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.

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
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

Feedback on the Fisheries Industry Transformation Plan (ITP) to transform the wild-caught fishing industry for a resilient and productive future

We are disappointed the ITP is all carrot and no stick. There are lots of actions in the plan that will reduce fishing impacts and restore damage done by fishing,  however they are already underway. Companies already do sea ranching in Aotearoa (first documented trails in 1990), research institutions, eNGOs, communities and iwi are already working on seagrass, shellfish and kelp restoration. Fisheries New Zealand (FNZ) has not provided any plans to restore historic damage done by the fishing industry. FNZ is failing to develop the regulations needed to push the industry to innovate for a healthier ocean. The plan adds little environmental value, embeds significant environmental harm and should not be adopted.

Ban mobile bottom impact trawling and protected species bycatch

Mobile bottom impact fishing is inconsistent with ecosystem based management because of the scale of damage it does to benthic ecosystems. Recent polls by the Hauraki Gulf Forum and Greenpeace show that the bottom trawling industry has lost its social licence to operate. Our government has a responsibility to lay down some serious challenges to transition the industry, we can’t find any in the ITP. FNZ has not provided any evidence that the proposed investment will reduce impacts on biogenic habitats. It’s irresponsible of FNZ to not lead the industry to transition to lower impact methods. The ITP is short sighted and the industry needs a long term vision. We fully support recommendations on an end date for mobile bottom impact fishing.

Bottom impact fishing prevents the ocean from sinking carbon

It’s good to hear FNZ talk about using public money to actively restore damage caused by the fishing industry, but it’s hypocritical to allow the industry to continue damaging habitats at the same time. The transition to lower impact gear and fishing methods needs to be mandatory. For example hook-shielding devices supplied for free to the Surface Long-lining Fleet by the Department of Conservation have not been adopted as best practice by the industry. 100% hook-shield use could save thousands of endangered seabirds caught every year as bycatch.

Action 1: Create an end date for mobile bottom impact fishing.

Action 2: Create an end date for catching protected species.

Systemic failure

The ITP only uses the word sustainability to refer to the industry and the stocks that support it. The damage that the industry does to ecosystems and protected species is not sustainable. FNZ need to start practicing ecosystem based management to stop the loss of biogenic habitat, the spread of kina barrens and the extinction of our seabirds. This is explained well by Professor Simon Thrush, “[The ITP is] focussed on ‘sustainability’ in terms of future fishing industry profitability and productivity, rather than the ‘sustainability’ of the marine environment“.

The export revenue from Aotearoa New Zealand’s fruit and nut industry is twice that of the of the fishing industry with much less environmental harm. The Aotearoa Horticulture Action Plan wants to grow the wider horticulture industry from 7b to 35b by 2035. This is a much better investment for the New Zealand public. The optimistic economic argument laid out in The case for a new inshore fishing fleet in New Zealand 2022 will only have a regional impact. The business case will not be sustainable, as (by its own admission) it will not produce boats that are competitively priced. The New Zealand public is willing to fund Crown Research agencies to develop low impact fishing methods and technology for the industry. This is quite different to subsidising the purchase of new boats. In asking the government for subsidies the fishing industry is showing its not financially sustainable. The ITP is evidence a review of the economic performance of the Quota Management System(QMS) is overdue.

The industry is too focused on profits for quota owners, not local jobs. New Zealanders want a commercial inshore fishery that is low impact, high value and artisanal. The boats should be regularly upgraded but kept small to support communities. It’s also better for local economies and communities if operators own their means of production (quota and boats). Quota owners who are not investing in their fleet and just sitting on quota (like it’s a rental that doesn’t need upkeep) are not good for the environment, the economy or the wellbeing of society.

Our international partners will ask “why is New Zealand subsidising its ‘sustainable’ fishing industry”

The public will ask “why haven’t our quota owners (who we give fish for free) been investing in the inshore fleet?”

Action 3: Commission a financial review of fishing quota and Annual Catch Entitlement (ACE) allocation to find out why profits are not being invested into the fleet.

Fish population biomass

We disagree with this statement in the ITP. “It is generally acknowledged that the volume of wild fish caught in Aotearoa New Zealand is unlikely to significantly increase, so we need to innovate to grow value” – Hon Rachel Brooking. The authors grasp at every straw except the ones that involve limiting commercial fishing.

1) It is logical to close certain areas to fishing as this would promote the growth of large animals which make a disproportionate contribution to fish populations. For example it takes thirty six 30cm snapper to make the same amount of eggs as one 70cm snapper. The creation of brood stock areas could dramatically increase fishery yield.

2) Many fish populations are being managed over the soft limit and too close to the hard limit. This shows the existing fleet is over capitalised. Lowering the TACC (Total Allowable Commercial Catch) to increase fish population biomass would reduce the effort required to catch the TACC, therefore reducing carbon emissions. MPAs can also increase CPUE (Catch Per Unit Effort) thereby reducing carbon emissions.

3) Increasing fish population abundance will help restore biological pump function and sequester more carbon.

Action 4: Trial the creation of brood stock areas to increase fishery yield.

Action 5: Lower the TACC to reduce carbon emissions and sequester more carbon.

Artificial upwelling technology

We were shocked to see FNZ entertain using artificial upwelling technology here, this is a potentially devastating technology that could have terrible fisheries outcomes. The process might not be stoppable, even after you remove all the plastic pipes from the ocean. We hope that any other technologies FNZ are entertaining are a lot less dangerous.


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