potential impacts on recreational bag limits are possible under
the Ministry of Fisheries recent management options due to be implemented
in October this year. The proposals include recommendations for
reductions to west coast snapper bag limits and northern North Island
mullet and flounder bag limits. Consultation on the proposals is
underway now and a public meeting is to be held this Wednesday night
at the Mangere Boating Club. (Meeting details
and map at the bottom of this page)
Once again the Ministry is
using a very poor consultation process. They have failed to adequately
advertise the management initiatives to all those who will be adversely
affected by the proposals and they have imposed a very short timeframe
for those who have an interest in the fisheries to respond.
option4 has sent this communication
to you to ensure that you can participate, be kept informed, have
your views heard and have these views taken into account in the
decision making process.
If you know of any other
people who are likely to be affected by reduced bag limits in these
fisheries please forward a link to this notice to them, it may be
the only way they find out about these proposals.
Ministry of Fisheries (MFish) are proposing to cut snapper catches
in SNA8 (west coast North Island), Flounder catches in FLA1 (Cape
Runaway to New Plymouth) and grey mullet catches in GMU1 (Cape Runaway
to New Plymouth).
The Ministry are proposing
two options for reducing the total catch in these fisheries:
- A proportional cut where non-commercial and
commercial fishers catches are purportedly cut by the same percentage,
but they are not. This option could see recreational catch bag
limits slashed by more than two thirds.
- A non-proportional reduction that could result
in recreational catches bag limits being slashed by up to two
option4 has grave concerns
regarding all of the proposals and their potential impacts on non-commercial
fishers now and into the future. The summary below sets out the
main concerns in more detail.
the proportional cut option non-commercial fishers would initially
be allocated a tonnage based on a flawed 1996 harvest survey which
may underestimate recreational catch by as much as two thirds.
This could mean we will
only get one third of what we actually catch now as an initial allocation.
Any cuts would then come from this massively reduced recreational
If the initial recreational
catch is capped at this lower level then cuts in total recreational
take in excess of 50% could be required when better information
Bag limits of one or two
fish per person would be required to reduce the total recreational
catch by this amount.
above, under the non-proportional option non-commercial fishers
would be initially allocated a tonnage based on a flawed research
1996 harvest survey which may underestimate recreational catch by
as much as two thirds.
This could mean we will
only get one third of what we actually catch now, as an initial
allocation. Again, if the initial allowance is insufficient to cover
current recreational catch then cuts in total recreational take
would require huge reductions in bag limits.
Ministry has stated that under either of the above options, “steps
will need to be taken to ensure that the recreational catch does
not exceed the reduced allowance”.
There is also a warning
in the Ministry proposal that the bag limit reductions proposed
are noted as being ‘a first step' in reducing recreational
take, clearly this means that further cuts are highly likely!
History of Proportional Allocation
Ministry's agenda to allocate fisheries resources proportionately
between stakeholders was first raised in the Soundings
document. The Ministry of Fisheries and the NZ Recreational Fishing
Council produced Soundings back in July 2000. Soundings
was all about proportional allocation and gave three options
for achieving it.
During public consultation
on Soundings Jenni McMurran, from MFish policy division,
was asked what the objectives of the Ministry were. She replied
that it was to cap the recreational catch and avoid compensation
issues for the Crown.
So there we have it, proportional
allocations are not about fairness, not about what is right, it
is all about protecting the Crown from compensation where fisheries
have been misallocated between sectors, mismanaged or both.
Proportionality is about
using recreational catch as a bank from which the Crown takes fish
and gives it to the commercial sector when commercial fishing has
Fishers in Double Jeopardy
allocation inevitably puts recreational fishers in a double jeopardy
situation when fisheries are in poor shape and allocation decisions
are being made.
Our catches are eroded
in the first instance by the low stock size. We end up catching
smaller fish, fewer fish, or both as the fish stock declines. The
overall tonnage of recreational catch drops as the biomass falls.
When we are allocated our
"share" it is usually based on our current catch in a depleted fishery.
Consequently, under the current proposals we are allocated the minimum
Then the Ministry have
the audacity to ask us to take further catch reductions under the
proportionate options under consideration.
This is clearly unfair
and unacceptable. To add insult to injury, the Ministry, in this
years proposals, has knowingly used flawed research to argue recreational
catches down even further.
If these proposals are
not challenged non-commercial fishers could wind up being seriously
under-allocated in these fisheries. Bag limits will need to be slashed
to constrain recreational fishers within the tonnage allowed.
The commercial allocation
is largely unaffected by the health of the fishery, they simply
apply more effort or more efficient methods to maintain their catches
and "proportion" in a declining fishery. They have also used the
Courts to inflate their quotas and "proportion" by up to 30% above
the scientifically determined safe level of harvest.
Coast Snapper Fishery
Ministry have a long record of failing to constrain commercial fishers
to a sustainable harvest level in the fisheries being reviewed this
year. In the west coast snapper
8 fishery (SNA8), which runs from Wellington to North Cape,
the fishing industry have taken in excess of their already inflated
quotas by using the deeming provisions of the Fisheries Act in almost
every year since 1987.
Over and above all of this,
the Ministry notes that dumping and high grading of commercial catch
(an unforgivable waste of a precious resource) is more widespread
in the SNA8 commercial fishery than in any of the other snapper
If recreational fishers
want a fair and just allowance in the snapper fishery it has become
obvious that they will have fight for it. The Ministry is far more
concerned with avoiding compensation than it is with fairness, truth
or making a just allocation.
allocation models for the flatfish (flounder) and mullet fisheries
demonstrate the lunacy of previous allocation decisions. In the
flounder fishery the
commercial sector have been allocated so much quota that they have
been unable to catch it in any single year since the introduction
of the Quota Management System in 1986.
allocations for commercial fishers are equivalently high. Concerns
about the sustainability of both fisheries have been raised in the
Ministry's papers this year.
MFish has proposed to
reduce the quotas on both species to the level that reflects current
commercial catches in these fisheries. Commercial fishers will continue
to take the same level of catch that has caused the sustainability
problem in the first place.
This appears to contradict
the Ministry's own advice that clearly says a reduction in actual
catch is necessary. Obviously if commercial catches are not reduced
these proposed cuts to quotas will have no effect on improving these
However, the proposals
could have serious impacts on recreational catch. Again the Ministry
seeks to set allocations based on flawed research which could under
estimate actual recreational catch by two thirds. As the Ministry
follow through with their promise to constrain recreational catch
to the allowance massive bag limit cuts will be required.
The proportional proposals
for mullet and flounder will effectively cut recreational catch
urgent meeting has been called for Wednesday night 20th July at
the Mangere Boating Club, Kiwi Esplanade, Mangere Bridge 7 –
9pm, to discuss the Ministry proposals and the way forward for recreational
For further information
please call Trish Rea on 09 8186205 or email firstname.lastname@example.org
The outcome of this meeting
is not a foregone conclusion and differing views on the way forward
for recreational fishers will be expressed.
It is imperative that if
you have any interest in the west coast snapper fishery, the northern
mullet or flounder fisheries that you attend this meeting. Your
attendance at the meeting will ensure that your views are taken
into account by option4 as it develops its response to these proposals.
If you cannot make it
to the meeting then please go to http://option4.co.nz/register.php
and subscribe to the option4 Updates to be kept fully informed of
option4 is currently developing
an online submission facility to ensure you can have your say (within
the next week) in the management of fisheries that are important
Don't forget, please forward
this email to anyone you believe has an interest in these fisheries.
It may be the only way they find out about it!
|A map of the location of the meeting
venue, Mangere Boating Club.
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