Request for comment on the proposed opening of the Tsitsikamma MPA to fishing

The South African ministry of the environment has proposed to open the country’s oldest Marine Protected Area, the Tsitsikamma marine reserve, to recreational angling by certain community members. The official press release by the Minister of the Environment can be found here.

A bit of background

There is wide acceptance in the scientific community that marine protected areas are a vital tool to arrest the damage caused to the world’s oceans by the over-exploitation of marine resources, which has been occurring for the last thousand years, with accelerating intensity in modern times. You can read about Colin Attwood’s assessment of South Africa’s MPAs, and about why MPAs work, here.

In the Marine and Coastal Component (pdf) of the 2011 National Biodiversity Assessment, Kerry Sink and co-authors found that 47% of South Africa’s marine habitats are threatened (about 30% by area), most of which are coastal environments. They also found that fishing has the greatest negative impact on marine biodiversity. Most of South Africa’s marine resources are over-exploited. The report states:

South Africa’s Marine Protected Area (MPA) network plays a key role in protecting marine and coastal habitats and sustaining fisheries. Coastal protected areas can support rural livelihoods and local economic development through providing jobs and opportunities for ecotourism and conservation-related industries. Protected areas attract foreign and domestic tourists, provide ecosystem services, and safeguard the environment for future generations. Fully protected MPAs help sustain fisheries by protecting breeding resources and by seeding adjacent areas with eggs, larvae or young and adults.

The first of the priority actions recommended in the marine component of the National Biodiversity Assessment is to “expand and strengthen” the network of MPAs around our coast.

South Africa has a network of 23 Marine Protected Areas, covering just under 22% of our 3,113 kilometre coastline (you can find a list of them along with details of their size and other information on page 147 of the National Biodiversity Assessment 2011: Marine & Coastal Component (pdf)). Less than half of the linear extent of coast covered by MPAs falls into no-take zones, where fishing is not allowed at all. The rest of the MPAs permit certain types of commercial and recreational fishing.

The Tsitsikamma Marine Protected Area

The Tsitsikamma MPA is South Africa’s oldest Marine Protected Area, gazetted in 1964. It covers 264.4 square kilometres of Eastern Cape coastline (about 80 kilometres of coast, three nautical miles offshore), stretching from Nature’s Valley to the mouth of the Groot River. No fishing of any kind is currently permitted in the MPA. It is managed by SANParks, who acknowledge its importance in South Africa’s MPA network.

The Tsitsikamma MPA was not originally a no-take zone; since 1975 fishing in the MPA has been gradually reduced, and it was finally closed entirely to fishing in 2000 during a time of crisis with respect to South Africa’s plummeting fish stocks. It gets over 200,000 visitors per year, employs many people from local communities, and is responsible for significant tourism revenue both directly from the reserve, and from activities in the surrounding area. You can find more detail about this particular MPA on pages 34-40 of the WWF’s 2014 technical report on the State of Management of South Africa’s Marine Protected Areas (pdf).

Scuba diving in the reserve is not permitted except in designated areas close to the Storms River Mouth, with designated operators.

The proposal

Certain areas in the Tsitsikamma MPA are to be opened to recreational anglers who reside in the Tsitsikamma community, and are in posession of a South African ID document. The anglers cite “cultural, historical and subsistence reasons” for wanting to fish in the MPA, and have been campaigning to do so for years.

These anglers will be permitted to fish and gather bait (with a permit) during daylight hours, from the shore, for at most four days out of every calendar month, and are subject to reduced bag limits. Three per person per day for fish with a recreational limit of less than 10 may be caught. For fish with no recreational bag limit or a limit of more than 10 per day, only 10 may be caught per angler per day. No sharks and rays may be caught.

Things to think about

An attempt was made to open the Tsitsikamma MPA to recreational fishing in 2007. This met with vigorous opposition from the scientific community and environmentalists, and was vetoed by then-minister of the Environment, Marthinus van Schalkwyk. In a statement on the matter (well worth reading and possibly a good starting point when you are crafting a response to these proposals), van Schalkwyk said that

The reasons for originally closing the MPA in 2000 and the prevailing underlying circumstances have not changed. It is important to note that this decision will not have an impact on food security in the area as the issue dealt with is a matter of recreational fishing.

He also commented that

Opening this MPA to recreational fishing will set a dangerous precedent in a conservation area that is closed to all, for the benefit of all. Allowing a few people access for recreational purposes would negate the benefits that accrue to all South Africans. A decision to open this MPA would effectively have signalled a broader shift in policy on the part of government and the beginning of a new approach that is neither sustainable nor in line with our stated objectives.

He further acknowledged that it would be extremely difficult for effective monitoring and compliance measures to be enforced.

Another (unsuccessful) attempt to open the reserve to anglers was made in 2010.

If the MPA is now to be opened to fishing, the question that must be answered is what has changed since 2007? Are any of the reasons cited by van Schalkwyk for keeping the Tsitsikamma MPA closed, no longer valid?

Environmental and economic impact

A WWF-funded report estimated in 2006 that the fish stocks built up in the Tsitsikamma MPA could be fished down in approximately 33 days (page 7). The benefit to opening the MPA would thus accrue very quickly to the local fishermen, after which the MPA would have fish stocks of similar quality and size to those outside the reserve and everyone would be worse off.

The largest fish, which spawn exponentially more (example – section 5.4) than their smaller counterparts, would be taken first. The MPA plays a vital role in re-seeding areas along its boundaries with new fish.

Enforcement

In the State of Management of South Africa’s Marine Protected Areas (pdf), Chadwick, Duncan and Tunley (2014) report that:

Enforcement continues to be a major challenge in most MPAs. The primary hindrances to enforcement activities include inadequate staffing, the lack of suitable regulations and poor morale. Morale would be boosted and enforcement efficiency improved if the judiciary became more aware of MPA issues and if all necessary enforcement actions were supported at the highest governmental levels without discrimination between law breakers. A lack of clear objectives for each MPA and a similar lack of understanding of the role and importance of MPAs at higher political levels poses a continual risk of existing MPAs being opened or de-proclaimed.

Can we expect SANParks to properly police the MPA when it is opened to fishing? What is the record of SANParks when it comes to policing of the other MPAs for which they are responsible? How, for example, will they determine whether an individual has already fished for his designated four days in the month? Will there be boots on the ground and boats in the water? There is already an illegal fishing problem in the reserve.

In announcing the proposal, Environment Minister Edna Molelwa states that “A detailed monitoring plan which includes fixed underwater cameras and process will be implemented. Furthermore SANParks has developed an operational plan which includes additional manpower for monitoring of access and regulations of permits.” (As an aside, do you think she’s talking about BRUVs?!)

Where is the funding for the “additional manpower” going to come from? If SANParks can whip it out of a hat at such short notice, why have they failed to provide proper support and enforcement to the other MPAs that they are responsible for?

Motives

Is the community goodwill that will be generated by opening the MPA to fishing sufficient that this proposal can be explained by the proximity of the 2016 elections? (I don’t know.)

If the proposed fishing is “subsistence” fishing as Minister Molelwa’s statement suggests, and stringent bag limits apply, is four days of fishing per month even a meaningful concession to subsistence fishermen?

Balancing human rights and conservation

For the other side of this debate, I ask you to consider how you would feel if you were accustomed to engaging in an enjoyable activity – one that perhaps even made you a bit of money now and then, and fed your family – close to home, but then were prevented from doing so. This is the experience of the angling community around the Tsitsikamma reserve, who were allowed to fish there until the closure of the MPA to fishing in 2000. Many, or even all, of the fishermen who have been campaigning to fish in the Tsitsikamma MPA are from groups of people who have historically had very limited access to South Africa’s resources, who lack the resources to travel long distances to other fishing spots.

Thursday’s post about balancing customary rights to fish with environmental imperatives is required reading for this section of the debate. What might a compromise look like, if you accept the view that the local fishermen have a case for being allowed to fish in the area?

Unfortunately you don’t get to be a thinking adult in South Africa without engaging with some hard questions with shameful historical origins. So get to it.

 How to submit your comments

Send an email to MPARegs@environment.gov.za, or use the postal address provided on page 4 of the relevant Government Gazette (pdf). Send your comments before 1 February 2016. Rationality and respect are never out of place when you’re trying to be heard.

You are welcome to copy and paste from this blog post when you put together your comments, although I haven’t made it as easy to do so as I did with the seal snorkeling issue because I don’t think it’s necessarily quite as clear cut. May I respectfully ask that if you talk to the press on the subject, or communicate about it in any public forum, that you use your own words.

Update (1 December 2015)

It appears that the fishermen are exerting pressure on SANParks to open fishing in the MPA by 15 December. Some sources (facebook) report that this is a done deal; other news sources (Times Live, The Herald) seem to indicate that this aspect is still under negotiation. The facebook report seems credible, particularly given the stroppy tone evinced in the comments by the original poster, when asked for more information.

In any case, giving in to pressure from the community would put the nail in the coffin of any theory other than expediency, ignoring scientific advice, and political pressure as a motive for the opening of the MPA.

Can someone explain to me (or the Environmental Affairs minister) how it is possible to both benefit society (by allowing fishing) AND to ensure the fish are protected for future generations (this would entail keeping the MPA closed)? Do fisheries scientists know that new knowledge has apparently revealed that allowing fishing protects fish? Has someone told them? This quote is from the Times Live article, emphasis mine:

Environmental Affairs Minister Edna Molewa said the move would benefit society and ensure such benefits were protected for future generations.

“The trade-offs between benefits and the protection of the resources that provide benefits are complex and subject to continuous change as human needs evolve and new knowledge accumulates,” she said.

“The government must be prepared to continuously reassess these trade-offs in consultation with its various partners.”

You know what to do. Send a jolly email: MPARegs@environment.gov.za. Send your comments before 1 February 2016. If you don’t send a formal response, but only bleat about it on facebook and other forums, you won’t be heard by the people making the decisions. Be a good citizen!