Submission on the Future of Our Fisheries Consultation Document
To: Ministry of Primary Industries
Name of Submitter: NZ Outdoors Party
Date: 23 December 2016
The NZ Outdoors Party was formed in 2015 to garner the collective interests of all those who enjoy hunting, fishing, camping, tramping, hiking, biking and all forms of outdoors recreation and have these represented by a single issue political party. Our “High Five Principles” are:
1. OUR MARINE FISHERIES
Recreational anglers not trawlers enjoying and managing our inshore fisheries for abundance.
2. OUR FRESHWATER
Our rivers and lakes should be clean, full and unmodified for the people to enjoy
3. OUR LAND
Our public land and its game animals are valuable resources to be properly funded and protected from commercial development and invasive organisms.
4. OUR SAY
Recreational users of our land, water and seas must have a greater say in its protection, management and access.
5. OUR FUTURE
We want a Futures Commission to help us decide our capacity for growth of our population, economy and infrastructure within environmental limits to ensure the outdoors is protected, enhanced in perpetuity for future generations.
We welcome the fisheries review and consultation process as a long overdue necessity. We support many of the principles proposed but believe the strategies and regulations do not go far enough to address the stated objectives of:
a healthy and abundant aquatic environment.
joint management of shared resources.
shared benefits of the fishery
an internationally trusted fishery
To this end we would urge the MPI to implement the following five policies:
The inshore fishery value to be maximised by designating it as principally a recreational fishery, along with customary and limited artisanal commercial fishery only – no trawling, no dredging.
Equal size limits for commercial and recreational fishers.
TACs to be set to increase abundance, not to maintain depletion (B40).
MPI funding of innovative precision trawling techniques and technology.
100% capture of catch details for all commercial fish vessels and 100% traceability from boat to consumer (boat to batter):
Responses to Consultation Questions
1. We believe live fish should be released if they are likely to survive but this will require innovative trawl nets and rigorous, blanket compliance checking independent of the fisheries industry. Currently we struggle to understand how any fish could survive after being dragged from the sea in a net and compressed under tonnes of other fish then left on the deck for some time prior to being released – a nonsense.
2. It is unacceptable to discard any dead fish.
3. Quota owners should have greater responsibility on the behaviour of those who fish under their quota as should the licenced fish receivers.
4. There should be equal minimum size limits for all fishers, commercial, customary and recreational. Net mesh size, construction and shape must be the way forward to enable smaller fish to escape alive before being hauled on board.
5. We agree with managing fish stocks for abundance.
6. The inshore coastal zone should be no trawling, no dredging and customary, recreational and small artisanal commercial fishers only. This is the best way to manage TAC for abundance and to maximise the value of the resource.
7. We have zero confidence that the NZ Government could meaningfully certify the environmental performance of our fisheries and recommend an independent body which has no commercial interests be selected to certify our fishery. Something akin to the SPCA blue tick for meat could be worth exploring.
8. We are cautious of any research into new fisheries as this has historically resulted in over-exploitation and led us to where we are now. Better to manage the existing fishery for value and environmental improvement.
9. Non-commercial fishers are supportive of data collection on catches.
10. Collecting fisheries data at finer scales is a worthy concept, not only locational but also seasonal to recognise the higher vulnerability to excessive capture during migratory and spawning runs. The trick is always to be able to verify the veracity of the data and not rely in commercial interests to self-report.
11. The wider values of the recreational fishery are well understood and we wonder why MPI feel the need to research this– the right to catch a feed for the family, the kiwi way, our heritage, the social and psychological benefits of friends and family out on a boat together, an integral part of the beach, the bach, the boat holiday. These are the fundamental values of the fishery and the kiwi psyche.
12. Whole ecosystem evaluation of fisheries is of value as it recognises the intrinsic links between all fisheries components. The key principles of ecosystem evaluation are that no practice should adversely impact the ecosystem and the primary objective is to protect, preserve and enhance the marine environment first and provide commercial benefit second.
13. We believe it is fair that who benefit most commercially should pay the most for research on ecosystem management that ultimately keeps them in business.
14. Externally commissioned research often has the highest value as it is not compromised or captured by commercial gain. To date most MPI have relied on data and research from commercial fishers with all the risks of conflict. Independent research is validated by accepted scientific processes (peer review and publication) and should MPI wish to impose criteria on research it should simply publish these and make them publicly available.
15. The benefits of a National Fisheries Advisory Council depend entirely on its composition and the extent to which its recommendations are adopted. The Land and Water Forum is an example of this, great in theory, terrible in practice.
1. The issue of data collection appears threefold: timeliness, accuracy and veracity. If the problem of using Observers is as set out then the IERS provides a good opportunity to improve data collection.
2. The objectives of the IEMS all stem from the need to stop dumping and discarding of fish.
3. We support full implementation of all components of the IEMS as soon as possible if and only if it does indeed prevent the appalling waste from dumping, discard and non-target species fish kill.
4. Given fish dumping should be eliminated by a combination of trawling technology improvement and monitoring what happens on every trawl on every boat, it would be useful for IEMS to be able to identify supporting data including when and where each trawl occurs and which nets or fishing techniques are employed.
5. We suggest that fully functioning EM, ER and GPR systems are a prerequisite of any commercial fishing activity i.e. If a camera is reported as failing during a fishing expedition there should be no catch allowed or paid for.
6. IEMS should enable fish harvests to be tracked from trawl net to consumer, analogous to the pasture to plate concept. This is an additional check to eliminate illegal fish harvesting.
1. We are surprised and suspicious of the data provided: Only 18% of boats reported trawling yet the technique is responsible for 84% of the catch?
2. We fully support changing the regulations to allow maximum innovation and diverse trawl gear technologies to eliminate unwanted catch (small and non-target species).
3. The criteria for assessment of trawl technologies seems right, although difficult it would be good to assess the condition and survivability of non-target escapees as an additional assessment criterion.
For further information or clarification please use the contact details below:
Contact person: David Haynes, Co-Leader, NZ Outdoors Party.
service of submitter: 158 Kanuka Rise, Wakapuaka RD1, Nelson 7071
Telephone: 03 546 6051