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Draft Integrated Management Strategy
for Fiordland’s Fisheries and Marine Environment.
option4
PO Box 37 951
Parnell
AUCKLAND
contact@option4.co.nz
1. INTRODUCTION
The Guardians of Fiordland have invited comment (views) on the
document “Beneath the Reflections” - Draft Integrated
Management Strategy for Fiordland’s Fisheries and Marine Environment.
The Guardians were kind enough to grant an extension of time to
present these views. That extension was until 31/1/03.
In hindsight, that timeframe has been insufficient for option4 to
adequately consult with its supporters. The far reaching and multi
faceted implications of many of the proposals contained within the
document really do demand more work to be done. However, the Guardians
are no doubt working towards (as yet unspecified) certain timeline
goals and are very likely working under time constraints of their
own. We would make the point that process timelines do need to be
more specific and detailed than otherwise contained within the document.
The unfortunate timing of presentation of the document for feedback/views
falling only 2 months before Christmas and then being extended only
one month after Christmas means that the public have, by and large,
had little chance to effectively engage. option4 strongly recommend
that additional time be offered for public input. Certainly, if
compliance is an expectation the Guardians must be aware of the
all important need for widespread public support and adherence to
whatever the outcomes are.
The Guardians have invested six years of hard work in producing
the “Draft Integrated Management Strategy for Fiordland’s
Fisheries and Marine Environment”. This far-reaching, quite
visionary document represents the views of the Guardians of Fiordland,
a group of people passionate about this region. There is much good
intention and good thinking to be gleaned from the many pages that
make up their analysis and proposals. However, whilst they have
toiled to do the best for their people and their region, so too
many of us have worked long and hard to more clearly define the
nature and extent of the rights of the public to gather seafood
to feed their families and friends. Many of the proposed management
initiatives need to be read in the context of this effort that the
Minister of Fisheries, Pete Hodgson, and his Ministry have been
so engaged with.
2. option4 ORGANISATION
Background
option4 was formed in the year 2000 by a concerned group of recreational
fishers, in response to MFish’s invitation to participate in
the process of redefining the nature and extent of the rights of
the public to fish and gather seafood in New Zealand.
MFish, in conjunction with the New Zealand Recreational Fishing
Council, compiled a discussion document called "Soundings".
This document suggested three options for the future management
of the public's rights and access to public fisheries.
In option4’s opinion, none of the three options presented were
acceptable for future management of New Zealand’s recreational
fisheries, nor were they capable of improving the lot of non-commercial
fishers. This was because all of the proposed options in the “Soundings”
document allowed for the continual erosion of the fishing public’s
individual rights.
option4.co.nz was developed to ensure that the fishing public, clubs,
and organisations, as well as individuals, could send a clear message
to the Government’s fisheries managers on precisely what is
required to ensure that the rights of current and future generations
of non-commercial fishers are protected.
Participants
Since its formation more than two years ago, option4 has gained
widespread support from the recreational fishing public, clubs and
organisations of New Zealand. In 2001 over 61,000 individual submissions
supporting the principles of option4 were made to the Minister on
the “Soundings” process. This represented an overwhelming
majority of 98.3% of total submissions received on the issue. Since
then, over 35,000 further individuals have made their support known
to option4. Through its nationwide network, and with on-going support
amongst recreational fishing clubs and organisations, option4 has
established that it has the support of the majority of the recreational
fishing public of New Zealand.
Principles of option4
option4 objective:
"To carry the four principles of option4 all the way through
the rights redefinition process and to have those principles enshrined
in legislation."
option4 principles:
- A priority right over commercial fishers for free access to
a reasonable daily bag-limit to be written into legislation.
- The ability to exclude commercial methods that deplete recreationally
important areas.
- The ability to devise plans to ensure future generations enjoy
the same or better quality of rights while preventing fish conserved
for recreational use being given to the commercial sector.
- No licensing of recreational fishers.
3. Recreational Sector Representative Groups Consensus.
On 8/12/03 the NZRFC, NZBGFC and option4 sent to the Minister of
fisheries a “letter of consensus”. We now quote directly
from that document: -
“This consensus has existed for some time and is now formalised
in this document.
- Principles developed during the Soundings process.
- Preference to non-commercial fishing as guaranteed by the cornerstone
statement in the 1989 Recreational Fishing Policy.
- Need for legislative reform to implement the principles and
preference statement and to ensure the public sector is adequately
resourced to be an effective contributor to fisheries management.
- Rejection of the capped proportional share concept.
- The requirement for improved information.
These key points are discussed in more detail below.
1. Principles developed during the Soundings process
The principles are: -
- A priority right over commercial fishers for free access to
a reasonable daily bag-limit to be written into legislation.
- The ability to exclude commercial methods that deplete recreationally
important areas.
- The ability to devise plans to ensure future generations enjoy
the same or better quality of rights while preventing fish conserved
for recreational use being given to the commercial sector.
- No licensing of recreational fishers.
These principles have been policy of the NZRFC for many years and
were reaffirmed at their AGM in July 2001.This endorsement took
place at the annual general meeting. Ministry of Fisheries staff
witnessed this process of arriving at consensus. NZBGFC have also
endorsed these principles, as have option4. We note to date that
only one of these principles has been adopted by Government with
your clear statement that there will be no licensing of recreational
fishers.
2. Cornerstone statement in the 1989 Recreational
Fishing Policy
The “cornerstone statement” in the 1989 Recreational Fishing
Policy, signed off by the senior Labour Party Minister, the Hon
Colin Moyle, states: -
“The cornerstone of the policy is presented in the first
national objective: to ensure recreational users have access to
a reasonable share of fishery resources. Government's position
is clear, where a species of fish is not sufficiently abundant
to support both commercial and non-commercial fishing, preference
will be given to non-commercial fishing. This position reflects
Government's resolve to ensure all New Zealanders can enjoy and
benefit from our fisheries.”
All three organisations are unanimous and consistent in their endorsement
of the 1989 Policy, and the Ministers forward in the form of his
formal letter of introduction and release and the cornerstone statement
contained in the 4th paragraph, now known as the “Moyle Promise”.
This very important policy document is still very much alive. It
has never been repealed by any subsequent Government, or the Ministry.
It was however ignored by the National Government and the Ministry
during the 1990s.
To the recreational sector, the 1989 Policy is the equivalent of
the Treaty of Waitangi to Maori. For many years, neither recreational/sustenance
nor the Maori sectors were recognised by the Ministry. The recreational
sector will not rest until the statement confirming preference to
non-commercial fishing (as stated by the Minister in the 1989 Policy)
is recognised by Government.
3. Need for Legislative reform
All three organisations have agreed on the need for legislative
reform and for the defining of the public’s right in the legislation.
We are open to further discussion on how this can be achieved but
before firming views and policies we have awaited the occasional
papers and legal documents that were promised in the paper “Recreational
Fishing Reform: Action Plan 2002-03” released by the Ministry
in January 2002. In that paper it was stated:
“Phase one: February - July 2002
Occasional Papers and Seminars
The consultation processes to date have identified some issues
of concern to stakeholders and the Cabinet has outlined some constraints
and objectives of future policy development. In order to address
these issues and concerns MFish will commission papers on the
issues of most concern. Where demand exists, seminars can be held
discussing the papers with stakeholders. MFish can provide experts
to speak where this is beneficial. These meetings will consist
of a presentation followed by discussion and consideration of
different viewpoints on the issue at hand.
Suggested topics include:
The Treaty of Waitangi and the Fisheries Settlement Act and
their implications for fisheries management
International obligations, common law rights and related issues
Property rights and their application to natural resource management
including the QMS and the management of commercial fisheries under
the Fisheries Act.
Environmental objectives of government including the Fisheries
Act and the Marine Reserves Act
Given that there are stakeholders around the country and participation
can be expensive, seminars will be held in the regions and only
where a demand is demonstrated. Seminars can be tailored to the
concerns of different regions and scheduled in consultation with
stakeholders.
The objectives of this phase are to foster a broad understanding
of how options might meet the objectives and constraints that
cabinet has set for the development of options for reform. It
will also serve to make information available on the broader policy
environment. MFish encourages people to take advantage of experts
and papers that we provide and to this end MFish will publish
the papers on it's website.
MFish will be happy to consider proposals for incorporation into
the policy development process from stakeholders at any time during
this phase (prior to the formal input in the consultation phase).
Options will need to address the objectives that government has
identified and to be achievable within the constraints that have
been set.”
Given that it is now December we wonder where these papers and seminars
are. To our knowledge none have been issued nor any seminars held.
We ask, why have the Ministry not yet delivered these documents
and when will they? Is it now the intention of you as Minister and
your Ministry to just present the sector with a fait accompli for
consultation on the Governments preferred option?
4. Rejection of the proportional share concept
The recreational sector has, and always will, totally and unanimously
reject a capped proportional share concept because of the Moyle
Promise referred to above. We accept that management of fisheries
will continue under the QMS but this needs to reflect the public
right of access and priority.
We reject capped proportionalism because the fish in the sea are
a public resource, and the public right to be able to expect to
catch a reasonable number of fish on a fishing trip must come before
commercial interests within the requirements of a sustainable fishery.
The surplus should be available to the commercial sector once they
have paid the Crown for the access right to generate revenue from
a public resource. We reject any agenda to cap the recreational
catch in order to preserve some “ fixed/defined proportion”
of the TAC for commercial concerns. As the High Court stated in
the judgement on SNA 1 (CA82/97) “If over time a greater recreational
demand arises it would be strange if the Minister was precluded
by some proportional rule from giving some extra allowance to cover
it, subject always to his obligation carefully to weigh all the
competing demands on the TAC before deciding how much should be
allocated to each interest group.”
5. Improved Information
It is agreed that a fundamental element of sustainable fisheries
management is to ensure that management decisions are based on accurate
estimates of all sector’s catches. The disparity between recent
estimates of recreational harvest and the historical recreational
harvest estimates that have been used for fisheries management decision
making to date, clearly indicate the need for more resources to
be deployed to prevent errors of such magnitude occurring in the
future. It is also agreed that better information regards “all
other forms of fishing related mortality” by all sectors need
to be developed.
Management
Until the rights of the public are clearly defined the public role
in the management of New Zealand’s fisheries cannot be determined.
If we are to become involved in management, surely we have to define
what it is we will be managing.
We accept that the recreational sector needs to play its part in
managing stocks to sustainable levels and suggest there is already
adequate evidence to that effect. The recreational MLS and reductions
in bag limits in the past are examples of our resolve to support
sustainability. At the same time the playing field has to be levelled
and the public sector representative organisations need to be assured
that adequate resourcing is available for the level of management
responsibility that comes out of the rights definition process…
ends.
4. Recreational Fishing Rights Reform/Definition
Process.
On December 16th 2002, representatives from the various Recreational
Fishing Representative Groups met with the Minister and his official
from the Ministry of Fisheries.
The Minister writes (21/1/03) ….. “It was good to meet
with you and the others on Monday night to talk through some of
the reform issues. I hope it provides a useful platform for further
work on the recreational fishing reform, which, as I indicated at
the meeting, is important to improve the fisheries management framework
in New Zealand.
I believe it is good news that the sector is now speaking with
one voice on reform issues. This means we can now focus on the issues
and a constructive process to identify what is achievable and what
is not.”
On January 29th 2003, those same representatives met with Ministry
officials to work on developing a process that can achieve public
fishing rights reform/definition. At that meeting, it was made very
clear that defining the rights of the public to fish their fisheries
was of primary importance. Changes to regulations in the interim
were also discussed at length and the public sector representatives
were very clear; any changes to regulations whilst right reform/definition
process was underway would only serve to distract and undermine
the considerable effort already invested and planned to be invested
in order to achieve this reform/definition outcome.
5. option4 Concerns with the Guardians Proposals.
All or Nothing Approach
The Guardians are quite clear in the “Implementing the Strategy”
section (7.1) that “the negotiated package of measures contained
in the strategy be implemented as a whole without compromising underlying
principles and balances”. The Guardians then go on to say “should
it be compromised the integrity of the strategy will be compromised”.
These are strong words – almost non-negotiable words. Where
one sector (we, the public) is giving so much and other sectors
so little, this is not a good place to go in a consultation process,
never mind negotiation.
5.1 Guardians Objectives
5.1.1 “Take a pro-active role
in identifying and advocating research and information needs…”
We note the lack of comprehensive historical catch and catch effort
data (as available already) contained within the document
5.1.2 “Ensure that the rights
of tangata whenua, recreational, charter operators, commercial and
other user groups are identified and recognised and that these groups
are involved in fisheries management decisions including access
to the fisheries resource – (page 3)
Nowhere in the document is there reference to the fact that the
public (including Maori who are fishing without the benefit of a
customary fishing permit) are currently fully engaged with the Minister
and his Ministry in work designed to define (identified) the nature
and extent of the publics right to fish. This is of serious concern.
The objective also states that “Ensure that ….. these
groups are identified..”
Nowhere in the document are the public sector representative groups
identified. This is of concern. Please reference to section 5.5
of this submission. - Representation of the Recreational Fishing
Sector on the Guardians.
The objective also states “Ensure that ….. these groups
are involved…”.
It cannot be said that the public sector has been involved (adequately)
at this stage.
5.1.3 “Prevent uncontrolled
expansion of effort/harvest by all groups”
All groups currently exercise their rights with varying degrees
of control and mechanisms to achieve that control. There is no uncontrolled
harvesting.
5.1.4 “Adopt a cautious and
responsible approach to proposals…”
The fisheries regulation proposals tabled, are, in the opinion of
option4, beyond cautious as they pertain to the public sector’s
rights to fish for food.
5.2 Developing the Draft Strategy
5.2.1 Gathering information
Despite emphasis of the Guardians intent to gather information,
the Draft Strategy document makes no reference to the relative harvest
of each fishery by each sector. Lets be clear, if sustainability
is at stake, the public will share the load of addressing that issue.
Before that is contemplated however, the causes and extent of the
threats to sustainability must be clearly documented. It is ludicrous
to expect the public to buy in to wide ranging cuts to their rights
to feed their families on the basis of fears that the public might
be a threat to sustainability at some unspecified point in time
in the future, unaccompanied by any tabulated summary of extractions,
historic catches or tonnages. Lets be told what % of each fishery
we are, have been and are likely to be before any changes to our
existing rights are tabled. Before the public can contemplate any
cuts we expect information every bit as detailed and objective as
would be required by the fishing industry to justify cuts to their
quotas.
The document does not deliver in terms of historical catch and
effort data. Whilst other publications might contain additional
data, the document itself does not satisfy the needs of those being
invited to submit their views. Until comprehensive data (as available
already in various forms) is made readily available, this document
fails in this respect. The document details much in terms of information
gathering method employed, sources tapped and process used and then
fails to tabulate the most basic information one might expect.
We are particularly concerned that proposed regulation changes
that are so detrimental to the public’s rights to harvest fish
for food are based on anecdotal reports from a few individuals.
The proposed changes appear to be trying to predict and manage future
fishing scenarios that may not even occur and in doing so are eroding
our rights to harvest fish for food now, clearly unnecessarily.
This element of the submission will be covered more comprehensively
when and if the need for more information is acknowledged by the
Guardians and they choose to engage/explore additional data requirements.
Time constraints prevent further elaboration in this submission
of this most fundamental view/criticism.
5.2.2 Defining “special nature”
The passion of the Guardians is to be acknowledged and applauded.
They are privileged to enjoy a remarkably unspoilt environment.
However, every one of us, in the big picture, share to varying degrees
the privilege of occupying and enjoying the very “special nature”
of New Zealand itself and the marine environment surrounding us.
Perhaps it is time we all took a leaf out of the Guardians book
and focused on the “special nature” of our own regions,
throughout New Zealand. Thankyou Guardians for a very well presented
outline of your region. The document, as it describes Fiordland
and many of its features, would make a first class text for all
schools. There is much value in “Beneath the Reflections”.
5.3 The draft Integrated Management Strategy:
Fisheries
5.3.1 Accumulation
Here we get an insight into the Guardians. Quick to point out that
they see accumulation of daily bag limits as merely a “defence
mechanism” contained within the Fisheries regulations as opposed
to an existing right that we, the public, hold very dear and, by
and large, treat with respect and care.
5.3.2 Why is accumulation detrimental? (3.6.4)
– they ask.
The document states “The present accumulation regime encourages
excessive harvesting of some species….” NO. The present
accumulation right allows members of the public to accumulate fish
from one day to the next, up to, but not exceeding those fish that
they harvest on any one given day. The use of the words “encourages
excessive harvesting” is totally inappropriate and out of place
in a document that purports to reflect the truth of the public’s
right to fish for food.
The right to accumulate daily seafood bag limits makes voyaging
into places like Fiordland a worthwhile exercise for many New Zealanders
who wish to see their families enjoy food from the sea. Is this
practise, this cultural and social fabric of New Zealand, causing
sustainability issues? If so, to what extent? The Guardians fail
to offer any specifics at this juncture. The arguments put forward
by the Guardians are centered entirely on assumption i.e. what we
could do in theory in terms of maximum harvesting. The reality/practise
however is quite different. Weather, fisher ability, freezer capacity,
individual needs/attitudes and practises are all variables that
combine to see fishers return to their homes with far less fish
than what the Guardians would have us believe.
There is no mention of any of the very positive aspects of the
right that allows us to accumulate what we catch from one day to
the next i.e. the ability to feed our families or give a friend
a feed of fish as a result of making the effort to harvest those
fish. The incredible joy and satisfaction derived from harvesting,
in a sustainable manner, seafood that is essentially off the menu
for most New Zealanders who now find themselves competing with world
markets for our crayfish, paua and hapuka. There is no argument;
nothing comes cheaply from the sea. The sheer distance and time
required to fish the abundant waters of Fiordland would make it
seemingly the last region in New Zealand where accumulation would
be so blatantly attacked. Lets be frank. The fishing industry desperately
want to see the public of New Zealand capped in terms of how many
fish they are allowed to eat. The less we catch and eat, the more
there will be available to industry to export as and when our precious
inshore shared fisheries make recovery from the boom and bust commercial
fishing practises of the past. Just when some sanity appears to
be returning to the management of our commercial fisheries, the
boot goes in to the public’s right to fish for food for their
families and friends.
The Guardians then go on to describe, in detail, a particular charter
party’s behaviour. This is not balanced writing. There are
no references to the excesses of the fishing industry anywhere in
the document. No, lets just get stuck into the public again and
paint them in the worst possible light.
There is no mention of the widespread practise of commercial fishermen
giving fish to whomever they choose whenever they choose.
This proposal has the potential to eliminate overnight fishing
for food voyages into Fiordland. We believe it is totally unreasonable
to eliminate accumulation throughout Fiordland.
In summary, a particularly unbalanced and disappointing segment
of the Guardians Strategy document.
5.3.2 Bag Limits
Bag limit changes outside the habitat line have little to justify
any change to current take. Small regional population, remoteness
and prevailing weather all offer natural barriers to excessive catch.
Once again there is no science and in this case even anecdotal evidence
that further restrictive recreational fishing measures are necessary.
It is unacceptable that no reduction in the commercial take is deemed
while the recreational take is severely slashed, particularly for
multi day trips. Will the result just be better fishing for commercial
operators, an increased commercial CPUE therefore an increase in
proportion of quota caught in Fiordland? A reduction to recreational
take outside the habitat lines is an unfair and unnecessary expectation
for the public fisher to bear.
The split bag limits suggested by the guardians do not meet the
criteria in Appendix 4 MFish compliance objectives and strategies
that include:
- Understanding and accepting the rules as fair and necessary.
- Believe that rules are being administered fairly and equitably.
- There is a reasonable chance of any cheating being detected.
- There is a high probability of being successfully prosecuted
or penalized.
The Guardians objectives state that they're trying to encourage
a shift in harvesting pressure from inside the fiords to the entrances
and outer coast.
option4 believes the document as written encourages people not to
fish in Fiordland at all. The restriction on bag limits and non-accumulation
discourages all fishing.
5.4 Process Equity
Our individual rights to harvest fish for food within the limits
of sustainability are no less important than the fishing industries
rights granted under the QMS to harvest fish to sell. Therefore
we ask for the same decision making standards and process as demanded
by and granted to the fishing industry before any changes to TAC’s
or TACC’s are contemplated.
- Robust scientific evidence of all factors pertaining to the
proposal
- Full consultation with all affected users
- Involvement in the decision making process
All of the documents thus far have failed to deliver the necessary
quality of information, consultation and involvement necessary for
us to agree with the proposals made.
We need robust scientific projections that support the claims made
in the documents produced to date that current or future levels
of public fishing for food will affect sustainability.
5.5 Representation of the Recreational Fishing
Sector on the Guardians
There are three people who are labelled “Recreational Fishing”
in the Guardians group. We have not heard from them. They are not
appointed by NZRFC or NZBGFC. Whilst they are free to describe themselves
however they like, it cannot be said that they are representative
of the public who fish for food if they have not adequately briefed
and consulted with the organisations that are so obviously set up
to do just that.
The NZRFC have been very visible for a very long time. The NZBGFC
have solid club affiliations throughout the South Island. option4
have made no secret of their commitment and availability to helping
to resolve the public “right to fish for food for family and
friends” debate.
These organisations are not represented on the Guardians group.
Nor can it be said that these organisations have been “involved”
to date.
It cannot be said that “recreational fishers” have agreed
to the proposed management measures as is claimed in section 3.7
– sadly, merely wishful thinking. Agreement to measures such
as these will require far more meaningful consultation, completeness
of information presented and respect for existing rights to be seriously
considered
5.5.1 Consultation
The document itself is unique in that it is much more than a fisheries
plan complete coastal management strategy for the region likes of
which have not been introduced elsewhere in NZ. As with all new
innovations being tested, caution should apply on implementation
for unexpected and/or adverse results may occur that were not the
intention of the Guardians or more importantly the very people who
use Fiordland and coastal area the most, the locals.
In developing the draft document there has been a lack of wide
consultation among the public.
In discussion with many fisherman, they have never heard of GOFF
or the document under discussion.
The meeting at the Working Men's Club in Invercargill was not widely
advertised. The SSFC had to make contact with GOFF and ask to attend.
The SSFC was not invited to the launch of the draft document, which
is unusual as it’s the Southern most sport fishing club with
Fiordland as its home waters. This typifies the lack of consultation
that has taken place.
The process initiated by the Guardians to date does, in our opinion,
represent “consultation
The section of the Strategy entitled “Implementing the Strategy”
has as its Key Objective
“The negotiated package of measures contained in the strategy
be implemented as a whole without compromising underlying principles
and balances.”
It is interesting to consider this approach with what the Wellington
Airport case says consultation should be.
An often-referenced New Zealand definition on effective consultation
was contained in the Court of Appeal decision arising from the case
between International Airport Ltd and Air New Zealand (CA 23/92,
73/92[1993] 1 NZLR 671). The relevant section of the decision is
as follows:
‘Consultation must allow sufficient time, and a genuine effort
must be made. It is a reality not a charade. To consult is not merely
to tell or present. Nor, at the other extreme is it to agree. Consultation
does not necessarily involve negotiation towards an agreement, although
the latter not uncommonly can follow, as the tendency in consultation
is to seek at least consensus. Consultation is an intermediate situation
involving meaningful discussion. Despite its somewhat impromptu
nature I cannot improve on the attempt at description, which I made
in West Coast United Council v Prebble at p. 405:
‘Consulting involves the statement of a proposal not yet fully
decided upon, listening to what others have to say, considering
their responses and then deciding what will be done.’
Implicit in the concept is a requirement that the party consulted
will be (or will be made) adequately informed so as to be able to
make intelligent and useful responses. It is also implicit that
the party obliged to consult, while quite entitled to have working
plan in mind, must keep its mind open and be ready to change and
even start afresh. Beyond that, there are no universal requirements
as to form. Any matter of oral or written interchange which allows
adequate expression and consideration of views will suffice. Nor
is there any universal requirement as to duration. In some situations
adequate consultation could take place in one telephone call. In
other contexts it might require years of formal meetings. Generalities
are not helpful.’
6. CONCLUDING STATEMENT
option4 thanks the Guardians for the opportunity to make these
submissions, and looks forward to your reply. We have taken on this
task in the full knowledge that the public are, to a large extent,
oblivious to what you are proposing. The limited response from the
public can be sheeted home to the limited efforts made by the Guardians
to ensure the public are informed.
Obviously there is still much work to do.
- Identifying any specific threats to sustainability is urgent
and immediate.
- Acknowledgement of the public’s right to fish for food
and the process to further define that right that has been going
on for four years is basic “good faith” and essential.
- Establishing information requirements beyond the information
offered in the Draft is very important.
- Working on the specifics of likely future scenarios, rather
than trying to deal with non-specific future scenarios will likely
allow for proposal that have a chance of broad public acceptance
and adoption. option4 would not expect any recommendations to
change any regulations until the concerns outlined in this document
are addressed.
We would like to be included in any future correspondence and meeting
notification.
We firmly believe that the Guardians have a responsibility to the
people of New Zealand. To that end we would strongly recommend that
you hold at least one meeting in both Wellington and Auckland to
outline the basis for any recommendations that come about as a result
of work done to date.
Yours faithfully
Scott Macindoe
“Beneath the Reflections” response coordinator
on behalf of the team and supporters of option4
option4.co.nz
PO Box 37 951
Parnell
AUCKLAND
contact@option4.co.nz
Acknowledgments: - Southern Sports Fishing Club, NZBGFC, NZRFC
and the many, many option4 supporters who have contributed to this
submission.
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