P.L.U.G. Submission on Proposed Biodiversity Statement

P.L.U.G. Submission on Proposed Biodiversity Statement

By Andy Loader, Chair P.L.U.G.

‘Biodiversity’ refers to all living things. This includes all plants and animals and the places in which they live. Aotearoa has rich and unique biodiversity, but over 4,000 of our indigenous species are threatened or at risk of extinction.

DOC is leading a consultation for an action plan from 2020. New Zealand’s last biodiversity strategy laid out actions to protect our nature until the end of 2019. The new strategy will set a vision and guide our biodiversity work for the next 50 years.

New Zealand provides comparatively few incentives for landowners to conserve biodiversity. For example, if a landowner decides to set aside land for biodiversity, perhaps in a Queen Elizabeth II covenant they bear a cost while the benefits of enhanced biodiversity are spread much more widely.

Over the 20 years since 2000 there has been an increase in the level of engagement and commitment to biodiversity protection and restoration from local councils and communities.

Areas of significant biodiversity on land (places which have been identified to contain threatened species or rare or naturally uncommon ecosystems) and freshwater and coastal wetland habitats are still being reduced today, pointing to a failure to protect them.

There is also a wider suite of threats and issues that haven’t received enough attention – with one of the main ones being the rapidly expanding numbers of Koi Carp. Koi Carp being endemic to the lower Waikato and Waipa river systems, with smaller populations in other areas.

The new proposed strategy for Biodiversity states the following:

The vision we see for New Zealand by 2070 “Nature in Aotearoa is healthy, abundant, and thriving. Current and future generations connect with nature restore it and are restored by it.”

Amongst other things, this means that, in 2070:

  • Our species, habitats and ecosystems (especially those that are currently rare and threatened) are increasing, not declining, in number and extent, across private as well as public land and in the sea;
  • This increase is not just captured in statistics, we can all see and feel it – for example, the dawn chorus across Aotearoa New Zealand sounds like it does on our offshore islands;
  • Thriving nature is seen to underpin our economic success and wellbeing, rather than being seen to be in conflict with it – economic growth is a net restorer, not a net sub-tractor, of our natural environment;
  • Biodiversity is core to all decisions about land and water management, including on private land;
  • Everyone who wants to can access nature and gain the benefits of doing so, no matter where they live, and can, if they wish to, be a part of restoration;
  • Mana whenua feel that they can genuinely practice their role as kaitiaki, and nature is thriving to the extent that they are able to practice customary take.

Yet with the failure at all levels (Central, Regional & District) of government to effectively address and put in place control measures for Koi Carp (A well-known omnivorous pest predator fish) we will never be able to see “Our species, habitats and ecosystems (especially those that are currently rare and threatened) are increasing, not declining, in number and extent, across private as well as public land and in the sea;” actually increasing.

The Biodiversity statement also has the following:

By 2030, if we have been successful, we will see:

  • No net loss of extent of rare and naturally uncommon terrestrial indigenous habitat (active sand dunes, braided riverbeds, estuaries, cloud forests etc)
  • Ten key freshwater pest species and ten key land-based weed species are reduced or controlled to a level that does not diminish ecological integrity.
  • Marine Protected Areas established in priority areas, and priority risks being actively managed. Indicators are demonstrating positive changes.
  • New Zealand acknowledged internationally as a source of biodiversity protection and restoration know-how.

Given the effects of uncontrolled expansion of numbers of Koi Carp which must be seen as one of the top freshwater pest species we will never be able to achieve this objective.

In fact with the current level of knowledge regards the Koi Carp and their effects on the freshwater ecosystems, we need to acknowledge that without putting in place some form of control we have failed currently and will continue to do so into the future.

The Biodiversity statement also has the following:

By 2050, if we have been successful, we will see:

  • Overall, the net extent of indigenous ecosystems is increasing.
  • The extent of our undegraded rare and naturally uncommon terrestrial indigenous habitat (active sand dunes, braided riverbeds, estuaries, cloud forests etc) is increasing.
  • The number and extent of our freshwater and coastal wetlands is increasing.
  • Ten key freshwater pest species and ten key land-based weed species have been eradicated.
  • Aotearoa New Zealand is free from stoats, possums and rats.
  • All established pests are reduced to the level where ecological integrity is not diminishing.
  • Populations are increasing for all our threatened species.
  • Bycatch of seabirds, corals, and marine mammals is reduced to zero.
  • Mahinga kai, cultural take and sustainable use of our indigenous species is taking place.
  • Every business is helping to restore nature.

All of the highlighted areas of the Biodiversity Statement that are shown above will be shown to have amounted to a massive failure without some form of control being placed on Koi Carp.

Koi Carp are an omnivorous feeder and they cause erosion of waterway margins as well as a severe degradation of water quality through release of sediments and consequent raised levels of Phosphorous which in turn support the increased levels of algal blooms in our waterways.

Koi Carp feed on the eggs and young of our native freshwater fishes as well as destroying their natural breeding habitats by this erosion from their feeding methods. They are able to survive in severely degraded water quality where our native fishes cannot, they have a highly successful breeding rate in the New Zealand conditions and this coupled with the lack of any natural predators in our waterways, makes them in my opinion the number one pest species in both our waterways and the riparian margins to those waterways.

The Biodiversity statement also has the following:

Proposed system shifts

The following section sets out five proposed system shifts for implementation. These have been identified based on what people have said are the most important areas to focus our efforts in the first five years of the strategy. It is proposed that by being focused and taking coordinated action in these areas, we – all New Zealanders – could make the greatest progress towards the goals and long-term outcomes of the new strategy. The system shifts are intended to be the main areas for investment and change across the biodiversity system for the first five years of the strategy. After this first five-year period, they will be reviewed to see if they are still the most important areas to focus on.

Our current biodiversity system isn’t working as well as it should. It fails to tackle issues at the scale needed to address the ongoing and cumulative loss of indigenous biodiversity. People have strongly voiced that action in this area must be a priority and that it needs to happen now in order to address the range of drivers of biodiversity loss.

There is currently a lack of coordination and clarity around who is supposed to do what. Central government (mainly the Department of Conservation, the Ministry for the Environment, Fisheries New Zealand, Biosecurity New Zealand and Te Uru Rākau) and local government have legislated roles and responsibilities for biodiversity, but these are ambiguous, and result in different approaches across the country.

The new biodiversity strategy will provide priorities at the national level and will support more detailed and specific planning at a regional, local and sector level. Local authorities have responsibilities under the Resource Management Act 1991 for land use planning and the management of natural resources. They do this through polices and rules in regional and district plans. Regional Councils also have responsibilities for biodiversity and biosecurity management. National direction, such as a national policy statement, can guide how district and regional plans are developed.

At present there is a lack of cohesive prioritisation or direction in the biodiversity system. It’s hard for everyone involved in the system to see how they fit together, where there are overlaps or gaps, and how to share knowledge or resources. No one has a role to facilitate coordination, partnerships and communication between those involved. A shift in culture across the system from one where entities work in silos to one where there is true collaboration, co-design and partnership would deliver better outcomes for nature.

We need to enable community ownership of biodiversity action. We also need to provide consistent, effective and targeted best practice advice, support and capability-building that is accessible to all individuals and groups. We need to standardise, align and simplify funding processes and ensure funding is tied to delivery of biodiversity outcomes.

There is an opportunity to enable and support local people, in monitoring and restoration projects.

Case study: The Waikato Biodiversity Forum

The Waikato Biodiversity Forum was formed in 2002, in response to the release of the New Zealand Biodiversity Strategy and its suggestion that regional networks be set up to better co-ordinate biodiversity efforts. It has been the first and longest running regional biodiversity network of its kind in New Zealand. The Forum is an enabling body which helps make biodiversity groups visible and utilises its strong network to connect groups to resources which are available to them (advice, funding etc), but may be difficult to source on their own. It utilises an interagency and community approach to support its biodiversity community, which creates efficiencies through collaboration. Over 450 individuals and groups are part of the Forum, including iwi, agencies, research providers, community and landcare groups, NGOs, plant nurseries, private landowners and interested individuals. The Forum recognises that no one agency, sector or element of society has all the answers to the biodiversity issues we face regionally and nationally – there is a need to work together.

This Waikato Biodiversity Forum was formed in 2002 and yet here we are in 2019 (17 years later) and still without any credible strategy to manage, control or eradicate Koi Carp.

The Forum is supposed to be an enabling body and with that in mind I question what exactly they have spent their funds enabling, as I can see no credible value in their existence. Koi Carp are still expanding their numbers exponentially and spreading their habitat with all of the accompanying deleterious effects on the waterways and our native flora and fauna. 

I have included a copy below of an excerpt from a report in relation to Koi Carp in Lake Ohinewai and I do so because it shows that the effects from Koi Carp were known back in the early 1990’s and yey we have still not got a credible strategy for control or eradication.

Whilst it is great to have a Biodiversity Statement/Strategy that puts in place templates for the process of developing plans for how we will control or eradicate pest fishes, it is much more important to actually do something physical to fix the problem.

So overall this submission has two parts;

  1. The need to recognise Koi Carp as an extremely serious pest that can affect our native flora and fauna in many detrimental ways.
  2. The need to put in place a physical system to actually deal with the problem rather than spend more time and money discussing how to go about it.

The problem has now reached such serious proportions given the estimates that there are approximately 500,000tonnes of Koi Carp in the Lower Waikato and Waipa River systems, that Koi Carp are actually a much bigger problem in relation to water quality in that area, than both farming and urban development combined.

I am also reliably informed that there have been Koi Carp released into the Lake behind the Karāpiro Hydro Dam. If this is actually true then the perpetrators of this release should be treated as environmental terrorists and face the maximum penalties available under the law.

Andy Loader
Co-Chairman P.L.U.G.
Primary Land Users Group.


5.2 Removal of Invasive Fish and Exclusion of Koi Carp from Lake Ohinewai

Grant Tempera 1, Nicholas Ling 1, Adam J. Daniel 2 &: Dai Morgan 3

  1. ‘The University of Waikato, Hamilton, New Zealand
  2. ‘Auckland/Waikato Fish & Game Region, Hamilton, New Zealand
  3. NorthTec, Whangarei, New Zealand

Management Issues

The lower Waikato River floodplain contains many shallow lakes. The floodplain has been highly developed for pastoral agriculture, primarily dairy farming, resulting in extensive drainage and flood control measures to regulate river and lake levels. Most lakes have degraded water quality as a result of nutrient and sediment enrichment, and the additional impacts of pest fish such as koi carp, goldfish, catfish and rudd have generally contribute9 to the total collapse of submerged macrophytes and progression to a highly eutrophic state. Of all New Zealand lakes monitored regularly for water quality, around 25% of those categorised as supertrophic or hypertrophic are on the Waikato River floodplain (Verburg et al. 2010).

Lake Ohinewai is a shallow (4.5 m depth), 16.8 ha lake on the floodplain. The lake has a 331 ha catchment that is primarily flat and dominated by intensive pastoral farming with several inlet drains. A single outlet drain leads to Lake Waikare via Lake Rotokawau and passes through a circular road culvert 930 m from the lake outlet. Lake Ohinewai deteriorated from a stable oligotrophic (macrophyte-dominated) state to a stable eutrophic (algal-dominated) state during the early 1990s, and now lacks aquatic macrophytes. In 1981, 80% of the lake was covered in aquatic macrophytes but by 1991 none remained (Edwards et al. 2005). 

Invasion by koi carp over this period was implicated in this change of state.

Lessons Learned

It is highly likely that the biomass of koi carp in this lake contributed to persistently poor water quality and the algal-dominated eutrophic state.