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.

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.

My request

FNZ response

Submissions Part 1

Submissions Part 2