Submissions with the Ministry of Fisheries on proposed Marine Protected Areas along the West Coast South Island that will have damaging impact on commercial inshore fisheries access close tomorrow. NZFCF Executive member Carol Scott has prepared and submitted a submission on behalf of the Federation.
WEST COAST SOUTH ISLAND
MARINE PROTECTED AREAS CONSULTATION
1. This submission is made on behalf of fishers and members of the New Zealand Federation of Commercial Fishermen (NZFCF) who will be impacted by the recommendations made by the West Coast South Island Marine Protection Forum (WCMPF).
2. Many of our members frequently fish the West Coast South Island inshore and offshore fisheries for a number of fishstocks. The proposition of any spatial exclusion will impact on their commercial fishing operations and the livelihoods that rely on them.
3. It was appalling to see the size and extent of the proposed Marine Protected Areas (MPA) proposed sites and the lack of consideration on the impact on existing users from other forum members other than the commercial representatives.
4. We understand that the commercial representatives provided alternate options for discussion that would minimise the impact on existing users and also meet MPA policy requirements.
5. It was therefore surprising to read the minutes of the WCMPF meetings whereby the Ministry of Fisheries official Nicola Pindur proposed that alternate options that are diverse in size should not be considered. This is totally inappropriate and against the planning principles of the MPA policy.
6. The MPA policy offers guidance that if consensus is not met by the forum that options should be proposed. The fact that the Agencies did not agree and then pre-empt any decision asked of the Forum on this matter is not acceptable.
7. We believe that throughout the planning and site selection processes that the commercial representatives had to on more than one occasion request that the MPA policy and protection standards be followed appropriately.
8. It was not surprising to NZFCF to see that other Forum representatives tried to use the forum process to further their own expansive views on marine protection and the exclusion of commercial fishing.
9. We strongly support the proposal in the Fisheries 2030 report to ‘implement a revised marine protected area policy and legal framework’.
10. We also request that the full review of the MPA policy documents is completed before any other Forum or MPA proposals are given momentum. This includes the current proposals put forward by the WCMPF. Such proposals need to be reassessed against the biodiversity and revised marine protected areas planning principles.
11. Clearly, the MPA policy and protection standards were not tested in any way before being adopted by the WCMPF. They do not necessarily reflect strategic planning for marine protection but offer an avenue only for the exclusion of commercial fishing and development of expansive areas for DoC management.
12. We were dismayed to see in-committee minutes on the WCMPF website with little evidential content that would have necessitated closed meetings. It reeks of exclusion and lack of transparency. Impacts on existing users have to be minimal and this would have been better achieved by the inclusion of other stakeholder organisations that will be impacted by the recommendations of the WCMPF.
13. We understand that a number of stakeholder organisations were not consulted throughout the process even though commercial representatives requested that they be able to attend to discuss the impacts. We are also aware that the Ministry of Fisheries officials did little to include other existing users in any form even though their Agency has all the information to catch and effort on the West Coast South Island (WCSI).
14. Given the level of impact on existing users and communities along the WCSI the Ministry of Fisheries and Department of Conservation should have commissioned an economic impact assessment (EIA) to better inform the WCMPF on the impacts of spatial exclusion and shift of effort to other areas.
15. We recommend that the Agencies not only commission an EIA but provide it to the WCMPF before any further consideration of MPA site selection and decision making is completed. We also request that the EIA be sent with any final recommendations to Ministers of Conservation and Fisheries to inform their decision making processes.
16. Finally, we endorse the content and recommendations made by the Challenger Finfisheries Management Company Ltd, Seafood Industry Council and the Combined Industry Submission.
Doug Saunders-Loder Pete Dawson
President Chief Executive