12 February 2003
The Conservator
Bay of Plenty Conservancy Office
PO Box 1146
ROTORUA
Dear Sir/Madam
Please accept this submission from -----------------------on the
Te Paepae Aotea (Volkner Rocks) Marine Reserve Proposal. This is
an expansion to the submission sent prior to the 14/1/03.
I/We oppose the Te Paepae Aotea (Volkner Rocks) Marine Reserve
Proposal
The Department of Conservation and the Steering Committee have
not recognised the importance of the south ridge as a national and
international Mecca for kingfish fishers therefore I/we
are totally opposed to any Marine Reserve at the Volkner Rocks.
The Importance of Kingfish
Recreational fishers recognise the kingfish fishery in the Volkner
Rocks area as being probably the best in New Zealand consistently
producing large fish for the last 20 years. New Zealand has almost
all of the World records for Southern yellowtail kingfish (Seriola
lalandi) caught on rod and reel, therefore the Volkner Rocks area
has arguably the best kingfish fishery in the World. Fishers from
all over New Zealand and indeed all around the world come to fish
the Volkners and White Island. Most of what they catch is tagged
and released for research purposes.
To state that some recreational fishers will be inconvenienced
clearly shows that after three years DoC and the steering committee
still dont know (or dont care) why the Volkner Rocks
is special. The ridge that runs to the south of Volkner Rocks rises
out of deep water and the current accelerates as it sweeps over
and around it. Kingfish hold in the current in front or above the
ridge but once hooked are soon taken over the ridge into deep water
where the powerful fish cant reach the bottom. This area is
the top kingfish location according to Ministry of Fisheries tagging
programme records. To describe the closure of this fishery in such
an off-hand way as an inconvenience to recreational
fishers we feel is dismissive.
DoC and the steering committee would take this fishery away rather
than face the slight inconvenience of having marine reserve boundaries
that werent a nice round shape, 1 mile from all islands.
Where is the Threat?
The reason this proposal must be rejected is that none of the significant
features listed in the justification are affected by the current
kingfish fishery. Kicking out the New Zealanders and international
tourists that pay good money for the Volkner Rocks fishing experience
will not enhance the distinctive and unique features described in
section 6.1. Fishing for kingfish will not disturb the spectacular
underwater scenery, of the clear water, or the rare invertebrate
species such as sponges and crabs, starfish and urchin. The smaller
marine fishers of the Volkners might actually benefit from having
a few less kingfish to feed.
The Volkner Rocks are a long way offshore and are very exposed.
These factors already offer them considerable protection from fishing
pressure.
The authors of this proposal clearly make the assumption that all
fishing is bad for biodiversity and there will be a recovery
phase once fishing has stopped. However there is absolutely no evidence
of damage caused by fishing for kingfish on any of the
special features or species the authors want to protect.
Where is the current threat? Where is the Justification for Plucking
Out one of the jewels in New Zealand recreational fishing and putting
it off limits forever?
New Zealand recreational fishers often rely on the hard working
volunteers elected to their club committees to inform them of issues
that affect them. The submission period over the traditional NZ
summer holiday break has made it difficult for committees to meet
and newsletters to reach club members. Most will realise too late
that they could have had their say. If the process is perceived
as unfair it will only galvanise opposition to future reserves.
Purpose of the Act
The authors of the Volkner Rock marine reserve proposal have misquoted
the purpose of the Marine Reserves Act (1971). They have totally
omitted the scientific study of marine life. Section 3.1 reads:
It is hereby declared that the provisions of this Act shall
have effect for the purpose of preserving, as marine reserves for
the scientific study of marine life, areas of New Zealand
Whereas the authors only quote what type of areas may be preserved
for scientific study, Section 3.1 continues:
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.
Surely the Volkner Rocks proposal needs to be consistent with the
primary purpose of the Marine Reserves Act (1971), which is scientific
study. Far from it the establishment of a marine reserve will severely
constrain existing Ministry of Fisheries funded research into the
age, growth rate and natural mortality of New Zealand kingfish.
Over 1000 kingfish have been tagged and released at the Volkner
Rocks over the last 20 years as part of the Ministry of Fisheries
Cooperative Tagging Programme (currently MFish project PEL2000/01).
One of the key objectives of the tagging policy is to measure and
tag fish larger than 1 metre long to help establish the growth rate
of larger fish.
Over the last 2 years more than 170 kingfish have been tagged at
Volkner Rocks with 95% of these measured before release - 72% (or
123 kingfish) were longer than 1 metre. There are few areas in New
Zealand where large kingfish are tagged in these numbers.
Over the last 2 years for all of New Zealand 433 kingfish greater
than 1 metre have been measured and released so 28% of this total
were tagged at the Volkner Rocks.
Recently another kingfish research project (Ministry of Fisheries
project KIN2000/01) has begun collecting otolith samples and length
data from Bay of Plenty charter boat skippers. To date about 90%
of length data has come from recreational fishers from Volkner Rocks
and White Island and nearly 50% of the otoliths (the ear bone used
in estimating the age of fish) come from this area. Research into
age and growth of kingfish will ultimately be used to determine
natural mortality and therefore the productivity of the kingfish
fishery in New Zealand, rather than using estimates for a Californian
sub-species.
There is no-doubt that existing and future research on kingfish
will be detrimentally affected by the Volkner Rock Marine Reserve
proposal. This is contrary to the purpose of the Marine Reserve
Act (1971), which is to promote scientific study. Again, where is
the justification for threatening these projects? On the other hand
the presence of the Kingfish fishery would in no way hinder studies
into rare invertebrates, reef communities, or geological features
at the Volkner Rocks.
Policy Disagreement
The foundation block of the New Zealand Big Game Fishing Council,
New Zealand Recreational Fishing Council and Option4 is ensuring
we have continued access to quality fishing opportunities for the
future, so that our children and their children will be able to
enjoy the simple pleasure of recreational fishing. Yes there needs
to be considered and careful management to achieve this but total
closure of nationally significant recreational fishing locations
such as the Volkner Rocks will be strongly opposed.
The proposal of the Volkner Rocks as an isolated region needing
special help to preserve the abundant and variety of marine life
that exists there cannot be justified. I/We have seen similar proposals
and arguments for a number of other offshore islands. I/We believe
this to be an active part of a Department of Conservation plan to
utilise the Marine Reserve Act 1971 to return the majority of off
shore islands and prime coastal regions to marine reserves. Using
as its mandate the act of conserving and protecting the natural
resource.
The preservation of invertebrate fauna should not be used as a
justification for closing such an important area to recreational
fishers.
Economic Considerations
Recreational fishing is a major generator of economic turnover.
An independent report on the value of recreational fishing (project
REC9801) released in September 1999 by MFish showed that annual
recurrent expenditure by recreational fishers to be $973 million
on just five of the most popular fish species. These are Snapper,
Kingfish, Blue Cod, Kahawai and rock lobster. Recurrent expenditure
included items of fuel, accommodation, travel, tackle, charters
and bait and makes no allowance for the purchase of capital expenditure
items such as Boats and fishing equipment. The Bay of plenty is
well known for its fishing especially in the area being considered
for reserve status. One third of the New Zealand Big Game Fishing
Councils membership (33,000) come from within this region
and considerable number of outer province and international anglers
travel into the region for the excellent year round fishing it provides.
Without having the specific figure available it would be a safe
bet to conclude a that a healthy proportion of the near Billion-dollar
turnover is spent in this region.
Since that time new estimates of the number of recreational fishers
in New Zealand have called into question the proportion (10%) used
in the 1996 recreational harvest survey and the economic report.
The new estimate (25% or more) is believed to be more accurate.
This would vastly increase the annual turnover of recurrent expenditure
calculated.
The committee should be aware that a radical change in access by
recreational fishers to kingfish in the proposed reserve area would
have a financial bearing on the local community. Drift fishing on
the south ridge can be successful in all but the worst weather.
The region already attracts non-extractive dive parties but the
Volkner Rocks are a difficult area to dive. Strong currents and
exposure to wind and waves from every point of the compass will
severely restrict the number of dividable days. The creating of
a large reserve is unlikely to rapidly increase the growth of this
activity and certainly not to the point where it will replace the
financial turnover presently generated by recreational fishers.
Uniqueness of the Volkner Rocks
The items identified on page one of your proposal document as being
unique, deserving of special treatment are mainly of the type that
are not in danger from normal recreational line fishing. Rare sponges,
lace coral, kelp forests, anemones and small plants and animals
are not what fishers target or even disturb by their process of
fishing for their preferred species. The non-extracting diving experience
offered by unique circumstances of geography, ocean currents and
volcanic activity are not threaten by recreational line fishing.
The real threat to theses species is from boats that have to anchor
such as dive boats.
Summary
I/we submit that the kingfish fishery at the Volkner Rocks is socially,
culturally and economically important to New Zealand. It should
be recognised as such.
Nowhere in the Te Paepae Aotea (Volkner Rocks) Marine Reserve proposal
has the closure of this fishery been justified. Nor has any attempt
been made to explain how the kingfish fishery actually affects any
of the special features that DOC and the steering committee are
trying to preserve.
There are two important research projects investigating kingfish
growth that require length data, release and recapture or otoliths
from large kingfish such as those caught at the Volkner Rocks. Closing
this area to fishing will be detrimental to current and future scientific
research, therefore this proposal is contrary to the purpose of
the Marine Reserves Act (1971).
Yours sincerely
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