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CONSERVATION (INDIGENOUS FRESHWATER FISH) AMENDMENT BILL

October 16th, 2018


To: The Environment Committee New Zealand Parliament

Submission on the

CONSERVATION (INDIGENOUS FRESHWATER FISH) AMENDMENT BILL

The New Zealand Federation of Freshwater Anglers (Inc.) would like to make the following submission on this Bill. The Federation represents anglers and angling clubs from throughout New Zealand and overseas. The Federation (NZFFA) works to protect, enhance and foster the sport and interests of the freshwater anglers of New Zealand. Further 'that as anglers we wade the water and see the effects of surrounding land-use on water quality and aquatic habitat'.

The Federation submits that this Bill is bad law, badly written. We note that this sentiment is shared by such diverse people as a Queens Council, The NZ Treasury, Statutory Resource Managers, and Politicians from a variety of Parties in the House. It was not produced following established Ministerial protocols, and either by accident or design, actually enables the very things that it proports not to do.

Some of those things, which the NZFFA strongly objects to, include:


  • Removing the ability of the Statutory Managers to manage the freshwater sports fisheries as currently defined under the Conservation Act

  • Excluding fish farming from the freshwater sports fisheries provisions of the Conservation Act, and

  • Excluding Treaty Settlement parties from the freshwater sports fisheries provisions of the Conservation Act.

  • That the position being taken by the Minister is not supported by the legal opinion from Sir Geoffrey Palmer dated August 30, 2018.

  • That there was no consultation with the Statutory Managers Fish and Game NZ who manage the freshwater sports fisheries as currently defined under the Conservation Act.


It is our submission that it should not be the function of Parliamentary Committees to rewrite poor legislation that cannot achieve its stated intentions.

We submit that this Bill should be withdrawn from the House, given to someone competent who can actually draft proper legislation, and resubmitted to the House when it is fit for purpose.

Graham Carter President New Zealand Federation of Freshwater Anglers (Inc.)


Speech to Select Committee

The manner in which the proposed bill was drafted creates major

concerns for every freshwater angler in New Zealand, everyone including the Fish and Game organization.


There are loop holes, and some clauses that need clarification. The proposed bill was clearly drafted in haste. The exposure of this corrupted Bill is, we believe, what is needed to put a stop to the current mis- information stating that trout are killing off native fish, when in fact there is more than enough evidence that it is a “cocktail of chemicals” from industrial farming and local body effluent managed and industrial discharge. Fertilizers, including nitrates and phosphates, and agricultural

herbicides and insecticides are significantly damaging our aquatic ecosystems by leaching e.g. Diazinon - ironically DDT’s replacement - is still widely used for combating grass grub and is described as “lethal to aquatic life".


The significant loss of the basic habitat medium (i.e. water) is a major factor, especially in the light of previous governments' push for more and more dairying in (known) low rainfall areas. Monocultures of pines, especially at planting and milling, are a major cause of siltation and also have a detrimental effect on water composition (i.e. pines induce a more acidic character which means lower invertebrate and micro-flora populations and diversity; these invertebrates are the staple diet for most freshwater fish).

A deep concern for our members is that DoC is silent on these issues. It is charged with conservation in NZ which the Federation of Freshwater

Anglers defines as “the wise use of resources.” Yet DoC is never seen advocating on the water quantity or quality or on chemical pollutant issues. Habitat quality is the key to conserving whitebait and eels and the myriad of organisms that share their habitat.

Another concern is DoC’s apparent lack of understanding of predator/prey relationships and basic food chain functioning. Nature settles into a balance of predator and prey. Trout were introduced over 150 years ago (1867). Food chain equilibrium would have been achieved within 30 or 50 years. It is time to reassess the ludicrous manipulation of the term “indigenous” and face reality.

Indigenous means "born in a region" (Concise Oxford). All humans in NZ have genes that relate to introduction by migration. Why are trout regarded by some ideologues as so different? Does DOC seek to control rye grass, cattle, sheep, lucerne, and the other organisms that contribute to the economy? While many species have evolved here, many vertebrates were self-introduced.


Our members have over years analysed trout stomach contents of trout caught and killed as have numerous theses and university and government research projects. The over whelming majority (90%+) of trout food items are insect nymphs/larvae, not small fish such as whitebait. This was borne out by Radway Allen’s internationally acclaimed production-biology study entitled “A NZ Trout Stream” (NZ Marine Dept. bulletin 10A 1952).

Individuals and groups, including Sir Geoffrey Palmer and Fish and

Game have done their job, on our behalf, of all anglers in all areas around New Zealand. We are appalled that DoC, in this bill, is attempting to encourage the farming and sale of trout. A market co- existence between trout farming and wild trout recreational fishing has not been successful anywhere in the world. It would be a negative conservation act.

DoC have recently put out a letter with a standard response that Trout are "not threatened". This is quite inaccurate in many areas. The most well known being the Lak Ellesmere/Waihora catchment.

The errors in this bill mean that it must be redrafted. Many of our members question the justification for its dangerously mis-directed contents. We request that it should be withdrawn and DoC ordered to deal with the real problems of habitat loss and water quality confronting our native fish, such as whitebait, galaxids and eels. That could include addressing the open commercial exploitation of whitebait by implementing bag limits (in weight) and restricting commercial selling of whitebait.

For DoC to be given 100% management of the Taupo Fishery, without any consultation with The Taupo Advisory Council or Fish and Game, would be a political and economic disaster. As the current bill is written, there is potential for that to happen.

Legislation needs to be enacted to sustainably manage both water

extraction and the levels of nitrates and other chemicals in our waterways so that the economic value of water is not placed above the value of recreational freshwater activities and the future of indigenous fish.

It is estimated that our rivers and streams generate over one billion dollars to our economy, including tourist angling, in direct monetary gain – yet the psychological recreational value of including relaxation and

welfare benefits are very difficult to measure. One freshwater fishery alone has recently been recorded as contributing $170 million to the economy annually.

It is a truism that healthy leisure pursuits do relate to the cost of running general and mental health services. There is a saying, “Give a kid a sport and keep him out of court.” A recent Horizon survey showed freshwater fishing, e.g. trout, has 5 times more participants than rugby.

This bill, in its present form, seems aimed to wrongly blame trout for indigenous fish demise and will impact on trout fishing availability for the 103,000 New Zealanders who buy a freshwater fishing licence annually. Then our Submission to be read out

Graham Carter President NZ Federation of Freshwater Anglers Inc 021 02600437 Advocacy for Freshwater Anglers NZFFA Facebook https://www.facebook.com/NZFFA/ Website http://www.nzffa.co.nz/ JOIN US FOR FREE MEMBERSHIP