Grey Mullet 1

Grey Mullet 1 (GMU1)

option4 Submission

10 August 2005

		(PDF 220Kb)

Mullet 1 (GMU1) West & East Coast North Island fishery

1. Introduction

The Ministry of Fisheries (MFish) has advised they are reviewing catch limits for Grey Mullet (GMU1) after concerns were raised about the sustainability of current catches and possible local depletion of various harbour stocks.

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

Table 1: The proposed TACs (tonnes), TACCs (tonnes), and allowances (tonnes) for GMU 1 under each option 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 Grey Mullet (GMU1)

Mullet are an easily accessible species important for the social and cultural well being of many local communities. The mullet stock has been allowed to become depleted through excessive Total Allowable Commercial Catches (TACC) being allocated since the introduction of the QMS.

Quote from IPP para 149 "However, the grey mullet fishery was intensively fished in the early to mid 1980s. The commercial catch limit introduced in 1986 (as adjusted over time by quota appeals, and the reduction in 1998 - 99) has not constrained the commercial use of the fishery to what is considered a sustainable catch level ."

On the other hand non-commercial fishers have been under-allocated in this fishery.

Quote from IPP para 58 " MFish considers that the recreational harvest of the GMU1 stock is more likely to be in the order of 150 tonnes than 100 tonnes, as provided by the existing allowance."

Further, MFish considers it prudent to reassess the recreational allowance in future years, when better information on the nature and extent of recreational harvest of grey mullet is available.

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 and maintaining low stock levels in those harbours. This behaviour has been to the detriment of local communities, non-commercial fishing interests (and sometimes local commercial set netters) and is a major cause of conflict.

3.4 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.

The current allowance for recreational fishing is based on an underestimate of actual catch in a depleted fishery.

As the Minister will be reviewing allowances for non-commercial fishers in GMU1 we ask that the points raised in proportional document attached and the fishery specific points above be drawn to the Minister's attention in the FAP.

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3.5 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.  

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 manaa-kitanga 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 and will the basis of future discussions between non-commercial fishing interests and the Ministry of Fisheries. (Appendix Three)

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.

option4 Conclusion for Mullet

We are concerned that the mullet IPP contains seriously flawed advice on supposedly proportional cuts that could see non-commercial fishers allowances set or confirmed on the basis of known underestimates of catch in a depleted fishery. It is proposed under some options to reduce non-commercial catch further to fit within the proportional options after constraining them to the known under allowance. Recreational catch allowances could be reduced by half or more if this advice is given any credibility. On the other hand the actual commercial catch will be cut by a much lesser proportion than it's purported "proportion" because of the excessive quota commercial interests have been given.

As the Minister is required to "allow for non-commercial interests" option4 recommends option 3C as a minimum first step.

Other solutions are obvious and necessary to actually address the real issues. We ask that these be considered in addition to option 3C:

• This QMA is far too large for effective management of the mullet 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 so that non-commercial fishing can be properly allowed for.
• Set netting and ring netting is the main commercial methods used in harbours for mullet. An increase in the minimum set and ring net mesh size for commercial fishers only would increase the biomass, and availability of mullet to non-commercial fishers. It would also increase commercial yield per recruit in the fishery. The capture and mortality of small mullet 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 can be reduced, then wastage to scavenging will be reduced and productivity increased. Shorter soak times should apply to all set netting by all sectors.

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

1. Set the TACC at 655 tonnes.
2. Allow 150 tonnes for recreational fishing interests.
3. The Minister notes that recreational catch estimates and allowances are uncertain and will be subject to revision when better catch information is available.
4. The Minister notes that non-commercial access has been adversely affected by lack of constraint on commercial catch and therefore the allowance is not a fixed proportional division of the GMU1 fishery .
5. Allows 150 tonnes for Maori customary non-commercial fishing interests.
6. Sets in place a mechanism where GMU1 can be subdivided into smaller QMA's so that community concerns can be addressed.
7. Sets in place a mechanism to review the minimum mesh sizes in the GMU1 fishery.
8. Sets in place a process to review soak times to reduce unnecessary wastage.
9. Makes no changes to non-commercial bag limits, size limits or gear restrictions in GMU1.
10. Sets the non-commercial allowances at a level sufficient to cover current or expected non-commercial catch.