“We are concerned about the unintended consequences on fish stocks outside the Hauraki Gulf Marine Park due to the spatial management proposed in this bill.
“Detrimental impacts on wider fish stocks will impact the wider industry and ancillary services that are reliant on sustainable fish stocks and a healthy environment.
“We are concerned about the precedent-setting nature of using bespoke legislation when the Government wishes to progress action and avoid normal regulatory scrutiny.
“There is a risk that this approach will undermine New Zealand’s fisheries management and the integrity of an evidence-based approach to spatial management.
“We are concerned about the lack of a considered whole legislative package being proposed.”
The company said it also has “significant concerns” at a lack of detail in the proposal that demonstrated a lack of consideration for the wide-ranging impacts of these proposals.
“Further work is required to understand the nuances of FMA 1 fishing operations and the impact of displaced effort in different areas.
“Displaced effort has been raised as a significant concern. The Regulatory Impact Assessment (RIA) notes that officials heard concerns about the displacement of fishing effort, particularly for rock lobster fishers.
“The RIA addresses this by assuming permit holders will not source new quota shares or annual catch entitlements for other quota management areas. We believe this assumption is misplaced.”
The submission said the proposed options for bottom fishing access zones (trawl corridors) in the Hauraki Gulf was not accounted for.
It also questioned the lack of detail around economic knock-on effects.
“For example, recognising increasing fuel cost, if a fisher has to start steaming further to reach fishing grounds it may become more economically feasible to change their operations and either domicile their operations in new areas or move areas completely.
“Operators domiciled on the east coast of New Zealand, notably Whitianga or Tauranga, are more likely to displace their effort to other areas.
“We have not seen any data that recognises the nuances associated with how displaced effort could happen in reality.
“The RIA provides inadequate analysis to support significant decisions that could result in severe unintended consequences, not just for the Hauraki Gulf but also for our fisheries.
“The fact that the bill only requires a review every 25 years only heightens our concerns.
“We are concerned that MPI (Ministry for Primary Industries) is seeking to make regulatory changes when there is still a paucity of information provided in the consultation paper to support these changes.
“ Further engagement is required before any regulatory change.
“More work is required to account for and consider the broader impacts of these decisions. The current work is inadequate to ensure any spatial management development is based on the best available data and modelling of displaced effort.”
If it becomes law, the bill would nearly triple protection in the Gulf from just over 6 percent, including the cable protection zones, to about 18 percent, with the intention to support the recovery of some of its most biodiverse regions, including its near-shore areas and deep reefs.
