Toward An Environmental Management Strategy for Fisheries

1. Introduction
2. Identification and ranking of key concerns
3. An appropriate policy balance in addressing these issues
4. Opportunities for environmental stakeholders to work with other stakeholders to achieve shared environmental goals
5. Summary of conclusions and recommendations

 

 

Appendix A   Ecologic - Pathways to Sustainability
Appendix B   Interviewees
Appendix C   Environmental Management for Fisheries: A response form for interested Ecologic members.

1.   Introduction

This paper is a contribution to the development of an environmental management strategy for the Ministry of Fisheries. The objectives of this exercise, as established by the Ministry, provide our terms of reference (TOR). They are to:

1. Identify and describe the nature of New Zealand environmental stakeholder concerns about the management of fisheries-related impacts on the aquatic environment
2. Rank these concerns in order of importance to environmental stakeholders
3. Identify the appropriate balance between protection and use of fishery resources required to address these concerns, nothing the rationale for and implications of this balance, and
4. Identify opportunities for environmental stakeholders to work with tangata whenua and other fishery stakeholders to achieve shared environmental goals.

While Ecologic’s primary goal is to advance environmental sustainability, we believe this can best be done through an engagement with economic and other interests, in which we seek to advance “triple bottom line” objectives simultaneously. This distinctive approach is reflected in our mission statement: “To reach for a future that is sustainable ecologically, economically and ethically through science, reason and dialogue.” The concept that Ecologic is an advocate for this integrated outcome, rather than for “ecological” outcomes alone, we term our “3-E’s” approach, the three E’s being ecological, economic and ethical well-being.  Further details of this approach are outlined at Appendix A.

The 3-E’s approach has implications for our contribution to an environmental management strategy, especially given TOR (c), which requires us to identify an appropriate balance between protection and use of fishery resources. For us, it is fundamental to consult other stakeholders in developing a policy position of our own.

The methodology used for this exercise reflected this approach, and was the following:

• Define key environmental issues from research and consultation;
• Use a qualitative, structured interview approach for consultation of other stakeholders for their perspectives on these issues;
• Review their comments from an environmental perspective;
• Implement an integrative approach to defining priorities and balance as required by the terms of reference, to develop a proposed position;
• Consult our membership on this proposed position, through an article in our magazine and a questionnaire;
• Write up a final report that reflects the information thus gathered.

Ecologic has previously had only limited involvement in the fisheries sector. This has been to avoid difficulties with other environmental groups already involved in the sector, and because of a perception on our part that there are larger environmental risks in other sectors such as agriculture, which should accordingly be given priority in our own work programme. However, we have had many requests to get involved in the fisheries sector from those who felt that our 3-E’s approach was needed in the sector. The government’s recent decision to develop an oceans policy clearly represents a significant opportunity for us. The Ministry of Fisheries also indicated that one of its criteria for funding the present work was “the extent to which involvement in the project will build relevant capacity in the environmental sector.”

The project has indeed enabled us to develop a policy overview and a network of new relationships in the fisheries sector, which will enhance our capacity for further involvement. This has taken considerably more time and resources than was anticipated when we accepted the brief, and it has been a steep learning curve for us. On the other hand, we believe a fresh approach and perspective could be helpful.

A list of interviewees, who have contributed materially to our understanding of environmental issues in the fisheries sector, is at Appendix B. We are conscious that many other people who could have contributed greatly to our balanced understanding of these issues, could not be interviewed in the time available for this project.

The questionnaire seeking membership views is at Appendix C. A summary of the results of the questionnaire is at Appendix D. The article published in our magazine Ecologic is at Appendix E.

A key element of the development of an environmental strategy for the fisheries sector is the need to clearly specify objectives. On the basis of our reading for this project, we consider there is a need for further work in clarifying the Ministry’s environment-related objectives. We are not in a position at this stage to profer a set of objectives that are adequately based in knowledge and analysis of issues in the sector, but we wish to highlight the importance of this.

2.   Identification and ranking of key concerns

Ecologic brought to this aspect of our brief, a primary concern for establishing a good understanding of relative environmental risk.

In doing so, we are conscious of the large gap that typically exists in the environmental field, between issues popularly believed to represent major sources of risk, and those which are understood to be so by those professionals who are expert in the field and have access to actual data. A twenty year-long programme of investigation and quantification of relative environmental risks by the Science Advisory Board to the United States Environmental Protection Agency has led a senior official of that agency to comment to Ecologic that “because of the political influence and statutory requirements of Congress, 85 percent of the resources of this agency are focused on 15 percent of the total environmental risk we face, while 85 percent of the environmental risk gets only 15 percent of our resources.”

To avoid such an outcome in the New Zealand fisheries management system, we would strongly urge the Ministry to develop an environmental risk analysis framework, seeking to rigorously analyse, quantify and rank risks as a basis for setting priorities and allocating resources.

We believe that, while Ecologic’s members may have various perceptions of their own about what the major sources of environmental risk in any sector are, their primary interest as members of Ecologic and their brief to us as employees of the organisation is to establish in as objective and authoritative manner as possible, what are the key areas of environmental risk; and then to devote policy and advocacy efforts to addressing these.

Our project design for the present project included development of a questionnaire enabling our members to comment on the relevant issues, and summarizing the results of this, in order to allow the variety of value judgments and perceptions amongst environmental supporters to be visible as part of the project. However, our primary focus has been on reading relevant scientific and policy literature and interviewing a range of professionals working in the sector, in order to develop an understanding on a well-informed and objective basis, regarding what the key sources of environmental risk are, and how important they appear to be relative to each other.

In this process it became clear to us that uncertainty is a major feature of the environmental context of the fisheries sector in New Zealand. The uncertainty on key issues, especially those relating to the nature and distribution of, and various impacts on, aquatic biodiversity, is markedly greater than is the case for comparable terrestrial environmental issues.

The main aquatic environmental risks which can reliably be quantified at present are the risks of over-harvesting on a limited number of fish populations which are commercially valuable. There is, in general, a lack of risk information available on the survival prospects of non-commercial species populations being affected by fishing activities. The size, distribution, recruitment and mortality characteristics of potentially at-risk populations are, with a handful of exceptions, still largely unknown. Indeed, it appears that a substantial proportion of the species diversity of the ocean environment, especially endemic species of the benthos, remains to be described.  The levels of environmental risk to be attached to such processes as accelerated sedimentation, inadvertent aquatic species introductions, and fisheries activities such as bottom trawling and dredging, appears to be significant but is yet to be clearly defined. Environmental performance indicators for the marine environment, other than those relating to fish stocks, are mostly still under development and will not yield useful data for three to five years.

This level of uncertainty has a number of effects on our ability to respond to the terms of reference for this study:

• It means our ranking of environmental concerns must be quite broad, and heavily qualified;
• It means that it is difficult at this stage to clearly identify an appropriate balance between protection and use of fisheries resources;
• Our recommendations for an environmental strategy for the fisheries sector must therefore place a high emphasis on data gathering and research; on the design of interim policies of a precautionary nature; and on principles and processes for resolving the conflicts between the results of ongoing learning processes on the one hand, and the existence of established property rights in the sector on the other.

1. From consultation supplemented by literature review, we sought to identify in a holistic, 3-E’s framework all the actual and potential adverse effects on or from fishing and fisheries management activities that need to be managed;
2. In the same manner, we sought to identify the drivers of those effects which could be described as “environmental” in nature, and characterized these as “issues of environmental concern;”
3. We developed four criteria for ranking the environmental issues thus identified, and applied these to broadly divide the issues into rank groupings.

1) Identification of adverse effects in 3-E’s framework:

The purpose of using a 3-E’s framework at this stage was to make ourselves more fully aware of the context in which ‘an appropriate balance’ between protection and use of fisheries resources (TOR (c)) would need to be struck. Our questions explored the effects of not only of fisheries activities but also of management measures directed at those activities (as well as the significance of external factors).  This allowed us to make some assessment of the significance of potential areas of conflict (what effect would such a policy if implemented have on your activities?) as well as potential areas of mutual benefit (can you foresee any benefits to you from such an environmental measure?) and possible solutions (is there a solution or point of balance here that you think would be widely acceptable?) In the event, much of this information proved to be of limited immediate practical usefulness for the present exercise because of the level of uncertainty surrounding key issues involved in any attempt at ‘balancing’ at this stage. We therefore record here the effects we identified in summary heading form only, although some of these matters are further discussed later in this report.

A. SOCIO-ECONOMIC RISKS

1. Socio-economic losses from catch declines
2. Socio-economic losses from management restrictions, actions and processes, including erosion of property rights and effects of uncertainty on investment

3. Biodiversity losses
4. Loss of resilience
5. Loss of climate stability from greenhouse gas emissions
6. Imbalances or persistent harmful effects from waste disposal

7. Impact on social equity
8. Loss of amenity
9. Loss of recreational opportunity
10. Loss of wilderness value
11. Loss of traditional freedoms
12. Loss of Maori customary uses
13. Loss of mana associated with ownership/management of resources
14. Loss of community values placed on local work, income and community support
15. Loss of/failure to develop an ethic of conservation of resources
16. Unnecessary cruelty to animals

To the extent that the drivers of the adverse effects listed above are environmental in character, and may be viewed as potentially manageable environmental risks, we formulated the following broad issues of environmental concern:

1. Risk of adverse effects on aquatic ecosystems from the unintended impacts of harvesting and aquaculture practices;
2. Risk of adverse effects on aquatic ecosystems from inadequate restraint on quantities being harvested;
3. Risk of adverse effects on aquatic ecosystems from breaches of New Zealand’s biosecurity, and of failure to effectively manage potential pest organisms once they are in the country;
4. Risk of adverse effects on aquatic ecosystems from failures to control accelerated sedimentation, contaminated run-off and other land-based sources of impact;
5. Risk of inadequate allocation of fisheries resources for primarily non-commercial purposes (conservation, recreation, customary management and other local community-based values);
6. Risk of loss of amenity in the aquatic and coastal environment;
7. Risk of poor energy and waste management.

1. Reversibility: Does this issue create significant risks of irreversible adverse outcomes, or adverse outcomes that are only reversible on a time scale of decades or at great cost?
2. Magnitude: Is this risk of large potential consequence?
3. Probability: Is this risk of relatively significant probability?
4. Adequacy of existing system for management of risk: Is there already a management system in place which, while capable of improvement, has a track record of identifying problems, generating solutions and successfully applying these?

The following table provides a summary evaluation of the environmental risks defined above, using the four listed criteria. In some areas we have separated the commercial fishery (C) from the informal fishery (I). Time for this project has not permitted us to peer-review the judgments made in this table, which are obviously quite arguable on account of the paucity of objective data available. We are using the table to provide the best approximation we can, of a ranking of the significance of environmental issues of concern, in response to TOR (b). The only conclusions we propose to draw from the table are that:

• The first three issues listed deserve to be given the highest ranking because, taking magnitude, probability and irreversibility of risks into account, as well as the ability of the existing management system to respond appropriately (especially in respect of the informal sector) these are areas of high potential environmental risk; and
• The second four issues listed are probably lower-ranking but still significant issues, which also deserve attention in an environmental management strategy for the fisheries sector.

3.   An appropriate policy balance in addressing these issues

Issue 1: Risk of adverse effects on aquatic ecosystems from the unintended impacts of harvesting and aquaculture practices.

The primary issue of concern to us under this heading is the impact of certain fishing practices on the biodiversity of ocean ecosystems.

A politically-driven response to this issue has so far, tended to focus on charismatic megafauna such as seals, dolphins and albatrosses. This has led to some useful, management system design innovations, such as the role played by DOC in researching and developing technical and good practice solutions, using a levy on the commercial fishing sector; and the commendable the role of commercial fishing organisations themselves in building awareness and adopting improved practices. In addition, as illustrated for instance by the recent ban on set nets believed to affect the North Island Hector's dolphin population, the existing management system has shown a capacity to initiate quite far-reaching actions to protect high-profile species.

Acknowledging progress in respect of these well-known species, our greater concern at this stage is about the prospects for those species which lack a high political profile, or even the requisite 'sexiness' to obtain such a profile. For the great majority of unique New Zealand marine species, especially those of the benthos, the management system has until very recently, shown neither an ability to respond to indications of loss, nor even an ability to identify what is at risk and find out what is happening to it.

We believe that it ought to be a systemic characteristic of the New Zealand fisheries management system, that it is pro-actively capable of conserving aquatic biodiversity in general, rather than simply responding to publicity and political concern about a few species that have the ability to catch the public imagination.

We have reviewed reports prepared on seamounts in the New Zealand region, used to justify the setting aside from bottom trawling activities of 19 of these features. We have also discussed the data and processes involved with both scientists and industry personnel. This exercise highlighted the huge amount of costly survey information that needs to be gathered to make a reasonable case for marine protected areas, and the difficulty of proving that particular fishing practices are harmful to biodiversity. Yet the process of providing for conservation of marine biodiversity has barely begun.

It is apparent from NIWA and MinFish publications, and from consultations with NIWA scientists, that soft sediment seafloor environments also have a distinctive and rich biodiversity, and that there is evidence of a high risk of large losses of biodiversity from activities which disturb these environments on a large scale. Key aspects of this evidence are:

• In soft sediments, habitats structured by immobile seafloor organisms have a very significant positive influence on seafloor biodiversity. This includes organisms that grow up into the water (eg, sponges, bryozoans, hydroids, black corals) or dig down into the sediments (eg, worms, shrimps, clams, echinoderms) thereby modifying their immediate environment and that of other animals;
• The removal of this habitat structure by dredging and trawling activities, even in relatively low-complexity soft sediment systems, significantly decreases their biodiversity in particular localities;
• Life-history traits typical of these species assemblages (great longevity, patchy recruitment, and restricted dispersal ability) probably mean that benthic habitat changes resulting from fishing activities are persistent, taking decades to restore even if not further disturbed;
• Repeated dredging and bottom trawling have been shown to have a marked negative effect on benthic species' richness and diversity, not just in particular localities but on a regional scale, that is, potentially on the scale of the total distributions of some species;
• This 'bio-desertification effect' (our term) has been shown to be correlated with site-specific indices of fishing intensity over time, when factors such as depth and substrate are held constant;
• Scientists believe there may already have been extinctions of some benthic species of localized distribution, species which were previously described but have not been found again in recent years.

Because fishing practices which affect the benthos are used over such wide areas; the distribution of benthic species is so little known; and the damaging effects of these practices on biodiversity appears to be cumulative; there is a prima facie case for early, precautionary establishment on an interim basis, of widely distributed areas of protected seafloor.

These interim protected seafloor areas should be selected on a basis which is as representative as possible, given present information, of the biogeographic diversity of seafloor environments in the New Zealand region; and which takes advantage of the existence of areas (within particular habitat categories) that are known to have been lightly fished. Fishing practices which disturb the seafloor should be excluded from these protected areas in the meantime, pending further research into a wider range of management strategies that may be capable of reducing the risks to benthic biodiversity.

In the longer term, we envisage an appropriate balance of protected and more-or-less intensively fished seafloor environments. Fishing practices in the latter areas may be modified over time to reduce impacts on benthic ecosystems, with benefits to both the sustainability of some target fisheries, and to biodiversity. The resulting balance of protected and sustainably utilized areas of seafloor would be analogous to the balanced portfolio of land uses which prevails in the terrestrial environment. In both cases, the existence of highly protected areas contributes to both the sustainability and the political acceptability of intensive utilization in other areas.

Some excellent work is under way to develop a marine classification system which, in some years' time, in conjunction with other research work, will provide a much-improved basis for establishing a system for conservation of marine biodiversity. The urgent need we see is for measures to provide interim protection for vulnerable areas of the seafloor, selected on the basis of information we already have, in order to minimize the risk of biodiversity losses in the meantime.

The discussion in this section is unable, in the time available for this study, to address comprehensively all the matters which arise under Issue 1. However, we have not neglected the significant environmental risks associated with practices used by some non-commercial fishers. These, for reasons of convenience, are considered as part of our discussion of the role of the informal fishing sector under Issue 2.

We have not been able to consider the implications of our recommendations for the overall management system including the property rights of quota-holders. We would hope however, that the concept of interim protection of areas of the benthos could be progressed in a rapid, pragmatic manner which either did not affect property rights, or could be accepted on an interim voluntary basis by quota holders.

We have been impressed by how technical innovations, such as the design of recreational fishing hooks and means of deterring dolphins and birds from set nets, can make a substantial difference to environmental outcomes of fishing practices. While innovations in the commercial sector are being funded from the conservation levy on commercial fishers, it would be desirable to stimulate public good innovation in the recreational and customary sectors as well, perhaps through provision of an independent Sustainable Fishing Fund, which could also support other community-based initiatives discussed in this paper. The concept would be analogous to the Sustainable Farming Fund.

Issue 2: Risk of adverse effects on aquatic ecosystems from inadequate restraint on quantities being harvested.

While there are clearly large potential risks to ecosystem health and stability from excessive commercial harvesting activities, we are reasonably impressed with the overall track record of New Zealand's quota management system (QMS) in reducing these risks. In general, and notwithstanding persistent difficulties especially with the orange roughy fishery, the QMS has shown itself capable of learning from mistakes, gathering better information and adjusting commercial catches downward when necessary; and in inshore fisheries, there broad trends of fisheries recovery from the depletion of earlier decades. In these respects the QMS appears to have performed better than other systems being used worldwide to manage fisheries.

In establishing total allowable catches for each fishery, the QMS takes into account fish catches by non-commercial fishing sectors, but it does not itself restrain these catches. This is because non-commercial fishers have been resistant to taking the kind of steps that would be required to integrate their activities into the QMS. At first glance, this situation does not appear to be of concern from an environmental perspective: the system as a whole remains within sustainability limits, since growing recreational pressure, while largely uncontrolled, could (if accurately measured) be accommodated by regular reductions of commercial catches.

In approaching this situation from a 3-E's perspective however, the ethical implications are of concern. The proposition that some participants in the fishery may have priority over others in the allocation of scarce resources may be justifiable, but it is problematic that this differential situation should be allowed to flow on to create, in effect, quite divergent ethical cultures and disciplines in relation to the conservation of fisheries.

We believe that the lack of a strong sustainability culture in what we term the 'informal' fishing sector is already contributing to undesired environmental outcomes at the local level; and it is likely that this largely un-managed source of environmental risk will lead to more serious deterioration in fisheries resources, on a larger geographic scale, over time. Such adverse trends would be accelerated by a feedback loop from the commercial sector: expanding recreational catches in some fisheries would erode the ability of commercial fishers in those fisheries to gain benefit themselves, from practices which conserve fishing stocks.

Equally, however, there is an important opportunity for this trend of undesired environmental outcomes to be reversed, through positive leadership and management effort focused on the informal fishing sector.

The informal sector includes a million New Zealanders who are at least occasional recreational fishers. It also includes customary Maori fishing; subsistence fishing and barter activities by socio-economically deprived communities; a substantial black market operation in some species; and commercial tour boat fishing activities. The informal sector is characterized by:

• The absence of any output controls on total fish catches;
• Relatively light restraints on fish catches, in relation to the non-commercial needs of most participants in the fishery;
• Relatively uncertain estimates of total catch in many fisheries;
• Thinly spread, patchy and relatively weak enforcement systems;
• Resource management in the sector is relatively heavily dependent for its effectiveness, on cultural norms and social capital.

• Damage to recreational fishing opportunity is widely regarded by New Zealanders as the most important environmental risk from activities in the fisheries sector;
• The growing total catches, and the practices being used, in the informal sector contribute a large component of overall impacts on, and risks to, the inshore fisheries resource and aquatic environment;
• While relatively effective systems to manage environmental risks are in place or are being developed in the commercial sector, in the informal sector such systems are weak, and are showing little sign of development;
• Continuing effective growth in the total share of several major fisheries taken by the informal sector has the potential, if not carefully managed, to impact adversely on the commercial sector's incentives to conserve inshore fisheries;
• Reducing environmental risks in the informal sector will depend on building public awareness of sustainability issues, bringing about change in cultural norms, and building social capital (functional networks and effective community organisations) in the sector;
• The existing skill base, modus operandi and perceived credibility of the Ministry of Fisheries mean that it is not currently well positioned to provide leadership in these tasks;
• The significance of the informal sector appears to be largely overlooked by the main environmental stakeholders involved in fisheries issues to date, even though the environmental risks associated with present attitudes in the sector are large;
• The attitudes of the million New Zealanders who are recreational fishers toward the need for output controls on their fishing activities, are also of high importance because of their undoubted linkage to a willingness to accept restraints for environmental reasons in other areas of their lives.

Unfortunately, we were able to find relatively little information of this kind for this study. Some preliminary results from the National Marine Recreational Fishing Survey were made available to us, together with a preliminary study of motivations and perceptions in the sector. We have also read a range of documents and publications (such as Fishing News) produced by recreational fishing interests, and interviewed several recreational fishing leaders, resource managers and researchers who have worked with fishers in the informal sector.

On this basis, a few preliminary observations can be offered:

• While up-to-date data will not be available until next year, and will have relatively wide error margins, it appears that the sector is continuing to account for a rising and significant proportion of the total catch in many inshore fisheries; and in relation to particular areas, the informal catch can be quite volatile;
• About 15 percent of fishers, who take 20 fishing trips a year or more, appear to account for almost two-thirds of the total recreational catch;
• Most of this group of frequent fishers, some of whom are very frequent fishers - fishing on 100 to 200 days a year - regularly take fish right up to the bag limit. We may thus characterize a high-impact fisher segment, a group which are probably a key influence on the state of the inshore fisheries they use;
• Evidently, unlike trout fishers, these high-impact seawater fishers do not practice a culture of restraint. Catch-and-release practices are not the norm (except for undersized or unwanted fish, which if gut-hooked or carelessly handled will often die anyway). The high-impact segment wants to take home as many fish as they can, to fill a freezer and give the rest away to friends and relatives;
• Unlike trout fishers, who seek deliberately to even the scales between themselves and their quarry by use of restrained technology such as light tackle, the high-impact seawater fisher segment favours more aggressive catching gear, including multiple-hook lines and set nets;
• While trout fishers appear strongly aware of the need to conserve fisheries resources, and financially support Fish & Game councils' work on improving fish habitats and on managing and replenishing stocks, many seawater fishers oppose similar institutional arrangements for their sector;
• While this stance might be interpreted as an indication of lower awareness of the need for sustainability practices, or of a lack of willingness to take responsibility for looking after the fishery, there is a complicating factor not present in the trout fishery, namely a popular perception of a 'hidden agenda' by the authorities, to restrict recreational fishing in favour of commercial interests;
• Notwithstanding their many differences with trout fishers, most seawater recreational fishers appear to resemble trout fishers in one key respect: the prime value they reportedly place on fishing is experiential, such as relaxation in the outdoor environment and an opportunity to get away from it all; this value is unrelated to the number of fish taken ashore. While the data on this issue is not particularly robust, it does suggest that a progressive shift toward more conservative fishing practices need not conflict too strongly with the core values of a majority of these fishers;
• It is important to note that the great majority of recreational fishers do not fish very often, with only a small proportion catching the bag limit on most of the days when they do fish; thus they do not constitute a major management problem for the fisheries they use. Indeed this large, low-impact segment has the potential to swing in behind a well-designed public awareness campaign on fisheries conservation, placing peer pressure on the high-impact segment.

The fear of being restricted to a fixed quota share is understandable. The average per capita entitlement to fish would then shrink over time in proportion to growth in recreational fishing effort, which could be considerable. Recreational fishing effort in a given area is driven by a number of factors: local population growth, rising incomes (those on higher incomes have a greater propensity to make fishing trips) and improved fishing opportunity associated with the recovery of valued recreational fish stocks such as snapper. All these factors are growing rapidly in the prime recreational fishing areas around eastern Northland, Auckland and the Bay of Plenty. This north-eastern area is an area where 57 percent of finfish anglers and 44 percent of shellfish/rock lobster fishers already believe that fishing grounds are being lost to them, or were no longer worth visiting, because of overfishing. In the long run, it is difficult to see that a policy of restricting recreational fishing to a fixed proportional share of a fishery can be politically sustainable in a democracy in which fishing is so popular.

On the other hand, the simple statutory creation of a recreational right in priority would be difficult to justify by itself, for a number of reasons:

• Economic: Over time, the allocation of fisheries resources would progressively shift from the commercial sector to the informal sector, thereby reducing the country's capacity to obtain export earnings from the inshore fishing industry;
• Social: Within the informal sector, the main winners from this shift would be the small segment of high-impact fishers identified above, who account for two-thirds of the recreational catch; while most New Zealanders would be losers, due to the reduction of their country's export earnings; this re-distribution of collective wealth toward a small group raises equity issues;
• Environmental: Allowing high-impact informal sector fishing to continue, and to expand, would enable the frontier mentality within segments of the informal sector to survive and prosper. With an unconditional right in priority, growing recreational user pressure on inshore fisheries would have to be met by simply shrinking the commercial catch year by year. This would initially undermine, and eventually destroy, the incentives on commercial fishers to conserve stocks, and could create scenarios leading to destructive conflict between the two sectors. Moreover, until the commercial catch reached zero, there would be no incentive on informal sector fishers to moderate their own catching behaviour. Environmental risks associated with perverse incentives and inappropriate attitudes within the fishery, and with the volatility and uncertainty of the informal sector catch, would be considerable.

We would like to offer a contribution, based on our work on this project. We suggest any solution should have a number of balanced elements:

1. There should be a widely agreed statutory mechanism which provides for increasing the recreational share of the fishery from time to time. This would confer priority rights in the allocation process, to recreational fishers, after customary fishers and before commercial fishers, but it would be conditional. The increased allocation could only be triggered by the prior fulfillment of certain widely agreed conditions relating to the development of good conservation practices within the recreational fishing sector.
2. While the detail of these conditions would be negotiated through a fisheries planning process, they would rest on a foundation of statutory criteria, and there would be a role for the Environment Court in making decisions, on evidence presented, against those criteria in the event that the parties were unable to reach agreement. We believe that a role for the Court is an important safeguard, offering the best prospect of sound, thorough, considered decision-making which has a regard to the long-term well-being of the fisheries management system as a whole.
3. We suggest that the Government should seek an electoral mandate for this policy framework, and then invite sectors to participate in working out the detailed criteria.
4. The opening allocation of fisheries resources to recreationists should be based on recently estimated historical catches (including the National Recreational Fishing Survey).
5. The statutory framework should address the issue that perverse incentives are created for commercial fishers once the marginal allocation reaches a certain percentage in favour of recreational fishers. Increases in the recreational share up to this level should be non-compensatable, while increases above this point should require purchase of quota being relinquished by the commercial sector. In the latter case, decisions of the Environment Court would not be final. The Court proceedings would take the form of an Inquiry, leading to recommendations to the Minister of Fisheries.
6. There should also be a policy of fostering the growth and effectiveness of recreational fishing associations. This can be achieved through the incentive of the conditional statutory mechanism described above; through the development of outreach and facilitation activities by central and local government agencies; and through the availability of contestable funding to associations which wish to take on fisheries management functions over particular areas. These areas should be developed on a 'dominant value' basis (see discussion under Issue 5 below).
7. There should be a government-sponsored public awareness campaign which rallies public support and peer pressure for changed recreational fishing practices. This would need to be based on prior research into the recreational fishing population, segmenting it in terms of attitudes and motivations. The campaign should be generally perceived as being led by media celebrities or well-known community figures, rather than by the Ministry of Fisheries itself.

A sub-issue we should like to touch on in relation to Issue 2 concerns the funding of research activities, especially those directed at stock assessment. There are some good arguments for devolving more responsibility for certain areas of research to quota holders' organisations. However, contemporary trends in public perception of science in the postmodern environment have created a significant threat to the credibility of industry-funded science, especially where the direction of private research activities has the potential to affect the public good. At this stage, it appears to us to be an advantage that most funding for research is channeled through an independent entity, the Ministry of Fisheries.

Issue 3: Risk of adverse effects on aquatic ecosystems from breaches of New Zealand's biosecurity, and of failure to effectively manage potential pest organisms once they are in the country.

In the time available to complete this work it was not possible for us to make a detailed evaluation of biosecurity risks in the fisheries sector. There are however a number of factors of concern:

• 160 species of alien marine organism have been introduced to New Zealand waters over the last 90 years, and these are continuing to arrive at the rate of at least 1.5 species per year, mostly on the hulls of visiting boats;
• Some of these alien species have substantially, and probably irreversibly, displaced indigenous ecosystems over significant areas, with substantial adverse effects on biodiversity and/or other community values;
• Many already-introduced alien species which have pest potential, have yet to be widely distributed around the New Zealand coast; fishing boats, including recreational vessels, are potential vectors of distribution;
• While an improved surveillance network is being established, there are as yet few systems in place to curb the spread of these organisms, and a low level of public awareness on this issue;
• Activities such as gross disturbance of benthic environments, and reduction of estuarine and coastal water quality, which place indigenous aquatic ecosystems under stress, can increase the risk of successful invasion by alien organisms;
• There appears to be a relatively high risk of further unwelcome species arrivals in New Zealand, and insufficient focus on measures to reduce this risk, with particular reference to organisms carried on the hulls of small, ocean-going pleasure craft.

Ecologic believes a higher priority should be placed on these matters, especially on achieving a reduction in the inadvertent movement of alien organisms within New Zealand. We note the Government has a major initiative under way at present on the development of a biosecurity strategy for New Zealand.

Issue 4: Risk of adverse effects on aquatic ecosystems from failures to control accelerated sedimentation, contaminated run-off and other land-based sources of impact.

Key aspects of this issue are:

• Many areas which are relatively accessible and potentially highly valued kaimoana/fisheries resources are subject to microbial contamination, especially after rain, from various sources that ought to be better managed. These include run-off from farming activities, stormwater from roads and urban settlements, sewage overflows from poorly maintained urban systems, and seepage from septic tanks. While this type of contamination is reversible in theory, in practice the contribution of contaminants from non-point source discharges associated with unsustainable land use practices means that significant fisheries are rendered more or less permanently unsafe for human enjoyment
• In some areas, the run-off includes persistent and bio-accumulative toxins such as heavy metals and poly-aromatic hydrocarbons. Even when discharged at low levels, these contaminants build up over time in marine sediments, and then in the fisheries food chain. Such discharges represent essentially irreversible risks to future generations.
• Many rivers discharge large tonnages of sediment, sourced from accelerated soil erosion that results from unsustainable land use practices. These discharges degrade estuarine fisheries, especially shell-fisheries, and in some areas, they smother wider coastal environments including reef fisheries.
• In some estuaries, large quantities of organic matter and/or nutrients discharged by farming activities and/or agricultural processing industries are causing anoxic sediments and/or periodic, eutrophic conditions in the waters. These conditions are inimical to healthy estuaries and fisheries.

• Insufficient site-specific scientific understanding of the relationship between unsustainable land use practices and downstream consequences;
• High costs of improved urban stormwater and sewage management where retrofitting of systems is required;
• Political reluctance to take regulatory action in respect of unsustainable rural land uses.

We suggest that the Ministry ought to play an active research, advocacy and facilitation role in respect of land-based sources of environmental risk to fisheries. It should:

• research and document adverse effects of land use practices on estuarine and coastal ecosystems and their fisheries resources;
• advocate for effective preventive action through Resource Management Act processes, including appeals to the Environment Court where necessary; and
• facilitate action by local groups of resource users with whom it has an active relationship, including groups seeking to develop fisheries plans.

In section 2 above we identified "risks to ethical and other cultural values." In many cases, such values are best realized through direct management of discrete geographic areas by those who hold those values most strongly (such as iwi organisations or recreational fishing associations), or by agencies which embody such values (such as the Department of Conservation). As well as managing the areas in question for a dominant value, or a group of compatible dominant values, there is a value being placed on the assumption of management control itself - as in the resumption of rangatiratanga and kaitiakitanga over a local fishery by iwi.

Behind many fisheries arguments at the local level, there lies a sense of loss of control over valued resources - often to outside commercial interests. Where it is possible, the best solution in such situations is that groups with particular interests could be enabled to play a dominant role in the management and conservation of selected areas of the coastal marine environment. This approach is already recognized in concepts like marine reserves for conservation, and taiapure and mataitai for customary Maori management; but in practice, few of these areas have yet been established.

Further, while the concept has been accepted in principle that Maori should have management of areas of customary importance to them, non-Maori recreational fishers who have a long and passionate relationship with particular areas have been given no similar recognition.

A sense of "ownership" over the management of a valued resource can be the key step that enables people to move on from blaming others, to taking on conservation responsibilities themselves. We foresee that the establishment of widespread networks of marine reserves managed by the Department of Conservation; taiapure and mataitai managed by iwi; recreational fisheries areas managed by recreational fishing organisations; and some combinations of the above, managed by community-based management groups; could eventually remove a great deal of the conflict and mistrust involved in the present fisheries management system, and restore or establish a much higher level of stakeholder satisfaction with the system. An aspect of this worth mentioning, is that it could free up commercial fishers to manage effectively, with less distraction, the large residual geographic areas which in effect, would be dominantly allocated for the exercise of their quota rights.

The potential for creating dominant-use areas depends to some extent on the boundaries of the relevant ecosystem. In the case of reserves for benthic biodiversity, for example, a viable benthic ecosystem could probably be protected without the need for fishing restrictions on fisheries in the water column above (except for a need to exclude aquaculture); whereas in the case of a recreational management area for fish with a wide-ranging stock area, it would arguably be quite difficult - although by no means impossible - to make the concept workable without taking over an entire fishery.

An interesting case study of the latter type of situation is provided by the proposal currently under development for the establishment of a community-managed fishery on the Kaipara Harbour. The proposal would in effect, be dominantly managed by recreational fishers, Maori customary fishers, and small commercial fishers based in the harbour itself. The latter would operate under a separate QMA for flounder, grey mullet and rig from the existing QMAs for those species, which cover the whole marine area around the top half of the North Island.

The purpose of the separation would be to protect the harbour from the incursions of fishers holding quota in the wider QMAs, who periodically cause local depletion in the harbour fishery, with severe impacts on recreational and customary fishing. The issue of subdividing off and separately managing a portion of the wider fish stock does not seem insurmountable, although a separately managed fishery for the Kaipara Harbour would need to include a sizeable zone around the mouth of the harbour for rig and snapper fishing, to remove the dysfunctional incentive which might otherwise exist, for quota holders in the wider fisheries for these species to scoop up a large proportion of fish entering the harbour.

While there are some stock management and economic efficiency issues associated with this proposal which need further analysis, the issue does appear to boil down to the question of the value, if any, to be placed on:

• Avoidance of localized depletion within QMAs, where this impacts on the sustainability of distinct community-valued fisheries, especially local recreational and customary fisheries;
• Encouraging the development of areas managed by particular interests on dominant-value basis, as a key part of the type of fisheries management system we wish to have in New Zealand.

We do not think that it is helpful for any parties to establish target areas or percentages of the coastal environment for management for any dominant use. There is no reasonable alternative to the process of gathering data, consulting communities of interest, and carefully working through the issues in each case. Finally, we think that careful consideration needs to be given to the design of accountability mechanisms for dominant-value management areas, to ensure they achieve their objectives.

Issue 6: Risk of loss of amenity in the aquatic and coastal environment.

Ecologic would not wish to make too much of an issue of the amenity losses associated with aquaculture development, however, it is striking what an adverse reaction such developments almost always produce in neighbouring communities. There are also some amenity and attractiveness issues associated with fishing facilities generally, particularly in remote and special places such as Jackson Bay.

The key systemic problem here is the failure of regional councils to adequately plan the allocation of space and other requirements for fishing, especially aquaculture, developments. The policy measures recently announced by the Minister appear to address this issue.

While we consider the failure of regional councils in the aquaculture planning area is indicative of a deeply-seated deficiency in the overall resource management system, which needs reform, analysis of these issues is beyond the scope of the present exercise.

Ecologic's overall view is that substantial expansion of the aquaculture industry, in line with the industry's stated goals, requires a relatively modest total area of land which it ought to be possible to accommodate in the context of suitable environments around the New Zealand coast. Given a co-operative approach, effective planning and the adoption of good practice by the industry, it should be possible to achieve this result without significant loss of amenity. It is clear from experience to date that placement of structures well off-shore is generally a key component of striking the desired balance.

Issue 7: Risk of poor energy and waste management.

The fishing industry has not been amongst the leaders in the implementation of policies for reduced generation of waste and of greenhouse gas emissions. From by-catch at sea to the waste produced at fish processing factories, there are major opportunities for waste reduction and resource recovery in the fisheries sector, which need to be actively explored. Use of fisheries waste in compost products is a particular opportunity. Improved management of residual waste discharges is also an issue, notwithstanding improvements in recent years. Fishing industry detritus which piles up on beaches continues to be an objectionable aspect of the industry's practices, and has a high public profile, yet it is very largely avoidable. The reduction of greenhouse gas emissions is a more difficult task, which will have to be faced.

There is a need for improved economic signals of the true cost to society of waste discharges and greenhouse gas emissions. These are likely to emerge from wider environmental policy developments over the next few years, and Ecologic believes the sector should be encouraged to take a pro-active stance by identifying opportunities for improved performance.

There is an immediate and prime need for effective collaboration in the development of an environmental strategy for the Ministry. In addition, this paper has identified a number of opportunities in which it is envisaged that such collaborations would take place, particularly in the development and management of dominant-value management areas at the local level.

Collaborations of this sort are not constrained by lack of opportunity in the formal sense, although it has to be recognized that achieving anything from such work is dependent on prolonged commitments of resources, that can seem quite major in the eyes of small environmental and community groups.

The issue is, how can such work be resourced, given that it requires the commitment of knowledgeable, skilled people over sustained periods of time? Lack of resources has long constrained Ecologic from becoming involved in work in the fisheries sector, and it may continue to do so, depending on a review of our priorities to be undertaken in the light of the present report, next February. The demands on Maori groups to participate in consultation processes on public good issues are quite phenomenal, and resources are an issue for them also, notwithstanding that some have sources of commercial income from the fisheries sector. Recreational fishers are, like environmental stakeholders, without income to support their involvement in public good processes and there are clearly limits on the extent to which they wish to divert their spare time from recreational fishing itself, to recreational fishing politics and management.

We suggest that the Ministry ought to follow up on its welcome funding of the present exercise, by allocating some resources to enable a better balance to be achieved in its consultation processes in future. Supporting such activities could be an aspect of the Sustainable Fishing Fund mentioned earlier.

General:

1. The Ministry should seek to obtain, through analysis and consultation, a clearer specification of the objectives it wishes to achieve in an environmental strategy.
2. The Ministry should develop a systematic approach to environmental risk assessment, and use this framework as a guide for the development of research and policy development activities pursuant to its environmental responsibilities.
3. The Ministry should recognize that successful implementation of an environmental strategy in its sector will involve large-scale change to existing attitudes and behaviours by the fisher population. It should therefore obtain an overview assessment of the world's best practice in voluntary behaviour modification campaigns, drawing not only on experience in fishing (which may be limited) but also on campaigns and approaches that have been successful changing behaviours in other resource use areas such as agriculture, and in modifying the habits of drivers and smokers.
4. The Ministry should establish a publicly-funded Sustainable Fishing Fund, which could support independent implementation on a project basis of a variety of the initiatives flagged in this paper for the non-commercial sectors, which will generally require funding support if they are to happen. These include: stimulating technological innovations in sustainable fishing methods; the development of plans and consultation processes for dominant-value management areas; community education, outreach and facilitation projects, including biosecurity awareness-building projects; and providing assistance for non-commercial groups to better participate in consultation processes under the Fisheries Act, including the proposed use of the Environment Court to resolve some allocation/conservation performance issues.

5. Ecologic's concerns as environmental stakeholders are strongly based on assessments of environmental risk, and they are open to being modified in the light of improved information about the nature, extent and manageability of those risks.
6. At a broad level our issues of concern are the following, and we have ranked them into two groupings, of high and moderate importance respectively:

 

 

Issues of high importance:

• Risk of adverse effects on aquatic ecosystems from the unintended impacts of harvesting and aquaculture practices. Under this heading, we have particularly focused on the immediate risks to benthic biodiversity.
• Risk of adverse effects on aquatic ecosystems from inadequate restraint on quantities being harvested. Under this heading, we have particularly focused on the fast-developing risks in the informal fishing sector, for which no adequate systemic restraints are currently available.
• Risk of adverse effects on aquatic ecosystems from breaches of New Zealand's biosecurity, and of failure to effectively manage potential pest organisms once they are in the country.
Issues of moderate importance:
• Risk of adverse effects on aquatic ecosystems from failures to control accelerated sedimentation, contaminated run-off and other land-based sources of impact.
• Risk of inadequate allocation of fisheries resources for primarily non-commercial purposes (conservation, recreation, customary management and other local community-based values).
• Risk of loss of amenity in the aquatic and coastal environment.
• Risk of poor energy and waste management.

7. Risks to benthic biodiversity: We support the establishment of a balance of protected and sustainably utilized areas on the seafloor, analogous to the balanced pattern of land uses which prevails in the terrestrial environment. In both cases, the existence of highly protected areas can contribute to both the sustainability and the political acceptability of intensive utilization in other areas. The evidence of likely short-term biodiversity losses on the benthos compels us to recommend some precautionary, interim steps to exclude representative areas of seafloor from bottom-fishing activities, pending the obtaining of better information for longer term decision-making.
8. Risks of lack of effective harvest restraints in informal sector: We propose the development of a balanced package of measures to address this issue, including the following major elements:
• A statutory mechanism enabling increases in the recreational share of the fishery, conditional on demonstration of good conservation performance in recreational sector fishing practices;
• A role for the Environment Court in making decisions on the basis of evidence and statutory criteria where stakeholders are unable to agree on shares between themselves;
• Provision for reductions in the commercial share of a fishery to depend on compensation of commercial quota holders in some circumstances;
• A policy of fostering the growth and effectiveness of recreational fishing associations
• A public awareness campaign fostering conservation practices in fishing, based on the prior use of market research to segment, characterize and target the market effectively.
9. Research: We favour continuation of a system under which the funding and direction of fisheries research activities with potential to affect the public good, is carried out through independent public agencies such as the Ministry of Fisheries.
10. Biosecurity: We favour a higher priority for educational and regulatory efforts to minimize biosecurity risks that are associated with the normal course of recreational and commercial fishing.
11. Land-based contamination: We propose that the Ministry develop an active research, advocacy and facilitation role in respect of land-based sources of environmental risk to fisheries.
12. Allocation issues: We propose that a higher value should be placed in fisheries policy, on these objectives:
• Avoidance of localized fisheries depletion within QMAs, where this impacts on the sustainability of distinct community-valued fisheries, especially local recreational and customary fisheries;
• Encouraging the management of particular areas on a dominant-value basis, for such values as recreation, biodiversity conservation, customary Maori use, and local community values, as a key part of the type of fisheries management system we wish to have in New Zealand.
13. Amenity: We believe substantial expansion of the aquaculture industry should be possible without serious impact on amenity values, provided there is a co-operative approach, effective planning and the adoption of good practice by the industry. Placement of structures well off-shore is generally a key component of striking the desired balance.
14. Energy and waste management: The fisheries sector should be encouraged to take a pro-active stance to energy and waste management by identifying opportunities for improved performance.

15. Stakeholder collaboration is immediately needed in the development of an environmental strategy for the Ministry. A number of other opportunities have been identified, particularly in the development and management of fisheries management areas managed on an agreed basis for selected, dominant values at the local level.
16. Collaborations of this sort are not constrained by lack of opportunity in the formal sense, but rather by lack of resources, given that collaborative endeavours require the commitment of knowledgeable, skilled people over sustained periods of time. We suggest that the Ministry should facilitate such collaboration on a project basis through the proposed Sustainable Fishing Fund.

Ecologic - Pathways to Sustainability

The launching of the Ecologic Foundation is based on this statement of our core values and identity.

We believe that all pathways to sustainability must respect and harmonise three sets of principles - those concerned with Ecology, Economy, and Ethics. These are the three Es of sustainability. Developed in a mutually supportive way, they can offer a new, multidimensional model of what we mean by wealth or progress.

We can claim sustainable progress when measures of economic, ecological and ethical well-being are all improving together - and not otherwise.

What do each of the three Es mean to us?

We believe that ecological well-being arises when people live in harmony with nature, and safeguard the interests of future generations, by sustaining fundamental natural processes over time. Ecological well-being is based on a respectful relationship with nature, something the world is gradually re-learning the need for. This philosophy supports the careful use of natural resources for human benefit, but requires the avoidance of undue risk to ecosystems and their components, including humans.

We affirm that economic well-being is vital to enable fulfillment, opportunity, and freedom. We embrace the potentially positive roles of technology, innovation, economic growth and globalisation. We seek practical, enduring and least-cost solutions to the problems and challenges of the development process.

We believe ethical well-being is a characteristic of a society which affirms and develops the highest human qualities. A contemporary understanding of the character of an ethical society is one that shows and fosters respect for all people, considering their needs, values and interests; which cultivates mutuality, civility, personal integrity, openness, good faith, cultural expression, and respect for science and reason; and which links freedom with responsibility to others.

Interviewees

The following people contributed significantly to our understanding of environmental issues in the fisheries sector. We are grateful to them for their time and insight.

Paul Barnes, recreational fishing advocate, Option 4
Rick Boyd, recreational fisheries researcher, Kingett Mitchell
Ron Brady, Chairman, NZ Rock Lobster Industry Council
Dennis Bush-King, Environment & Planning Manager, Tasman District Council
George Clement, Orange Roughy Management Company Ltd
Martin Cryer, scientist, NIWA Auckland
Pete Dawson, Southeast Finfish Management Ltd
Bob Drey, policy adviser, Ministry of Fisheries Auckland
Nici Gibbs, Science and Policy Manager NZ Seafood Industry Council
Max Hetherington, NZ Recreational Fishing Council
Dylan James, recreational fisheries policy specialist, Ministry of Fisheries
Craig Lawson, policy manager, Te Ohu Kaimoana
Megan Linwood, marine policy specialist, Ministry for the Environment
Dominic McCarthy, water quality scientist, Auckland Regional Council
Alison McDiarmid, community fisheries researcher, NIWA Wellington
Jim Mace, Hoki Fishery Management Company Ltd
John Mitchell, Nelson Maori fisheries interests
Steve O'Shea, scientist, NIWA Wellington
Graeme Ramsay, mayor of Kaipara District and chair, Kaipara Harbour Sustainable Fishing Study Group Dargaville
Don Robertson, divisional research manager NIWA Wellington
Kirsty Woods, policy adviser, Te Ohu Kaimoana

Please respond on this form (or on an additional sheet if required) and return to Ecologic Foundation, PO Box 756 Nelson by 24 December 2001

Your response to this survey will be confidential to Ecologic. However, if you would like to receive a copy of our report to the Ministry of Fisheries, or to participate in Ecologic activities on fisheries issues, please add your name and address here:

Name: .......... Copy of report: Yes/No Further participation: Yes/No Address: ............................................................. ......................................................................

1.  Do you agree with our characterization of the following environmental risks facing the fishing sector (please indicate any suggested changes or additions):

Issues of high importance:

• Risk of adverse effects on aquatic ecosystems from the unintended impacts of harvesting and aquaculture practices. Under this heading, we are particularly concerned about risks to seafloor biodiversity.
• Risk of adverse effects on aquatic ecosystems from inadequate restraint on quantities being harvested. Under this heading, we are particularly concerned about inadequate conservation practices in the recreational fishing sector.
• Risk of adverse effects on aquatic ecosystems from breaches of New Zealand's biosecurity, and from failure to effectively manage potential pest organisms once they are in the country.

• Risk of adverse effects on aquatic ecosystems from failures to control accelerated sedimentation, contaminated run-off and other land-based sources of impact.
• Risk of inadequate allocation of fisheries resources for primarily non-commercial purposes (conservation, recreation, customary management and other local community-based values).
• Risk of loss of amenity in the aquatic and coastal environment.
• Risk of poor energy and waste management.

Summary of main recommendations:

1. Risks to benthic biodiversity: We support the establishment of a balance of protected and sustainably utilized areas on the seafloor, analogous to the balanced pattern of land uses which prevails in the terrestrial environment. We recommend some precautionary, interim steps to exclude representative areas of seafloor from bottom-fishing activities, pending better information for long term decision-making.
2. Risks of lack of effective harvest restraints in informal sector: We propose the development of a balanced package of measures to address this issue, including:
• A statutory mechanism enabling increases in the recreational share of the fishery, conditional on demonstration of good conservation performance in recreational sector fishing practices;
• A role for the Environment Court in making decisions on the basis of evidence and statutory criteria where stakeholders are unable to agree on shares between themselves;
• A policy of fostering the growth and effectiveness of recreational fishing associations;
• A public awareness campaign fostering conservation practices in fishing.
3. Biosecurity risks: We favour a higher priority for educational and regulatory efforts to minimize biosecurity risks that are associated with the normal course of recreational and commercial fishing.
4. Risks from land-based contamination: We propose that the Ministry develop an active research, advocacy and facilitation role in respect of land-based sources of environmental risk to fisheries.
5. Allocation issues: We propose that a higher value should be placed in fisheries policy, on these objectives:
• Avoidance of localized fisheries depletion within QMAs, where this impacts on the sustainability of distinct community-valued fisheries, especially local recreational and customary fisheries;
• Encouraging the management of particular areas on a dominant-value basis, for such values as recreation, biodiversity conservation, customary Maori use, and local community values, as a key part of the type of fisheries management system we wish to have in New Zealand.
6. Amenity: We believe substantial expansion of the aquaculture industry should be possible without serious impact on amenity values, provided there is a co-operative approach, effective planning and the adoption of good practice by the industry. Placement of structures well off-shore is generally a key component of striking the desired balance.
7. Energy and waste management: The fisheries sector should be encouraged to take a pro-active stance to energy and waste management by identifying opportunities for improved performance.
8. Sustainable Fishing Fund: We propose the establishment of a publicly-funded Sustainable Fishing Fund, to stimulate technological innovations in sustainable fishing methods; support community projects for better fisheries management; and enable wider participation in Fisheries Act processes.