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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