7 Other Relevant Comments made by Submitters
Comments made by submitters that were not in direct response to the questions posed in the discussion paper are summarised in this section. Following are the common themes that came through in submissions.
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There is a need to ensure that adequate and appropriate resources would be allocated for governing, enforcing, decision-making, researching and knowledge-building to effectively and sustainably work with the offshore environment.
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An overarching oceans policy should ideally be developed first, to set the framework for this type of regime. This overarching policy should be transparent, easy to follow and pragmatic, and should not to weaken or undermine existing legislation.
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Any activity carried out in the EEZ should be done so sustainably, and be managed using international best practice models where available, or in a way that sets international best practice.
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Environmental NGOs tended to support an ecosystem-based approach to managing the EEZ.
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Lack of information needs to be considered as any policy is developed. Information needs to be appropriately utilised and weighted, including drawing from international “lessons learnt”.
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There is a need to have clear rights and responsibilities for commercial users, recreational users, academic and research users, and any future user groups.
Chatham Islands Council suggested the discussion paper be amended to include “and improving regulation of the socioeconomic effects in New Zealand’s Exclusive Economic Zone upon the Chatham Islands”. This submitter also recommended using commonsense reasoning to recognise the more isolated regions of the Chatham Islands and the Chatham Rise, and the Kermadec Islands and the Kermadec Ridge.
Telecom New Zealand suggested the discussion paper should be revised to reflect the fact that in the event of any conflict between express freedoms in UNCLOS and general but unspecified national goals, the express freedoms in UNCLOS would prevail (as discussed by legal opinion in their submission).
The New Zealand Marine Sciences Society and the Otago Conservation Board noted that the Department of Conservation (and the Marine Reserves Act 1971) is responsible for the protection of deep-water habitats, and that provision should be made for such protection.
Auckland Conservation Board proposed:
Potential Seabed Food Cultivation: In the interests of the nation, the seabed of New Zealand’s Exclusive Economic Zone should be subjected to intensive scientific monitoring to establish potential seabed appropriate stratum to develop future marine agricultural farming (not aquaculture as we know it today with supporting structures but a new defined marine food produce planted in the seabed for harvesting similar to commonly grown vegetables on land).
Greenpeace New Zealand recommended the establishment of an interconnected network of marine reserves in the EEZ. This submitter advocated a moratorium on consents in the EEZ until the “designation and enforcement of substantial marine areas fully protected from all human activities” are established. Greenpeace New Zealand suggested incorporating 40 per cent of the EEZ into marine reserves within the next 10 years. This submitter commented that the impacts of commercial fishing, aquaculture, mineral and oil exploitation on oceanic ecosystem function and integrity are not well known, and that New Zealand must manage the full spectrum of human activities that have an impact on EEZ ecosystems, and develop associated indicators of pressure and change in the marine environment.
