Submission on proposed amendments to the Fisheries Act

STET Ltd opposes all proposed amendments to the Fisheries Act. The changes prioritise commercial interests over ecosystem health, weaken regulatory oversight, and reduce public accountability. Key concerns include:

  • Multi-year catch decisions and management procedures: Reduce scientific scrutiny, ignore environmental variability, and risk locking in unsustainable harvest levels.
  • Low-information stock management: Lacks robust ecological data and invites industry bias.
  • Rebuild periods: Allow economic factors to delay recovery of depleted stocks.
  • Non-extractive values: Are overlooked, including ecological roles and non-commercial cultural practices.
  • Voluntary sustainability measures: Are unenforceable and exclude recreational/customary conservation efforts.
  • ACE carry forwards and deemed value threshold changes: Undermine sustainability and enable quota banking.
  • On-board camera proposals: Removing footage from OIA and weakening camera use reduces transparency and compliance.
  • Discard and landing rules: Erode sustainability by enabling increased discards, higher juvenile mortality, and underreporting.

STET urges Fisheries New Zealand to adopt science-led, precautionary, and ecosystem-based management that upholds public interest over industry lobbying.

Read the Full Submission here

Make your own submission here

Protecting Regional Councils’ Role in Marine Conservation

The proposed Resource Management (Consenting and Other System Changes) Amendment Bill threatens to strip regional councils of their ability to regulate fishing impacts under the Resource Management Act (RMA). This shift would place decision-making solely in the hands of the Ministry for Primary Industries (MPI)—an agency primarily focused on fisheries extraction rather than ecosystem health.

This change ignores a key legal distinction: RMA-based marine protections are not about fisheries management but about safeguarding biodiversity, cultural values, and ecosystem integrity. The Motiti Decision confirmed that councils have the authority to protect marine habitats from fishing when necessary to maintain indigenous biodiversity.

The Fisheries Act has failed to protect marine biodiversity, as evidenced by the expansion of kina barrens in Northeastern New Zealand and the complete collapse of the commercial scallop fishery. If councils lose the ability to implement marine protections under the RMA, these problems will only worsen.

New Zealanders overwhelmingly support better marine protection, yet only 0.4% of our oceans are fully protected, placing us behind international standards. The Bill would make it harder to achieve meaningful protections, contradicting both public expectations and international commitments like the 30×30 initiative.

The RMA already allows for 10-year marine protection areas, providing a practical and adaptable tool for ecosystem recovery. Removing this mechanism would take away a proven, community-driven conservation tool.

We oppose the Bill and urge the Select Committee to reject these restrictions, retain regional councils’ ability to manage fishing impacts, and ensure marine protection remains in the hands of local communities—not just the fishing industry. Now is the time to strengthen protections for our oceans, not weaken them.

The STET LTD submission

Make your submission here

UPDATE: Speech presented 03/03/2025

Submission on Regulatory Standards Bill

Regulatory Standards Bill

The proposed Regulatory Standards Bill prioritises private property rights over collective environmental interests. It asserts that “legislation should not take or impair, or authorise the taking or impairing of, property without the consent of the owner unless: there is good justification for the taking or impairment, fair compensation is provided to the owner, and compensation is provided to the extent practicable by or on behalf of the persons who obtain the benefit.” While this protects individual property owners, it could discourage essential regulations, like wetland protections or agricultural runoff controls, by imposing significant compensation burdens. This approach overlooks the shared value of ecosystems and the collective responsibility to safeguard them for future generations.

Full submission on the Regulatory Standards Bill here

Close CRA 2

Close CRA 2

I am publishing my draft submission on CRA 2 early. Key points below:

  • The ecological imbalance caused by overfishing kōura (spiny rock lobster) in CRA 2 has led to the proliferation of kina barrens, devastating kelp forests along Northland’s east coast.
  • Kelp forests in the Hauraki Gulf could be worth up to USD 147,100 per hectare annually, far exceeding the $10.17 million export value of CRA 2. Kina barrens, by contrast, provide no ecological or economic value.
  • Fisheries New Zealand’s reliance on biased data, such as Catch Per Unit Effort (CPUE), underestimates kōura depletion. Independent research shows kōura populations, even in marine reserves, are well below natural levels.
  • The proposal to close commercial and recreational kōura fishing in the inner Gulf for 10 years is the largest fisheries closure ever suggested for the Hauraki Gulf Marine Park. However, fisheries independent data shows it’s not enough.
  • A new biomass target is precedent-setting and a significant step for Ecosystem-Based Management initiated by Sea Change – Tai Timu Tai Pari. A 3x BR target is essential to control kina populations, halt the spread of kina barrens, and restore productive kelp forests.
  • Independent data must be prioritised, and a precautionary approach adopted, including a full closure of the CRA 2 fishery. Further delays will only worsen environmental and economic losses.

Make your submission here.

End of year submissions 2024

Kina Mangawhai Heads

Posting my submissions from the last few months.

Submissions from the last few months

Shane Jones, Fast-track Bill

Early analysis of submissions on the Hauraki Gulf / Tīkapa Moana Marine Protection Bill

Submissions on the Hauraki Gulf / Tīkapa Moana Marine Protection Bill began to come online here on the 17th of January 2024. There are about 6,540 submissions so far, some have supplementary material. I have been playing with ChatGPT to write Python code to download and categorise the submissions and supplementary material.

I downloaded 7,586 PDFs. It looks like at least 70% of the submissions came from here or have similar concerns as 5,518 PDFs include one of these words / terms ” racist”, ” all people of New Zealand”, ” ancestral”, ” all New Zealanders”, ” race”, ” racism”, ” racial”, ” remove acknowledgment of customary rights”, ” customary rights should not exist”, ” oppose the customary fishing rights”, ” 1 set of rules”, ” one set of rules”, ” one law for all”, ” all people”, ” one people”, ” people equally”, ” apply to everyone”, ” skin colour”, ” discrimination”, ” apartheid”, ” separatist”, ” all citizens”, ” for all to enjoy”, ” all the people”, ” all people”, ” treated differently”, ” select group to fish”, ” one law”, ” exception for any group”, ” any one group”, ” regardless of ancestry”, ” same rights” or ” divide the people”.

Note that nearly all these submissions support the protection measures in the bill, but object to customary rights. The number of submissions appears to be increasing daily as they are processed by parliamentary staff.