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Firstly, congratulations to the group, for producing a good site that is providing people with an opportunity to air their views and carry on the debate. I am pleased to hear that option4 is now declared to be "at a preliminary stage", and "embryonic" and the admission "that there is much to be done before a fully-fledged proposal is developed". This is in a much different place than as first claimed, i.e. being "The Answer". I am also pleased to hear that the group wants "to remain open minded through the consultation process" however this statement is somewhat at odds with the statement that "option4 representatives are not negotiable on the following objectives and will demand the following."
There has been the suggestion that an option4 representative should be part of the group that reviews the submissions to Soundings. "Not negotiable" is not a suitable qualification for any member of any review group.
In replying to those people who replied to my response, let me say that I agree with all of them that a clear definition of the Public Marine Fishing Right is the first and foremost requirement to come from this consultation.
I guess that I took that as read and moved on into the nuts and bolts of protection, management and enhancement of that Right. That has been described as putting the cart before the horse, however what the Soundings discussion has initiated includes, the cart, the horse, the load, the destination, and the itinerary of overnight stops and provisioning required, for a really long journey.
I also agree, therefore, that it would be very appropriate, as suggested in the option4 Group response, that a two tier round of consultation take place, to first have the Public Marine Fishing Right clarified and approved by Cabinet. Then a follow up round on; a structure to represent it, the resources required and how they will be obtained.
However there are other aspects of the replies that need some further discussion.
- All replies that suggest that the Soundings Document has nothing to do with defining recreational rights are wrong. A defined share, proportional, priority, or any other form of share, of the TAC, is a definition of the recreational right. Just as the QMS, and in particular ITQ, i.e. a defined share of a fishery, defines the commercial right.
- Despite the option4 group's belief that the '89 Policy gives recreational a priority over commercial, that is quite simply not true, unless the particular fishery is reduced to a state which cannot support both sectors. So in all our shared fisheries, we are entitled to a "reasonable share" as stated in that Policy. We never had priority, we have not lost a priority, and we are unlikely to get a priority unless we are prepared to buy commercial out of their share.
The '89 Policy with it's "reasonable share" is no more defined than the Soundings discussion on a "fair share" and option4 has not made any proposal on an improvement of that definition. The clearest definition of the Right can only come from a specific share, in the shared fisheries.
Of course, defining that share has to include allowance for growth in the population and acknowledgment that noncommercial goals in the fishery are different to commercial because, in any year, we want some fish in our share to be not caught so that they can grow to be bigger ones.
Also if noncommercial and commercial are declared to be 50/50 stakeholders in the shared fisheries there is no need for a priority for noncommercial. Each half of the stakeholding has to be equally cognisant of the other's objectives in the fishery. More on this when we get back into the SNA1 discussion.
- Licensing is neither a red herring nor is it in the Soundings Document "to divert attention away from the real issues.." In Soundings, it is merely one of six suggestions on possible ways that recreational representation could be funded. It is the option4 group that has pushed it up to being the number one issue. More importantly, if the Fish and Game model of licensing were used, it would provide much more than just a way of equitably obtaining funding from all fishers. It also provides a statutory status for a defined, accountable structure to represent recreational fishers and the best possible database to supply a mandate for that structure. In this model licence fees do not go to the Government, they belong to the structure which sets them.
I have been to three Soundings meetings in the BOP and heard the loud and clear call for no licensing, however manipulated that was. OK. We can settle for something less than the best way of providing our equitable funding, statutory status and the mandate from a database of all people who go fishing. But if there is to be no compulsory form of funding then there must be considerable improvement in voluntary funding. I hope you will all come out in droves to join the NZRFC. And not just as some $1 per head levy from clubs but as individual $25 members. There are other funding options to explore and they are coming forward, all of them will be more achievable if we have shown that we care enough about our fishing to come up with sustainable self-funding.
- There was also comment in the replies on whether we do or don't want to participate in management, or, if we do, how much. WE DO. WE MUST. We already do, under the status quo, to our voluntary, under-funded best. I repeat my statement from my first response. ALL OPTIONS (INCLUDING ANY OTHERS THAT COME FORWARD IN THE PROCESS) REQUIRE RECREATIONAL REPRESENTATION TO ACHIEVE BETTER REPRESENTATION OF, AND PROTECTION FOR, THIS VERY IMPORTANT RIGHT AND SHARE OF THE FISH, THAN WE ARE CURRENTLY ACHIEVING. At all of the meetings that I have attended, there was a clear call for our involvement in management.
- Many people have been very quick to be critical of the performance of the NZRFC, of its place in producing the discussion document and of its current performance in endeavouring to represent the public fishing right in the MFish management process. Well, it is a council formed from its constituent membership and will only ever achieve to the level that it is supported. By people who are prepared to step up to the mark and get involved. By people who are prepared to provide the financial backing that it needs. Anybody can stand around and criticise from ringside but the people who are stepping up to the mark to represent the NZRFC are volunteers, untrained, unpaid, prepared to contribute their time and resources to get the job done. Any of the critics who think that they can do the job better are more than welcome to step up and add to the team.
- Much has been made of the issue of the Crown not wishing to raise compensation issues with commercial, as if this was some kind of dodge of responsibility. Any responsible Government should do its utmost to avoid compensation because it is taxpayer money "gone down the drain". It is taxpayer money paid to a few individuals, money that will come off the budgets for police, education, hospitals, doctors, nurses, mental health, victim support, etc. The other point on this issue is that if commercial and noncommercial are declared to be 50/50 stakeholders in the shared fisheries there is no need for compensation at all.
- My comment on Orange Roughy were not meant to belittle the problems and issues in that fishery, it's just that there are more than enough issues in the fisheries that we do fish in.
- Which brings us back to the Snapper 1 discussion. The replies suggest that there was not a clear understanding of my proposal, maybe that was my fault in not providing a clear enough explanation. I know that the current noncommercial share of the total harvest is about 36%. What I suggested was that the commercial and noncommercial sectors could be declared to be 50/50 stakeholders in that (and maybe any other) fishery. This is regardless of what the proportion is in the harvests. That 50/50 relationship would need to be declared in the Fisheries Act.
There is the requirement in the Fisheries Act to operate all fisheries at or above Bmsy. Snapper 1 is expected to be there by 2020 and then able to support a 10,000t harvest. Commercial, at 4,500t, already has most of their half of that fishery so will not get any further increase in TACC until it can be shown that their half share equals more than 4,500t (i.e. when the fishery is back at Bmsy).
If the noncommercial (recreational and customary maori) harvest is currently at about 2600t and our half share is 5,000t then we will have almost double the current fishery to accommodate our future requirements. We will not necessarily increase our rate of harvest at any greater rate than is current so the rate of rebuild is not affected. (There has been little done in the way of forecasting how our rate of harvest might increase when there are more fish in the water but we have to deal with that whether under the status quo in management or any other option) However we are still unlikely to be harvesting up to our entire share until a long way past 2020. I agree with the comments that operating the fishery above Bmsy does not increase the total yield but it does allow more fish to become another year older and therefore the fishery contains more fish that are bigger. This is one of the noncommercial objectives in the management of the fishery.
So a declared 50/50 stakeholding in this fishery, of up to 5,000t each, does fit within the known sustainable yield, does not require any TACC reduction (dependent on future stock assessment advice), does not require compensation, does not require a priority for either share and can meet the objectives of both sets of stakeholders.
Once again thanks to the group for providing this forum to debate the issues. I still believe that there is a long way to go in working out how to implement a defined Public Marine Fishing Right and that a structure and the resources required to protect, manage and enhance that Right are as important as the definition.
Peter Ellery |
