Submitted 18 September 2009: The NZCA appreciates the opportunity to provide comments on the Minister’s Initial Position paper on the proposed introduction of bladder kelp seaweed, Macrocystis pyrifera, into the Quota Management System.

Submission date: 18 September 2009
Submitted to: Ministry of Fisheries

1.0 Introduction

1.1 The NZCA is a statutory body established by section 6A of the Conservation Act 1987. Its members are appointed by the Minister of Conservation on the nomination or recommendation of four specified bodies (4 members), after consultation with three specified Ministers of the Crown (5 members) and after the receipt of public nominations (4 members). This process ensures that a wide range of perspectives contribute to the advice provided and decisions made by the NZCA. The functions of the NZCA are centred on policy and planning which impacts on the administration of conservation areas managed by the Department of Conservation, and on the investigation of any conservation matter it considers is of national importance. The NZCA has the power to advocate its interests at any public forum and in any statutory planning process.

The NZCA places a high priority on marine issues and in December 2000 adopted a series of principles that relate to governance, preservation and protection, and sustainable use of the marine environment. The NZCA Marine Principles are attached to this submission.


2.1 The NZCA supports the protection of the marine environment and its resources. The inclusion of bladder kelp seaweed into the Quota Management System (QMS) is supported, as it provides a statutory mechanism for its management; the alternative being for an open-access fishery, which is not supported because of the vulnerability of the attached stage, and the potential for demand to exceed a sustainable harvest.

In particular the NZCA:

2.2 Emphasises the ecological significance of this species as a key habitat component, without which many other species cannot survive and function. It is a particular concern that this highly important ecological component could be harvested for relatively low value uses.

2.3 Notes there is no assessment of

  • the economic value of the species for its habitat values or role in the foodchain for other fisheries (fish and shellfish), including in its free-floating stage
  • its ecological significance to invertebrates or birdlife. This is of concern considering the species is “essential to the functioning of coastal and inshore ecosystems”.
  • its role in managing coastal erosion
  • the potential for its removal to exacerbate the spread of the invasive Undaria

2.4 Advocates a precautionary approach to decision making in the marine environment:

  • knowledge is limited, especially in this case where the major source of information appears to be from North America with a different marine climate, scale, and conditions, ( and a declining industry)
  • biological response is uncertain (marked differences over small spatial scales and between seasons).

2.5 Questions whether there is sufficient hard evidence that harvesting can be managed sustainably (in terms of sustaining the indigenous ecosystem and habitat structure, not just the species being harvested).

2.6 Recommends the identification and legal protection of significant and representative beds before any harvesting occurs.

2.7 Supports investigation into the establishment of the farming of bladder kelp seaweed for economic use.


  • The NZCA queries whether the fisheries management areas are appropriate to the distribution and ecology of the species. If harvesting does occur (and we are not convinced that is appropriate), management at the micro level is likely to be required.
  • Setting of the Total Allowable Catch (TAC) - A full stock assessment should be carried out before any TAC is determined (if any).
  • Any initial harvest should be on an experimental basis (adaptive management) with provision for discontinuance should that prove necessary.
  • Consideration should be given to providing a harvest limit for recreational harvesters

3.0 General comment

We note that reference is made to Pirker et al (2000) but this publication is not cited in the References


The NZCA supports the inclusion of bladder kelp seaweed into the QMS as a means to ensure sustainable management. Adequate information is necessary, including experimental harvest on a small-scale that incorporates careful monitoring and with provision to cease harvest if there are adverse effects on the ecosystem.

Any harvest proposals must go hand in hand with protection of significant and representative areas.

The New Zealand Conservation Authority - Marine Principles


  1. Protection of marine biodiversity and marine ecosystems and marine landforms unique to New Zealand is a national and international responsibility.
  2. The marine environment will be governed for the benefit of all New Zealanders.
  3. The marine environment is viewed as a taonga – there for everybody and upon which we rely, rather than as a resource base on which to create property rights.
  4. Any allocation of rights to use marine resources will be based on robust and
    appropriate, environmental research.
  5. Decision-making will be informed by traditional knowledge of tangata whenua along with new sources of information and research.
  6. Where there is insufficient information, the precautionary principle will apply.
  7. Preservation and Protection

  8. Priority for protection will be afforded to our unique indigenous flora and fauna.
  9. Responsibilities to future generations requires that non-extractive values of the marine environment - intrinsic values, wildness values, spiritual values, ecosystem services1 - are protected.
  10. A spectrum of protection mechanisms will be employed to enable communities to be involved in the protection and preservation as well as the rehabilitation and use of marine ecosystems (e.g. taiapure, mahinga mataitai, reserves).
  11. Representative, rare, and special marine ecosystems will be preserved in perpetuity as “no take”2 areas within the limit of the EEZ.
  12. Sustainable Use

  13. The marine environment will be sustainably managed in a way that maintains its potential for future generations.
  14. The marine and terrestrial environments will be managed in an integrated way that recognises the complex inter-relationships of land, sea and atmosphere.
  15. Rights to use the marine environment should be exercised in an ecologically sustainable manner.
  16. Where finite resources are being used e.g. mining of finite resources, this is to be carried out in a manner that mitigates the adverse impacts of the activity on the marine environment.

1 Ecosystem services are the natural resources which underpin sustainability. These substantially add to the quality of life. Up till now no economic value has been put on them - i.e. natural resources such as clean water and air, or the ocean as a means of transport and waste disposal have been taken for granted. New economic models are being developed to put a dollar value on these services.

2 By “no take” the Authority means nothing to be taken in the column from sea surface to seabed.

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