Urgency missing from on-board camera rollout for commercial fishing
Public consultation is being sought on a proposal to support a wider rollout of on-board cameras across the inshore commercial fishing fleet in NZ. The proposal is aimed to support a more sustainable seafood sector, by giving independent information about what goes on at sea. According to FNZ, on-board cameras “help verify catch reporting, and monitor fishing activity by commercial fishers to encourage compliance with rules”.
ELI has lodged a submission on this consultation and how the proposal could be improved. Marine biodiversity is in steep decline in New Zealand, and on-board cameras are known to improve the accuracy of reporting of both fish species and protected bycatch species, such as seabirds and mammals. According to FNZ, when electronic monitoring was introduced to Australia’s longline fisheries in 2015, “reports of interactions with seabirds and mammals increased 7 times”.
For these reasons, ELI welcomes the rollout as a means of improving transparency in commercial fishing practices. However, in our view, there are several elements of both the proposed rollout and its framing of the issues which need improving.
There is important context missing from the consultation document
When it comes to placing regulations around how we interact with our environment, it’s important to remember what’s at stake. Without a strong sense of “why,” the solutions we arrive at might be misplaced, diluted by commercial pressures, or fail to properly address the problem at hand.
Aotearoa, like most places in the world, is suffering a serious biodiversity crisis. Biodiversity loss is not just something that happens “out there” at sea, but something that harms us all - with many communities, economies and industries relying on long-term ecosystem integrity to function. But biodiversity loss is not inevitable - in fact, lots of it is driven by things we can fix - like weak regulations, absence of enforcement, and poor compliance.
For example, widespread illegal activity aboard commercial fishing vessels is an invisible but significant driver of marine biodiversity loss. A common practice is the dumping or high-grading of low-quality fish, which is known to happen in New Zealand. Another driver is fishers failing to report the accidental capture of protected species (bycatch). The latter issue presents serious threats to many protected species - including seabirds, marine mammals, turtles, as well as protected sharks and rays.
It’s important to state the facts before diving into solutions. Currently, observers are only present on very few inshore fishing vessels, meaning we have a deficiency of data on the frequency of this sort of offending (read: we don’t even know how bad things are). For example, the protected species bycatch database shows that for set nets, only 5-6% of net metres have been observed per year in the past five years. Before then, it was less than half that.
Because this type of offending happens out of sight, at sea, and is coupled by a lack of enforcement or observance, there is very little to deter these offences. Non-reporting normalises a culture of non-compliance, and harms the integrity of the data upon which we make decisions about our oceans. Place this in the context of our biodiversity crisis and the sheer urgency of this rollout becomes clear.
“Non-reporting normalises a culture of non-compliance, and harms the integrity of data upon which we make decisions about our oceans.”
These factors – widespread illegal activity and a worsening biodiversity crisis - are critical for contextualising the importance of on-board cameras for commercial fishing vessels, and help to justify the cost, speed, and need for strong ‘back end’ systems supporting the rollout. Considering this, it is surprising that the word “biodiversity” does not appear once in the consultation document. There is also no reference to Te Mana o Te Taiao - Aotearoa’s Biodiversity Strategy, nor the views of the Department of Conservation, who play an important role in NZ’s biodiversity conservation.
Another surprise relates to mentions of timeframes. Internationally, we’re already lagging behind others in this development: Canada has already been using camera technologies on their vessels for 20 years. Original decisions to implement cameras on boats and other electronic monitoring were made five years ago, and several elements of this have already been delayed. Documents released by DOC immediately after the latest consultation closed appear to show that officials are still at odds about how to process camera footage. Given all this, the vague timeframes proposed in the consultation (spanning an additional three years) reflect an inappropriately relaxed approach to the rollout. The surprises continue with the treatment of costs and data processing elements of the rollout. The documents suggest, without robust justification, that many processing costs should be with the Crown. The relevant law clearly provides these costs should be with industry. Elsewhere the documents suggest that neither costs nor data processing are really part of the consultation at all.
The clear implication, in ELI’s view, is that Fisheries New Zealand has preferred positioning to accurate context in order to gain a smoother rollout. In ELI’s view, omitting or distorting key context means failing to capture the gravity and urgency of the very problem that the rollout is designed to address.
Implementing cameras on board will be costly. That is exactly why its costs need to be properly justified against the facts of our current situation, rather than against political positions. This might also inspire a faster rollout, as an additional three years will mean more bycatch and less reliable data, ultimately impacting the health of our oceans.
“In ELI’s view, omitting or distorting key context means failing to capture the gravity and urgency of the very problem that the rollout is designed to address. ”
NZ has one of the largest Exclusive Economic Zones (EEZ) in the world, spanning 4.2 million square kilometers (15x greater than the entire land mass of New Zealand). In ELI’s view, this means we have a greater responsibility in regards to protecting the health of the world’s oceans, and ensuring our fisheries are abiding by ethical, sustainable and lawful practices.
The cost might be high, but the cost of further inertia and stalling will be much much more grave. Read our full submission to FNZ below.
