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.
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.
High res graphics from the State of Our Gulf 2023 so everyone can access them. Please see the full report for context and reference the report if citing a source.
Our feedback on the strategy asks Auckland Council to consider the impacts development has on shorebirds and to identify shorebird feeding, roosting and nesting habitat losses due to Sea Level Rise. Post your feedback here.
Logging where and when I have been looking for the exotic Caulerpa species that have been recently introduced to Aoteroa New Zealand.
28 June, Low tide walking, 2hrs. This seagrass meadow near the Half Moon Bay Marina is vulnerable. Good coverage but a drone would be more effective. Checked the high tide line on my return.11 July, High tide scuba /snorkel 2hrs. This bay is north east of the Kawau Bay incursion. Dive report here.12 July, Low tide walking, 2hrs. This bay is north of the Kawau Bay incursion. Very calm and I could see a few meters under the water. Checked the high tide line on my return.25 July. High tide walking 2hrs. Beach cast seaweed on high tide line checked. 26 July. Low & Mid tide walking. Beach cast seaweed on high tide line checked. 26 July. High tide walking. Beach cast seaweed on high tide line checked. This marina is a vector.23 August, High tide scuba for 30 minutes around rock (swimming fast). Free dived at two other locations in the bay. This bay is north east of the Kawau Bay incursion
This summer many people asked me about a front page article on the New Zealand Herald about a large black marlin that was killed off the coast of Northland. They wanted to know what I thought about it because they knew I would disapprove. The article did not include other views on the anglers “monumental effort” which took 10 hours. People posted negative reactions to the article on Facebook calling it animal torture but there was a shortage of facts about conservation and moral concerns.
Is marlin fishing sustainable?
In Aotearoa New Zealand the fishery of marlin is 100% recreational since 1988. Billfish caught overseas should not be bought to eat because bycatch from this fishery is going extinct (whales & dolphins, sharks, seabirds and turtles). Our commercial catch of billfish is not targeted due to a Memorandum of Understanding Between Commercial & Recreational Fishing Interests October 1996. However there is a targeted commercial Swordfish fishery. Commercial landings have fallen dramatically over the last 10 years indicating a change in fish population, fishing methods or reporting, the former is most likely and concerning *. The 126 tonnes of landed in the most recent year represents more than 1,000 fish, more than the number of animals reported in the recreational tag and release programme. Other billfish like marlin are released whether the animal is alive or dead upon capture. Cameras on all commercial surface longline fishing boats would tell us how many of these animals are being released (alive or dead).
The population trend and conservation status of each species is assessed by the International Union for the Conservation of Nature (IUCN). This is how they categorise the threat of extinction for all species on our planet.
Note that catch from the 2019-2020 was impacted by the Covid 19 pandemic so I have used the previous years which is more indicative of average catch.
Most of the recreationally caught animals are striped marlin, although they are categorised as Least Concern, the population in the Southwest Pacific is overfished with an estimated decline of 25% between 2001 to 2016.
Aotearoa New Zealand participates in the Western and Central Pacific Fisheries Commission to manage broadbill populations. This 26 member commission is slowly making progress towards sustaining the world’s biggest tuna fishery, but failing to manage bycatch including billfish. The commission meets just once a year to make decisions via consensus. Aotearoa New Zealand is responsible for a very small percentage of the fishery. We have the moral high ground and are well positioned to argue for changes to stop these species from going extinct.
While commercial billfish bycatch in Aotearoa New Zealand is unknown, recreational fishers both target and land billfish. Because our fisheries are recreational, reporting on how many billfish are caught is voluntary. The latest report on the tagging programme notes an increase in the number of boats and a probable increase in unreported catch. This needs to change and more information would help us with our questions about the conservation status of these species. Climate change will push billfish populations towards the poles, increasing catches in Aotearoa New Zealand and masking our ability to detect population decline here.
The sports fishing industry awards and celebrates the capture of the largest fish. Large old fish produce more eggs and sperm than younger fish. Female billfish are larger than males. This means the most productive members of the population are landed for records, trophies and prizes. A large blue marlin at a weigh-in station does not represent a gain of 500kgs of freezer meat, but a loss of millions of eggs which could have helped rebuild the population. The situation is just as important for our striped marlin which have lost 94% of their spawning biomass since 1960’s.
Marlin batch spawn in tropical waters.
As our culture evolves fishing is becoming less about machismo and more about connecting with the environment. Recreational fishing industry leaders could do more to discourage fishing techniques that target species that are going extinct. They also need to find ways to land less big fish. It won’t be easy for them, change may take a generation. Is catch and release the solution?
Is catch and release helping conserve billfish in Aotearoa New Zealand?
About 800 of our billfish are caught, tagged and released every year. The tagging programme is voluntary for recreational and commercial fishers. On average only three of these are recaptured per year. The other 797 plastic tags (which cost $5 each) end up in the ocean. Some tags fall out, some sink to the bottom of the ocean with the exhausted fish.
Many billfish are released, all of them injured. The fish are vulnerable to shock, disease and predation.
Marlin released with or without tags are vulnerable to shock, disease and predation.
Overseas studies have found survival is not great with one in seven released fish dying. Fishers gamble with the lives of these animals every time they put a hook in the water. The ‘catch and release’ practice makes a significant contribution to the sustainability of our share of the fishery – if its stopping those fish from being landed and killed. However it’s unquestionable that the fish would be better off without being caught at all.
The small number of recaptures have shown where our fish travel, but much more information could be gained by using satellite tags. Genetic sampling techniques are better conservation tools and have existed for more than five years.
With so little conservation value in the tagging programme, is it worth it?
Billfish respond to a hook in the mouth, throat or guts by trying to move away from the source of the pain. Fishers call this the ‘fight’. The amount of fight a fish will put up to reduce its suffering is extended by international game fishing rules. These rules are endorsed with additions from Legasea / The New Zealand Sports Fishing Council. They encourage fishers to try and land game fish on lighter line classes. This is thought to give fish a “sporting chance” as heavier fish can more easily break lighter lines. This makes the fights (which the fisher instigates for their own enjoyment) longer, it’s not uncommon for fights to last hours. This is done at the expense of the fish. Longer fights prolong the suffering of billfish and increase the chances of post release mortality due to physiological stress.
The New Zealand Society for the Prevention of Cruelty to Animals (SPCA) opposes big game fishing for sport due to the prolonged pain, injury and distress on the fish involved. SPCA advocates for a ban on the use of “light tackle” to catch big game fish.
The New Zealand Animal Welfare Act 1999 recognises fish as sentient animals. The activity recklessly ill-treats animals (an offence under section 28 A) it also contravenes other sections of the act (30A1-3). There is a NAWAC guideline on how to deal with practices which are inconsistent with the spirit of the Animal Welfare Act. The guideline asks ‘Is the suffering necessary’? It is not necessary and undeniably inhumane.
There is enough conservation and moral evidence to take the precautionary approach and stop the sport today, but I think it should be phased out, like big game hunting overseas.
Big game fishing is being compared to (less socially unacceptable) big game hunting
What should we do?
Aotearoa New Zealand should show leadership by pushing for global population estimates using genetic tools. We need to do a better job of arguing for changes to international fisheries methods and quota. We can also show more leadership by mandating the reporting of caught billfish (both landed and released, commercial and recreational) and developing a Code of Welfare for sports fishing which will identify standards to prevent pain and distress.
* UPDATED APRIL 2024. Phil Clow (president of the Whitianga and Coromandel Peninsula Commercial Fisherman’s Association) pointed out that the drop in commercial swordfish catch is due to fishers targeting tuna instead. I looked into it and it does look like that accounts for 50% of the drop. Annotated graph below.
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.
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.
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.
