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Understanding proposed changes to New Zealand’s whitebait regulations


To understand DOC’s discussion document “Improving whitebait management” January 2020, it is useful to have an understanding of the Machiavellian nature of NZ government departments and most critically an awareness of DOC’s humiliation when it first attempted to review the West Coast whitebait regulations on instructions from parliament in 1994.

Annoyed at DOC’s attempt to change the season and by DOC’s lack of consultation, Coasters decided to lawyer up and get the government to overturn DOC’s regulations leaving this lucrative regional fishery unchanged. (1)

Bureaucracies exist primarily for the benefit of bureaucracies building a power base on the back of their regulatory role with public funding dependent on the size of the bureaucracy.

The size of a bureaucracy can be increased by taking turf from another government department as occurred when the NZ Forest Service assumed control of deer culling operations from Internal Affairs. (2)

Careers are made or lost on decisions that either advance or are perceived to harm the credibility of the bureaucracy. This can create a culture of “issue avoidance” where the safest course for managers is simply not to make decisions. This was DOC’s initial strategy when they first took control of New Zealand’s whitebait fishery under the Conservation Law Reform Act in 1990. (1)

“Discussion papers” appear to serve two useful roles – first to give the illusion of democratic government by allowing the public to express their view on forth coming legislation within tightly controlled boundaries and without power, second as a final test to see if the legislation might expose the Minister to an unacceptable level of risk.

The Minister

With the nationwide deterioration of water quality, over abstraction, loss of habitat and probable over exploitation of the declining whitebait resource, this subset of native fish (along with the rest of New Zealand’s native fish), are in trouble.

Given this is an election year the Minister of Conservation has tasked her department to demonstrate to the (non whitebaiting) public that she is capable of managing a concern identified by the public.

The Ministry – DOC

In light of the above, the discussion document is a master class of bureaucratic expediency and self-interest:

1. The West Coast commercial whitebait fishery.

DOC has played a blinder by removing this high risk, (to DOC), sector from the scope of the whitebait management discussions claiming the West Coast whitebait stands come under the jurisdiction of regional councils under the RMA 1991.

At least for the West Coast this makes a mockery of any whitebait management as commercial registered stands can measure their catch in tons while recreational fishers measure their catch in kilograms.

The discussion document furthers this deceit by defining whitebaiters “who catch a feed” as visitors and commercial whitebaiters as keen recreationalists (p. 18)

DOC appears to have “pissed in the pockets” of the (commercial) West Coast Whitebaiters Association by proposing the banning of everything that is perceived to threaten the size of their commercial harvest – sock nets, nets with traps, “introduced predators”, and “visitors”.

2. Self- interest

DOC plans to shorten the season and streamline the regulations for the convenience of DOC’s compliance monitoring obligations.

In 1981 when MAF managed the whitebait fishery they shrank the regulations from 63 clauses & 14 pages to only 11 clauses & 6 pages for the West Coast plus one clause on one page for the rest of the country.

McDowell considered this a questionable action given the complexity and regional variably of this fishery. (1)

3. Growing the bureaucracy

Appendix 1 – pps 81-122 “Sites in regions that may be appropriate for selection as refuges for whitebait species” might be seen by some as an opportunity to gain more territory for DOC to control.

4. A conflicted Ministry

Whitebait place DOC in a conflicting situation – while their core role is conservation of native species, in this instance they are charged with managing the exploitation of native fish. (1)


From the writer’s point of view the Discussion Document reflects the complexity of the New Zealand whitebait fishery – it has a valued place in New Zealand’s identity, participants include both amateurs and professionals, it is incompletely understood, (as is the biology of most of New Zealand’s native fish), there are no reliable catch records, or any measurable evidence that the fishery is truly in decline.

Most who participate in the whitebait fishery and other freshwater angling are alarmed by the rapid deterioration of New Zealand’s freshwater fisheries in general, and know falling populations inevitably results in the requirement for reduced exploitation.

Some of the discussion document proposals for improving whitebait management make sense

· Refuges such as the Manhinapua Creek for the Hokitika River or the One One Creek for the Wanganui River have not doubt helped sustain whitebait runs in these rivers

· All life stages of a managed species must be considered – this means managing habitat for all life stages – management involves identifying and addressing “bottlenecks”.

· Adjusting regulations via catch methods, limits, and season length in order to make a fishery sustainable is valid.

· Back markers provide clarity

· Investment in further research is required

· The document’s management goal and desired outcomes are laudable.

Proposed changes to catch methods favour the commercial “keen recreationists” to the disadvantage of the amateur “visitors”. DOC appears unwilling or unable to take on the well organised West Coast Whitebaiters Association which has the support of the local MP.

The proposed changes contained in the discussion document are unlikely to reassure the public that the Minister is a capable manager of the whitebait fishery.

Whatever regulations come out of the discussion document for improving whitebait management they will achieve little unless two key elements are addressed;

1. The unacceptable state of New Zealand’s freshwater resources must be acknowledged and acted upon

2. There is no place for the commercial exploitation of threatened species.

Dr Peter Trolove

President of the New Zealand Federation of Freshwater Anglers


1. Managing the New Zealand whitebait fishery: a critical review of the role and performance of the Department of Conservation. R. M. McDowall, NIWA Science and Technology Series No. 32, (1996).

2. THE DEER WARS, The Story of Deer in New Zealand, Graeme Caughley, Pub. Heinemann. (1983).