| Kahawai
Submission Extension Request
NZRFC
February
2004
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N Z RECREATIONAL FISHING
COUNCIL |
PO BOX 26-064
NEWLANDS
WELLINGTON
64 4 972 5041
64 4 972 5048
rfcmax@xtra.co.nz |
PHONE
FAX
EMAIL |
23 February
2004
Ministry of Fisheries
P.O. Box 1020
Wellington
Attention Mike Arbuckle
Re: Introduction of kahawai to the QMS
Dear Sir
The New Zealand Recreational Fishing Council is committed to providing
- a submission to the single option provided on the future management
of kahawai
- an alternative option for the management of these most important
non commercial inshore shared fisheries.
The letter accompanying the IPP for kahawai dated 12th January 2004
stated “You are requested to submit written comments by
27 February at the latest". We will not be able
to deliver our Submission and alternative management option by the
27th February. The NZRFC are committed to providing the submission
and a viable management option by 16th April 2004, at the earliest.
Meaningful Input
The Ministry has acknowledged the insufficient capacity of the non-
commercial sector to participate in fisheries management for many
years. The MFish Implementing the National Objectives for Marine
Recreational Fishing (14 Oct) document states, “Effective
participation and advocacy on behalf of recreational fishers requires
time, funding, and other resources such as independent research.
This is probably beyond the means of virtually all the groups at
present”. As recently as 12th March 2003 during a meeting
of non- commercial fishers and Ministry staff a Point of Agreement
was reached that “amateur fishers needed resources to
be better represented in fishery management processes”.
Despite this continual acknowledgement we now find ourselves in
a position where Ministry are insisting we present our submission
on the IPP for kahawai and 18 other species by 27th February 2004,
if it is to be considered.
The NZRFC consider the submission deadline to be unfair and unrealistic.
The 400+ member clubs that make up the NZRFC only meet once per
month, and most do not meet in the month of January due to the holiday
period, therefore it is impossible for us to consult with our members
and meet the deadlines requested by MFish. For a species of national
significance such as kahawai, we require more time to advise the
public, our members and consult with those same people. The cultural,
social and economic implications of the introduction of kahawai
into the QMS demands the Ministry should allow us more time. The
suggested submission deadline also places unrealistic demands on
our volunteer representatives to contribute at a meaningful level.
Potential Risks
Many previous fisheries management decisions have been made without
meaningful contributions from the non- commercial sector. Some of
these decisions have resulted in injustices being wrought on the
public. The NZRFC will not stand by and witness more injustice occur.
As representatives we consider we have a right and a duty to inform
you of the inadequacy of this process and the timeframe. It is not
beyond our capacity to challenge the Ministry, in public, if you
insist on continuing to force these changes without allowing reasonable
timeframes in which we can operate. We would also advise you the
New Initiatives 2002/06 document Sector Engagement in Fisheries
Management states, “ A lack of ability by stakeholders
to participate, take on responsibilities, and work toward consensus,
has significant repercussions including…without an increased
understanding and acceptance of the operation of the regime there
are increased risks of resource wasting argument and potential legal
challenge”. In order to facilitate a better outcome an
extension of the submission deadline to 16th April would be more
just and reasonable.
Last year, we participated in a very similar process for the introduction
of kingfish to the QMS. The Ministry released the IPP to us on 14th
May 2003, allowing us only 30 days to work through our process to
deliver our submission. This proved to be inadequate. The executive
of NZRFC are clear that we and our constituent organisations must
follow “good process”. This insists on reasonable time.
We believe meetings between MFish staff and non commercial fishers
to discuss their kahawai recommendation would be useful. Hopefully
the necessary people will be available by mid March.
We note that the study, “Characterisation of the Kahawai
Fishery” is due for delivery on 1/3/04. We understand
that the contractor (NIWA) may be a little late in delivering this
report.
The NZRFC submission delivery deadline should allow more than enough
time for the Ministry to prepare the Final Advice for the Minister.
We note the timetable for kingfish submissions allowed input up
to and including 17th June 2003. Our process gives the Ministry
an extra two months to advise the Minister on kahawai, compared
to last years process for kingfish.
We look forward to receiving your approval for us to submit by 16th
April 2004 for kahawai. Would you please acknowledge receipt of
this letter and your acceptance of the timeline we are working to
within five working days, as time is of the essence and we need
to commit our resources to achieving the best possible outcome for
non-commercial fishers.
Yours faithfully
Ross Gildon
President NZRFC
c.c. To Minister of Fisheries
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