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"Ministry advice to the Minister on feedback tabled at MCG August 2001 - released under the Official Information Act Feb 2002"

Released Under the Official Information Act - Feb 2002

ASB Bank House,
101-103 The Terrace,
PO Box 1020,
New Zealand.

MINISTRY OF FISHERIES Te Tautiaki i nga tini a Tangaroa

Ref 211412
9 July 2001

Minister of Fisheries


  1. You have received a submission from the Ministerial Consultative Group (MCG) providing comment on the policy papers released to the group on 25 June. The submissions are in general critical of every aspect of the policy papers package and do not offer proposals to move forward.
  2. The MCG submitters appear to desire complete open access arrangement for recreational fishers. Virtually any form of management that may lead to a limitation on the harvest of recreational fishers is rejected.
  3. in discussing their response, and considering options for reforms, it will be important to outline to them the overarching framework of fisheries management In New Zealand we do set a TAC that has been very successful in limiting commercial fishing and restoring recreational fishing to a level not seen since the seventies To destabilise the process that manages commercial fishing is to jeopardise all of these gains and threaten sustainability (and therefore recreational fishing).
  4. Their criticism of the quota system is unjustified. It has for the most part been extremely successful in addressing the problems for which it was designed to address; namely, inshore depletion, overcapitalisation and inefficiency. The submission lists a series of fisheries management issues that are dealt with in various ways with various degrees of success, but fails to acknowledge that recreational fishing is the best it has been for a long time due to the management framework that is employed.
  5. The submission is not internally consistent. There are also some misconceptions about the nature of what is being considered in the policy papers. Comment on several of the issues in the submission is provided in Annex 1.

    Further Meetings

  6. It may be necessary to have a further meeting with the MCG. This could be arranged for the evening of Thursday 26 of July following another commitment you have in Auckland. A further meeting could be used to outline your intended course of action and conclude the process.

    The 1989 Policy

  7. At the first meeting there was a request for a reinstatement of the 1989 Policy on marine recreational fishing. The submission also considers the 1989 policy.
  8. The 1989 National Policy for Marine Recreational Fishing has a very good set of aims, principles and objectives. These are still reasonable as the high level goals of management and any policy reform. But the current proposals are looking for mechanisms to effect these principles - this requires legislative amendment
  9. However, the fisheries management environment has evolved a lot since 1989. The Deed of Settlement was signed, centralised planning processes were abandoned, we have introduced a more ecosystems based approach and Fisheries Plans are bringing a new methodology for local management.
  10. In order to implement the objectives for recreational fishing the current fisheries management framework must be taken into account. This includes;

    a) The total removals from any fishery must be constrained to a sustainable level
    b)) The QMS provides good economic and biological outcomes for fisheries management

    c) Amendments to the regime should not undermine the Deed of Settlement
    d) The current recreational right is based on a right to access and use, but does not guarantee any amount of fish

  11. The submitters see the 1989 Policy as establishing a priority right for recreational fishers.

    On allocation the 1989 Policy stated:

    To ensure that recreational users have access to a reasonable share of fishery resources

    Allocation of fishery resources should reflect the most beneficial use of the resource. Historically, many fishery resources have supported recreational fisheries. The objective recognises the benefits of maintaining recreational fisheries by means of an allocation to recreational users. This allocation may take the form of a share of the sustainable yield or as areas set aside primarily for recreational fishing.

    Preference will be given to non-commercial fishing in areas readily accessible to and popular with the public, where a species is not sufficiently abundant to support both non-commercial and commercial fishing.

  12. In promoting this objective, the MCG tend to drop the reference to areas and maintain that it refers to a share of the TAC. (These are clearly distinguished in the policy) in fact this was a very qualified form of preference. It does not provide priority to an ever-increasing share of the TAC. The priority refers more to method exclusions of commercial operators in the inshore. This is not similar to the priority share noted as one option in soundings and sought by option4.


  13. These comments are provided to assist your discussion with the MCG in the meeting tomorrow evening.


  14. it is recommended that you;

    a) Note the contents of this paper.

Mark Edwards
For Chief Executive
Ministry of Fisheries


Hon Pete Hodgson
Minister of Fisheries

/ /2001


Issues raised in the submission

  1. Information Requirements

    In general no new issues are raised here. The submission questions the scientific merit of doubling the estimate frequency. It should be noted that this is a management objective not a scientific objective. Once the management objective is decided upon, for example two yearly estimates for fisheries management purposes, then we can look at the best method for determining the estimates. Over time the methodology will change a lot but we would expect the objective of at least two yearly estimates should remain (Continuous estimation would achieve this obviously).

    The submission suggests a technical review by the working party on estimation methods. However all working parties work to achieve a management objective. At present there is an absence of any such objective.

    We admit that accuracy is a problem just as much as frequency. Nevertheless, a two yearly cycle for major fish stocks where change is apparent is a reasonable management goal; similarly a greater focus on areas where estimates are unreliable is also a reasonable goal. Establishing the management objective will require a focus on both of these.

  2. Charter Boat reporting

    The issue of safety and non-compliance is raised. One assumes that by safety they mean that if reporting is required, boats will not obtain a license. This would lead to prosecution. In our view it is unlikely that a small compliance cost would lead to jeopardising an entire business.

    The package of reforms needs to be looked at as a whole. It is also proposed that charter boat operators effectively propose their own rules through the management groups. It is difficult to understand why operators would lie to themselves. We recognise the potential for incentives to provide false returns, but given that there is no intention to use this information to limit charter boat activities it is not expected that this will be a significant problem. This will mitigate the incentive to make false returns. (It will also be an offence)

    The purpose of the proposal is primarily to provide the information that charter boat operators need to manage their businesses in an environment of growth. Over time we would expect the charter sector would come to see the value of the information.

    It would not generally be possible to know how the information each boat was providing would affect the overall estimates of catch in any case. This would further remove the incentives to create false returns. However we freely admit that this will be an
    evolutionary process. The time series that is collated will be an invaluable management tool however.

    In general these people are making money from a public resource. They have an obligation to participate in the management of that resource from which they ultimately benefit.

  3. Defined rights

    The criticism tends to reject the possibility that recreational harvest is capped. This is not a sustainable position. It must ultimately be capped irrespective of whether there is any commercial fishing. In doing so it must always be recognised that there is a need to consider the impacts on the commercial industry.

    The submission suggests that a fundamental change in the mindset of the ministry is required. We recognise that more effort is required in recreational fishing management. We agree that it is important that management be informed of and take into account recreational objectives. Independent managers to address recreational concerns are where the gains to recreational fishing will come from. So in this sense, the package is designed explicitly to create the ability to incorporate recreational objectives directly into management.

    These managers must however recognise the fisheries management framework in which they operate and not be merely lobbyists for one sector. Recognising this framework will include recognising the need to limit the catch from all sectors (no matter what you call it: share, allowance etc). There must also be recognition that a framework for allocating between sectors is required. The Working Papers provide a range of options to achieve this. To reject limiting and allocating is to reject fisheries management and therefore sustainability.

    The policy papers outline the argument that we do not recommend management structures without a defined share. Unless explicit recognition is given to the fact that all harvest must ultimately be capped for sustainability reasons then we do not recommend responsibility for fisheries management be passed to these groups. This is due to the fact that to not accept this is to not accept the framework of fisheries management in which they will have to operate.

    Whether allocation decisions are made in favour of the recreational sector, or in favour of the commercial sector, is a second order question. The primary issue is recognising that these decisions must be made. Setting a TAC and a TACC that is effective in limiting commercial catch implies that a proportion is allocated to the recreational sector.

    "If one sector has created the decline why should other sectors be reduced?" We agree and we do not think that this should be the case. The policy papers should include reference to the cause of a decline being relevant in considering who should bear the cost of reductions.

  4. Inconsistencies

    There are contradictory claims that managing to MSY and not managing to MSY are both undesirable.

    For example it is claimed that leaving fish in the water in the case of a recreational share that was not fully utilised (i.e. managed above MSY) is inefficient and undesirable.

    " ...if the TAC was increased and the recreational sector could not take the increase it would create inefficient use of the resource. "

    There is also the claim that managing to MSY is the Ministry's only focus and a change in mindset is required.

    "...the legislation it works under is centred around extracting the greatest meat weight from the commercial fishery"

    These positions are not immediately reconcilable. However, it does imply that there are trade offs to be made here.