The Option4 group has discussed Peter Ellery's paper in depth. The group has sought advice of fishers and fisheries managers/researchers with considerable experience in fisheries planning and research and we would make the following comments:
We agree with Peter that the option4 position is at a preliminary stage. We don't find that surprising.
The Rights Working Group has been working behind closed doors for two years and has finally put out a proposal last month. Public consultation on the Working Group proposals has been operating for less than a month, we are still learning about the proposal as we question and probe at the public meetings.
It is to be expected that option4 will be at an embryonic stage while we are still gathering information from the Ministry and Council on their deliberation, and listening to the Public comment. We want to remain open minded through the consultation process, but that will not stop us from asking hard probing questions, and floating ideas of our own to get feed back from the public.
There is still much to be done before a fully-fledged proposal is developed, and our position will be defined once this round of public consultation meetings is completed.
Even so we believe option4 with its basis in the Labour Governments Marine Fisheries Recreational Policy as stated by Minister Moyle (and not Option 3 as Peter suggests) is still a better defined statement of the Marine Recreational Fishing Right than the current Working Groups proposal.
Peter is correct that the Bmsy is predicted to be a 10,000 t fishery by 2020. What Peter hasn't fully realised is the extent to which some quota holders in 1986 took a quota cut on their SNA 1 catch history without compensation. They have a clearly defined Right to get first allocation of any TACC increase. They will undoubtedly exercise that option - how could they convince their shareholders that after waiting 10 20 years for a quota increase that they should give it away to recreational fishers.
The obvious option is for the Government to compensate them. However (based on Mfish Policy Analyst Jenny Mc Murran statement) Government will not do this. We can understand Governments reticence, the quota holders would want compensation for lost earnings on the quota forgone for the previous 10 - 20 years as well as the potential future earning.
Peter says we have nearly double the fishery to grow into. We don't know the basis for that statement. The Ministry's scientific assessment is that the fishery can grow only another 40 percent. Under a proportional share (based on current catch and no compensation to commercial quota holders) only a third of that would go to recreational fishers. Since Government does not support compensation, we cant see that changing. Peter also seems to suggest that if we rebuild above the Bmsy the yield will increase further. That is not the case. The term Maximum Sustainable Yield obviously implies that if you go above the MSY the yield will decrease.
Peter dismisses the concept of a recreational quota. However de facto that is the situation now. The reason being is that the management is predicated around the Commercial Right (TACC and Individual Transferable Quota), as part of the process the Minister defines the recreational tonnage catch to be allocated. We believe the options paper is deficient in not exploring options such as recreational quota. That does not imply that we support it, only that the full range of options needs to be considered.
It is for these sorts of reasons that we feel that the Soundings paper is really consultation on one option with three variations. It is a continuum starting with status quo at one end, with a second variation of status quo type management with proportional share, and some closed areas for recreational take (which recreational fishers have de facto now i.e. that is just part of the status quo option). The third variation is just the second variation with recreational fisheries management added in.
The major problem with the third option is that it just the status quo (+/- proportional share) with the recreational sector funded to go to meetings. The document clearly states that MFish would still manage. Just funding recreational fishers to attend meetings will do little. The end result of option three is that the recreational leaders would just get criticised by fishers for becoming another link in the chain further slowing the process and frustrating fishers who are now funding or part funding the management process with no change in decision making.
Option three proposes Fisheries Management Plans as a way of the stakeholders working together. An article in the current Seafood New Zealand on Fisheries Management Plans makes it obvious that it will be a process run by the Ministry i.e. the status quo. What is needed is a management planning process run only by the stakeholders (Maori, commercial and recreational) approved by the Minister, and with the Ministry's role being solely advice to the Minister and auditing of plans and its operational performance. The Soundings document seems to superficially cover the significant issues such as stakeholder self-management options. There are better example of rights based management regimes in the Customary Maori regulations. For example the Mataitai semi autonomous management approach. These are referred to in the Soundings document but the management principles and approach is not presented in detail as a potential management system that could be adapted for recreational management.
We don't agree with Peter's proposal that if recreational fishers get a 50% share it will have equality with the commercial sector. The issue is far more complex than just a funding issue. To think that a body whose members are primarily interested in simply the opportunity to go out and fish with a minimum restriction is equal to a billion dollar industry comprising multinational companies with all the specialist support services at their resources is ludicrous. Addressing that imbalance is one of many hard questions that the Sounding document should be addressing but doesn't.
Peter's paper focuses on processes such as funding and structure, but that is putting the cart before the horse. First the Marine Recreational Fishing Right needs to be clearly defined. Only once you know what the Right is can you respond to the funding and structural issues.
Given the lack of clarity on the definition of the Right and effectively only one option up for debate, we would suggest a two round consultation process. The current round should focus on the definition of the Marine Recreational Fishing Right. Once Cabinet has clarified and approved the Right consultation can begin on management regimes, funding and structures.
This approach would address Peter's concern that the Option4 group has not proposed a management structure and process, how can it if the Right has not been clearly defined, and a full range of options has not been publicly debated. It would also allow the Ministry to propose more specific proposals on processes and structure; not the least of which is the funding option currently clouded by the red herring of licensing.