Author: Shaun

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Submission on Regulatory Standards Bill

Regulatory Standards Bill

The proposed Regulatory Standards Bill prioritises private property rights over collective environmental interests. It asserts that “legislation should not take or impair, or authorise the taking or impairing of, property without the consent of the owner unless: there is good justification for the taking or impairment, fair compensation is provided to the owner, and compensation is provided to the extent practicable by or on behalf of the persons who obtain the benefit.” While this protects individual property owners, it could discourage essential regulations, like wetland protections or agricultural runoff controls, by imposing significant compensation burdens. This approach overlooks the shared value of ecosystems and the collective responsibility to safeguard them for future generations.

Full submission on the Regulatory Standards Bill here

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Ring net fishing in proposed protected areas

Trevally driving krill to the surface where they are predated by seabirds that are At Risk of extinction.

After a decade of consultation and compromise on the Hauraki Gulf / Tīkapa Moana Marine Protection Bill the government is proposing last minute changes to allow commercial ring net fishing in two areas. I have provided ministers analysis showing the proposal would compromise the objectives of the marine protection areas. I also asked Fisheries New Zealand for data on ring net fishing. They replied 49 working days later with a partial response, two days after the bill was debated in the house and I had complained to the Ombudsman.

The data provides factual information to support new arguments against the proposal to allow commercial ring net fishing in the proposed protection areas.

  1. Commercial ring net fishers in the Hauraki Gulf catch an average of $26,588 worth of fish in the proposed protected areas, which is only 6.8% of their total Gulf catch (averaging $366,213 annually). In weight, this equates to 17,616 kg or 12.5% of their total catch. This demonstrates that the proposed protected areas account for a small percentage of their overall income, especially considering these fishers also operate on Auckland’s west coast.
  2. The average annual catch from the proposed protected areas is 17,616 kg worth $26,588, which is small compared to the natural variability in catch outside these areas. For example, the catch outside protected areas fluctuates by 35,103 kg and $141,801 across years, far exceeding the potential loss from protection.
2019-20202020-20212021-20222022-2023Average
Inside protected areas (kgs)28,05123,1259,5759,71317,616
Outside protected areas (kgs)120,961119,841108,851143,954123,402
Inside protected areas ($)$28,383$47,838$16,280$13,852$26,588
Outside protected areas ($)$297,053$376,722$352,221$438,854$366,213
Commercial ring net fishing in proposed protected areas of the Hauraki Gulf

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Close CRA 2

Close CRA 2

I am publishing my draft submission on CRA 2 early. Key points below:

  • The ecological imbalance caused by overfishing kōura (spiny rock lobster) in CRA 2 has led to the proliferation of kina barrens, devastating kelp forests along Northland’s east coast.
  • Kelp forests in the Hauraki Gulf could be worth up to USD 147,100 per hectare annually, far exceeding the $10.17 million export value of CRA 2. Kina barrens, by contrast, provide no ecological or economic value.
  • Fisheries New Zealand’s reliance on biased data, such as Catch Per Unit Effort (CPUE), underestimates kōura depletion. Independent research shows kōura populations, even in marine reserves, are well below natural levels.
  • The proposal to close commercial and recreational kōura fishing in the inner Gulf for 10 years is the largest fisheries closure ever suggested for the Hauraki Gulf Marine Park. However, fisheries independent data shows it’s not enough.
  • A new biomass target is precedent-setting and a significant step for Ecosystem-Based Management initiated by Sea Change – Tai Timu Tai Pari. A 3x BR target is essential to control kina populations, halt the spread of kina barrens, and restore productive kelp forests.
  • Independent data must be prioritised, and a precautionary approach adopted, including a full closure of the CRA 2 fishery. Further delays will only worsen environmental and economic losses.

Make your submission here.

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End of year submissions 2024

Kina Mangawhai Heads

Posting my submissions from the last few months.

Submission on Proposed Management Measures for the Northland Spiny Rock Lobster Fishery (CRA 1)

Submission on Let’s Protect Our Environment. Auckland Councils Regional Pest Management Plan.

Submission on Development
Contributions Policy 2025

Submission on GD05 Erosion and Sediment Control Guide for Land Disturbing Activities in the Auckland Region Review

Supporting Patuharakeke Hapū’s request to extend the Section 186A Closure on Mair and Marsden Banks, Marsden Point to the harvesting of ALL SHELLFISH

Support for temporary fisheries closure for harvesting mussels, Ōhiwa Harbour, Bay of Plenty

Submission on Resource Management (Freshwater and Other Matters) Amendment Bill

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Ten reasons why MPs should support Gulf protection bill

Snapper Goat Island

Recreational fishing lobbyists LegaSea are making a last ditch effort to stop the Hauraki Gulf / Tīkapa Moana Marine Protection Bill. Here are ten reasons why Scott Simpson and other MP’s should support the bill as it stands:

  1. Broad Public Support for Protection: There is overwhelming public support for marine protection. The bill will increase protection from 0.3% to 6%. 77% of the public want much more (30%) of the Gulf protected.

  2. eNGO Support for Increased Protection: Environmental groups have consistently asked for more protection than the bill currently provides, indicating that the bill is already a compromise aimed at balancing diverse interests​.

  3. Protection to Address Depletion and Habitat Damage: The bill addresses overfishing, habitat destruction, and declines in marine biodiversity in small areas. Lage scale bottom-impact fishing​ is being delt with through a different process.

  4. Scientific Evidence Supports High Protection Areas (HPAs): While recreational fishers claim there is no evidence to support HPAs, scientific studies worldwide demonstrate that protected areas are fantastic for restoring fish populations and biodiversity​.

  5. Minimal Economic Impact on Recreational Fishing: Recreational fishers will still have access to 87.4% of the Gulf for fishing. The HPAs cover a small portion, reducing the impact on fishing activities while promoting long-term marine ecosystem health​.

  6. Displacement Concerns Are Overstated: The limited fishing restrictions introduced by the bill are offset by gains in fish abundance in nearby areas, as larger, reproductively mature fish spill over into fished zones, ultimately benefiting fish stocks outside HPAs.

  7. Limited and Controlled Commercial Fishing: The bill may include ring-net fishing in two HPAs compromising their objectives. However, 10 high protection areas and the two marine reserve extensions will be unaffected by the amendment.

  8. Ecosystem Benefits for Seabirds and Marine Species: High Protection Areas will help protect seabird foraging grounds and marine ecosystems, which directly impacts terrestrial food webs and biodiversity on islands in the Gulf.

  9. Strong Legislative Foundations: The bill aligns with New Zealand’s marine protection obligations under international agreements, reflecting a responsible approach to safeguarding marine biodiversity while considering local cultural and socio-economic factors​.

  10. A Balanced Approach to Sustainable Use: This bill offers a compromise between no-fishing reserves and managed-use areas, establishing a multi-use marine park with regions for both recreational fishing and high protection. This approach meets both conservation and fishing community interests without entirely prohibiting either​.
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First look at the Bream Bay sand mining area

When I saw the proposed new Fast-track sand mine in Bream Bay placed on a map by Marc Daalder I thought I would have a look at the site.

I launched my kayak from Uretiti Beach and paddled 6.5 km to the site. On the way I paused six times to drop a weighted GoPro on timelapse from a dive line to photograph the seafloor. I then paddled South West of the mining site and took 12 more photos in a 1km North East transect.

I was not expecting to see much benthic biodiversity as the area is frequently trawled. However I was very pleased to find extensive non-calcareous tubeworm fields (Spionidae – I think) in half the photos, mostly at the north-eastern end of the transect. The filter-feeding tubeworms are a good sign the seafloor is stable and able to support even more complex biogenic habitats if trawling pressure was removed. (Sand mining directly and indirectly impacts biogenic habits, these complex 3D structures made by life on the seafloor are easily buried by unstable substrate.) The tubeworm fields are also associated with tipa / scallops. I was only clearly able to identify one live tipa in the 12 photos but tipa shells were a common feature of the area.

It was a quiet afternoon on the surface with no workups seen, however single tākapu / gannets were working the area, I counted five kororā / little penguin on the way to the site and a tight ball of forage fish.

tipa shells
large ostrich foot snail
live tipa
tight ball of forage fish
tubeworm field
tubeworm field

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Brief for restoring extremely degraded seafloor ecosystems

Degraded seafloor - sediment - mudification

I don’t know how to solve this problem, so I am writing it up as a public brief for people smarter than me.

Brief for restoring extremely degraded seafloor ecosystems

Soft sediment marine ecosystems support diverse and productive biogenic habitats like shellfish beds, sponge gardens, tubeworm fields, and bryozoan mounds. Direct impacts such as mobile bottom contact fishing, and indirect impacts such as sediment pollution, reduce the function of these habitats. Stopping or reducing the impacting activities can help the habitats recover naturally over many decades. Active restoration (like mussel and oyster seeding) can be done in areas where the habitat is not recovering naturally; however, some environments can be too degraded for these methods.

Problem

In my opinion, at least tens of square kilometres of the Hauraki Gulf Marine Park are too degraded to restore with known techniques. In these extremely degraded areas, the seafloor is very soft, deep mud. It’s not lifeless; there are burrows and infauna present. But the areas would be more diverse and productive if the seafloor was less soft with less sediment in suspension. Even when pollution input has been reduced in these extremely degraded areas, legacy sediment is constantly resuspended – choking filter-feeding animals and smothering photosynthesising plants. It is difficult to visually convey the condition of these ecosystems, as visibility is usually less than 30 cm on a good day.

Solutions

To increase biodiversity in these areas, the benthic enhancement method must be low-cost at scale. This means traditional erect concrete and steel structures are not likely to be the solution. In my opinion, resurfacing the seafloor with demolition rubble or quarried aggregate is too extreme because it kills all the infauna. Anything heavy deployed will immediately sink into the mud, anything lighter than the mud will quickly be covered by sediment. A smarter solution might contain one of these elements:

  • Local pits or trenches to collect the most mobile sediment.
  • Dispersed erect artificial shellfish (think horse mussels) to slow benthic currents and allow sediment to fall out of the water column in fields or fences.
  • Regular deployments of waterlogged woody debris.
  • Biological concrete structures that grow using elements from the local environment.
  • Hardened local seafloor sediments (think mudbrick or mudcrete).
  • Growing dense algae at the surface which will 1) slow currents and surge to reduce resuspension 2) drop fragments for sequestration, feeding invertebrates, collecting sediment and seafloor hardening.

Caution

While these solutions will restore some ecosystem function they will not restore the original ecosystems. Hard surfaces will likely be first colonised by invasive species and the new habitat will offer more ecosystem services but be novel / new. We must first halt the destructive activities that degraded the seafloor ecosystems.