Submission to Ministry IPP
by New Zealand Recreational Fishing Council
31 July 2002
We note that MFish proposes an increase in TAC from 265 tonne to 463 tonne, an allowance of 20 tonnes for customary fishing, and an allowance of 40 tonnes for recreational fishing.
We are concerned with the fact that MFish has used the 1993-94 recreational fishing survey as the basis for the 40 tonne recreational allowance. MFish has acknowledged during Recreational Fishery Meetings that the number of anglers determined from that survey was flawed and therefore does not really acknowledge the true recreational catch.
We are also aware of a number of anglers who use dropper lines with say 5 hooks whilst they are out Hapuka fishing. After they have finished line fishing they then recover their dropper lines. These fishers have significant catches on this type of rig and a large number of the fish caught are ling.
We are also aware that most of these fish are well in excess of the 4Kg maximum that MFish have used in their formula to determine the recreational tonnage caught.
With the number of fishers flawed in the 93-94 survey and the top end of the scale weights that have been used to determine the allowance being too low, we believe the recreational catch to be far in excess of the tonnage allowed. We are unaware of the total tonnage but would estimate that 80 tonne would be a lot closer to the actual figure than the 40 tonne allowed for.
Maori Customary Allowance
Using the same formula as used by MFish whereas the customary allowance should be 50% of the recreational allowance would mean that a figure of 40 tonne should be allowed for a customary allowance.
The 1996 Act requires the Minister to take a precautionary approach when setting TAC’s and we believe that our figures are far closer to target than the MFish formula would suggest.
Red Gurnard (GUR3)
The NZRFC acknowledges that MFish propose to decrease the TACC from 906 down to 706 tonne, and make an allowance of 3 tonne each for customary Maori and recreational fishers.
We support the dropping of the TACC due to industry not fully utilising the stock over the past few years.
We believe that MFish have got it all wrong when they suggest that recreational anglers do not target Red Gurnard. There are many anglers, who target gurnard, and not just occasionally, but very frequently. There are many recreational fishers who believe that the flesh of gurnard is highly under rated, and prefer the flesh to snapper.
Our advisors on the East Coast of the South Island also indicate that an allowance of 3 tonne is a joke. Although the fish usually weigh less that 1.0kg, there are many caught throughout the coastline. The 1,000 fish indicated during the 1996 survey indicates how flawed some of the modelling is, and produces unrealistic figures that cannot be believed.
We note that the 1,000 fish recorded from the 1996 survey have been estimated at an average weight of 2-3kg. We are wondering where we have to go to catch 3kg gurnard
- TAC set at 715 tonnes
- The recreational allowance should be set at 10 tonne, and customary Maori allowance at 5 tonne
- The TACC be reduced from 900 to 700 tonne
- The GUR3 AMP be reviewed in 2005
MFish recommends that the TAC be set at 460 tonnes
Allowances are set at 20 tonne for Customary Maori, and 40 tonnes for recreational fishers.
The TACC be increased from 252 tonne to 360 tonne. (An increase of 43%)
This proposal is of major concern to our Council.
The estimated 40 tonne allowance has been taken from data received from the 92/93 and 1996 telephone and diary surveys.
We are aware that industry has already has had an increase in the past for overcatch and there does not appear to be any information available to show what industry has done to avoid this continually happening. We would expect there to be some action taken by industry to avoid the overcatch happening but this does not seem to be the case. The Ministry is very quick to action overcatch of birds and mammals but not as enthusiastic when it comes to fish overcatch.
We would like to remind the Ministry that the recreational fishermen used to have a bag limit of 30 snapper.This was reduced down to 20 fish around 91/92 and reduced again more recently to 15 fish per day 95/96 and more recently 10 fish per day. This was supposedly to increase the stock levels.
It was the recreational sector that took the cuts, not industry, and we now see the Ministry proposing to give industry a 43% increase in TACC and no increase to the recreational allowance. Does this equate to the recreational sector being penalised in favour of the fishing industry?
If industry receives a 43% increase we will accept nothing less than a 43% increase in the recreational allowance of the TAC and an increased bag limit for SNA2 recreational fishers. We have offered an alternative in our recommendations.
To increase the recreational allowance of a TAC without increasing the bag limits does nothing more than to provide a buffer zone for the commercial operators. They are on a win win situation. When they fish the fishery down, we lose our allowance and we haven’t even had a chance to catch it.
We note that the assessment indicates the abundance has substantially increased since 1986 and the fishery has rebuilt to at or around the Bmsy level.
- A TAC for SNA 2 be set at 460 tonnes
- An allowance of 26 tonnes be set for Customary Maori ( an increase of 30%)
- An allowance of 52 tonne be set for recreational fishers ( an increase of 30%)
- An allowance of 40 tonne be set for other sources of mortality
- A TACC of 342 tonnes be set (an increase of 35%)
- Recreational Bag Limits for snapper in SNA2 be increased from 10 to12 fish per angler per day
We note that Mfish proposes to discontinue shelving quota, but the catch levels remain the same.
Mfish propose reducing the TAC from 124.19 tonne to 105 tonne and the TACC from 112.19 to 90 tonne.
We note that Paua 5 was subdivided into three areas Oct 1 1995 and 5B was allocated one third of the TACC for Paua 5 being 147.66.
Over the past six years we note that industry has taken 787 tonne out of area 5B.
Based on the modelling that was carried out to determine the recreational catch for area 5B (which we do not have much confidence in) shows that the annual tonnage taken to be around 2.5 tonne per year or 10 tonne for the four year period 1995/96 – 1999/2000.
In 1999/2000 the Minster made an allowance of 6 tonne per year for the recreational sector. Assuming that the 6 tonne per year was taken for the years 99/00 and 00/01 would equate to 12 tonne for the two-year period.
During the period 95-01 industry took 787 tonne and the total recreational take from 95- 01 would equate to a total of 22 tonne. One doesn’t need to be a rocket scientist to see that the recreational take was less than 3% of the total take for the six-year period.
This recreational sector are not interested in even discussing bag limit cuts when so much of the damage has been caused by one sector.
Other sources of mortality
We believe the three tonne allocation to be far too low.
The stock assessments suggest as much as 54% of Paua taken could be undersized (Pirker 1992). On this basis the 787 tonne kept by industry would equate to 46% of the total paua removed from reefs. Therefore 100% of total paua removed from reefs would be 1,710 tonne. With this figure in mind it would mean that the 54% of the paua returned to the water would be 923 tonne, and Pirker suggests that 13% of these or the 120 tonne of paua returned may fall victim to predation.
Even though these figures are from the 2002 Fishery Assessment Plenary document they appear to have been ignored. If Pirker’s figures are wrong, they shouldn’t be in the stock assessment document. If they are right, why is the ministry suggesting a mortality rate of only 3 tonne?
I appreciate that we are working from the top end of the scale, but MFish is suggesting a TACC of 90 tonne, and using Pirkers figures 120 tonne is killed. With a stock of such high value, it appears to be ludicrous.
We will be seeking to have areas in 5B closed to commercial fishing to ensure that our rights to harvest seafood for sustenance are not threatened by the commercial sector. The process is working in 5D so we are confident that we can manage areas in other Paua subdivisions.
- TAC be set at 105 tonnes
- Recreational allowance be 6 tonne
- Customary allowance be 6 tonne
- The Ministry allows a realistic tonnage for other mortality
- The Ministry allow a realistic TACC after allowing for the other mortality tonnage, (yet to be calculated)
- Ministry to investigate closing areas for recreational only take
We note that the ministry intends setting a TAC and to reduce the TACC for area PAUA 5D.
Each TAC option includes a non-commercial allowance of 45 tonnes incorporating 3 tonne for customary Maori, 22 tonne for recreational interests, and 20 tonne for other sources of mortality.
The Ministry intends talking with recreational interests on how they can ensure that the recreational catch remains within the allowance.
We see this as another fishery where the dollar signs took over from sustainability. We also believe that the state of the fishery now is solely a result of unrealistically high TAC’s being set and quota appeals being added to initial TAC’s which have been ongoing since 1986.
Since Paua has been a commercially sought after species, the industry has continued to reap the harvest of the mighty dollar and the ministry has been satisfied that the fishery was going through a fishing down stage and future assessments would show when the stock had reached the MSY.
It is of serious concern to our sector that the ministry has allowed this decline to go on for so long and not putting a halt to the onslaught. The recreational sector has on many occasions expressed concerns to the ministry and has not seen our concerns met or any preventative action taken until now when the fishery is at a critical stage.
The recreational sector have obviously found it harder to catch their bag limits over the years, and have resorted to getting most of their paua from the recreational only areas. They have found it too hard to get a limit bag outside the areas.
The drastic decline in fish stock is certainly not due to the recreational sector taking only 22 tonne per year. If there had been no commercial fishing in the area, the stocks would have still been in a healthy state, so the blame lies with the commercial sector. We can support this statement by suggesting that the areas set aside as voluntary recreational take only areas and the areas closed by regulation to the commercial sector still have good stocks and in some cases building stocks.
As we have not had time to get full consultation from our sector due to the time restraints in producing this submission we cannot say that our members fully support our suggestions. To get full consultation will take longer.
We accept that it would appear that the recreational take is in the vicinity of 22 tonnes and that we have not seen any evidence so far to show that since 1996 there has been any increase in recreational take as suggested by the ministry. We accept that we may harvest up to 22 tonnes but do not accept it as an ongoing cap.
We believe that the present bag limit of 10 are realistic and that reducing the bag limit to 8 will have people diving on both days of a weekend and thereby taking 16 paua so nothing will be gained.
From discussions so far closed areas are more favourable than lower bag limits.
It has been suggested that closed areas may be acceptable if managed the right way. Selected areas should be easily identifiable as geographic areas with prominent landmarks identifying boundaries.
The areas need to be selected and made in consultation with local iwi, local residents, and local fisher organisations. Ideally they need to be closed and opened on a rotational basis, and the time of closure agreed to by all concerned. These areas should not extend over wide areas to enable gatherers to get paua within a reasonable travelling distance.
We would also insist that customary also support and assist in developing and managing the closures and that the gatherers respect the closures and exercise constraint when issuing customary permits.
In the voluntary closed areas and regulated closed areas we would support a management plan, and managed by a local committee that reflects a local community and recreational interests. We must stress that these areas are showing good sustainability levels and that is certainly not evident outside the recreational areas.
- The NZRFC supports option 2 with a TAC of 159 tonnes and a TACC of 114 tonnes
- The bag limit remain at 10
- Local management committees are set up to manage closed areas
- MFish liase with locals on closed area rotations
The TAC is reduced to 220.24 tonnes with an allowance of 15 tonne for customary Maori, 15 tonne for recreational interests, and 3 tonnes for other sources of mortality.
Reduce the TACC from 240.73 tonne to 187.24 tonnes.
We note that industry shelved 20% of the TACC of the 2000/01 fishing year.
The Minister reduced the TACC by 10% 2001/02.
When considering the present state of the fishery is it all a little too late. The present state is obvious when considering the CPUE from 256kg down to 92kg. And the voluntary reduction by ”shelving” not being adhered to by all commercial operators. This shelving appears to be no different than to voluntary no go areas. Only one operator needs to ignore the agreement and the whole procedure goes out the door.
We note with concern the doubt that has been raised over the accuracy of landing information in recent years due to miss reporting.
We are aware that the local recreational fishers association has an improving relationship with the paua industry and would like to be working more closely with them.
We note that the voluntary closed area is showing signs of restocking and that generally the recreational sector are adhering to the voluntary 5 bag limit within the closed area.
We would like to think that other areas could be set aside as closed areas. They work well in PAUA 5D and show more and more signs of improvement as time progresses so we see voluntary closed areas as an obvious answer to stock depletion.
Other Sources of Mortality
We have concerns over the allowances made in PAUA5B, PAUA5D, and PAUA7 for other sources of mortality. If Pirkers figures are even 50% correct then the allowances being made by Mfish do not even come close to what they should be.
- Set a TAC of 220.24 tonnes
- Set a TACC of 187.24 tonnes
- Retain non commercial allowances of 33 tonnes
Tuna Longlining Form
At a pelagic working group meeting some time back it was decided to state on the return form, the rules relating to marlin. Industry suggested that there were always new players coming into the industry and that these new members were not always up with the play.
It was decided at that meeting that it was too costly to change a form but when a new form was to be introduced the regulation would be printed on the form somewhere.
Has this been forgotten?
President N.Z. Recreational Fishing Council
(07) 308 4077