PO Box 37951
The Minister of Fisheries
The Honourable Pete Hodgson
We realise that
this letter will arrive after the closure date for Stakeholder Submissions.
However new, critically important and very material information
has just come to hand. On Friday, 12/9/02 we received an email (from
a member of the NZRFC Executive) that would indicate that the 1999/2000
NMRFS has been confirmed.
We were relieved
to read in your Preliminary Views statement, dated 9/7/02, where
you wrote I note that the results of the 2000 recreational
survey have not been confirmed as yet. I propose to take into account
the results of that survey if the information is confirmed prior
to the time of my final decision. I request stakeholders to provide
specific comment on the issue of the recreational allowance for
We note in the
new estimate recreational catch from SNA2 may be as
high as 720 tonnes.
The vast difference
between the recreational catch estimates now on the table, 40 tonne
advise/recommendation from the Ministry and 700 plus tonnes from
the latest available information (1999/2000 NMRFS) must generate
serious doubt about where to set the critically important TAC for
SNA 2 and what if any surplus is available to increase the TACC.
you directed your Ministry to re-run the stock assessment model
with a higher recreational allowance, which recreational allowances
did they run? If they did not run 360 tonne (1/2 of the highest
estimate available) and 720 tonnes (the highest available estimate
of recreational catch) we ask that you do this before you make your
decision, so that the full range of catch estimates can be adequately
considered in your decision.
At this juncture
we would also draw your attention to the warning offered by the
reviewer, Bob Kearney (paragraph 6.2 page 20):- I also caution
against the presumption that because some of the harvest estimates
from the national surveys appear high they are, by necessity, incorrect.
In the absence of quality data perceptions of the magnitude of recreational
fish catches have, world-wide, tended to under-estimates
this to mean that the recreational catch of snapper in SNA 2 could
be at the upper end of the new estimates.
We also ask
that, at the forefront of your decision, you bear in mind that the
whole proposal to increase the TACC in SNA 2 is based on the unobserved
and unvalidated claims of commercial fishers that their incessant
overcatching of the TACC has been unavoidable. We ask that you direct
your Ministry to tally up this years Commercial Catch Returns received
to date, to see if the overcatch has persisted in the light of the
new ACE regime in place for this current fishing year. We believe
that the constant, historic problem of overcatch should have been
largely addressed by this new regime.
, we believe it prudent to get a better estimate of the recreational
catch to remove this additional uncertainty from your decision.
We strongly believe it is wrong to use, seriously flawed recreational
catch estimates from 1996 when considering increasing a TACC increase.
We ask that
you follow the precautionary principles of the Act and do not increase
the TACC until the estimates of recreational catch for snapper in
SNA 2 have been determined with acceptably low CVs (sampling
We ask you,
once again, Minister, to reject Ministry proposal and to not increase
the SNA 2 TACC in the light of such uncertainties.