area has an estimated 30,000 population. If every man woman
and child responded against this proposal it would still fall
short of a majority influence when just one organisation such
as Forest and Bird Society has 70,000 subscribing members
NZ wide and has encouraged all its members to submit in support
of the proposal. This makes a mockery of the submission process
and can force the agenda of a national environmental action
group on a local population against their will.
Recreational fishing rights
28. Presently, compared to Maori customary and Commercial
fishers, the public’s right to access and harvest food
from the marine environment is poorly defined. While recreational
fishers have rights, the access issue is at the discretion
of the Minister of Fisheries to uphold. This is currently
under review by the Minister of Fisheries with a goal of legislation
change within the Fisheries Act 1996 to better define the
rights of the public to recreational and sustenance harvest.
This review will better define the interaction with the other
main stakeholders and relationships with other legislation
such as aquaculture, marine protected areas and marine reserves.
29. Also the government is actively creating its Oceans policy
which is still in draft but will also describe public good
relationships within the marine environment. The formation
of the proposed reserve will, without doubt, affect the local
and visiting fishers ability to take fish and therefore impinge
their rights. TAG submits that the NZUA proposal should wait
until the completion of the review of recreational fishing
rights and completion of the Oceans policy. Until these reviews
are completed there is little legislated and policy guidance
as to the needs of the reserve compared to the disadvantaged
public fishers. Under the current Marine Reserves Act it is
unlikely that the Minister of Fisheries will give his consent
which is required, when recreational fishers will be seriously
disadvantaged.
Conclusion
30. Using the Triple Bottom Line factors of social, economic
and environmental impacts on the local community, this proposal
does not comply. TAG also considers this proposal to have
undue and adverse affects on existing use of the area for
recreational purposes as per section 5 of the Marine Reserves
Act part 6 (d), therefore TAG oppose this proposal on these
grounds and the points already stated.
Thank you for the opportunity to have our input. It has been
very valuable in gauging public opinion on a marine reserve
in this area.
Rex Smith
CHAIRMAN
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