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MPA Submission NZBGFC


Marine Protected Areas Policy Submission

NZ Big Game Fishing Council

28 February 2005


Coordinated approach
Definition of an MPA
Generic principles
Network principles
Site and tools
Implementation plan


Dear Sir

Please accept this submission from the New Zealand Big Game Fishing Council on the marine protected areas - policy statement, principles and implementation.



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


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