Consultation on Improving Whitebait Management
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Consultation on Improving Whitebait Management C/ - Secretary, Trish Roney 44 Stuart and Chapman Drive, Karoro, Greymouth Ph 03 768 7103 Cell 027 768 7103 [email protected] Whitebait Management Consultation Department of Conservation PO Box 10420 Wellington 6143 Dear Sir/Madam Re: Submission on Improving Whitebait Management This submission represents the interests of 441 members of the West Coast Whitebaiters Association and their families, in relation to the proposed new regulations outlined in the document “Improving Whitebait Management - Te Whakapai ake i tewhakahaere inanga, and has extensive support of the wider c ommunity of the West Coast including the support of the Westland, Grey , Buller and West Coast Regional Council s . The two local West Coast Iwi, Te Runanga o Makaawhio and Te Runanga o Ngati Wae Wae both support this West Coast Whitebaiters Association submission. 1 Interest: Our membership consists of both registered stand owner s and casual whitebaiters . As principally West Coast resident s , we are aware of the importance of whitebaiting to our community. Whitebait fishing is part of the fabric of our culture, history, and identity. As a result of mining and forestry restrictions, whitebaiting and more importantly , visiting whitebaiters, are a significant component of local economies. For those of us who are stand owner s, we have considerable and ongoing investment in the whitebait fishery , incl uding equipment, batch es and payment of local body rates and stand fees. Several of the proposed changes to whitebaiting regulations have the potential to severely restrict, or even end our whitebaiting. Two obvious examples are the closure of rivers and the ban ning of screens which would make whitebaiting from stands impossible, and fishing in many sections of our rivers extremely difficult. Overview: The ‘Improving whitebait management’ consultation discussion document proposes many changes to the regulation s which we agree with, and can be viewed as sensible and practical ways to contribute to the sustainability of whitebait (Galaxias sp) populations nationally . However we have a major criticism of the entire process in that it is based on the dogma that a ll whitebait populations in all parts of the country are at risk or in decline. In our region this is simply not the case. The Department of Conservation have stated in a response to an Official Information Request (2018) that they have no evidence of a decline in whitebait numbers on the West Coast or Fiordland , together the largest contiguous area of whitebait habitat in New Zea land . (Ref. 18 - E - 0614 and DOC – 5588499). A further illustration of this are the graphs below for three major whitebaiting rivers on the West Coast. (This data given in good faith, was supplied by individual whitebaiters on the basis of anonymity). As e xpected there is considerable variation between years depending on a combination of factors , including the weather during each season . For example in 2019 spring saw most West Coast rivers in almost continuous flood. The important statistic however is the trend in the data, which shows no decline in whitebait numbers over the period s recorded . In fact, the reverse could be argued . 2 Daily catch rate Wanaganui River - with trend 10.00 9.00 8.00 7.00 y 6.00 a d / 5.00 g K 4.00 3.00 2.00 1.00 0.00 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 2017 2019 Year Catch rate Buller River Kg/day with trend 14.00 12.00 10.00 y a 8.00 d / g 6.00 K 4.00 2.00 0.00 Year Catch rate Karamea River Kg/day with trend 7.00 6.00 5.00 y 4.00 a d / g K 3.00 2.00 1.00 0.00 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 Year 3 Data: T he ‘ New Zealand Freshwater fish Database ’ and associated ‘New Zealand Threat classification System’ are the major reference s up on which the consultation document is based . While pointing out that four of the five species of whitebait are either threatened or in decline, they admit that some species are ‘data poor’ with estimations of some species being extremely wide (eg Giant Kok o pu ( 20,000 – 100,000). The Inanga (Galaxias maculatus ) which is 90% of the whitebait catch in New Zealand, while being described as ‘at risk’ , i s further described as ‘secure overseas’, being found in many Southern Hemisphere countries. Similarly, Koaro (Galaxias brevipinnis ) described as ‘at risk’ has a similar southern distribution. Yet some conservationists and even politicians describe eating a whitebait the same as eating a kiwi. ( Labour MP Duncan Webb stated in Parliament that “eating Whitebait is akin to eating a kiwi”. ) Sadly, such ‘misinformation’ is widely accepted by many New Zealanders who take such statements at face value and perpetuate the myth. The reliability of the New Zealand Freshwater Fisheries Database has been questioned by Crow et al 2016 in a NIWA repor t . “Crowe et al. (2016) discuss the biases present in the data contained in the NZFFD; for example, differences in habitats surveyed, methods used and environmental conditions. The variability generated by these differences require standardisation of dat a to be undertaken. Crow et al. (2017) found insufficient accurate data to generate standardised trends for any of the whitebait species, except for kōaro. Once data was standardised, kōaro were predicted to be declining by 0.05% (+/ – 0.02%; CI 95%) per ye ar (Crowe et al. 2017). A comprehensive New Zealand - wide network of monitoring sites is required to gather accurate, long - term information about population trends for the five migratory galaxias species” Clearly, this critical analysis relegates Database figures for four of the five whitebait species as worthless, and for Koraro (Galaxias brevipinnis) reduces the rate of decline from an estimated 10% to70%, itself a very wide range, to just a 0.05% (or one 20 th of 1 % )decline. Hardly significant in anyone ’s terms. A further consideration in the management of whitebait is the fact that all five species of whitebait can now be successfully bred through aquaculture, to the extent that at time of writing Paul De ck er of Manaki Whitebait , Wa r kworth ( guest speaker at an association meeting 20.1.2020 ) has 120,000 Giant Kok o pu living in his tanks. He has also supplied short - jawed k ok o pu to Auckland Regional Council for restocking rivers. The potential of the conservation benefits of aquaculture and emerging t echnologies appear not to be considered as a conservation measure in this document. It should also be noted that this latter figure is greater than the total number of wild Giant Kokopu estimated by the NZ Threat Classification System. 4 Another major concer n is that the proposals appear in isolation of other more generally accepted and more critical conservation requirements such as habitat enhancement and facilitation of migration to adult habitat and spawning areas. Indeed , to quote Minister Sage in 2018 : "For many threatened native fish, being caught on a line or net is not the threat. Restoration of habitat and preventing further habitat loss is essential to ensure our native freshwater fish thrive". ( Stuff – Charlie Mitchell feb . 14 th 2018 ) Furthermore “A guide to restoring Whitebait habitat” NIWA Research carried out by J. Richardson; M. J. Taylor. Science Communication is germane : “Our research has indicated that whitebaiters catch only a small proportion of the whitebait run in medium to large rivers (Mora 1992, Allibone et al. 1999), so further restrictions on the fishery are unlikely to have much impact on inanga populations. In contrast, studies of freshwater growth and egg development showed mortality during these stages was very high (Mitchell 1991, Richardson et al. 2000), so management strategies that improve inanga adult and spawning habitat and increase survival could substantially benefit the fishery. ” (https://niwa.co.nz/sites/niwa.co.nz/files/a_guide_to_restoring_inanga_habitat .pdf) This suggests that the closure of large to medium rivers, at least their main flow, is pointless and would simply achieve ongoing resentment among whitebaiters and the local community. Management Strategies: Clearly, all whitebait conservation strategies need to be integrated and holistic and it is staggering to learn from DOC D irector General Lou Sanson that the department has no dedicated budget for managing whitebait! ( Reference : Grey mouth Star 12 Oct 2019 ) . Establishing a dedicated budget for whitebait management should be an obvious first step. The second step should be to immediately begin gathering reliable and valid scientific data on whitebait population dynamics throughout New Zealand and then base management strategies upon this to achieve the sustainability outcomes desired by all. It is significant that the DOC whitebait working group (publicised minutes meeting 1 2018) cited a lack of data and scientific kn owledge as a major issue for whitebait fisheries management nationally, specifically citing the following critical areas: 5 On populations On population structure (“stocks”) On species dispersal and recruitment around different parts of the country amount o f redundancy in the population? different population trends in different parts of the country? unknown predation by introduced species how much habitat do species (populations) need throughout their life cycle? composition of catch (varies year to year) Obviously, such a wide ranging lack of data and scientific knowledge in such critical parameters makes the majority of management proposals in the consultation document extremely arbitrary, and suggests they reside in the context of a knowledge vacuum. By gathering reliable population and catch data, whitebait fishery managers would have a sound basis upon which to develop management strategies. Such management strategies must be adaptive and link to population trends, taken over time, for individual catchments.