Submission by EDS on the 2011-12 SQU6T IPP
I can’t believe that I am about to take a swipe at the Environmental Protection Society (EDS). I am a huge fan. They are a go and get organisation that is definately in the solutions business rather than problems business. However of late they are confronting wider problems – and as the scope of their proposed solution must also broaden, so too must operational know-how.
EDS are RMA experts – No doubt! Their water policy proposals are second to none! Their submissions and policy proposals for land use. are forward thinking, logical and contribute to New Zealand’s national integrity. They have definately caught the ear of Government in those respects (i.e. EDS were instrumental in the development of policy behind the EEZ and Continetal Shelf Bill going through Parliament at the moment). However of late EDS have been branching out especially as they develop EEZ and extended Continental Shelf resource use policy – and as a consequence of this branching out, EDS are coming face to face with a variables of a different kind. Submarine or highly mobile variables that can’t be seen or are difficult to quantify and manage (i.e. interactions with mammals and birds, fish harvest strategies, mobile resources that are not confined spatially). Their lack of familiarity in these areas is beginning to show. I just read their submission on the SQU6T Initial Position Paper put out by the Ministry of Fisheries. I was disappointed to read a submission not only similar in both subject and tone to that of other eNGOs, but even less comfortable with the subject matter. Many of eNGOs in New Zealand are vastly experienced countering Seafood Industry/Government initiatives, and are more than comfortable in the application of appropriate discourse. EDS advocate the use of the precautionary approach, when, if they had engaged with the Seafood Industry and the Ministry of Fisheries (MAF), they would definately have a better understanding of the extent of precaution embedded in measures that are taken by both MAF and the Seafood Industry. Furthermore EDS advocate the application of the precautionary approach with the interpretation that precaution is synonomous with inaction. This is incorrect and inconsistent with the Fisheries Act and is the same interpretation applied by all other New Zealand eNGOs. The Fisheries Act requires that weight be equally applied to both the utilisation components and the environmental components of the purpose of the Fisheries Act.
I really think EDS ought to engage with the Seafood Industry more. Not only to get the terminology right. I try not to roll my eyes everytime I see fishing vessel interactions with marine mammals (including sea lions) referred to as by-catch. To be taken seriously the correct terminology should at least be attempted. Coral scooped up in a net is by-catch. As are non-targetted fish species harvested as an incident of targetting another species. But Marine Mammals? Marine Mammals are agile, intelligent animals, that deliberately put themselves in the way of harm in order to secure an easy meal from a fishing net – that is they deliberately interact with fishing gear, and only very occasionally are they captured. Honestly, this learned behaviour results in a concentrated food source, and is for these intelligent animals, a legitimate foraging strategy. Why else would they do it? Anyway it is for this reason that the most accurate terminology that should be used is ínteractions‘or ‘captures‘.
It is my firm opinion that engagement with the Seafood Industry would have provided EDS with information on the work that has been done to ascertain the survivability of New Zealand sea lions in the event of capture, collision and escape through a SLED. It would have lead to an understanding of the problem from a sustaianble utilisation perspective and would have shown them how much work is being done by the Seafood industry in collaboration with DOC and the MAF, not only address the pup decline, but also understand New Zealand sea lion behaviour in order to minimise, avoid or mitigate any adverse effects of fishing. It is my firm belief that the solution orientated approach and expertise of EDS, would further the sustainable utilisation of New Zealand’s marine resources, and be part of the solution to avoid of mitigate any adverse effects on the surrouding marine environment.
It is important to note that the Seafood Industry in New Zealand is made up of quota owners – who have property rights in a means of production – no different to farmers and foresters (save the resource is wild caught). EDS have done some great things for farmers and foresters – furthering the cause of sustainable utilisation. The seafood industry is no different. EDS won’t get very far if they just do what the other eNGOs in New Zealand do, and simply be contrary when contrariness is required and revisit the same principles in the same way as other eNGOs visit them. The Seafood industry already has squarely fastened to its toolbelt the precautionary approach, and an ecosystem approach to fisheries management, amongst other tools. The Seafood Industry in New Zealand are an environmentally driven and savvy bunch, intent on providing New Zealand with the benefit of sustainable resource harvests and healthy marine environments. EDS if they engaged with them – would find that too. And together – they could do alot…. But…. I am thinking that EDS have already chosen a direction.
Check out the article posted on Voxy outlining the EDS submission on the 2011-12 SQU6T IPP (Tuesday, 20 December, 2011)and check out the EDS submission on the SQU6T Initial Position Paper below the article (even compare it to the submissions of other NZ eNGOs). I am right, aren’t I?
New Zealand sea lion slides towards extinction
In a submission to the Ministry of Fisheries, the Environmental Defence Society (EDS) has called on the government to reconsider proposals for the Auckland Islands squid fishery. “The Ministry of Fisheries’ proposal for the 2011/12 fishing year is deeply flawed, radically different from past years and will hasten the New Zealand sea lion towards extinction,” said EDS Senior Oceans Researcher Kate Mulcahy.
“Whereas previously the fishery would be closed if a specified level of sea lion bycatch was exceeded, this year the proposal is to keep it open.
“The New Zealand sea lion is an endemic species, found principally in the Auckland Islands. The population has been declining for a number of years, and in 2010 the Department of Conservation reclassified the species as ‘nationally critical’, the most endangered category available in the classification system. Research shows that squid fishing is probably a key cause of the population decline.
“The squid fishing season coincides with the pupping season in the Auckland Islands. Sea lions caught in the squid trawl nets tend to be females out hunting to feed their pup, which remains onshore. These females are often pregnant as well, so the death of a female actually results in the death of three individuals.
“The Ministry’s proposals are based on new research which, it claims, shows that the squid fishery is in fact not a significant cause of the decline in the population because sea lion exclusion devices (SLEDs) enable sea lions caught in the trawl net to escape.
“In fact, we do not know how many sea lions die in squid trawl nets. Although SLEDs provide an escape route, we have no idea what condition the sea lions are in when they pass through the SLED because the research hasn’t been done.
“So the Ministry’s rationale for the proposal is flawed. It addresses only one way in which sea lions may be killed in the trawl nets and ignores other research showing that the squid fishery is very likely a significant factor in the population decline.
“Rather than scrapping the bycatch limit, the government needs to strengthen it further and do more to protect this unique species from extinction. This should include a population management plan developed by the Department of Conservation,” Kate Mulcahy concluded.
- Here is a Link to EDS Submission on the SQU6T Initial Position Paper
- Here is a link to Forest and Bird submission on the SQU6T IPP