Please find attached evidence in support of petition 2014/114 requesting:

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1 David Meek Clerk of the Primary Production Committee Parliament Buildings WELLINGTON 18 June 2017 Dear David Meek Re: Petition 2014/114 of Kyleisha Jade Foote and 3,156 others I am writing in regards to Ian McKelvie s request to provide a written submission to the Primary Production Committee on the matter my petition deals with. Please find attached evidence in support of petition 2014/114 requesting: That the House note that 3,156 people have signed an online petition requesting that the House of Representatives enact a ban on the sale of New Zealand whitebait (Galaxias species) as they are threatened endemic species. I appreciate the Committee in taking the time to read this evidence. I would like to request to speak to our evidence in front of the committee. Yours Sincerely Kyleisha Foote MEnvMgmt Research Assistant in the Institute of Agriculture and Environment Massey University

2 Supporting Information Requested by the Primary Production Committee on petition 2014/ We present this as evidence in support of petition 2014/114 of Kyleisha Jade Foote and 3,156 others requesting: That the House note that 3,156 people have signed an online petition requesting that the House of Representatives enact a ban on the sale of New Zealand whitebait (Galaxias species) as they are threatened endemic species. Introduction 2. New Zealand s whitebait species are in decline. If something urgent is not done to conserve these species, they will be lost. 3. Whitebait are made up of threatened species with the same threat rank as kiwi and other fully protected New Zealand bird species. 4. Data shows that the adult whitebait species are declining and if the decline continues at the current rate, all whitebait will be extinct by Any pressures on whitebait will be contributing to their decline. 5. Allowing whitebait to be commercially harvested and sold when they are a threatened species in decline is not conducive to their conservation. There is wide support for a review of the whitebait regulations. 6. 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" 1. The current whitebait management scheme in allowing commercial fishing does not achieve this. 7. The only prudent management for fisheries is a precautionary approach 2. This is the basis of fisheries management and thus uncertainty must not be used as an excuse to keep the status quo, rather it should require limiting fishing until certainty is available. 8. A combination of approaches is needed to halt and reverse the decline of whitebait, but stopping the commercial harvest can relieve some pressure and is effective from the moment it is enacted. 1 Conservation Act 1987: Part II, 6(ab) 2 Kriebel et al. (2001). The precautionary principle in environmental science. Environmental Health Perspectives, 109, 9,

3 Threatened species 9. In 2013, the Department of Conservation listed 74% of New Zealand s native freshwater fish as threatened or at risk of extinction 3. Within the five whitebait species, one was listed as threatened - nationally vulnerable (Galaxias postvectis shortjaw kokopu); three as at risk declining (Galaxias argenteus giant kōkopu; Galaxias brevipinnis kōaro; Galaxias maculatus īnanga); and one as not threatened (Galaxias fasciatus - banded kōkopu). 10. Compared with New Zealand s native birds, these are the same threat rankings as the great spotted kiwi, North Island brown kiwi, and yellow-eyed penguin (nationally vulnerable), and North Island rifleman, Northern blue penguin and the fernbird (at risk declining) 4. However, these birds are all fully protected under New Zealand law with most of these having conservation plans. 11. Other countries have made moves to protect their whitebait species. For example, in Australia, whitebaiters require a licence and are not allowed to sell their catch. Only recreational fishing is permitted. There is also a maximum daily catch of 2kg and a maximum catch per licence for the season of 10 kg New Zealand is a signatory to CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora), an international agreement between governments. Its aim is to ensure that international trade in specimens of wild animals and plants does not threaten their survival 6. This is contradictory in selling and exporting endangered species, such as whitebait. Decline of adults 13. The decline in whitebait numbers has reached a time critical stage where mitigation actions must be fast acting and urgently implemented. 14. The adults of all five major whitebait species are in decline and will likely be extinct by 2034 (Figs. 1 & 2). These declines have been modelled using data from the New Zealand Freshwater Fish Database 7. This database contains records of over 34,000 observations of fish from around the country. When accounting for variable numbers of observation (i.e. sampling effort) the declines are apparent and statistically significant. 15. Different species have different rates of extinction. Giant kōkopu is likely to be extinct before 2020, banded kōkopu by 2023, and shortjaw kōkopu has already passed its modelled extinction date, indeed none have been recorded in the NZFFDB since 2015 (Fig. 2). 3 Goodman et al. (2014). Conservation status of New Zealand freshwater fish, Department of Conservation. 4 Robertson et al. (2013). Conservation status of New Zealand birds, Department of Conservation. 5 Inland Fishery Service. Whitebait Regulations. Tasmania Government and 7

4 These models should be considered best case scenarios, however, as they do not account for potential Allee effects 8 or for increased land use intensification and the current worsening water quality. All 'whitebait' species Figure 1: Rate of decline for all whitebait species. Upper and lower lines are 95% prediction intervals. Central line is modelled prevalence. The x intercept is indicating that these species will likely not persist beyond the year Inanga Koaro Giant Kokopu Shortjaw Kokopu Banded Kokopu Figure 2: Breakdown of rates of decline for the five common whitebait species in New Zealand. Upper and lower lines represent 95% prediction intervals. When considered alone the situation for shortjaw kōkopu, giant kōkopu, and banded kōkopu become much more urgent with none of these three surviving beyond When Allee effects are present, population size and per capita growth rate are correlated. This results in a critical minimum population size threshold, below which the population will crash to extinction.

5 17. There are many factors implicated in the decline of whitebait species: Declining habitat quality is a leading cause of their decline 9 Loss of breeding habitat due to flood control and channelization 10 Poor fishery management 11 Whitebait fishing Habitat restoration is essential for the survival of these species. However, the timeframe in which habitat restoration projects take to be effective is likely beyond the expected persistence of these species. 19. Water quality is still declining nationwide. Therefore, if the species are to survive, actions must be taken that are effective in the short term. Stopping the sale of whitebait species immediately removes one pressure from these endangered species. 20. Very little data is collected regarding the whitebait harvest. What little data do exist suggest that the total whitebait harvest is a substantial portion of the total whitebait run. Estimates of minimum catch vary between 1.9% and 44% of total galaxiid juveniles and average 19% 13. Taking one fifth of the potential run is not conducive for whitebait conservation. Regulations/data 21. The whitebait regulations have not changed since 1995 after the Department of Conservation assumed responsibility for the fishery in In 2013, DOC then classified four of these species as in decline or threatened with extinction. The regulations are outdated and need to change based on the current status of whitebait. 22. In 1996, it was noted that the Department of Conservation required more data collection in order to manage it sustainably That, twenty years later, the Department of Conservation still has no data on the size of the national population makes it very difficult to believe that they are able to preserve these fish and protect the fishery. 24. When faced with uncertainty, a precautionary approach should be taken, not waiting for more data. The precautionary principle has been characterised this way: when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established 9 Richardson, J.; Taylor, M.J. (2002). Reprinted with minor revisions 2004 A guide to restoring inanga habitat. NIWA Science and Technology Series No p. 10 Richardson, J.; Taylor, M.J. (2002) 11 Waikato River Independent Scoping Study (2010). NIWA 12 Allibone R.; Boubee J.; and West, D. (1999). The ones that got away: determining whitebait movements and rates of escape. Water and Atmosphere 7 (1), NIWA 13 Allibone et al., (1999) 14 McDowell, R. (1996). Managing the New Zealand whitebait fishery: a critical review of the role and performance of the Department of Conservation. NIWA

6 scientifically 15. The current whitebait regulations and particularly allowing the species to be commercially sold does the opposite of this approach. Comments from supporters of this petition 25. Some of the reasons for signing this petition from supporters are as follows: Because our native fish are an important part of our ecosystem and the reduction in their numbers by commercial fisheries is damaging to our entire country's ecosystem. The whitebait catches say it all! 50 years ago people caught kerosene tins full of them and used them for garden fertiliser. Now in most river mouths people catch just a cup full if they are lucky. A cup full is hundreds of young fish being taken before they have a chance to replenish the populations. It's just a classic case of abuse of natural resources. Galaxiids have enough problems without commercial harvesting. By my observations they are functionally extinct in most NZ rivers. Because I think that our native species need time to replenish for the future generations of New Zealand to learn about. We are already over fishing in New Zealand and this needs to be stopped. A group of us are working on improving the quality of a freshwater stream that still has whitebait exchange. Until the numbers can be increased however, I consider it is inappropriate to harvest them. The commercial fishing of endangered species should be illegal. It is unnecessary abuse and doesn't contribute to our eco system! Conclusions and remedies sought 26. Adult whitebait numbers are declining as shown by records in the freshwater fish database. If the decline continues all whitebait species will be extinct by There are no reliable data on actual population sizes. The existing distribution data show that the species are declining rapidly in range and will likely become extinct in the near future. It is very difficult to manage an actively harvested population of threatened species without knowing anything about the fishery. A precautionary approach should thus be taken. 28. Four of the five species of whitebait are threatened or at risk of extinction. 29. A ban on commercial whitebait fishing has wide public and organisational support, including scientists, recreational whitebaiters, environmental organisations, and statutory bodies. 15 Kriebel et al. (2001). The precautionary principle in environmental science. Environmental Health Perspectives, 109, 9,

7 30. Given the points above we recommend the following actions be taken: End all commercial whitebaiting. Maximum catch allowances implemented for recreational whitebaiting. Monitoring of whitebait catches and survey of population numbers. Continuing research into the lifecycle and breeding habits of galaxiid species. Independent review in next five years to assess the state of the whitebait fishery and assess whether the recreational fishery is sustainable at all or also needs to be stopped. 31. New Zealand whitebait includes endemic threatened species, found nowhere else. We are at risk of losing these if we don t act quickly. Whitebaiting has a long history in New Zealand, and we want our children, grandchildren, and further future generations to enjoy this pasttime. This is not realistic with current management. New Zealand needs sensible leadership when it comes to conserving our unique biodiversity, which makes up the foundation of our brand and is important for all industry sectors. New Zealand s unique freshwater fish must be protected now. Regards Kyleisha Foote MEnvMgmt Research Assistant in the Institute of Agriculture and Environment Massey University