| Submission on SNA8, FLA1 and GMU1 Proposals
By Muriwai Sports Fishing Club
10 August 2005
Introduction
Muriwai Sport Fishing Club Inc was established 1989/90 and has current membership at around 170 in number, with many of that number being family membership, parents and children counting as a single membership unit.
The club is based at Muriwai on Auckland’s West Coast and club boundaries extend from Erangi Point –Te Henga (Bethells Beach) north to and including the Kaipara Harbour. Notwithstanding those boundaries, club members’ fishing activity is not necessarily constrained to within them, but, because we are a club based primarily on trailer boats capable of being launched directly into the west coast (Tasman) surf, our members do exercise mobility in their fishing venues. The principle focus of the club is on game fishing (the club being a member club of the New Zealand Big Game Fishing Council and IGFA affiliate).
Nevertheless the subject species of this submission are important to our members, many of whom fish all three species for food. There are many members who fish both open inshore and Kaipara Harbour waters for Snapper, net both Muriwai Beach and the Kaipara for Mullet, and net the Kaipara for Flounder.
Summary of Recommendations
SNA8
We ask that the Minister:
| 1. |
Rejects all of the proportional catch reductions options as unfair to recreational fishers.
|
| 2. |
Makes no change to recreational bag limits, size limits or gear restrictions. |
| 3. |
Notes that recreational catch estimates and allowances are uncertain and may be subject to review when better catch information is available. |
| 4. |
Sets the recreational allowance at a level capable of covering the current level of recreation catch and allowing a margin sufficient to accommodate the expected and anticipated increase in recreation activity in this fishery. |
| 5. |
Cuts the TACC for SNA8 to 1000 tonnes to allow a rapid rebuild of this fishery to above BMSY.
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| 6. |
Introduces and an effective means of compliance measures to ensure that the TACC is not persistently overcaught as has been longstanding practice for this fishery.
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FLA1
We ask that the Minister:
| 1. |
Makes no change to recreational bag limits, size limits or gear restrictions. |
| 2. |
Notes that recreational catch estimates and allowances are uncertain and may be subject to review when better catch information becomes available. |
| 3. |
Sets the recreational allowance at a level capable of covering the current level of recreation catch and allowing a margin sufficient to accommodate the expected and anticipated increase in recreation activity in this fishery. |
| 4. |
Notes that we consider that this fishery is subject to considerable localised depletion of stocks and the huge and varied coastline of FLA1 renders effective management under present regimes impossible. We consider that the fishery should be split into, as a minimum, two management areas, East Coast and West Coast, and that respective significant harbours e.g. Kaipara, Manukau, should have individual commercial extraction limits. |
| 5. |
Notes that recreational access has been adversely affected by the distinct lack of constraint on commercial catch. |
| 6. |
Sets the TACC at a level commensurate with what is being caught and adopts a TACC of 740 tonnes, a recreation allowance of 270 tonnes, a customary allowance of 270tonnes and an “other mortality” allowance of 27 tonnes to give a TAC of 1307 tonnes, per the second option of the IPP. |
| 7. |
Reviews the mesh size of commercial only set nets with a view to increasing that mesh size. |
| 8. |
Looks to introduce a maximum soak time for commercial set nets of one tide cycle only i.e. no two high tides, no two low tides. |
GMU1
We ask that the Minister:
| 1. |
Makes no change to recreational bag limits, size limits or gear restrictions. |
| 2. |
Notes that recreational catch estimates and allowances are uncertain and may be subject to review when better catch information becomes available. |
| 3. |
Sets the recreational allowance at a level capable of covering the current level of recreation catch and allowing a margin sufficient to accommodate the expected and anticipated increase in recreation activity in this fishery. |
| 4. |
Notes that we consider that this fishery is subject to considerable localised depletion of stocks and the huge and varied coastline of GMU1 renders effective management under present regimes impossible. We consider that the fishery should be split into, as a minimum, two management areas, East Coast and West Coast, and that respective significant harbours e.g. Kaipara, Manukau, should have individual commercial extraction limits. |
| 5. |
Notes that recreational access has been adversely affected by the distinct lack of constraint on commercial catch. |
| 6. |
Sets the TACC at a level commensurate with what is being caught and adopts a TACC of 655 tonnes, a recreation allowance of 150 tonnes, a customary allowance of 150tonnes and a “other mortality” allowance of 30 tonnes to give a TAC of 985 tonnes. |
| 7. |
Reviews the mesh size of commercial only set nets with a view to increasing that mesh size. |
| 8. |
Looks to introduce a maximum soak time for commercial set nets of one tide cycle only i.e. no two high tides, no two low tides. |
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Discussion on these Recommendations
SNA8, FLA1, GMU1
Rejection of Proportional Catch Reduction Options
The concept of Recreation Fishers participating in a Proportional Share/ Allocation management regime was soundly rejected in the “Soundings” process of recent years. Proportional share /allocations do nothing to foster recreation fishers interests and are seen to impact significantly on the potential recreation catch. They are in reality a “double whammy” against recreation fishers – the first impact is through the fall in biomass resulting in recreation fishers having fewer fish to catch and the second when the already reduced recreation catch is further reduced in proportion to the cut applied to the commercial fishers. It places no onus of responsibility on the sector that has profited from the “over fishing” giving cause to the need for reductions, not does it equitably encourage recreation fishers to conserve or effectively manage their catch.
As a concept it is totally rejected by our membership.
SNA8
No Change To Recreation Bag Limits, Size Limits or Gear Restrictions
Unlike the commercial sector that in the last eleven years has not constrained its catch to TACC, the recreation sector has regularly contributed to the rebuild and conservation of this fishery. A chronological summary of constraints that have been placed on recreation fishers is:
| 1985 |
First bag limit of 30 snapper per person per day set |
| 1993 |
Snapper bag limit reduced to 20 per person per day |
| 1994 |
Size limit for recreation fishers increased from 25cm to 27cm. No such size limit increase for commercial – remained at 25cm |
| 1995 |
Snapper bag limit reduced to 15 per person per day |
| 1995 |
Recreational long line hook number reduced from 50 to 25 (halved!) |
The increased size limit has impacted significantly on recreation fishers from within the N.I.West Coast harbours primarily Kaipara and Manukau which are regularly fished by our members. Unless one ventures to the outer reaches of these harbours, legal size snapper are not common and in many instances the inner harbour catch of legal size snapper is reduced to zero.
Recreation fishers have already participated significantly in the intended rebuild of this fishery and have participated willingly in formulating regulations that are intended to help in that aim.
Meanwhile we have seen NO restraint by commercial to fish within the “rules” demonstrating ineffective management of the commercial take. In fact from introduction and setting of TACC in 1987 through to the 2003 season – 16 years -(IPP does not give 2004 or 2005 catch figures) commercial have caught within the TACC only THREE times, the last eleven years straight exceeding TACC by as much as 166 tonnes (111% of TACC in year 2003), 130 tonnes (109% - 2000), 136 tonnes (109% - 1998), 113 tonnes (108% -1996), and 104 tonnes (107% - 1999).
Conversely of the three individual years where catch did not reach TACC the greatest under catch was 130 tonnes (92% of TACC –year 1991). The other two years under catch were much closer to TACC at 96% and 97%.
All percentage figures are rounded to nearest whole unit, and tonnage/year figures drawn from previous IPP and data.
The fish down of this fishery and need for rebuild can only be attributed to the initial rape and carnage of trawlers pre QMA and more recent over fishing by commercial interests. Recreation fishers have already contributed to a promised rebuild by 2008 –(para 1b of IPP) through bag limit reductions, size limit increases and gear restrictions. No further constraints on any of these fields should be expected of recreation fishers. Rather a greater emphasis should be placed on management and constraint of the commercial take.
In addition to the constraints of bag and size limits and gear restrictions the recreation sector faces further constraints in this fishery in particular through weather and sea conditions. There are often long periods when recreation boats are unable to venture outside harbour entrances or launch into the open sea, and often swell conditions prevent shore based fishers from participating. With the almost non availability of legal size snapper in the upper and more sheltered regions of the harbours there is no “take” from recreation fishers during these restrictive weather /sea conditions. Therefore an ability to retain a catch of 15 snapper per person on trips when they can be made is not considered unreasonable.
Our members see no reason to effect a catch number restriction on their entitlement just because a lower limit applies further south.
FLA1, and GMU1
These two fisheries are important to recreation interest primarily as food source. Both are easily accessible and impact on social and cultural wellbeing of many local communities. Both have seen localised conflict between commercial and non - commercial interests. Significant in the management of these fisheries is the fact that the TACC has never constrained the commercial catch and having been set at artificial levels relative to catch numbers, has openly invited commercial interest to fish these intensively or “to the max” in effort.
than inflict further imposition on recreation interests, effective constraint on currently unconstrained commercial activity would better assist the rebuild of both fisheries. Both these fisheries are in decline, as acknowledged in the IPPs and the decline in these fisheries is impacting on recreation ability to catch a decent feed. Rather than look to cut recreation catch limits when seldom is the daily catch limit attained, for a rebuild mechanism we suggest implementing a sensible commercial take limitation and look to split both these fisheries as to size in QMAs, with explicit extraction rates from significant harbours.
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Recreation Catch Estimates and Allowances
Throughout the IPP are references to the uncertainty of the recreation catch and the likely increase in recreation activity in this fishery. In addition it is noted that this year the Ministry proposes to introduce a TAC for FLA1 and consequently allowances for recreation and customary take. We acknowledge that as more data becomes available there may be need and reason to review the currently uncertain catch limits and make amendments to proposed allowances. Similarly as the recreation and customary interest in these fisheries grows there will be need to review upwards the allowances set now.
Reduce TACCs to Allow Rebuilds of These Three Fisheries
IPP suggests that the FLA1 and GMU 1 fisheries are in decline and the rebuild of SNA8 has not occurred as expected (and promised by previous Minister when reviewing non commercial catch limits and size). In each instance there is no doubt in our minds that the decline or lack of rebuild can be attributed directly to over fishing by and mismanagement of commercial interests.
Such over fishing and consequent decline or lack of rebuild already impacts on the ability of recreation fishers to catch their entitlement or needs and clearly we are already bearing pain of others actions. It is now time for commercial interests to shoulder their share, they have gained socially and financially through their activity now they should be expected to pay for their gain and our pain.
Commercial Net Mesh Size and Soak Times
An increase in net mesh size and reduction in soak time for commercial only, in both the flounder and mullet fisheries would bring about an increase in the biomass and consequent availability of both species to recreation fishers. An increase in mesh size would reduce mortality in juvenile fish and also benefit the harbour fish stocks in general by having similar benefits to by-catch.
Undersize snapper, gurnard, dogfish and trevally are all caught in commercial netting activities and the bycatch of these would reduce if mesh size was increased. Flounder and mullet are relatively quick growing and reduced capture of juveniles of both species would quickly benefit the fishery through these escapees quickly attaining retention size.
Set netting is a wasteful method when nets are not cleared quickly and regularly. Sea lice, sharks, rays and other predators quickly home in on fish left in nets and wastage through scavenging can be reduced – resulting in reduced need for high “other mortality” and or increased financial return per fish caught. It is our belief that nets should not be left for more that on tide cycle and in many instances a full tide cycle is in fact too long. We consider that the current maximum 18hour soak time is far too long.
Other Comments Relevant to These Fisheries
FLA1 and GMU1 QMAs
Our members believe that probably the most significant move to get improved participation and management in these fisheries would be to address the large impractical nature of these QMAs. It is our belief that the East Coast and West Coasts should be separate QMAs and then significant harbours and fishing effort areas should have their own extraction limits.
Part of the problem with these fisheries is the mobile nature of the commercial fishers, and without individual area extraction limits they are able to move around the top half of the North Island, quickly over fishing and depleting one harbour then moving on to the next. It is the hard hitting bulk extraction by these mobile fishers that is the cause of localised depletion and of concern to the many communities dependent on regular catch for sustenance.
SNA8
Currently there is a 1 nm no trawl zone down the top half of the NI west coast, that zone increasing to 2nm harbour bubbles. There is also a 4nm set net ban for Maui Dolphin areas. Our members suggest that a no trawl ban of 4nm should be imposed for the SNA8 zone particularly for the northern regions - say Tirau Point north. We would like the Minister to consider this as a spatial separation of commercial/non-commercial interests.
Bernie Ward
Muriwai Sport Fishing Club
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