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I also want to present an oral submission.

SUBMISSION ON PROPOSAL TO BAN BOTTOM TRAWLING FROM ONE THIRD OF NEW ZEALAND WATERS

Ministry of Fisheries, PO Box 1020, Wellington, Dear Jim Anderton, Thank you for seeking public input on the proposal by the fishing industry and Government to prohibit bottom trawling in one third of New Zealand waters. This is an important step to address the impacts of one of the most destructive methods of fishing. Thousands of square kilometres of ocean floor in New Zealand waters have been cleared of much of its deep-sea life including large cold-water corals, sponges and a range of other unique life. Given these impacts and our poor knowledge of marine biodiversity, extinctions are likely without these species ever having even been named. Unfortunately, the detail in the fishing industry's proposal does not address bottom trawling's impact on deep-sea biodiversity to the extent necessary to adequately protect it. Furthermore, most areas the proposal covers are either too deep to economically fish, have no fish, or are too difficult to trawl. This means the proposal offers little protection for the vulnerable deep-sea life that is currently being impacted. I am also concerned that areas that deserve strong protection for deep-sea life could either be downgraded from their current level of protection or are simply not covered by the proposal at all. PLEASE PUT PROTECTION ON A SCIENTIFIC BASIS Currently, the proposal covers areas that the fishing industry is willing to 'give up' that will have the least impact on its destructive business of bottom trawling. Very little of the area industry has proposed be closed to bottom trawling has or will ever be trawled. Most of it is just too deep (84.5 percent of the closures are deeper than 1500m) or the fish are not there in economic quantities to trawl. Given the aim of the proposal is to protect benthic life I would like the Ministry of Fisheries to contract NIWA (National Institute of Water and Atmospheric Research) to produce an independent and unbiased proposal, covering an area of at least equal size, outlining which areas should be protected from destructive human activities including bottom trawling and seabed mining. This should be based on known biological data, but also incorporating the precautionary principle where data is insufficient, to protect important areas of biodiversity most at risk within New Zealand waters. I believe that this should form the basis used for choosing which areas to close that cover an area at least as large as one third of the EEZ. BUFFER ZONES The proposal suggests that all trawling can occur, so long as it respects a 'buffer zone' above the sea floor. However, there is no definition of what that 'buffer zone' is. With the surge of large swells, nets heavy with (presumably) fish, and the stretch of cables that go down hundreds of metres, coupled with the common practice of dragging trawl nets across the sea floor, it is important to take the precautionary approach and ensure that the method of protection used prevents any contact between fishing gear, the sea floor and benthic life. Please raise the level of protection up to the precedent-setting quality of the 19 seamounts that were protected in 2000/01. 19 PROTECTED SEAMOUNTS - NEED TO RETAIN THEIR PROTECTION The proposal severely downgrades the level of protection for those 19 seamounts already protected in 2000/01. If the Government wants the EEZ bottom trawl closure to have any integrity, the level of protection for those 19 seamounts already protected must be retained - and be extended to other areas to be closed. The proposal outlines the industry's desire to remove total protection from the Pinnie, a hill feature on the South-southwestern Chatham Rise. It is the only hill protected in this part of the Chatham Rise and is surrounded by an area that has been heavily trawled for deepwater dory. Please retain strong protection here. PLEASE DON'T TIE THE GOVERNMENT'S HANDS The industry wants to use this proposal to change the Fisheries Act so that the current proposals are considered as the end of any discussion about biodiversity protection in the EEZ which may stand in the way of industry's aspirations. There are clauses, for example, that demand that: - protection goes no further, i.e. these proposals are not turned in to marine reserves and no additional areas are protected; Why would further protection not be discussed? - there are no marine reserves beyond 12 miles and no extension of Marine Reserves Act beyond territorial waters ; What about protection outside of these areas and in international waters? - there will be no additional controls on bottom trawling to protect biodiversity in future. Surely this is unacceptable? Is the Government really closing down debate on biodiversity protection? This gives little incentive to improve fishing methods or "avoid, remedy or mitigate the effects of fishing" as required by the 1996 Fisheries Act. Please ensure the final accepted proposal is strictly in line with these clauses of the 1996 Fisheries Act and reject all clauses intended to prevent marine conservation. Furthermore, it is important that this proposal does not pre-empt the Oceans Policy process. PLEASE SET A GOOD INTERNATIONAL PRECEDENT Internationally New Zealand is looked to as a nation with progressive legislation that protects the environment. New Zealand's bottom trawl closures must be strict, enforceable, have scientific integrity and, most importantly, emphasise protection for vulnerable deep-sea life that is at risk. I look forward to the Government advancing appropriate proposals that protect life in the deep sea, now and well into the future.