Submission on the Oceans and Fisheries portfolio Cabinet Paper - ensuring healthy ocean ecosystems
IntroductionSubmitted 13 May 2022: Read the NZCA's submission in response to the release of the Oceans and Fisheries portfolio Cabinet Paper, discussing ways to ensure healthy ocean ecosystems.
Marine issues are a longstanding priority for the New Zealand Conservation Authority / Te Pou Atawhai Taiao o Aotearoa (NZCA). In 2000, the NZCA developed a statement of principles about marine conservation that addressed governance, conservation, protection, and sustainable use of the marine environment, including that:
- marine and terrestrial environments will be managed in an integrated way that recognises the complex inter-relationships of land, sea, and atmosphere.
- protection of marine biodiversity, marine ecosystems, and marine landforms, unique to Aotearoa New Zealand, is a national and international responsibility.
- decision-making will be informed by traditional knowledge of tangata whenua, along with new sources of information and research.
- responsibilities to future generations requires that non-extractive values of the marine environment – intrinsic values, wildness values, spiritual values, ecosystem services – are protected.
- 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. taiāpure, mahinga mātaitai, reserves).
The NZCA’s principles for marine and coastal management have recently been updated, reflecting our increased understanding of: the urgency of the impacts of both global and local climate change; the biodiversity crisis; as well as changing perspectives on the management of natural resources in New Zealand, such as Te Mana o Te Taiao / Aotearoa New Zealand Biodiversity Strategy, along with its recently released Implementation Plan, Environment Aotearoa 2022, and other key documents and strategy statements.
Comments on the June 2021 Cabinet paper
The vision, objectives, principles, and work programme for the government, as outlined in the June 2021 Cabinet paper, are of great interest to the NZCA. The Cabinet paper summary of the current context of marine management and protection in Aotearoa New Zealand covered a number of the issues which have been of concern for the NZCA.
We note, in particular, the section on “Inadequacies of the marine management system in responding to challenges” that refers to the fragmented nature of marine management, and the resulting lack of an holistic or integrated approach across the system. We also note the acknowledgement that pressures are not being responded to in a timely manner (e.g. the recent decisions on scallops and recreational catches are important steps, although have been challenged as ‘too little, too late’).
There are also critical issues around the lack of capacity to manage cumulative impacts, and the apparent inability of current systems to acknowledge the interdependencies between land and sea and to manage these in an effective way, resulting in declining health in estuaries and nearshore coastal environments.
Vision and Objectives
The NZCA endorses the vision of Ensuring the long-term health and resilience of ocean and coastal ecosystems, including the role of fisheries. The stated Objectives - 1. Promote an ecosystem-based approach to research, monitoring, and management; 2. Establish a spatial planning framework that optimises the protection and use of marine space and resources; and 3. Support the development of a high-value marine economy that provides equitable wellbeing benefits – provide clear directions. The objectives are, however, silent on non-extractive values of the marine environment – intrinsic values, wildness values, spiritual values, and the critical ecosystem services on which we all depend.
We have some questions about some of the stated principles, and look forward to these being clarified, articulated with greater detail, and to be provided with examples of how these principles are being given effect:
- Precautionary approach and adaptive management – from the NZCA perspective, the application of the precautionary approach has been rarely seen in Aotearoa New Zealand in marine contexts.
- Equitable allocation of costs and benefits – which costs and which benefits are being referred to? Loss of intrinsic values, wildness values, spiritual values; loss of access to customary and recreational fisheries as a consequence of overfishing (commercial and recreational); cumulative impacts and sedimentation in estuaries and in the near shore environment as a consequence of inappropriate land use practices (nutrient loading from certain farming activities; loss of soil and erosion from forestry, etc) – and how will such costs be allocated fairly?
- Give effect to the principles of Te Tiriti o Waitangi/Treaty of Waitangi, including through fisheries and aquaculture settlements and other legislation - while we endorse this as a principle, it is critical that how this principle will be achieved is articulated.
- Decision-making based on sound science and traditional knowledge – incorporating mātauranga and a range of science disciplines to the management of marine environments is We note that funding for fisheries research has been declining, with management increasingly reliant on models without ground truthing (PM Chief Science Advisor’s report refers). Competing interests, as well as siloed management frameworks, appear to have resulted in delays in the application of precautionary decisions being made about declining fish stocks, and the environmental impacts of fishing activities. Where there is strong evidence and research, this has not always been applied, e.g. the research on the impact of toxoplasmosis on endangered marine mammals has not been followed through with appropriate strategies to manage cat populations.
We commend the intent of the Initial Oceans and Fisheries work programme, particularly items 1. Fisheries system reform, and 2. Improved fisheries monitoring – on-board cameras, although we are concerned by the apparent continuing delays on both of these objectives. We were pleased to see 4. Marine protected areas reform: to create a more strategic, nationally coordinated framework for marine protection with modernised legislative tools and processes that improve integration with wider marine use.
As noted in the background above, NZCA has been advocating for over 20 years for reform of the marine protected areas legislation and to improvements to the tools and processes employed. The specific examples selected for attention in the June 2021 paper (Sea Change, Rangitāhua/Kermadec Sanctuary, SEMPF, Hector’s and Maui dolphins) are all issues that have needed to be addressed for some time. We are unclear if there are milestones that have been met.
Longer-term future work
The paper refers to some examples of longer-term future work, and in particular we want to highlight the following:
- In our view the incorporation of Māori world views and interests is crucial in any legislative and institutional reforms, and in any funding arrangements.
- We are seeking much better integration of the land/sea interface, and the capacity to address cumulative impacts of anthropogenic Incorporation of marine coastal spatial planning in the Government’s resource management reform programme is a pathway for these issues to be addressed – we are unclear if this opportunity is being seized.
- While the paper refers to “Emerging threats such as ecosystem disruption from climate change, plastic pollution, discharge of chemicals and other contaminants, and biosecurity” – these are far from emerging – they are already embedded and having significant consequences on the distribution and survival of species, including on commercial fish stocks, habitat forming species such as kelps, as well as on the viability of aquaculture ventures in the face of rising sea temperatures, and changing patterns of nutrient availability, reduced oxygen, and increasing ocean acidification. Plastics are already known to be in the deep ocean, and in the fish and shellfish we consume. Marine heat waves – their intensity, duration, and season of occurrence – are now part of annual cycles. What we once understood about seasonality is being reshaped, although the profound consequences of these changes are still not clear.
- There is no reference to the increasing need for, and interest in, restoration of the marine environment - habitat, species, and ecosystem services restoration. We consider this is an important area for future research and engagement with tangata whenua, civil society, and NGOs, to develop tools and approaches that can be applied
Undoubtedly progress has being made on a number of fronts on marine issues over this first year of operation of the Oceans Secretariat, and we are pleased to see the multi-agency approach that has been instituted.
We are concerned that the combination of land driven stressors, climate change impacts, and the use of marine resources, are having significant negative impacts on marine species and ecosystems – and that our current systems are not sufficiently responsive to face current and future challenges. In order to protect the values and services provided by the marine environment, we need a system that responds in a much more timely way; we do not see this adequately reflected in the Cabinet paper of 2021.