The Enigma Projected by Marine Protected Areas (2022)

Chapter : THE ENIGMA PROJECTED BY MARINE PROTECTED AREAS.

Now in my dotage, after a lifetime of fishing for fun and for profit, having gained a great deal of personal experience of all types and aspects thereof, my hope is that I might be able to leave a legacy, no matter how small, of wisdom that might be of use to future generations. After all, South Africa and its fishing industry have been the mainstay of my life enabling me to have lived well, to have brought up my children in circumstances of relative privilege, given them a good education, and hopefully set them a reasonable example of adding more to society than what we take from it for ourselves. Do not read me wrong! Much of that example was so far from perfect that I still shudder as I remember and regret my failings. But even the wrong is still a necessary part of their learning, provided you always have the integrity to admit it by drawing their attention to those mistakes you made. After all, we are only somewhat frail and faulty humans with few, if any, exceptions.

Like artists and sportsmen, a fisherman’s skills are unquestionably born in him. How he usesthat ability is up to him, but you probably can’t learn it if you have not been born with it. As a “Fisherman,” is clearly where my skills lay, mainly for fish, then for diamonds, definitely for people, and I have spent the whole of my life fishing for opportunity. Because of that gift, I have been mostly a successful in that direction. However I believe my greatest privilege was to be able to not only enjoy the pleasureof fishing, but to actually be able to make its science my hobby, whilst living in that unbelievably beautiful and exciting world of the marine environment.

Marine protected areas have been an enigma for me for almost 40 years. It was in the 80s of the last century, when the world’s scientists, and others influenced by the green parade and attention seeking activists, became conscious that overfishing was not receiving the consideration it warranted. Following some dramatic decreases in landings from some the planet’s traditional major fishing grounds a decade or so earlier, governments were persuaded by scientists to create marine reserves similar to those on land. It is my opinion that this was decided too hastily, rather than to have considered stricter controls and regulations to reduce catches immediately. After all, the marine environment is as different to the terrestrial situation as oil is to water! This resulted in their proliferation in many countries all over the world, thanks again to over-hasty decisions by institutions like the IUCN (International Union for the Conservation of Nature), who proposed the principle that a minimum percentages of a country’s coastline should be protected against all exploitation on any of its resources, including all fishing activities.

Subsequently, this appears to have been replaced, without any detailed explanations that I can find, by the proposal that 30% of all Oceanic area from the High water mark to the edge of the territorial waters 200 nautical miles offshore should be protected by the creation of MPAs. Is this in addition to, or combined with, the previous recommendation? They were then to be restricted for purposes of scientific study alone, purportedly offering all sorts of other benefits which verge on the disingenuous. With one or two genuine exceptions, where the benefits can clearly be proven, to date there is little evidence that these actions are having, or would have, the desired effect in general!

In fact, there is a growing body of scientists suggesting that such closures are doing more harm than good. However, what has worked has been the total closure of several fisheries following landings been reduced to financially non-viable levels. These have either recovered substantially enabling fishing to have restarted subject to stricter regulations, or are showing definable signs of resource regrowth.

For the last 40 years, particularly after legislation was passed declaring 19 such areas in South Africa, I agonised over their validity and viability, frequently changing my opinion from one extreme to the other. I suppose, with hindsight, that my mind continually absorbed certain facts on the matter subconsciously. Then further legislation in 2019 by the authorities resulted in the creation of over 20 more such areas along and off our coastline. I am afraid this was again mainly motivated by scientists, their associations, and the conservation fraternity, still without much cognizance been taken of all stakeholder’s interests, particularly those at the rock face.

Here, once again, I must repeat my opening mantra of this book, so no one loses sight thereof:

1. In our country, where more than 50% of our peoples go to bed at night underfed, whilst our population continues to increase at an unsustainable rate, the maximisation of food production, from our oceans surrounding us, is an absolute imperative. However, an equal imperative is that such harvesting always has to occur at scientifically proven sustainable levels.

2. Nevertheless, this cannot excuse the one exception to this overall goal. We are a country that is close to being financially broke, with again over 50% of our potential workforce unable to find jobs, and thus improve their standard of living, reduce their dependence on handouts, whilst simultaneously help grow our economy. All of this deems that a first priority in the Marine environment must be to support, without exception, any commercial activity that may lead to the creation of wealth, like recovering our own oil and industrial gas, and for that matter any other needed minerals. Surely, it does not need a genius to appreciate what such development would mean to our overall economy, together with the creation of countless jobs, whilst saving the costs of importing same!

Unfortunately, you again do not have to be a genius, to see how the restrictions generated by the creation of MPAs flies right in the face of the above priorities! Then, I am reminded that, similar to the Phakisa Initiative, the preparation of the Marine Protected Areas Motivation Exercise took six years, from 2006 to 2011, and a large amount of scientists’ time at the cost of millions of Rands dragging on until 2019 Then these proposals, as amended after some further consultation, were gazetted as final Legislation. Was it all worth it? What has it achieved? Well I am probably not sufficiently erudite to answer those questions, but my gut feeling is very little, other than further confusing the wished for simplest manner for Branch Fisheries to do a good management job of their responsibilities. However, I suggest you draw your own conclusions after considering the further content of this chapter. There is however one question that I would like to ask, and that is, “How many scientists have ventured onto fishing vessels to experience the harm that each type of fishing here in South African waters could be doing to the Ocean environment and its contents?” Please don’t answer that you get such conclusions from other scientific reports and papers, whilst sitting at your desks! Particularly in the South African context, they could be wrong!

Finally I have reached my own conclusions. They are not plucked willy-nilly out of thin air, as many will probably suggest. I am often called a contrarian, equally explained away regularly when coupled to the fact that I’m not a scientist, nor scientifically trained. Even if my conclusions can only reasonably be related as simple opinions, my experiences over many years must have some anecdotal value, which, at long last, as opposed to in my youth, is now considered acceptable, and in fact “needed” by scientific researchers. That conclusion is that the importance of MPA’s, though valid in certain instances, is seriously overstated with the risk that the negatives of such a situation often far outweigh the benefits, if any, of unnecessarily created ones.

This leads me to another very important “Query.” Recently, our scientists were thrilled to receive their first genuine underwater research vehicle, and in a very short space of time a group have used it to greatly benefit our research in waters too deep for normal diving. This to be applauded, and I have read with great interest some of the results of their work. What I would like to ask is, “Over the last decade, both in respect of the deeper water research as well as the standard shallow water work, what could not have been undertaken if it had not been inside an MPA.” I suspect the answer is very little, if any at all.

To protect Marine Resources, It seems clear to me that far more can be achieved in one way or another through legislative management regulations. This view is shared by Ray Hilborn, the Professor of Aquatic and Fisheries Science at the University of Washington in the USA, as well as many other scientists worldwide in one way or another.

Before listing all the MPA’s now declared on or off our coastline together with the scientific or other motivation for each’s creation, I would first deal practically with some of such, which are so erroneously, I believe, repeated time and time again. First one must understand the principle of an MPA as it was defined by the World Conservation Union (IUCN 1994). This in itself is difficult to do as the organisation clearly has trouble in explaining how they see it, frequently confusing their uncertain intentions. The very first problem arises in understanding what the difference is between an MPA and a Sanctuary. In my humble opinion, a sanctuary is created to protect a specific species that is not widely encountered but only concentrated in a, or a few, specific easily defined areas. If this is the case, then obviously the risk of overfishing such a species in a relatively short time is considerable to the extent that its mass could be seriously reduced. Let us assume that the scientists consider its strength adequate to support sustainable exploitation, then declaring the areas of its existence and aggregation as Sanctuaries would simplify its carefully regulated Compliance. Alternatively, if its quantitive mass is determined as too little to withstand commercial exploitation, it should be protected by a closed sanctuary with carefully regulated access rights.

They then have a table of seven categories as relevant to a Protected Area. These categories are then given explanatory names further complicated when they suggest that more than one category can apply to each entity, which is of course a nonsense. They should simply note names for different types of Protected Areas with simple descriptions for each. Finally, they contend that this nomenclature should be used for both the Marine and Terrestrial environments, equally confusing nonsense. There should be different names and different categories for each!

They start off with a ‘strict nature reserve’ then a ‘wilderness area’, the first being category 1A, which will be managed mainly for science, with the second, 1B, being managed for wilderness protection. In my language a reserve is mainly a terrestrial location, as with a wilderness. Again this is a nonsense. I will simply deal with Marine Protected Areas and the various categories and conditions that could apply to such an area, if relevant.

The ICUN defines an MPA in this somewhat garbled fashion-: “any area of intertidal or subtidal terrain, together with its overlying water and associated flora, fauna, historical and cultural features, which has been reserved by law, or other effective means, to protect part or all of the enclosed environment.” ‘Once again what nonsense instead of: “Any area of the Sea/Ocean in order to protect that environment, or specie/s therein, reserved by law and/or regulation thereto for the following reasons.”

In a later chapter, I am going to start evaluating the most recently legislated MPAs, as per Gazette no 42478 0f the 23rd May, 2019, which I believe is MPA number 21 on page 5.Together with these I will also deal with the original numbers 1 to 20 created earlier in year 2000, apparently without any explanatory motivations. These have now been added. Unfortunately, as yet, I have not being able to trace any records of many sanctuaries and other restricted areas legislated, I presume, by regional and local authorities! What a mess, and who is responsible for the Compliance and Research for each.

REASONS GIVEN: All sorts of motivations for the creation of all our nationally declared MPAs have been given, some for good purpose, others for “Green” emotions, quite unnecessary reasons, delusional beliefs, with many laughable statements. As over and again in most of these areas the same ones apply every time, I have tried to analyse them to avoid continual repetition in my comments on each.

(1) To contribute to a national, regional and global representative system of marine protected areas, by protecting a linked system of shore, estuarine, bay, island and shelf ecosystems and their associated biodiversity and ecosystem processes in a contiguous coastal conservation area;

i. Firstly, all Estuaries should be separately grouped and regulated providing they are at least part saline, tidal, or occasionally open. Many closed Bays are served by an Estuary, with them then falling under such regulations. I.E. Knysna, Langebaan, ect.

ii. Contiguity with a terrestrial coastal conservation area is irrelevant, as the only Ramsar questionable condition for marine protection does not apply in the South African context.

iii. Exactly what/which Ecosystems, with their associated Biodiversity and processes, need to be protected to be studied. Surely, that must be determined with motivation, as to why they need protection, before you declare an MPA “just in case.”

iv. What do we gain or lose should we go about it in the logical way, rather than simply following the ICUN’s apparently arbitrary recommendation?

(2) To facilitate fisheries management by protecting spawning stock, allowing for stock recovery and enhancing stock abundance in adjacent areas, particularly for line-fish species and Abalone.

i. Firstly, to protect spawning stock in a small area is simply a waste of time. The spawn of nearly all fish of Inshore and offshore species are subject to distribution effected by tides, wave action, sea conditions, and currents, so will be continuously washed In and out of such area, as with the developing juveniles. So what are you protecting?

ii. In a very large area, like iSimangaliso, Tsitzikama, De Hoop, etc., the protection of no fishing will ensure very much higher existence of all largely territorial species. Once an area’s maximum capacity is reached propagation will inevitably slow, thanks to Nature’s own conditionality. If you were to fish that area the catch rates, to nobody’s surprise, will far exceed a regularly fished area. However, suggesting that this then enhances availability in adjacent areas, looks to be nothing more than a pipe dream in my and all other knowledgeable fisherman’s experience. There appears to be no credible proof that this ever occurs for whatsoever reason.

(3) To support sustainable nature-based tourism opportunities in the area through the protection of marine wildlife; and to protect and regulate a scenic area to support sustainable nature-based tourism, cultural and spiritual assets, and a functionally connected coastal marine system to retain a land-ocean ‘sense of place’;

i. These are fancy and meaningless words that say absolutely nothing to motivate the declaration of a MPA!

ii. I know of no Cultural or Spiritual Assets in the ocean. The nearest I can come to anything similar is the propensity of certain religion’s representatives (Pastors) to wish to christen their followers by total immersion in the sea. This can and does happen anywhere, for which you do not need a MPA.

iii. “And a functionally connected ……….. ‘Sense of place.” What utter rubbish!

iv. What protection does Marine Wildlife (whatever that is meant to describe) need as no one predates upon it.

v. The only exception to this might be a famous, well, and frequently used diving area of reasonable proportions that you might wish to protect from other users. Swimming beaches, and the like, should remain the responsibility of local authorities, who should be required to get Branch Fisheries approval to apply whatever limited and conditional usage they would like.

(4) To protect and provide an appropriate environment for research and monitoring, and to promote and contribute to environmental education.

i. Does this mean the education of others, or does it mean to improve the knowledge of the researchers. If the former, or even the latter, what needs to be protected?

ii. Why would the MPA have to be an “appropriate environment?” Surely the need for protection would be entirely dependent on what you were researching or monitoring.

(5) To conserve and protect ecological processes and ecologically sensitive biodiversity associated with these ecosystems thereby facilitating seabed management.

i. Once again, cart before the horse; surely one must establish the ecological systems, processes, and biodiversity to establish whether protection is needed for their study, let alone their management as part of the seabed.

(6) To support the recovery of line-fish by protecting important nursery, spawning, foraging, aggregation, and refuge areas for overexploited line-fish including, Geelbek, Silver Kob, Red Steenbrass, and Seventy Four;

i. Part of this is already explained away in (2) above.

ii. Why would you need to protect foraging areas which either apply everywhere or change all the time depending on what the particular species is feeding?

iii. None of these inappropriately selected species are known to aggregate. School yes, for Kob and Geelbek, being benthic but still migratory. Red Steenbrass are not believed to migrate, but do wander, and we have no idea about Seventy Four, which after too many years have, I think, recovered enough to be exploited again conditionally as allowable Recreational landings.

iv. I believe it can be said about potential ‘refuge’ areas in the same way as (2) above.

(7) To facilitate species management by conserving and protecting an area of life history importance for migratory species including seabirds, turtles, sharks, large pelagic fish, seabreams and other fish;

i. Why and where “an area of life history importance, and what does it all mean. What will protection of an area do for the species noted? If and when they are there, I believe absolutely nothing. Once again, fancy words to try and make up motivation that is nonsense!

(8) To support Eco-certification is a questionable claim, as for years before the consideration of additional MPAs, the Association of deep water Hake trawlers had no problems with certification.

Well, I think that is enough for people to understand what I am trying to explain, so let’s apply them to the motivations noted for each and every MPA listed with my further comment. Where there is no noted motivation, it will simply be my personal comments and feelings about it. Where I have dealt with a motivation used, I will simply refer a reader to it by referring to the above general comments, numbers 1 – 8. It may, therefore, be a good thing for you to print these for easy reference.

The legislation by gazetted notices is covered by annexures xx and xx at the back of the book, and are explained by a SANBI research document/site. To help towards a full understanding of all the implications and intentions of MPAs, I am extremely grateful to have been allowed to attach this as a further annexure.

1) ORANGE SHELF EDGE.

I fail to understand a single good reason for declaring these two areas as MPAs. Against that there some very good reasons not to declare them as such! By the proposers own admission, no trawling occurs there and the only possible fishing is Large Pelagic Longline, which does not need to be protected against, and anyhow the area is outside their traditional grounds. I have also never heard of any sort of aggregations by any species in the areas. All other attempts at motivation are dealt with under my eight evaluation points above.

As opposed to all of this, both areas fall within a basin structure of which less than 20% falls within Namibian waters where huge concentrations of gas with indications of oil as well, have been discovered. The rest, with every likelihood of the same discoveries, are in our waters. However, until development occurs in that regard, what is to stop your intended research in the meantime without any obvious need for protection.

2) NAMAQUA FOSSIL FOREST.

What are you protecting against what? No mining or fishing occurs here, nor is it suggested that gas and oil exploration is likely. One can carry out research unhindered, and anyhow there are plenty of fossil forests in terrestrial circumstances to study onshore along the northwest coastline. All other so-called motivational benefits are dealt with under my eight evaluation points above. The whole northwest coastline mid-shore waters act as a nursery area for juvenile hake to a degree so their protection in small areas becomes irrelevant, and anyhow they are not fished.

3) NAMAQUA NATIONAL PARK.

Firstly, I am not aware that the Groenrivier was a permanently running river, let alone an estuary. If it is, it should be protected by specific estuarine regulations. I can understand why the terrestrial park is important, but do not see the need to protect the Marine environment, which I doubt needs protection as its circumstances are mirrored along the whole northwest coast. I am actually not aware that a ban on recreational or commercial catching of crayfish is actually enforced, and, again, what Marine ecosystems are threatened? All other so-called motivational benefits are dealt with under my eight evaluation points above.

4) CHILD’S BANK.

It seems that much of the fears that might motivate protection are unfounded. No bottom trawling over the bank and its immediate surrounds is possible, but if some of the area of the MPA is trawlable, it should not be in it. For the rest, why does it need protection, as no mining or gas and oil recoveries occur there, or are even anticipated at this stage? All other so-called motivational benefits are dealt with under my eight evaluation points above.

5) BENGUELA MUDS.

I would guess there are similar muds available for study in many areas where bottom trawling is not possible, whilst this MPA, as far as I can see, is right in the traditional west coast trawl grounds. Why? All three motivations stated are dealt with under my eight evaluation points above.

6) CAPE CANYON.

A wholly non-trawlable area that has never been used in the past! However, certainly used by large Pelagic Longliners, Pole vessels, and occasionally Recreational Tuna boats, none of which pose a threat to Research activities, nor Marine mammals, seabirds or ecotourism. All other so-called motivational benefits are dealt with under my eight evaluation points above. So why the need for an MPA?

7) ROCHER PAN.

No problem at all with the Nature reserve, but what use is a three km long by half a kilometre wide MPA, protecting only resting not nesting birds, mainly Cormorants, that do not actually need any more protection above what is already afforded them! To suggest it offers any meaningful protection to continually moving surf-zone fish is simply untrue.

8-12) WEST COAST NATIONAL PARK.

Considerable confusion obviously exists in the minds and knowledge of the MPA motivators regarding this complex of areas making up what is described as the West Coast National Park MPA, being adjacent to part of the terrestrial WC National Park. Firstly fishing from the shore into the sea used to be allowed, and as far as I am aware still is. However, access from the park to the coastline is very limited. Then why fishing from a boat off the shoreline in the sea, if as stated is not allowed, I cannot understand.

Then, confusion reigns as to where you cannot fish from the shore in Saldanha Bay, as does the question as to where the Bay ends and the Lagoon and estuary begin. All lagoons that are open to the Sea/Bay and have an estuarine system should, with their lagoon/bay be subject to separate protection regulations for Estuaries in accordance with their relative circumstances. Then again, the lagoon and its estuary commence well south of Skaapeiland, which I note is therefore not part of any MPA; nor, incidentally, does the estuary or lagoon act as a nursery area for Kob, Geelbek, Snoek, or White Stumpnose.

Although I have no problem with the complete closure of the three islands because of their importance to marine bird life, I doubt the claim that anything like 30% of SA’s African Black Oystercatchers live there! Any further restrictions in or around the islands or Saldanha Bay should

be carefully reconsidered

13) ROBBEN ISLAND.

How does the Robben Island MPA contribute to its Heritage status? It simply does not. Then the whole MPA interferes with fishing grounds of at least eight fishing sectors for no real valid reason. All research can be carried out at other sites, where, in most cases, no protection would even be needed.

All other so-called motivational benefits are dealt with under my eight evaluation points above.

The only valid protection that is relevant, is protecting the Cape Town harbour needs, and this should be considered in consultation with the harbour authorities.

14) TABLE MOUNTAIN NATIONAL PARK.

With the Cape Town Metro, including the Cape Peninsula and the Cape Winelands acknowledged as one of the world’s premier holiday resorts, despite our dysfunctional Government’s best efforts to downplay it, the need for certain protection of the Coastline’s Marine environment for tourism finally becomes justified! However, just like the Saldanha area and the Sixteen Mile Beach, confusion reigns supreme between the Metro, Sanparks, the Regional Government structures, and National Government’s Branch Fisheries. One thing is certain, and that is that the Metro, whether happy to have the assistance of Sanparks or not, should have, if not the final say, at least an equal say, in respect of protective marine and terrestrial legislation, to what extent it should apply, and who should be responsible for Compliance. If present or not, this necessary cooperation is vital, if Cape Town is to retain its current status as a holiday resort of note!

Exactly why the MPA is created as shown, and how the sanctuaries fit in, let alone whose responsibility they are, is very difficult to understand. From boats and fishing vessels no restrictions are clearly stated, nor evidenced by factual control. The same goes for Recreational shore Angling or other activity. I used to know, having lived adjacent to the Peninsula, what you could and couldn’t do, particularly in respect of crayfish; not anymore! Of course there is logic in restricting most activities where heavily built up areas and public beaches are involved; equally where regularly utilised snorkelling and scuba or free diving sites are identified. However, why so far off the coastline? What are you protecting? Certainly not birds or sea mammals, which stupidly includes seals, as all are already protected by legislation. There are also hundreds of kilometres of Kelp forests in the Western Cape. I also fail to see why cultural or historical assets in the sea need protection, if you can find them. Protecting fish species, line-fish or otherwise, is simply a waste of time, as I have indicated many times. In addition, it would be quite unfair from both recreational tourism and marine food supply circumstances here.

15) HELDERBERG.

Let’s deal firstly with the spiritual or cultural assets said to need protection. There are none, unless you count the ocean, which is everywhere! I am well aware of certain religion’s pastors, who wish to christen their flock by way of total immersion in the sea. This is a common sight from time to time on most of the beaches in False Bay and elsewhere, and my bet is that Helderberg is the least popular. This activity bothers neither the participants nor other beech users, as everyone gives the other due respect. Such a tiny MPA makes a mockery of all other so-called motivations as I have detailed.

16) BETTY’S BAY.

This is one of those MPA’s that cause my calling them my enigma. Despite what you might think reading all of this, I am in favour of some large shore based MPAs solely as an example of pristine like environments, where no predation or major disturbance of any sort occurs, as a guide to what the perfect environment would be when over-exploitation does not happen.

The Betty’s Bay coastline is one of those very rich areas, but is far too small. In addition, being close enough to tourist friendly and heavily populated areas, it offers great opportunity for needed relaxation and marine activities. In fact the area immediately west of the MPA is one of the most popular venues to catch recreational Crayfish and Perlemoen, although today the latter activity is illegal. One day, hopefully that regulation will change again!

Although shore based angling is still allowed throughout the area, I don’t see why boat angling should not be allowed say outside one kilometre from the coastal strip (100 metres above the high tide line). No protection, other than for the Penguins, especially when nesting, is needed. For the rest protection for reef fish will achieve nothing, nor for ecotourism and education, which is quite unnecessary, as stated previously!

In fact, in an area which is renowned for its poaching of Perlemoen and Crayfish, normal activities may well contribute to an improvement in this regard.

17) WALKER BAY.

As a limited time per annum Whale sanctuary, it is ridiculous to assume its creation will extend any further benefits as suggested.

As to offering protection at the same time to whales and their young, my enigma again raises its head. Having lived much of my life at Cape Infanta and Witsands with a bigger population of the same whales, though less humans, no MPA exists there. Unlike the Walker Bay situation, where little boat fishing would occur in the sanctuary, plenty does off the Breede River mouth, and it is the boats that often feel they need protection! The inquisitive and friendly behemoths approach and encircle them, often in the company of their calves, perhaps to explain to them what we and our boats are, with no need to fear us. Those boats containing sightseers, as opposed to fishermen, exit the river mouth, avoiding the whales that like to lie there, proceed out into the bay, and then stop and wait for the whales to come to them! Makes you wonder why protection is even considered.

18) SOUTHEAST ATLANTIC SEAMOUNT.

No problem with your intention to research what you list, if and when you have both the time and ability to do so. However, why do you need protection to do this? The only type of fishing possible in this whole area is Large Pelagic Longlining, which will not get in your way, and does no damage of any significance to the pelagic marine environment.

All other so-called motivational benefits are dealt with under my eight evaluation points above. Please note, however, that the Seamounts are south, not west, of Cape Point.

19) BROWNS BANK.

The only fishing that can occur here is for Large Pelagics and possibly some Hake Longlining, none of which would interfere with spawning hake, nor benthic Corals, etc. Perhaps the scientists should make sure what they need to research first that would justify MPA protection. All other so-called motivational benefits are dealt with under my eight evaluation points above.

21) DE HOOP

All the so-called motivational benefits are dealt with under my eight evaluation points above.

However, this MPA, adjacent to what should be one of the most popular terrestrial natural game, avian, and floral reserves in the Western Cape, is one that I would earmark as one worthy of being maintained for its value as an example of a rich pristine area. It has, only from time to time, circumstantially been very lightly exploited for over one hundred years

However, its facilities and services, like guided tours, need to be urgently upgraded by Cape Nature, who should also be responsible for the MPA. Then it needs to be properly publicised. It seems quite wrong to extend the seawards boundary to more than one kilometre from the shoreline, as presently it interferes with both inshore trawling and line-fishing.

The scientific researchers can now do and imagine whatever they like inshore here!

22) STILBAAI.

Both the Estuary mouth and the Harbour area, should be controlled by their respective Authorities and relevant Regulations, The cultural assets only need protection from the often destructive ocean, which no MPA will ever achieve! All other so-called motivational benefits are dealt with under my eight evaluation points above. Anyway, I believe the creation of such a small MPA to simply be a waste of time.

23+20) AGULHAS BANKS COMPLEX AND AGULHAS MUDS.

I have combined these two MPAs as they are virtually the same being adjacent to one another. In addition I suspect that the Agulhas Muds interferes with traditional Inshore Trawling grounds, yet the Muds that the scientists wish to evaluate also occur in the overall Agulhas Banks complex in many places both shallow and much deeper. It is common cause that there are hundreds of square miles of this complex where no bottom trawling is possible. Establish, plot, and warn other users including non-damaging fishing activities to give you a wide berth, when you are onsite, and you can research a myriad of environments without the need of an MPA.

Anyhow, I am a bit confused as to the need to create so many MPAs in order to research mud ecosystems. I suspect, without admittedly any comprehensive knowledge about such ecosystems, that most are very similar with only minor environmental changes relevant to depth temperature and pressure. Other than in very shallow water, I understand that depth temperature is not normally affected by surface temperature in the case of temperate to tropical oceans.

Of course, the Agulhas Banks are one of the best natural environments for the propagation and protection of our line-fish and benthic fish species resources, as very little consumptive exploitation occurs there. Being adamant about the failure of any indication that inshore MPAs reinforce stocks in adjacent areas, I am at a loss to judge the effect of a vast area like the Agulhas Bank system. However gradual spreading of its resources hopefully may occur. Despite this, certainly inshore of them, there is no indication that coastal angling or boat fishing is measurably better than other areas where such an offshore system is not present. Surely, because of their huge extent, it seems unnecessary to create any MPA over them, especially the inside sections where a degree of bottom trawling and boat line-fish exploitation is possible and needed. For the rest, exploitation limitations on the various fishing sectors by means of an MPA is pointless. Deep water crayfish trapping does not require it in view of the strict Quota controls. Longline and pole fishing catch relatively small quantities of their overall landings there. Pelagic fish, marine mammals, and birds, merely pass through the area, and would gain nothing from its protection, whilst benthic scientific study is unlikely to be negatively affected as I have noted above.

Incidentally, the statement about the activity of foreign trawlers exploitation could not be more wrong. The only known trawling activity in the region occurred at the behest of Fisheries, who asked the Japanese to experiment with rough bottom Bobbin Trawl nets in order to establish whether such method was viable. Continuous loss of costly gear and the fish that might have been caught by it, soon resulted in the Japanese pulling out, and recommending that such exploitation was hopelessly impractical and unviable due to the nature of the bottom!

All other so-called motivational benefits are dealt with under my eight evaluation points above.

24) SOUTH WEST INDIAN SEAMOUNTS.

Firstly, this is offshore south of Mosselbaai, not Cape Point. Then, I doubt whether any oil and gas exploration would be limited to the corridor you have chosen to leave between the two MPAs. Then with the only possible fishing activity being Large Pelagic Longline fishing, which happens to seldom occur here, why do you need protection for scientific research. Certainly none is necessary for seabird foraging, no matter how rare the specie may be, nor for that matter anything else!

25) GOUKAMMA.

The Estuary and Knysna Lagoon (not Bay) should be protected by a separate authority, and, once again, the size of this MPA would negate any real benefits. All other so-called motivational benefits are dealt with under my eight evaluation points above.

26) ROBBERG.

One must ask once again, what is this MPA protecting? Not Seals and Seabirds feeding areas, for why and against what do they need protection? What possible harm would Boat Recreational fishing do?

27) TSITSIKAMMA.

Possibly the oldest large marine reserve in Africa dating back to 1967, it was officially renamed an MPA during the first listings thereof in 2000.

I am old enough to have had the privilege of fishing there in the middle 1950’s with Howard Andrews, an Eastern Province rock and surf team angler at that time. Climbing down those near vertical cliffs with your tackle took nearly an hour, and back up again with the limited amount of fish you could carry, over an hour and a half! On my very first trip, with his help, I landed the largest Red Roman either of us had ever seen then or since. He estimated it to weigh over twenty pounds (around ten kilograms). It was hardly red, been a dirty brownish white colour with the only signs of red and proper white on its head and tail. When I picked it up in my arms to move it to our fishing bags, it flapped out of them and slid of the rocks back into a deep gulley from where we had landed it. Howard commented that in fact we should have let it go anyhow, but that he should have photographed it immediately!

Today, it is to a degree compromised in that local Community members are granted individual permits to fish from shore in about 20% of the length of the MPA. They are so-called “historically empowered artisanals,” though in my youth we never encountered any member of those communities fishing then!

This again, like De Hoop, deserves to be treated and protected as a near-pristine area. It is already a very popular tourist hiking venue, and is much better managed as such by Sanparks.

28) AGULHAS FRONT.

The only fishing that occasionally occurs here is Large Pelagic Longlining which neither interferes with, nor damages anything. All other so-called motivational benefits are dealt with under my eight evaluation points above. So why the necessity for an MPA?

29) PORT ELIZABETH CORALS. Some years back, when Longlining for Hake was first allowed, the participants soon learnt that they could specifically target Kingklip far more profitably than Hake. This was then followed with the realization after a few years that this was reducing Deep-sea Trawl landings as a result of Longlining over exploiting the overall Kingklip resource. This resulted in Regulations limiting the allowable landings of Kingklip.

During the scientific investigation into the reasons for declining landings, it was discovered that in the area adjacent to this now declared MPA, aggregations of spawning Kingklip occurred. On the advice of the scientists, the Deep-sea Trawl and Longline Hake industry sectors then agreed to voluntarily not fish in the Kingklip Block, as it came to be known, for certain periods during the year. This is absolute justification for the creation of an MPA that incorporates the Block to try and hasten the rebuilding of the diminished stock, irrespective of the other motivations put forward.

30) SARDINIA BAY.

The creation of an MPA here does nothing to enhance the pleasure of the coastal walk, and the other projected benefits are meaningless in such a tiny MPA. Anyhow, all other so-called motivational benefits are dealt with under my eight evaluation points above. So why the necessity for an MPA?

However, this area happens to be adjacent to the very prolific and largest known aggregation area for Squid in South African waters, which is the main resource for this fishing industry sector. This clearly would justify the creation of an MPA to protect it, instead of the one above. Why has this not happened?

31) ADDO ELEPHANT NATIONAL PARK.

As always, the whales and sharks do not need protection over and above what they presently enjoy through Regulations. The same goes for penguins and gannets, with nobody denying that the Islands are important in this regard, but how does an MPA protect their foraging? Nor will the importance the terrestrial park be diminished without an MPA adjacent to it, and the terrain of the park does not favour seeing the so-called big “Big Seven” from the coast, or is it 8, 9. or 10. At the same time the Estuary is already subject to protection not linked to MPA regulations. Lastly what protection does nature based tourism require?

For the rest, all other so-called motivational benefits are dealt with under my eight evaluation points above. So why the necessity for an MPA?

32+33) AMATHOLE INSHORE AND OFFSHORE PROTECTED AREAS

The three small inshore areas restricted with only no boat fishing allowed almost certainly do not improve the offshore boat fishing as the local clubs and fishers believe. However, with no other benefits accruing through being denominated as MPAs, if the locals wish to maintain the status quo, the Metro should take over responsibility for their management.

However, when it comes to the offshore areas, and the benefits purported to be derived therefrom, all my previous criticisms of MPAs rise again. Rather important line-fishing occurs in the inshore sectors of these two MPAs and virtually no trawling anywhere, only a bit of Large Pelagic Longlining. The southern end of the Gxulu area represents at times the extreme end of the grounds for Squid and deep-water crayfish trapping, neither of which activity should be interfered with. As a result scientific research does not need protection. For the rest, all other so-called motivational benefits are dealt with under my eight evaluation points above. So why the necessity for these MPAs?

34) DWESA-CWEBE

35) HLULEKA

Both these MPAs are too small to be effective in any form that might warrant protection. Estuaries should never be protected in the form of an oceanic area, but in terms of their own Regulations and authority specific to each one. In neither case does justification exist to ban boat fishing for Line-fish or Large Pelagics. No offshore trawling or other types of fishing activity take place in the area, so what are you protecting from what.

It’s amazing how often the protection of aggregating juvenile hammerhead sharks is used as a motivation for protection from here right up to SA’s border with Mozambique. If so many, why do they need protection? Of course, they don’t, nor do they aggregate. They are one of the very few shark species that shoal and then cover very large distances in search of food!

For the rest my counter for motivation reasons remain dealt with under my eight evaluation points above. So why the necessity for these MPAs? However, one of the most important reasons for their disbandment is the coming inevitable conflict between their existence and the aspirations of community artisanal needs and promises!

36) PONDOLAND. The Wild Coast.

My enigma again! Firstly no fishing of any sort other than offshore boat, rock and surf, and inshore crayfish, octopus, mussels, oyster collection, occurs along this coast. Offshore, there are no known grounds for bottom trawling or any other fishing activity. Then, as above, the problem of small scale artisanal fishing is going to arise. I am not clever enough to offer up a solution. Of course, estuaries should not come into the further discussions that will have to take place.

Once again, all other so-called motivational benefits are dealt with under my eight evaluation points above, if they end up having any relevancy in these circumstances!

37) TRAFLGAR.

This tiny MPA has always been an absolute waste of time!

38) PROTEA BANKS.

There is no together (with Trafalgar) as the MPA only begins two to three kilometres out from the coastline! I am glad that you acknowledge that hammerheads school, not aggregate, but, to the best of my understanding Raggedtooth and giant Guitar sharks do neither. I also do not see that the sharks can offer tourism anything, as they are not visible from the coast, nor normally seen on the surface from a boat. The area is already a much sought after tourist area, and it is difficult to see how this MPA will boost same.

What are the ecological processes of the Sardine Run (Spawning migration) that need protection, and since when are certain sharks, including hammerheads and tiger sharks, threatened, let alone exploited in any way? Apart from inshore line-fishing, which should not be interfered with, only properly regulated, no fishing that will affect any of this MPA occurs in it, or even near to it.

Once again, all other so-called motivational benefits are dealt with under my eight evaluation points above. So why the need for MPA protection?

39) ALIWAL SHOAL.

Most of which applies to the Protea Banks above, also applies to the Aliwal Shoal MPA. For the rest, no Commercial fishing of note occurs in the MPA, other than Line-fishing, and, once again, all other so-called motivational benefits are dealt with under my eight evaluation points above. So why the need for MPA protection with the one exception of the Crown scuba diving area which should then restrict all other activity except non-consumptive boat tourism excursions? I am not aware of any Shark Cage Diving undertakings anywhere in KZN. However, if I am wrong, the similar and other necessary protection should be afforded to that location as well.

40) UTHUKELA BANKS.

The Tugela Bank, its common name used by most scientists, the local KZN Fishing Industry and the general public, is a very complex area. Immediately adjacent to its Eastern edge are some very rich deep-sea trawl grounds, some of which now fall inside the MPA. In its centre is an extremely rocky area where no fishing of any sort occurs, and is also too deep for line-fishing. Against the coastline off the Tugela river mouth lie some small but extremely rich Penaeid fishing grounds. Their abundance is almost entirely dependent on the nursery area of the St Lucia Lake system, which having closed for the last twenty years or so effectively weakened this resource so much that it has not been viable to trawl.

Stories that were publicised about this fishery, its interference with propagation of so many species like turtles, juvenile hammerhead sharks, and all sorts of other fish, are so ridiculous to the point of delusional thinking. The same applies to its dangerous levels of discarded and the destruction of bycatch!

Nearly all the admittedly complex and interesting features and ecosystems that the scientists wish to study are to be found in the unfishable areas so what is the formation of this MPA protecting them against.

Perhaps most important of all is the fact that the Crustacean trawl fishery is only just financially viable without the cream on the top of the inshore resource. Now every effort is been made by the authorities and scientists to open the lake system permanently again. Then it would be expected to only take a few years for the inshore Prawn resource to return to its previous strength. The importance of the small Crustacean Trawl Industry cannot be overstated for the product that it produces that attracts tourism to the Durban area, and for the jobs it creates!

Once again, all other so-called motivational benefits are dealt with under my eight evaluation points above, and no Estuary should fall under an MPA.

41) iSIMANGALISO.

This is part of my Enigma complex once again, with my having fished/explored recreationally this whole Coastline whilst living in KZN for some fifteen years. You can also say that I have had the same experience commercially, except that was in the negative sense. There are no financially viable fishing grounds in the area from just north of St Lucia right up to the Mozambique border in any offshore or inshore area of the present MPA. No other fishing occurs apart from a bit of Large Pelagic Longlining and Recreational. So why have most of this area protected?

By the way, the World Heritage and Ramsar Sites have nothing to do with the sea, only the lake and estuary systems, all of which are controlled by independent regulations. As I have stated time and time again, these should also fall under a separate body for their management.

As local and other regulations protect both the Turtle nests and the sub-tropical Corals, what other activities endanger them that an MPA would give protection against?

Once again, I believe implicitly that it is wrong to suggest that overfishing will be reduced by the creation of MPAs. Only sustainable exploitation levels determined by science and managed through relevant regulations will do this, as what is not caught in the MPA may well be caught elsewhere effecting the same reduction in overall resource levels. This applies equally to nearly all line-fish species despite what many scientists will claim.

Despite what they claim, I am yet to read, let alone experience, any conclusive evidence of the stock of an MPA in any way enhancing inshore populations of any other neighbouring, inshore environments, not even those immediately adjacent to them. Yes, the inshore protected area does improve its local population over time when no fishing is permitted, but only up to a point, which is at this stage still to be determined. Who gains, whilst the fishermen, including artisanal communities, lose out? Then, what do the large pelagic fish have to do with it, any more than the whales, whale sharks, coelacanths, seabirds, turtles, sharks, marine mammals, etc? What protection do they need, and what can a protected area offer them In this regard. Yet again, all other so-called motivational benefits are dealt with under my eight evaluation points above.

Perhaps a part of this again, like De Hoop, deserves to be treated and protected as a near-pristine area. It is already a very popular tourist and hiking venue increasing in popularity all the time!

As an aside, I would like to give you some details of two of my own experiences, (and there were many more of mine and of many other close fishing friends,) that negate the belief that protected areas give rise to enhancing fishing in areas adjacent to them. When I arrived in KZN back in the 1980’s, I soon found myself in the company of a group of rock and surf anglers, which included two Provincial and one South African team members. They introduced me toangling from the beach at Vidal, where, if you knew what you were doing, you caught very nice inshore reef and gamefish. One afternoon, when the sea was a bit rough, we had driven north while trying different spots but catching very little on the way. We then reached, unbeknown to me previously, the boundary of the fishable area, after which fishing was banned. I then said are we not going to fish here as fish from the sanctuary must overflow into the fishable area. “No,” said Ian, “both Rudi and Bruce from the Oceanographic Research Institute have told us the same, but it is just not true,” I said it had to be right, and though we did then fish there, no one got even a bite.

By now it was quite late, so I suggested there would be no risk of Parks Board patrols any longer, so let’s go a kilometre further into the reserve and try there. In the face of a bit of grumbling that we could all lose our fishing licences and get fined, we eventually did. After choosing a nice looking area, we all cast out and were into fish within minutes. After Douglas commented that it was probably a fluke, we went a little further with exactly the same result. Believe it or not, we released all the fish we caught inside the reserve!

We then went back and chose a nice looking place outside the reserve. It was now the perfect time to fish with the sun setting, a rising tide, and diminishing swell; so the five of us fished until dark for the princely reward of one small Blacktail and a barely size Shad which must have got lost! Again, whether you believe it not, we did the same exercise again once on the Red Cliffs, and then also on the Sodwana side with the same results.

The second relates to De Hoop in the Western Cape. Here, I had a house on the Infanta side of the Breede River with it having been my main home for many years. The coastline from the lighthouse to the river mouth was adjacent to the end of the reserve, and friends of mine actually had a holiday house on the boundary. Coincidence or not, they always claimed to land more fish from the cliff rocks inside the reserve than when fishing anywhere to the north eastern side of the house. My experience over many years was that I fished inside the two bays that these cliffs formed, both almost an exact duplicate of the other as far as size, depth, rocky bottom and kelp beds were concerned, with neither been ever over-fished. The water was normally clear, and from my boat you could see the Red Roman, Hottentot, Steentjies, and Bamboevis swimming around the reefs in and out of the Kelp. For whatsoever reason, there was almost five times the amount of fish in the bay inside the reserve than ever in the outside bay maybe a kilometre away. Far from the rock and surf landings for the next ten or more kilometres from the reserve boundary showing any improvement, it was only beyond that this occurred remaining constant thereafter, but nothing like former times.

42) THE PRINCE EDWARD ISLANDS.

I find it difficult to evaluate the whole situation of this internationally recognised very small part of South Africa’s land mass, yet very large part of our extended territorial waters. As far as the latter are concerned, the whole area is declared an MPA. For what reasons I am unsure, but as the only type of fishing available there is Longlining for Patagonian Toothfish which is permitted, I guess no harm in this. I understand there is a research base established there which, I think links up with a research base we man, in terms of international agreement and funding on the Antarctic landmass or, presently, permanent ice shelf. Who is responsible to manage the island base and finance it, I also do not know. I gather one of the main terrestrial requirements is to research and protect the Irelands’ breeding seabird colonies, though again I am not aware under whose control. That should not be a Fisheries matter. Nothing, however will interfere with any scientific ocean ecosystem research Fisheries determines should be carried out there.

NOTES to the above:

1} So there can be no misunderstanding, I wish to repeat that all the above is simply my opinion, and, as much as I would like to discuss them with the scientific promoters of these MPAs, I seriously doubt that I would be afforded that privilege. I am not a trained scientist, and the study of fisheries, ocean, and related science is simply, and always has been, my hobby. I could never be so egotistical as to claim that my opinions must be right. I would just like to believe that it would be worth evaluating them. Getting meaningful legislation passed by our incompetent Government is a big enough job. Trying to get it reversed would probably be a waste of time!

2} I have criticised the motivations put forward in ministerial legislation of 2019. Then because the authors and collaborators of the South African Biodiversity Institute have done such an excellent job of evaluating not only the 2019 list of MPAs, but also the original 2000 legislated list, I have combined my overall criticism based on both evaluations.

3} Forgetting initially the question I continually ask as to the explanation of why the various MPAs are needed, nowhere does the various legislation and literature even consider the question of Compliance management for these zones. This raises two very important questions. The first is that if Compliance Management is not important, there can be no need of it, and therefore, by the extension of natural logic, surely no need for a declared MPA.

Secondly, if there is need for it, is everyone assuming this will be the responsibility of Fisheries, the Navy, or the Air Force? Here we must remember that Fisheries seaborne ability to patrol is very limited both manpower and competence wise, let alone financially, with most of their long distance patrol boats non-operative.

To further complicate matters, the Navy is about to receive three new specially constructed patrol vessels where the motivation to order same originally was primarily to carry out fishing compliance patrols. The various ironies of the situation are that they took a year to decide that they lacked the competence to run Fisheries’ own vessels for this job, after offering to do so, and presently have several suitable vessels, amongst several others, laid up. Again this appears for lack of competent manpower, so what will have changed to see them operating these new vessels successfully.

4} One thing is certain, and that is that the various authorities ability to effect particularly Benthic Ocean Research has developed dramatically since the start of this century. That ability to acquire and operate very sophisticated equipment so effectively is startling and brilliant. However, this leads to my one embarrassing question already asked: “How much of this Research undertaken would not have been possible if the area involved had not been an MPA.” Only my gut feeling, but I suspect very little if any at all! So again why the complexities of these MPAs for Research.

5} Despite the comprehensive list of 42 MPAs, I see that there a whole lot of other restricted areas that are not listed. These arise from restrictions placed on areas under the domain of Metros, even some coastal Municipalities, Harbour Authorities, by way of fishing sector conditions, and even by general legislation. All restrictions placed on area in and below the legislated coastal strip, should be registered and listed with the Department in full detail, as per the working list on the pages above.

6} I am confused in trying to understand what motivates our Government to seek to increase our territorial waters. I fail to understand what advantage this would afford us, whereas on the negative side we are nowhere near competent to patrol and look after our present territorial waters. Perhaps someone could enlighten us?