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Sent to the Department of Conservation on 27 February 2020

Summary of Forest & Bird's submission to Department of Conservation on whitebait management:

New Zealand’s six whitebait species are at risk. If something urgent is not done to conserve these species, they could be lost forever.

The Department of Conservation’s mandate is: "To preserve so far as is practicable all indigenous freshwater fisheries, and protect recreational fisheries and freshwater fish habitat". The Department is not performing adequately in this regard.

The only prudent management for fisheries is a precautionary approach. A combination of approaches is needed to halt and reverse the decline of whitebait, which should include the options put forward by the Department in the consultation document, but must include a license requirement, a catch limit (on both commercial and recreational fishing), and a method to collect data on the juvenile migratory galaxiid fish caught during the fishing season.

We therefore seek that the Department of Conservation (DOC) correct its oversight by establishing, for whitebait fishing: a license requirement, a catch limit on both commercial and recreational fishing, and a data collection method.

With regards to the options provided in the consultation document, Forest & Bird generally supports the recommended options as supplementary to the imperative management options outlined above. Additionally there are a few provisions where we seek clarification and changes. These items are addressed in the section: Consultation Document Options.

Forest & Bird warns that the failure to incorporate a precautionary approach in the management of this fishery will be detrimental to the fishery and the long term survival of the six native species. This is largely due to the fragile nature of population dynamics associated with freshwater diadromous fish, especially in the face of climate change (i.e. changes in ocean current dynamics, hydro thermodynamics, unanticipated disease and yet to be seen exotic species predation.)

We implore DOC to adopt our recommendations to ensure we do not lose these species forever.

Full submission:

901.72 KB

Sent to the Department of Conservation on 27 February 2020

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