Submission date: 18 October 2010
Submitted to: Department of Conservation
The New Zealand Conservation Authority (NZCA) thanks you for the time extension for its submission which enabled it to discuss the important proposal to amend the process for developing population management plans under the Marine Mammals Act at its meeting last week.
The NZCA had an extensive discussion on the topic, attended by Doris Johnston General Manager Policy for the Department of Conservation. The recommendations and requests below reflect that discussion.
The NZCA considers that as a matter of principle there should be only one decision-maker. However, the NZCA understands that the motivation behind the proposals is to develop a process that is supported by fishing interests and joint decision making is seen as necessary to that. It also understands that the Department believes that this will result in worthwhile plans which will contribute to the recovery of marine mammal populations, even though that progress may be slower than that desired by those who weigh the conservation of marine mammals highly.
The NZCA recommends some enhancements to the proposal, some of which are intended to give clarity which the NZCA considers should assist achieve beneficial outcomes.
The NZCA recommends that:
- a non time-dated long term goal for population management planning of self-sustaining populations of marine mammals be included.
- provision be included for staged reviews of population management plans to assess progress to achieve plan goals and make any necessary adjustments to attain those goals
- ‘threatened’ and ‘at risk’ be defined
- ‘recovery’ be defined
- the significance of the time spent in New Zealand waters in the life cycle of the species, such as vulnerable life stages e.g. breeding times, be factored into the formula for apportioning the NZ maximum allowable level of fishing-related mortality(MALFiRM) from the total MALFiRM.
Both the discussion paper and the covering letter to the NZCA are silent on the roles of the conservation boards and the NZCA in the development of population management plans. Both have roles in the current statutory process. The NZCA notes that conservation boards have territorial responsibilities which do not necessarily fit well with population management plans for marine mammals. It is confident that in those instances where a population management plan is confined in territorial coverage, the Director-General of Conservation, when drafting the plan, would consult the conservation board along with others with known interests in the protection and conservation of marine mammals.
The NZCA seeks to retain its own current statutory responsibility to the Director-General and Minister of Conservation to give advice on the final draft of any population management plan.
The NZCA is likely to participate further in this process when the Bill is considered by the Select Committee.