Flatfish 1

Flatfish 1 (FLA1) Flounder

option4 Submission

10 August 2005

		(PDF 180Kb)

Flounder 1 (FLA1) West & East Coast North Island fishery

1. Introduction

The Ministry of Fisheries (MFish) has advised that they are reviewing catch limits for Flatfish (FLA1) in response to expressions of concern from coastal communities about sustainability and local depletion of stocks in various harbours on the west coast of the North Island.

An Initial Position Paper (IPP) was issued to stakeholders on 30 June 2005. MFish has invited stakeholders to provide comments on the consultation document.

Original deadline for comments was 29th July 2005. MFish then extended the deadline to 10th August.  

This document comprises the submission from option4 an NGO which promotes the interests of non-commercial marine fishers in New Zealand.

2. Ministry of Fisheries Proposals

The following management measures are proposed by the Ministry of Fisheries for the FLA 1 fishery for the 2005 - 06 fishing year:

EITHER

Option 1

Set a TAC of 1 382 tonnes for FLA 1 and within that TAC set:

• a customary allowance of 270 tonnes;
• a recreational allowance of 270 tonnes;
• an allowance of 27 tonnes for other sources of fishing-related mortality; and a TACC of 815 tonnes.

OR

Option 2

Set a TAC of 1 307 tonnes for FLA 1 and within that TAC set:

• a customary allowance of 270 tonnes;
• a recreational allowance of 270 tonnes;
• an allowance of 27 tonnes for other sources of fishing-related mortality; and a TACC of 740 tonnes.

The current TACC is 1187 tonnes. A TAC and other allowances have not yet been set for FLA 1.   Both options propose to base the TAC, TACC, and allowances on recent catches.

The proposed TAC, TACC, and allowances are set out in Table 1.

Table 1: The proposed TAC (tonnes), TACC (tonnes) and allowances (tonnes) for FLA 1 for the 2005-06 fishing year

3. option4 Submission

3.1 Proportional Allocation Decisions

The attached paper on Proportional Allocation of Fisheries Resources in NZ (Appendix One) is a major part of this submission and must be read in conjunction with it. We ask that the issues raised in the Proportional Allocation of Fisheries document along with the fishery specific issues raised in this document be addressed by the Ministry in the Final Advice Paper on which the Minister bases his decision.

3.2 Consultation

The timeframe allowed for consultation by the Ministry of Fisheries is unworkable for many non-commercial stakeholders with an interest in the fisheries being reviewed this year. The time between delivery of the IPP and submission deadline is too short for adequate consultation with the diverse range of non-commercial fishing interests who could be affected by this years proposals. option4 comments on the consultation process are included in this submission as Appendix Two .

3.3 Flatfish (FLA1)

Flounder are an easily accessible species important for the social and cultural wellbeing of many local communities. The west coast flounder stock in particular has been allowed to become depleted through excessive Total Allowable Commercial Catch (TACC) being allocated since the introduction of the QMS.

We are concerned that neither of the two proposed options may fully address community concerns about access to and sustainability of the fishery. Option two is the only option that borders on being credible because it may actually constrain commercial catch in some years. Option one is unlikely to constrain commercial catches at all.

option4 notes that initial FLA1 quotas were set at a high level based on 1983 catch levels. This was the highest catch on record. MFish now considers the existing TACC appears to be artificially high given that it has never been caught. They also note that inter-annual abundance is not as variable as previously thought. Both of these factors indicate the TACC has always been set too high.

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3.4 Commercial Catch

As the TACC has never constrained commercial catch in this fishery it has always been fished intensely. This intensive fishing effort has caused serious conflict between commercial and non-commercial fishing interests.

We note a declining trend is evident in major fisheries like the Kaipara Harbour. Catch rates peaked in the 1990's and have subsequently declined. This is indicative of "localised" depletion within the harbour according to MFish. We stress "localised" as this is the biggest harbour in the Southern Hemisphere and in our opinion should be a separate QMA.

The ability of commercial fishers to deplete a harbour as large as the Kaipara to the detriment of local communities shows the absurdity of the size of the Quota Management Area (QMA) for FLA1. This fishery extends from Taranaki, around North Cape and down to Cape Runaway on the East Coast.

The combination of excess quota and massive size of the QMA has led to the development of a mobile fleet of set netters capable of depleting entire harbours until they become uneconomic to fish. Just as the fishery starts to recover the mobile commercial fleet returns and repeats the depletion. This behaviour has been to the detriment of local non-commercial interests (and sometimes local commercial set netters) and is a major cause of conflict.

We are disappointed that none of the proposals deal with the main issues in this fishery. While reducing quotas to ACTUAL current catch levels will possibly prevent the conflict from escalating, the current level of conflict will likely continue. Those who have been fighting for years to have sensible management of these fisheries will yet again feel the Ministry has failed to deal with the real issues. The QMS has failed to deliver fisheries management for flounder that meets the social and cultural expectations of many coastal communities.

3.5 Initial Allocations

Commercial fishing interests have had priority in this fishery since the introduction of the QMS. The excessive quotas issued have allowed commercial fishing interests to determine the biomass available to non-commercial fishers through the Ministry of Fisheries failing to constrain commercial catch.

The commercial sector has been able to fish vast areas within FLA1 until the area is no longer economically viable before moving to the next area. Because flounder are a fast growing species this behaviour has been repeated annually and has caused serious conflict between commercial fishers and communities, which has been well documented.

As the Minister will be setting initial allocations for non-commercial fishers in FLA1 we ask that the points raised in proportional document (Appendix One) and the fishery specific points above be drawn to the Minister's attention in the FAP.

3.6 Maori Fishing Interests

Flounder and mullet are considered a taonga, a treasure. Both species are also important food sources for local communities in many harbour and estuarine areas. Historically, both of these species were readily available, easily caught and accessible. Sadly, with the depletion of the flounder and mullet stocks this is no longer the case. Maori can no longer meet their social and cultural needs.  

At the recent hui at Whakamaharatanga Marae, Hokianga, (which MFish officials attended) Maori leaders were put in the embarrassing position of having to apologise for the small size of the flounder they had caught locally and provided to the manuhiri (visitors) for dinner.

Sonny Tau, Chairman of Te Runanga A Iwi O Ngapuhi, recently made the following comment, " We treasure flounder and mullet as an integral part of our ability to manaaki our manuhiri".

Ngapuhi's Professor Manuka Henare summarises manaakitanga in this way: "manaaki tanga relates to the finer qualities of people, rather than just to their material possessions.   It is the principle of the quality of caring, kindness, hospitality and showing respect for others. To exhibit manaakitanga is to raise ones mana (manaaki) through generosity." Maori customary fishing must be allowed for, manaaki manuhiri is paramount.

Sonny added "Prior to the signing of the Sealords deal when Maori went fishing to feed their babies they were fishing customarily. Since the 1992 settlement 99% of the time Maori now go fishing to feed their babies, they are categorised as recreational fishers."

Over the past few months two hui have been held with Ngapuhi, other northern iwi and recreational non-commercial fishing interests. The outcome of both hui was very clear; there are insufficient fish in the water, including mullet and flounder, to meet the needs or aspirations of Maori, whether they are fishing to feed their family (currently categorised as recreational fishing) or for customary purposes. The flounder and mullet fisheries must be rebuilt so that the reasonable needs of tangata whenua can be met.

Both hui unanimously agreed that achieving "more fish in the water" is the only way to resolve their concerns. The agreement reached at Whakamaharatanga Marae in Hokianga was formalised into one document (Appendix Three) and will the basis of future discussions between non-commercial fishing interests and the Ministry of Fisheries.

Ongoing mismanagement of our inshore shared fisheries has come at a high social, cultural and economic cost for Maori. Tangata whenua do not want to continue to bear the brunt of MFish's inability to manage inshore fisheries.

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4. option4 Conclusion for Flounder

We are concerned that neither option put forward in the Initial Position Paper (IPP) is capable of addressing community concerns regarding access to, or the sustainability of, the flounder fishery.

As the Minister is required to "allow for" non-commercial interests we recommend option two as a minimum first step. This is because option two is more likely to reduce the risk of further escalating the conflict in communities that have borne the brunt of the poor management of the flounder fishery to date.

Other solutions are obvious and necessary to actually address the real issues. We ask that these be considered in addition to option two:

• This QMA is far too large for effective management of the flounder fishery on a local scale. The QMA needs to be subdivided and sustainable quotas allocated to contentious areas so that these fisheries can rebuild and non-commercial fishing can be properly allowed for.
• Flounder are a fast growing species and set netting is the main commercial method used in harbours. An increase in the minimum set net mesh size for commercial fishers only would increase the biomass, and availability of flounder to non-commercial fishers fairly quickly. It would also increase commercial yield per recruit in the fishery. The capture and mortality of small flounder would be also be reduced at higher mesh sizes. A further benefit would be a significant reduction in the mortality of other juvenile fish found in harbours. The wasteful catch of undersized snapper, trevally, small dogfish and gurnard would decline markedly.
• Set netting can be an extremely wasteful method when nets are left to soak for extended periods of time in areas where sea lice are present. The current maximum soak times are far too long at 18 hours. If actual soak times prevalent in the fishery now can be reduced, then wastage to scavenging will be reduced and productivity increased.

4.1 In addition to the above option4 submits that the Minister:

1. Reduces the TACC to significantly less than 740 tonnes to allow this fishery to rebuild.
2. Sets in place a mechanism where FLA1 can be subdivided into smaller QMA's so that community concerns can be addressed.
3. Sets in place a mechanism to review the minimum mesh sizes in the FLA1 fishery.
4. Sets in place a process to review soak times to reduce unnecessary wastage.
5. Makes no changes to non-commercial bag limits, size limits or gear restrictions.
6. Sets the non-commercial allowances at a level sufficient to cover current or expected non-commercial catch.
7. Notes that non-commercial access has been adversely affected by lack of constraint on commercial catch and that the allowance is not a fixed proportional division of the FLA1 fishery.
8. Notes that recreational catch estimates and allowances are uncertain and will be subject to review when better catch information is available.