7th May, 2003
option4 write to the Minister
regards his upcoming allocation decisions for Kingfish as it enters
Minister of Fisheries
Mr Pete Hodgson
Last month we received your letter stating your decision to put
some shellfish species into the QMS on the 1st of April 2004. This
reminded us that soon you will be thinking about proposals for setting
the TAC, TACC, Maori and recreational allowances for kingfish.
We know the Ministry of Fisheries will be working on the “Initial
Position Paper” (IPP) outlining their proposals for consultation
on the kingfish catch levels so the catch levels can be set in time
for the start of the next fishing season on October 1, 2003.
We are concerned the Ministry of Fisheries will favour the commercial
sector as they did in their SNA2 recommendations last year.
The 2002 SNA2 recommendations were probably the worst example of
the Ministry’s bias we have ever seen. We still believe SNA2
should be reviewed again and the TACC decreased to take into account
the fact that your Ministry chose to ignore the recreational catch
results from the 2000 recreational fishing diary survey in their
IPP recommendations to you.
One good outcome from the SNA2 process was that you showed yourself
to be immune to the flawed advice provided by your ministry. You
were independent and this was reinforced in your “preliminary
views” letter last year where you proposed an option quite
different to the Ministry’s’ recommendations.
You have clearly been able to disassociate yourself from the interests
of the commercial sector in the past and we ask you do the same
with the kingfish allocation process
Based on our previous experience with the Ministry of Fisheries
we believe they will be considering proposals for the catch levels
for kingfish close to the status quo, or with a slight catch decrease.
The purpose of this letter is to ask you to again be independent
and consider catch level proposals much less than the Ministry’s.
The TAC and TACC setting part of the 1996 Fisheries Act provides
you, as the decision maker, with a lot of discretion.
Specifically, for KIN1 we consider the TACC should be around 20-30
tonnes of kingfish – at about the amount of the true unavoidable
by-catch from trawling. There simply should be no kingfish by-catch
from set netting as there should be NO set netting on the reefs.
The TACC for KIN2 should be near 10 tonnes. We will provide you
with additional comments on kingfish and set netting when we make
our submission in June-July.
Minister, the critical point we ask is that you state your own
proposed options for the kingfish catch levels in your “preliminary
views” letter to stakeholders when you comment on the Ministry’s
proposals. We fear that if you do not, you may become locked in
to only considering the Ministry’s proposals at the time that
you have to make a decision - about August.
We apologise for labouring points that we know you will be well
aware of. Kingfish is so very, very important to the recreational