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.
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.
End of year submissions 2024
Posting my submissions from the last few months.
Submission on the Crown Minerals Amendment Bill
“The ‘crisis’ is a creation of a small number of businesses that have not invested in a low emissions future. The consequences of addressing the ‘crisis’ with high-risk activities and increasing emissions impact the entire planet and future generations.”
Submission from STET Limited on the Crown Minerals Amendment Bill
Submissions from the last few months
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.
Submissions on Gulf protections
It’s been a busy month with many submissions due.
Proposed Bottom Fishing Access Zones in the Hauraki Gulf Marine Park
Submissions on the protections proposed by Revitalising the Gulf
I spent a few days going through the 7,550 submissions on protections proposed by Revitalising the Gulf. I’m estimating 77%-90% of the submissions were positive about the protection proposals. However huge numbers concerned about the continuation of bottom impact fishing outside the protected areas and cultural take inside them. So there is a general need for more protection. This level of public support for marine protection can be expected and can be seen in Polling from the Hauraki Gulf Form, Submissions on the recent Waiheke Marine Reserve Proposal and the Live Ocean Barometer 2023.
Most of the names were redacted from the submissions but the organisation names were left public. Here are the names of the organisations that made significant submissions.
OPPOSED | PARTIALLY SUPPORT | SUPPORT |
Legasea 2xs Charters / Balmain Boating Services Alan Seasprite Charters CRA 2 Rock Lobster Management Co Dr Hook Charters Fisheries Inshore NZ Kina Industry Council Mercury Bay Game Fishing Club NZ Rock Lobster Industry Council New Zealand Charter Boat Association New Zealand Sport Fishing Council Paua Industry Council Princess Carol Charters Provider Adventures Ltd Sea Urchin NZ Ltd Seahawk Fishing Charters Slipper Island Residents Association Snap Attack Specialty & Emerging Fisheries Group Tairua Adventures Ltd / Artisan Fishing Co Te Ohu Kaimoana Te Ra Charters The New Zealand Angling & Casting Association Whitianga / Coromandel Peninsula Commercial Fisherman’s Association |
Aldermen Islands Marine Reserve Group Friends of the Hauraki Gulf Mama Fish Sanford Limited |
Forest & Bird Revive Our Gulf Auckland City Centre Residents Group Auckland Conservation Board Auckland Council Auckland Sea Kayaks Auckland Sea Shuttles Coromandel Marine Farmers Association Devonport Yacht Club Environmental Defence Society Foundation North Friends of Taputeranga Marine Reserve Trust Goat Island Dive and Snorkel Good Fishing Hahei Residents and Ratepayers Association Leigh Penguin Project Live Ocean Foundation Meadowbank School Marine team Motuora Restoration Society Mountains to Sea Conservation Trust New Zealand Conservation Authority New Zealand Geographic New Zealand Marine Sciences Society Ngāti Hei Ngāti Manuhiri Settlement Trust Ocean Voyages Inc Pakiri Community Landcare Group Pest Free Kaipātiki Ports of Auckland Limited Shakespear Open Sanctuary Society Inc Sir Peter Blake MERC Stet Supporters of Tiritiri Matangi Te Whanau o Pākiri The Friends of Te Whanganui‐A‐Hei Marine Reserve Trust The Glass Bottom Boat Whitianga The Hauraki Gulf Conservation Trust The Hauturu Supporters Trust Tāmaki Estuary Protection Society Tāwharanui Open Sanctuary Society Inc Waiheke Marine Project Waikato Regional Council Wakatere Boating Club Yachting New Zealand |
Most of these submitters were upset about continued bottom impact fishing in the Gulf. Most of the Charter fishers all sent in the same submission. | These submitters indicated support for marine protection but did not express that much support for the proposed measures: | Most of these submitters wanted more protection than what was proposed and also wanted bottom impact fishing banned. |
I have not published the names of many organisations who used the LegaSea form as those submissions contained dramatically less information than those from the above organisations. They were mostly small owner operator companies who are also keen fishers. The big Purse Sein operator Pelco NZ Ltd and Te Ahu wai o Tangaroa sustainable ecological aquaculture did make significant submissions but they did not speak to the protection proposal.
In response to the submissions the Department of Conservation has reduced the amount of protection. Submissions are now open on the Hauraki Gulf / Tīkapa Moana Marine Protection Bill.
P.S. These bottom impact fishing effort maps were made public by Fisheries Inshore NZ and are useful in considering the proposed ‘trawl corridoors’.
Submissions on the Hauraki Gulf Fisheries Management Plan
Over 10,000 submissions on the Hauraki Gulf Fisheries Management Plan are likely to be the largest data set of opinions on fisheries management in Aotearoa and definitely the largest in the Hauraki Gulf Marine Park.
This copy is displayed when asking for public submissions:
Submissions are public information
Note that all, part, or a summary of your submission may be published on this website. Most often this happens when we issue a document that reviews the submissions received.
People can also ask for copies of submissions under the Official Information Act 1982 (OIA). The OIA says we must make the content of submissions available unless we have good reason for withholding it. Those reasons are detailed in sections 6 and 9 of the OIA.
If you think there are grounds to withhold specific information from publication, make this clear in your submission or contact us. Reasons may include that it discloses commercially sensitive or personal information. However, any decision MPI makes to withhold details can be reviewed by the Ombudsman, who may direct us to release it.
I’m disappointed that Fisheries New Zealand has not released all the submissions citing section 18(f) of the OIA—that the information requested cannot be made available without substantial collation or research.
I’m going to read over the submissions provided (which are substantial) before asking for more detail.