to the Minister of Fisheries
Hon Jim Anderton
December 16, 2005
Congratulations on becoming
the Minister of Fisheries from the team at option4. I am sure you
will find the portfolio both challenging and highly rewarding.
I write to you as project
leader of option4 , an NGO that promotes the interests of non-commercial
marine fishers in New Zealand. Our group has been actively participating
in fisheries management for the past five years and several of our
team have over 20 years experience in fisheries management, and
representing recreational fishers. A record of our process is online
at www.option4.co.nz . Our main role is advocating
on behalf of those who fish non-commercially and keeping the public
informed about issues surrounding their ability to fish for food.
The option4 team work very closely with the New Zealand Big Game
Fishing Council, New Zealand Recreational Fishing Council and Ngapuhi
on matters of mutual concern.
Our understanding is Mark
Edward's team and Dr. Robin Connor are developing an Insectorial
Allocation Policy with a view to possible legislative change. A
fair and practical allocation method for non-commercial fishers
is all we seek.
I have spent many years working
very closely with Doug Kidd when he was the Minister of Fisheries
and found that relationship mutually beneficial. My experience also
includes working with the Department of Conservation to develop
an underwater setting device to reduce seabird mortality and with
MFish to improve hook technology to reduce the mortality of undersized
snapper. I also represented recreational and environmental interests
on the Set Net Task Force established by Doug Kidd in the mid 1990's.
I am sure Doug Kidd would welcome a conversation with you regarding
my involvement in past fisheries management should you require any
More recently option4 has
been privileged to participate in the building of close relationships
with tangata whenua, particularly Ngapuhi, and the subsequent establishment
of the Hokianga Accord.
We would like to discuss
with you our concerns regarding the current proportional allocation
model used in shared fisheries, and our participation in the development
of any alternative allocation model. Stan Crothers gave an
undertaking at the hui of the Hokianga Accord in August that the
Ministry would work with option4 and others after October 1 st to
resolve the issues raised by proportional allocation. We appreciated
that commitment and look forward to the Ministry following through
on this promise.
The Ministry continues to
impose a proportional allocation model when reducing fishing quotas
and allowances. There are many serious issues with this model, not
the least of which is a complete absence of any proper process for
setting the initial allocations.
It is of concern that proportional
allocation decisions made under the current system completely removes
all conservation incentives for non-commercial fishers. These decisions
are also perceived as being unfair by non-commercial fishers as
they create a double jeopardy situation where the non-commercial
sector is penalised twice, while the commercial sector only receives
one quota cut. Confidence in fisheries management and the QMS are
compromised by the above as negative publicity inevitably follows
each new decision.
Your Ministry has acknowledged
many of the shortcomings of the proportional allocation model in
their SNA 8 FAP in response to papers I wrote on proportional allocation
 for this year's fisheries
decisions. MFish have also acknowledged that allocation is the number
one critical issue in domestic fisheries management. I have spent
15 years working on these issues and I do not have confidence in
many of the recently appointed MAC members on this topic. I do not
believe most have sufficient grasp of the complex issues surrounding
proportional allocation to fulfil their primary function in giving
strategic advice on this matter, nor do they have adequate resources.
One of the fundamental reasons
for the failure of Soundings , the MFish consultation process
on non-commercial fisheries reform launched in 2000, was that the
initial process was conducted behind closed doors and the recreational
participants had insufficient understanding of the issues and inadequate
resources. It would be a shame to see any new process fail to gather
the necessary public support for the same reasons.
My offer to you is that option4
would be available to fully engage in the early stages of this new
process. Our participation would bring the resources of option4
to bear on the real issues. This would include paid legal and scientific
advice, a robust communications network and a range of committed
personnel, including myself, who would collectively bring a comprehensive
variety of expertise in fisheries management.
I firmly believe it would
be far better to have these resources working within the process
rather than outside, as happened with Soundings . A more
robust solution is the likely outcome, as the core issues would
be dealt with before the public consultation gets underway. This
would add transparency and confidence that the real issues, costs
and benefits would be put openly before the public during the consultation
Preference Debate and MSY
Your predecessor, David Benson-Pope,
announced in July " that species important to recreational
fishers should be managed above, or even significantly above, what
fisheries documents refer to as B MSY – the size of a fish
stock that delivers the maximum sustainable yield." We believe
that allocation and the target biomass fisheries are managed at
are inextricably linked. When fisheries are managed below the level
required to produce Maximum Sustainable Yield preference is given
to commercial fishing interests. This is because they can maintain
catches in depleted fisheries through bulk fishing methods, increasing
effort by deploying more gear or fishing for longer periods of time.
Technological advances also help to improve their efficiency and
maintain catch rates even when fishing in depleted fisheries.
Non-commercial fishers catches
are more controlled by the size of the fish stock. In healthy fisheries
they will catch more because the fish are bigger or more abundant,
or both. In depleted fisheries they will catch less because the
fish are smaller and scarcer, or both. This means the commercial
sector can cause a reduction in non-commercial catch by maintaining
the stock at levels below the level required to produce the Maximum
Sustainable Yield. This has already happened in many fisheries.
When the Ministry finally takes action quota and non-commercial
limits are generally cut in proportion. This is the double jeopardy
situation mentioned above. First, the non-commercial catch is suppressed
to low levels by the low stock size then this reduced catch is cut
again in the name of sustainability and because of the preferred
proportional allocation method used by the Ministry.
Conservation efforts by non-commercial
fishers and excessive commercial fishing are ignored in the Ministry's
proportional allocation process. The recent snapper 8 decision is
a good example, the decision has punished those who have conserved
and rewarded those who have exceeded their entitlements.
Our team would like to meet
with you at your earliest convenience to discuss the above issues.
I suggest you invite Stan Crothers , Mark Edwards and Kevin Sullivan
from your Ministry to this meeting, as I believe they could give
you sound advice and answer any questions raised. option4 would
send four or five of its best people to this meeting. We are sure
that such a meeting would be of immense value to you and enable
you to better understand the recreational perspective. We hope you
find the time in your busy agenda to meet with us and if so, we
look forward to meeting with you as soon as possible.
Wishing you a Merry Christmas
and a Happy New Year.
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