Submission to Ministry IPP
by New Zealand Recreational Fishing Council
31 July 2002
The New Zealand Recreational Fishing Council represents the following National Organisations, and is aware that the N.Z. Big Game Fishing Council is submitting their own submission and we support that submission, N.Z. Angling & Casting Association, N.Z. Big Game Fishing Council, N.Z. Trailer Boat Federation, N.Z. Marine Transport Association, N.Z. Underwater Federation, N.Z. Sports Industry Association.
We also represent the following regional associations, Northland, Auckland, Bay of Plenty/Waikato, Taranaki, Wellington, Tasman Bay, and Otago.
Adaptive Management Programme
Our Council understands the various reasons why the AMP framework was put in place but have some concern about the way that the programme is currently being used. From our viewpoint it would now appear to be one of the methods that industry is using to get higher TACC allowances.
An example of this is where under the Adaptive Management Programme TACC’s LIN3 and LIN4 were increased by about 30% for the 1994/95 season. The intention being that it was expected to allow any decline in biomass to be detected by trawl surveys of the Chatham Rise. The TACC’s were set at 2810 and 5720t respectively. These stocks were removed from the AMP on Oct 1 1998 and the TACC’s maintained at the increased levels. However from Oct 1 2000 just 2 years later the TACC’s for LIN3 and 4 were reduced to 2060 and 4200t respectively.
This type of action tells us to be wary of any new species being considered for the AMP process. We believe that there are too many “guesstimates” being used as to whether a stock is suitable for inclusion into the programme.
Our Council is unaware of when the changes took place to the new look AMP. None of our members are aware of any consultation taking place otherwise concerns that we have now would have been raised at the time. TAR1 for example is a major recreational area where non-commercial users take a significant percentage of the catch. To introduce TAR1 into the AMP process is offensive to our sector.
We do not have a problem with the AMP programme being used by industry to research new fishing grounds and to explore areas for potential development but are wary when it becomes involved with existing or established fisheries. It would appear to be too easy to get a species into the process and to take extra tonnage under the guise of AMP.
Once a species has been introduced into the AMP process we can envisage huge pressure placed on the Ministry to maintain the higher levels of a TACC at the end of the evaluation process.
We note that participants in AMP fisheries are “requested” to provide information in submissions about the nature of agreements entered into. It is our belief that this material should be “mandatory” before any species is considered for AMP and should be available to all stakeholders.
Because Industry is consistently overfishing a TACC does not automatically give it the right to suggest that it cannot help the overcatch.
We note that the TAC is currently set at 1398 tonne and has been at this figure since 1989/90. The May 2002 Fishery Assessment Plenary is suggesting that the recreational catch would equate to say 300 tonne taken from the 1996 Diary Survey. This would suggest that industry has been fishing a TACC of approx. 1,100 tonne and for the past fifteen years have been fishing at 40-50% above the TACC.
MFish are suggesting that the recreational catch under the AMP proposal should be considered as 310 tonnes. We are unsure where this figure came from. The diary survey carried out in 1996 is now six years old and MFish consider the recreational catch has only increased by 5 tonne during that period. We believe this figure to be far too low and would suggest a figure closer to 600 tonne as more realistic.
Whilst at recent meetings between MFish and the recreational sector, the Ministry has acknowledged that they had under estimated the recreational sector by half and therefore there would be a larger historical catch than previously considered.
We are also aware that MFish are suggesting the customary catch could be 155 tonne, and they are suggesting a new TAC of 2,482 tonnes. With a recreational catch of 600 tonne plus the customary catch of 155 tonne would leave industry with a TACC of 1,727 tonne or a 57% increase.
We are unclear where the 1,210 tonnes that was the introduction level into the QMS came from. If we disregard the increase in TACC as a result of Quota appeals, maybe we should be basing all figures on the 1,210 tonnes rather than the 1,398 tonne
Context for proposal
We do not believe that there is sufficient data available to support the proposal.
We have not been advised who suggested that “a recent analysis of commercial catch suggested that the abundance of tarakihi has remained stable or has possibly increased”. The 2002 plenary suggested that they “thought” the current catch levels to be sustainable. The plenary also reported “that it is not known if the current TACC’s and recent catch levels will allow stocks to move towards a size that will produce MSY”.
We are surprised that there is no stock assessment available considering that tarakihi has been a target species for so long.
We have concerns as to whether the increase in TACC is sustainable. We note that the biomass in TAR7 has decreased even though the commercial catch has been fairly consistent.
We are disappointed to see that the recreational interest in tarakihi in the Bay of Plenty was only “noted”. From our own surveys we have deduced that tarakihi is a more popular species than snapper by a large number of anglers. Overall it rates as second most popular eating species for all anglers in the Bay.
We have more and more sustenance fishers targeting tarakihi as the snapper are becoming harder to catch and this is producing larger bag limits than we have seen previously.
Analysis of the AMP
TAR1 Decision Rule. We oppose this wording in the decision rule. If the TACC is increased by 43% and CPUE index falls by 30%, then the increase should be closed forthwith until the ADM FAWG approves any increase.
We have some concerns that the fox appears to be looking after the hen house here and we seek to see all data validated by an independent source. This work should be tendered out and funded by the proposers.
We also note that a biomass index will be based on a West Coast survey. In the past we have found these surveys to vary significantly each time that they are carried out and do not have total confidence in the data collected.
We have the same concerns with shed sampling programmes, unless the Ministry of Fisheries or an independent contractor carries them out.
“The proposer offers to make every effort to ensure any increases in catches is apportioned throughout TAR1”. This statement also rings warning bells with our Council. We have had this type of written statement in the past and the operators themselves know nothing of any agreements. Therefore they are ineffective.
We also note that there is very little data available of remedies as to how the increase in TACC will affect other stakeholders. We do not support the theory that the recreational catch has been stable over the past decade. Our indicators are showing the opposite. More boats, more anglers, and more fishers actually targeting the tarakihi.
TAC Option and Allowances
Our Council believes that if the proposal for TAR1 proceeds;
- Set the TAC at 2,482 tonnes
- Make allowances of 155 tonne for customary Maori and 610 tonne for recreational catch
- Make an allowance of 20 tonne for unreported catch
- Increase the TAC from 1,398 tonne to 1,697 tonnes
- Proponents to assume responsibility for updating standardised CPUE analysis.
- We are unsure why MFish is restricting the fishing to existing areas, when there is a possibility of creating a new fishery
- Monitor the performance of the fishery under the AMP in accordance with the steps agreed to at the 2002 fishery assessment plenary
We are unclear when the Ministry adopted the policy for setting the recreational catch allowances to use data received from diary surveys etc. This is the first time that we have heard of diary survey data being used.
- The NZRFC does not support TAR1 being included in an AMP
- The NZRFC would support a small increase in TACC for TAR1
- The NZRFC supports exclusion zones and catch spreading where spatial conflict is likely to occur with other stakeholders if an AMP programme proceeds
We note that the Northern Inshore Fisheries Company Ltd has submitted a proposal to increase the TACC for RBY1 by 175% to 300 tonnes under a five year AMP programme.
Our Council would support option 2.
We note that there are projects in place on the species and support them all.
Social, Cultural, Economic Factors
We note that Mfish is not aware of any cultural or recreational implications relating to RBY1 proposal.
At times, a number of these species are caught as bycatch whilst recreational anglers are fishing mid to deep water for Hapuka, Bass, Bluenose. They would come into the same category as Gemfish. We are unaware of just how many are caught in a year but at times there can be quite a few caught when anglers are fishing the 600 metre knolls.
Some recreational allocation should be allowed for in a TAC. We are aware that Rubyfish are caught in the Bay of Plenty and around the East Cape towards Gisborne. We are unaware of any recreational catches through other parts of the country but no doubt there is some catch.
The NZRFC has difficulty in accepting an increase in TAC and TACC when the SEFML proposal acknowledges that an overcatch may not continue until the end of the current AMP due to variable recruitment. Is this not considered to be Pulse Fishing?
It would appear that MFish have taken the existing TAC and split the difference between the current TAC and the TAC that SEFML have asked for. We do not find this to be a very scientific method of managing a fish stock.
We also believe that a five tonne allocation to be too low for the recreational sector. Our advisors on the East Coast of the South Island believe that the figures taken from the 1991 surveys and the 1996 diary survey to be inaccurate.
Our Council also has concerns about industry continually overfishing TACC’s and expecting a further increase every couple of years. We must ask what steps industry has taken to avoid overcatch, before we can agree to an increase.
We also find it strange for industry to suggest that after already having sought an increase in 2001, they are now suggesting that they may not really need the extra tonnage over the next two years but that they want the increase any way.
As stated earlier we cannot agree with the figures used for the estimate of recreational harvest and believe that the figure should be doubled to ten tonne at the very least, until we have a chance to carry out further research ourselves into the fishery. Data used from the 1996 survey is now six years old, and does not reflect the true state of recreational harvest.
Our Maori Affiliate Ngai Tahu also believe their allocation to be too low but are awaiting more recent data to become available before re-estimating the customary take.
We acknowledge the concerns of fishing mortality rates involving Hectors Dolphins.
Assessment of Management Options
We acknowledge that the Minister when setting or varying a TAC has to have regard to the TACC for that stock and allow for customary and recreational fishing interests.
The 96 Act requires the Minister to take a precautionary approach when the data is insufficient and we ask that the recreational allowance be increased prior to the TACC being set.
We note that further research is planned by industry, but no dates have been given for this work to be carried out.
- As a precautionary approach increase recreational allowance to 10 tonne
The NZRFC acknowledges that the recreational sector has very little interest in Stargazer and that an allowance of two tonne has been allocated for recreational catch. We would agree with this allowance.
The NZRFC acknowledges that the recreational sector has very little interest in Silver Warehou. We are aware of some catch in SWA1 but unaware of any catch in other parts of the country.
Most fish caught in SWA1 are caught as bycatch when targeting kingfish on reefs at a depth of around 120-150 metres.
Although the total catch may be insignificant when compared to the commercial catch, we believe that some allowance should be made in the TAC.
Page Two » » »