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Marine Reserve Submission October 2003

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.



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.  



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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