Protect Avaavaroa Passage
Who we are and our interest
Snorkel Cook Islands is a locally owned, shore-based turtle snorkel tour business that has operated at Avaavaroa since 2018. We don't use motorboats or sea scooters, so we have a commercial interest in how the passage is managed, and we say so openly. We have not signed the Cook Islands Tourism Turtle Tour MOU. This page explains why.
Environmental impact
Engine noise
- When boat noise was added to reef sound, 44% of settlement-stage reef fish larvae swam away from it, compared with 8% when reef sound was played alone.1 Fewer larvae settled on reefs where boat noise was played.2
- Motorboat noise made reef fish six times less likely to startle at a simulated predator. In field trials, predators ate more than twice as many prey fish while motorboats were passing.3
- In one coastal turtle foraging area, noise within the turtles' hearing range was 26 dB higher at busy boating times than at quiet times. The researchers say this could affect turtle behaviour.4
Fuel and oil
In conventional carburetted two-stroke engines, "up to 30% of the fuel passes through the combustion chamber unburned or partially burned", and is released into the water and air (US EPA).5 Losses are highest at low speeds,6 and modern direct-injection engines cut unburned hydrocarbons by 70–90%.7
Propellers and speed
Only 4% of green turtles moved out of the way of a vessel travelling at 19 km/h, compared with 60% at 4 km/h.8 In tests, propeller guards did not prevent catastrophic damage to model turtle shells at 40 km/h.9 Hawksbill turtles are Critically Endangered.10
Safety hazard
Cook Islands Tourism has described the passage as "notorious for drownings".11 It has also said that "voluntary compliance alone is not enough".12
What the law requires
- Every motorised vessel under 24 m must be registered, and anyone driving one needs a Motorised Vessel Drivers Licence.13
- Commercial passenger vessels need a Cook Islands Boatmaster Certificate or equivalent.14
- Vessels travelling at 10 knots or more must stay 60 m from any person in the water. Bow riding is banned.13
The risks we see
- Collision risk where boats, sea scooters and swimmers share a narrow rip channel
- Speed and wash near swimmers
- Passenger loading compared with each vessel's rated capacity
- Whether licences and registration are checked in the passage
Why the MOU is not enough
The Turtle Tour MOU is voluntary and "not legally binding".15 Cook Islands Tourism says it "was created and is driven by the TTOs [turtle tour operators] themselves".16 It does not address either pillar.17
| Issue | What the MOU does |
|---|---|
| A Engine noise | No clause at all |
| A Fuel, oil, engine standards | No clause. There is only a general promise to minimise "adverse effects" |
| A Speed near turtles | No limit. Keep 3 m from turtles "whenever possible" |
| B Boat and scooter numbers | No cap |
| B Licensing | Clause 2(h) of Annex A only promises to "abide by" Ministry of Transport rules. Nobody has to prove it |
| B Passenger loading | The 1:4 ratio counts guides in the water only |
| Enforcement | No sanctions. Any party can withdraw on 10 days' notice |
What we ask
We ask the Cook Islands Government, the Ministry of Transport, the National Environment Service and Cook Islands Tourism to:
- Replace the voluntary MOU with an enforceable permit system for Avaavaroa.12
- Create a motor-free core swim and turtle zone, with speed limits informed by the research on turtles.8
- Cap the number of boats and sea scooters, and permit only low-emission engines (four-stroke or direct-injection) for commercial use.
- Actively check vessel registration, licences and passenger limits in the passage.
- Fund baseline monitoring of underwater noise and water quality, in line with the Southern Passages Environmental Management Plan.
This is not about any one operator. It is about one enforceable standard for everyone.
Sources
- Holles et al. 2013, MEPS 485:295. https://doi.org/10.3354/meps10346
- "Small-boat noise impacts natural settlement behavior of coral reef fish larvae", JCU. https://researchonline.jcu.edu.au/47771/
- Simpson et al. 2016, Nature Communications 7:10544. https://doi.org/10.1038/ncomms10544
- Samuel et al. 2005, J Acoust Soc Am 117:1465. https://doi.org/10.1121/1.1847993
- US EPA, Low-Pollution Marine Engines. https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=91022L6U.TXT
- boats.com, DFI two-stroke outboards. https://www.boats.com/on-the-water/outboard-expert-dfi-tutorial/
- SAE 911849 (IAPAC DI outboard). https://doi.org/10.4271/911849
- Hazel et al. 2007, Endang Species Res 3:105. https://doi.org/10.3354/esr003105
- Work et al. 2010, J Exp Mar Biol Ecol 393:168. https://doi.org/10.1016/j.jembe.2010.07.019
- IUCN Red List, Hawksbill. https://www.iucnredlist.org/species/8005/12881238
- RNZ, 28 Dec 2023. https://www.rnz.co.nz/news/pacific/505614/cook-islands-popular-turtle-swimming-spot-notorious-for-drownings
- Cook Islands News, 19 Mar 2025. https://www.cookislandsnews.com/internal/national/local/environment/tourism-takes-action-to-enhance-safety-in-turtle-tours/
- Ministry of Transport, Small Motorised Vessels. https://www.transport.gov.ck/maritime/small-motorised-vessels/
- Ministry of Transport, Boatmaster. https://www.transport.gov.ck/maritime/boatmaster/
- RNZ, MOU non-binding. https://www.rnz.co.nz/news/pacific/510705/cook-islands-turtle-tour-operators-sign-up-to-non-binding-agreement-to-boost-conservation-efforts
- Cook Islands Tourism partnership page. https://cookislands.travel/turtle-tour-operator-partnership
- Turtle Tour MOU, Jan 2024. https://cookislands.travel/sites/default/files/2024-02/MOU%20-%20Turtle%20Tour%20Operators%20JAN2024%20for%20website.pdf