Submission from the New Zealand Recreational Fishing Council on the Te Paepae Aotea (Volkner Rocks) Marine Reserve.

14 January 2003

The Conservator
Bay of Plenty Conservancy Office
P.O. Box 1146
Rotorua

Dear Sir,

SUBMISSION FROM: New Zealand Recreational Fishing Council

SUBMISSION ON: Proposed Te Paepae Aotea / Volkner Rocks Marine Reserve.

The New Zealand Recreational Fishing Council represents the following National Organisations: N.Z. Angling & Casting Association, N.Z. Big Game Fishing Council, N.Z. Trailer Boat Federation, N.Z. Marine Transport Association, N.Z. Underwater Federation, N.Z. Sports Industry Association.

We also represent the following regional associations, Northland, Auckland, Bay of Plenty/Waikato, Taranaki, Wellington, Tasman Bay, and Otago.

As well as the National and Regional Associations, we have 243 clubs as members and in total represent approximately 239,000 members.

All of our associates are affected in some way by the creation of a marine reserve at the Volkner Rocks. It is one of the few locations left in New Zealand that most anglers from throughout New Zealand dream of fishing. Most make the trip at least once in their life to visit this group of rocks out in the middle of nowhere where they can have high expectations of catching a fish far larger than anything that they have caught before.

We are aware that some of the National Associations and option4 are making their own submissions, we support their submissions, but we do not support the submission from N.Z. Underwater Federation and they have been made aware of this.

OVERVIEW.

Our Council has some major concerns with the application for the marine reserve application that has been made for the Volkner Rocks, or referred to as the Te Paepae Aotea Reserve.

Due to these concerns we do not support the application
in its present form.

In this submission we will expand out our concerns, and advise of the ramifications involved if the application proceeds in its present form.

It is the New Zealand Recreational Fishing Council’s policy that; no new marine reserves should be created until the Governments Oceans Policy has been completed.
Or
Until the recreational fishing rights have been defined in law which is presently being negotiated.

The Minister is required evaluate the impact of a reserve on fishing and recreational use. The Act clearly states ”Any adverse effect” on recreational or customary fishing is sufficient grounds for the Minister to decline the application. When one considers the number of out of town domestic anglers, and the number of International anglers that frequent the Volkner Rocks, any closure will have an adverse effect. The effects will not just relate to fishing, they will also affect international tourism, business for a small community, etc.

It is our interpretation that the reference to “fishing” in the Act is not just the act of catching, but it should also be read as a reference to the quality of the fishing experience.

The 1971 Marine Reserve Act clearly states the conditions under which the Director General can make a marine reserve application, and we do not believe that these conditions have been adhered to. Surely the Volkner Rocks proposal needs to be consistent with the primary purpose of the Marine Reserves Act (1971), which is scientific study. Far from it, the creating of a reserve at this location will severely constrain existing Ministry of Fisheries funded research into the age, growth rates, and natural mortality of New Zealand kingfish.

On closer examination, the scientific studies that are quoted by the steering committee and DOC are totally inadequate to justify the establishment of a 1-mile marine reserve at the Volkner Rocks over other potential sites at White Island.

Consultation and representation can only be described as abysmal and no “meaningful consultation” has been carried out. There have been opportunities where both members of the steering committee or DOC have had the chance to promote their cause to the general public and this has not happened.

The continuation of the fishery targeting kingfish by drifting baits in relatively deep water in no way effects the special features that the proposal uses as justification for marine reserve status. The closure of this fishery by creating a 1 mile radius reserve cannot be justified.

The location of the Volkner Rocks and their physical construction, and because of the strong currents, wind, and waves from almost all four corners of the compass, and the fact that they do not offer any protection from the weather does not make this the ideal site for diving. Dive boats anchoring in the reserve, particularly in bad weather will do considerable damage to the special invertebrate life that they are trying to protect.

The alteration of documentation namely the “Froude Report” creates a misleading representation of the facts when there is no statement to advise that it is an amended copy of the report that is accompanying the application.

We are concerned that changes to the proposed marine reserve boundaries were made without sufficient consultation with all stakeholder groups.

Not all the important facts known to the steering committee being passed on to relevant stakeholders and submitters to allow them to make appropriate comment in their submissions.

Our Council believes that by not advising the public prior to submissions closing that Ngati awa or Te Ehutu iwi had Treaty claims in for the waters around the privately owned White Island and when the claims were settled that they would probably turn the waters into some type of reserve. Now this is pretty damning information. Especially when the steering committee is privy to this information and the public were not advised of the situation prior to submissions being called for the Volkner Rocks.

We are aware that originally White Island was to be part of the Whakaari Reserve and that there was to be 0.5 mile closure around both White Island and the Volkner Rocks.
Because we do not have all the steering committee meeting minutes, it would appear to us that after Ngati awa and Te Ehutu iwi advised the committee of their intentions on settlement of their treaty claims. At about that time, the steering committee dropped the White Island part of the reserve and increased the Volkner Rocks reserve out to 1mile, and Maoris' intentions have been kept from the public to ensure that it didn’t affect the results of the submissions. We consider these actions to be non-disclosure, and will be taking the matter further if the existing proposal becomes a reality.

Abnomalies in the application

Our Council finds that it is strange that the Volkner Rocks appear to be on the move. According to the application, the Volkners are located 55km NN.E. of Whakatane. All of the charts that we have referred to show the Volkners to be NNW of Whakatane and closer than the 55km referred to in the application.

1971 Act

Section 5. Procedure for declaring a marine reserve
Sub Sect 6. (d)

It is our belief that the establishment of a marine reserve with a radius of 1 mile around the Volkner Rocks is an unnecessary large area and will unduly interfere or adversely affect any existing usage for recreational purposes so is contrary to this section of the Act.

Section 5. Procedure for declaring a marine reserve
Sub Sect (9)

Under this section of the Act, the Minister can declare an area a marine reserve either
“Unconditionally or subject to any conditions” and one of those conditions is “permitting fishing within the reserve by persons not holding a permit issued under (part III of the Fisheries Act 1983) until such time as a management committee for the reserve is appointed and is working and has been consulted as to whether a notice under Sect 3 of this ACT should be given or not. He shall if the Ministers of Transport and Fisheries concur recommend to the Governor General the making of an Order in Council accordingly."

This section allows the steering committee to recommend any catch within the reserve
by recreational fishing. We assume this to be the section on which Tuhua reserve was designed.

Once the management committee is established and working they have the ability to create bylaws for the reserve and again they have the powers to allow selective fishing within the reserve under the Act.

The White Island / Volkner Rocks has given Whakatane the title of Kingfish Capital of the world, due to the size and abundance of kingfish that are known to exist in the area. Whilst it has been suggested by the chairman of the steering committee that there are other areas where kingfish can be caught, we believe it is tongue in cheek stuff. Of course there are other areas where kingfish can be caught, but they do not consistently have the sizes of the fish caught at the proposed reserve area..

We are aware that we have many domestic anglers fishing this area because basically they have tried other locations and not had the success that they have had at the Volkner Rocks. Foreign anglers from Australia, Singapore, other Asian Countries, Germany, and USA all come to this area with one species in mind and that is the yellowtail kingfish. We would suggest that Tourism New Zealand would have more accurate figures than we can offer
These anglers cannot believe that they are forced to return fish to the water because they do not make minimum size under the general code of practice operated by most charter boats and they have never caught a fish so large before.

International anglers wanting to catch large striped marlin go to the Bay of Islands because they know that they have a chance of catching a record sized fish there. People travel to Cairns Australia to catch the largest of large Black Marlin, and they travel to Whakatane to catch oversized kingfish. Anglers know that they can travel to other areas and catch a striped marlin, or a black marlin, or kingfish but after travelling half way around the world they want value for dollars spent so they operate out of recognised ports, and Whakatane is the recognised port worldwide for kingfish. In all three locations mentioned the vast majority of fish caught are tagged and released.

Anglers are not interested in fishing for the reef species out at the Volkners as very few of them would be classified as edible when compared to snapper etc. If they are looking for that type of sustenance fishing they will stop off at the inshore islands either before or after they travel to the White and Volkners.

The fish caught at Volkner Rocks are more often than not tagged and released unless they are getting close to a record sized fish. For the past twenty years recreational anglers have been tagging and releasing kingfish at the Volkner Rocks and White Island in the Ministry of Fisheries cooperative tagging programme. The focus of their current kingfish tagging is the growth rate of fish 1 metre and larger, measured on release and recapture. Many of the larger fish tagged are caught at the Volkner Rocks. The numbers of kingfish captured here are evidence of the success of the programme.
There have been more than 200 kingfish recaptured at the Volkner Rocks. One fish was caught three times over a period of three years.

Sciences to justify a marine reserve application

The chairman of the steering committee, and we assume other members of the steering committee, believe that adequate scientific data is available to warrant the establishment of a marine reserve. Our Council disagrees and provides the following data to justify our concerns and disagreement with the chairman's statement.

In 1992 the New Zealand Oceanographic Institute carried out some survey work out at White Island and the Volkner Rocks. The title of the report that was a result of the survey was " A survey of the marine habitats and communities of White Island." In the report the author quoted, "since the time available for field work was extremely limited each dive was organised to maximise data obtained." Our Council believes a statement like that means that it was a hurried job and insufficient was spent to obtain the necessary data. There were no numbers of dives recorded, or time actually spent in the water, which would indicate that it was not well organised research.

We are aware that 10 different sites were chosen. Eight sites were dived around White Island, and two sites at the Volkner Rocks. At the eight of the sites around White Island transects were carried out and the number of and types of species countered and compared with those of other sites compared. However, at the two sites at the Volkner Rocks the reports says, "Although quantitative transects were not conducted at the Volkner Rocks, the fish species and abundance's appeared similar to those observed on the Southern side of the Club Rocks. A statement like this in a document as important as this cannot be considered scientific evidence, it can only be considered as anecdotal comment and carries no credibility.

The report suggests, "Recreational fishing in the area may place sufficient pressure on the resources to prevent their enhancement." The author of the report could also have said that recreational fishing "may not" place pressure on stock enhancement. Again there is no science in a statement like this and cannot be justified. The report continues, "Catch data from amateur fishers, big game fishing clubs, and commercial landings have not been analysed for this report." Without knowing what the catches are now, or were in the past because no other survey had been carried out, the author would not have any knowledge as to whether any fish stock was under pressure or not. He would not know what impact recreational fishing has on the stocks, so this comment can be considered nothing more than anecdotal information either, and carries no credibility.

We are also aware that no research has been carried out in the past at the Volkners and the scientists have used minimal data that was obtained during research of the Tuhua Reserve application some 50 nautical miles to the west of the Volkners for comparison. We find this to be totally inadequate and unscientific for a report of this nature.

The second report referred to in the application was a report completed for N.Z. Navy in 1997 by a company called Kingett Mitchell and Associates. The title of the report was "Assessments of the effects of ordnance on the marine resources of Volkner Rocks.
The basics of the report taken from the report itself "is an assessment of the effects of defence force ordnance on the biological resources at Volkner Rocks after 30 years of bombing by the Navy and the Air Force.

The researchers visited the site twice in November 1996 and once in April 1997 and a quote from the report says, "no significant sub-tidal work was able to be completed on the first two occasions due to poor weather conditions." Therefore the researchers in this case spent three days counting the number and types of war-heads and practice bombs encountered, and the areas that the heads and shells covered, and as to their physical state having been submerged for various lengths of time. They did acknowledge that they saw the same species of fish encountered by the previous researchers.

The research reported in this document has nothing to do with the placing of a site under a marine reserve status and should not be even referred to by the steering committee.

The third report referred to by the steering committee was carried out in 2001 for DOC Bay of Plenty Conservancy, by Victoria Froude. She used to work for DOC but is now a private consultant. The title of the report was "Compilation of ecological information on the Volkner Rocks / Te Paepae marine area."

The basics of this report are only a summary of "existing information" and a "desk-top exercise only" as quoted by Ms Froude. She had nothing new to offer, only what was in the previous two reports. However, Ms Froude did say "There has however been no survey designed to collect information about a marine reserve based solely around the Volkner Rocks. This means that it is not possible to fully answer some important questions." Our Council agrees fully with this comment.

Summary of Scientific Data.

There is really only one report that can even be considered as somewhat scientific, and our council has a number of difficulties relating to comments in the report. The report would certainly require more substance to support a marine reserve application as there are too many anecdotal comments being referred to as evidence.

We are aware from the steering committee minutes that they had the opportunity to alter (and they did) the Froude Report before it was submitted with the application. Now we appreciate that the report was written for DOC and they have every right to do what ever they want with the report, but it should show as an amended report not as an original. We know that the steering committee changed Ms Froude’s report, and although there aren’t any recorded indications, we can only assume that DOC also made changes. We therefore discount any reference to the Froude Report and we question whether the author was advised that her paper had been altered before it was attached to the application..

The authors of this proposal clearly make the assumption that all fishing is bad. However, apart from some anecdotal comments in one of the reports, there is no scientific data to show that fishing for kingfish caused any damage on any of the “special features” or species that the proposers want to protect. It is proposals such as this that will continually have the recreational sector fighting to get some logic in marine reserve applications.

There is no scientific basis for the Government to close off 10% of our coastline or the green element wanting to close off 20% of our coastline to become marine reserves. To lock up areas without knowing what is there and whether anything there is under threat, and even if reserves are the best management tools to use is reckless when it involves peoples culture and birthright.

Consultation

We consider the consultation process for this application to be a farce. Meaningful consultation (Wellington Airport v's Wellington City Council) has been non-existent.

The steering committee apart from the statutory requirements and visiting three marae for hui's, attending a Whakatane District Council committee meeting, and the Trident High school pupils with an advocate for marine reserves. We are aware that the chairman has spoken to a couple of organisations and very recently started a campaign on the local radio.

The Department of Conservation refused to attend a Public meeting at the Whakatane Sportfishing Club, and did not visit any other fishing clubs in the area. In fact, there were no public meetings organised by the steering committee. We find this to be inexcusable, and we consider that this decision was made to avoid having to listen to argument and comments towards possible changes to the proposal that would reduce the size of the Marine Reserve.

The only consultation carried out was the bare minimum as per required under the Act and this is unacceptable when so many people rely on these islands for enjoyment and recreational purposes.

Steering Committee meetings

Whilst the New Zealand Recreational Fishing Council was invited to the launch at Ohope Charter Club and attended, our council was never invited onto the steering committee. We thought it would have been obvious to have a representative that had mandate from the majority of recreational fishers throughout the country to represent them and not just a person representing a local fishing club. Even when the commercial fishing representative on the steering committee suggested at a steering committee meeting that the Rec. Fishing Council become involved we were never invited to attend. We do note however that RF & BPS were invited to have representation.

Most fishing clubs throughout the country do not have personal who are experienced enough to attend meetings of this nature and is obvious by some of the decisions that have been made at the steering committee meetings. We note from the minutes (that we have received) that the Whakatane Sportfishing Club had five different representatives attend meetings throughout the process. This is obviously not satisfactory and cannot be considered as meaningful consultation. Members of the steering committee and especially DOC should have recognised the problem, and done more to rectify the situation at the time.

We note from the documentation received, that the Department of Conservation worked very hard to get Maori on their side, even though DOC has suggested in the media that they are not biased either way. They have suggested that they are only the tools to move an application forward. We disagree. It is clear from the steering committee meeting minutes that DOC was the driving force behind this application and only used the members of the steering committee as pawns to achieve their aims.

One only has to look at the makeup of the steering committee to realise the bias toward an eco-tourist operation and a green sector. This reasoning becomes far more obvious when some of the decisions are taken into account that have been made at the various steering committee meetings.

The frequency of meetings on such an important issue can only be considered a joke. Our Council sought all minutes of the steering committee meetings, and whilst we did receive some minutes of the meetings listed below, we are aware of other meetings that did take place and the minutes were not released to us even though they were not officially declined. Working with only some of the data does not assist us in making an informed decision.

The steering committee minutes can only be described as pathetic or an obvious attempt to hide hidden agendas. We fail to understand why the minutes are so sparse when we have been advised that the meetings were being taped. We include as an appendix one committee members comments relating to 30 inconsistencies to the minutes of just one meeting relating to what was written and what was actually said and not said at the meeting. Two other steering committee persons pulled out of the committee due to the inefficiencies and the way the meetings were being run.

Various individuals at these meetings raised issues and the answers to any political or controversial type question are not shown, and motions put forward by individuals and the results of these motions are not shown in most cases. There is very little evidence showing what was comment and what were decisions.

We are aware that Maori had two representatives on the steering committee. Mr Joe Mason representing Ngati awa, and Mr Manny Mokomoko representing either Whakatoea or Te Ehutu Iwi. Whilst we can understand both of these gentlemen who our Council knows and highly respects, all matters in the steering committee minutes relating to these two representatives are regarding Customary Maori issues. Neither representative raised the matter that 95% of all Maori people fishing is carried out under the Amateur Fishing Regulations, not the Customary Regulations.

It is of further concern that none of the Maori recreational anglers whom we interviewed at the Whakatane and the Kutarere boat ramps were aware that their representatives had supported the Reserve application, and were not aware of any consultation taking place regarding the Te Paepae Aotea Reserve.

From the steering committee meeting minutes of Aug 31 we note there were twelve people present and that the following proposal was decided upon. “To publish for public comment the Volkner proposal as shown: ½ nautical mile reserve around Volkner Rocks but providing for, with the demarcated area shown on the chart, a take of one kingfish per angler per trip, at minimum size of 90cm"
At a subsequent meeting when there were only four members present, the proposal was changed to remove area Y that was the major contentious issue. We have to ask in which other democracy can a meeting of only four committee members override a decision made by twelve members at a previous meeting.
One committee member has advised us that the proposal wasn’t even an agenda item at the meeting that it was changed.

This astounds our Council that twelve Committee members make a decision and then it is overridden by a questionable quorum of four at a following meeting.

At a steering committee meeting held on May 2nd 2000, Forest & Bird representative Meg Collins asked for the size of the reserve to be doubled in size from ½ mile radius to 1.0 mile radius. At that meeting there were eight of the steering committee members present including two members of DOC “It was felt that amount of change would create more opposition” and wasn’t supported. At the very next meeting with only five members present, three of them from DOC (a majority vote) it was proposed to include the 1mile radius as an option in the new proposal. It is obvious to our Council from that point on DOC had taken over the steering committee.

What are we trying to protect?

Is it the fish stocks? Or is this just another “it would be nice to have one there” reserve.

This application started way back some 10-11 years ago with the recreational sector opposed to bulk harvesting of fish stocks in the area. It was nothing more or nothing less. Now all of a sudden the proposal is for the whole area is to be closed to all stakeholders within a radius of one mile.

There were many options for the steering committee to consider achieving the initial aims. Options such as Taiapure, Maitaitai, were never offered to the public to vote on. Comments from MFish staff, Richard Fanslow, and Todd Sylvester who were invited to meetings were never taken on board or even discussed further by the steering committee.

Without naming the 59 species listed in the N.Z. Oceanographic Institute report, there is but one species that the recreational sector travels to the Volkners to catch and that it the kingfish. Because of the size of the baits and jigs used for these fish, they are not endangering the black angelfish, the crested blenny, or any of the other reef species that are domiciled in the area.

From the charts shown by both N.Z.O.I. and Kingett Mitchell, once you get out more than 50 metres from the Volkner Rocks, it is too deep and the type of bottom doesn’t suit these reef species. From time to time schools of species such as blue maomao will be encountered on the surface, but we can assure the Minister that recreational anglers do not travel 50km off the coast just to catch blue maomao.

The vast majority of kingfish fishing is done with a drifting boat again because the depth drops away too quickly for a boat to have safe anchorage and this would also apply to dive vessels. There are very few locations where one can anchor a boat, and we are sure that anchoring dive vessels will do far more damage to the eco-system than drifting fishing boats.

We are aware that there are very few areas out at the Volkners suitable for snorkelling and with the size of some of the highly migratory species that frequent the area, as a parent I certainly wouldn’t let any of my school children dive the Volkner area. This cannot be compared with the Leigh Marine Reserve which is a great place for children to study life in the sea.

From the data that was supplied in the scientific reports, with very little information available existing beyond the 50 metre mark out from the rocks, why do we need a reserve of 1.0 mile. It is a huge area considered by some that is closed, that is of no benefit to any fish stocks, because even the predatory species will be in the confines of the bait fish (reef fish). One doesn’t stand on the opposite side of the road and watch all the meals going past. One wants to be in and amongst it.

The only species that are more than likely to travel through “no mans land” will be the seasonal Tunas, Billfish, Sharks, etc., and recreational anglers targeting these species are surface fishing and certainly will have no effect on the reef species in against the rocks.

Arguments about the beneficial effects of marine reserves are imported from overseas jurisdictions where fisheries are essentially unmanaged and fisheries practices are unsustainable. These arguments do not apply in New Zealand where fisheries are managed by a world-renowned system second to none under the Quota Management System. The QMS already sets catch limits well above the level at which each stock can replenish itself.

Whilst the commercial sector is controlled by quotas, the recreational sector is controlled by; species bag limits, minimum length sizes, number of hooks used, length and number of nets, number of crayfish pots etc. With these types of regulations it is easy to adjust the recreational take up or down as the need arises. The Ministry of Fisheries also has the ability to close off areas short or long term as the need arises. i.e. Toheroas.

The Recreational Council is not opposed to the establishment of Marine Reserves. It does however believe that they must be set up for the right reasons, and such reserves can only be successful if the community as a whole is supportive of them. We obviously don’t know at this stage the support that the Volkner application has, but in a small community as divided on an issue, as there is on this matter that does not make a good base for sound decision making.

There are ways and means by which the points of both sides can be satisfied. But imposition of a solution that favours one group at the expense of another only makes for bad law that divides communities. Enforcement can become extremely difficult in such circumstances.

The proposal suggests that an indirect effect of the marine reserve could be improved fishing of some species around its margin due to fish life building in the reserve and “spilling over” to adjacent areas. In our view, that is not the decision that the Minister must make. He is not required to reach a judgement about “viability of the wider fisheries” – The Minister is required to make a decision about the interference and effects on fishing. Nothing more and nothing less.

Whilst the proposers talk of “spill over” they have not made any comment on the benefit to a growing population of reef species by removing some of the predators (kingfish) from out of the environment. It is our belief that natural mortality would account for far more reef fish deaths than anything that the recreational angler targeting kingfish could achieve.

Kingfish

We are not convinced that the kingfish population at the Volkner Rocks is under any stress and any suggestion that the stock is suffering is only anecdotal by one charter boat operator.

Prior to 1995 the bag limits for kingfish was 30. Our Council and one of our National Members were involved with the Ministry of Fisheries in reducing the bag limits to 3 and introducing a minimum size limit of 65cm. In places like White Island and the Volkner Rocks the species has been on the rebuild ever since. Long time operators at the Volkners considered last year to be an exceptional season for size, and this year is shaping up to be a good season for numbers caught but it is too early for the larger fish to be caught at this stage.

At the time the bag limits were reduced all data available suggested that kingfish spawned at around 60cm and it was then that the size limit was voluntarily introduced and accepted by the recreational sector. The intention was to give all fish the opportunity to breed at least once before they could be killed.

The only exception to this ruling was kingfish caught by trawler, these operators were allowed to keep fish smaller than the 65cm. The Ministry after carrying out research found that there was no need for an exemption for trawler caught fish and these operators are bound by the regulations relating to kingfish caught by all other methods.

More recently, we have become aware from Australian information that kingfish possibly do not become mature enough for breeding until they reach 94cm. So it has been ours, and other associations recommendations that a minimum size for keeping be 1.0 metre and for the pelagic working group of the ministry of fisheries to consider bringing this minimum size into regulation. Most clubs and charter boat operators have already adopted this minimum size on a voluntary basis.

We are aware that most boats have voluntarily adopted the killing of only one kingfish per day so we believe that an earlier proposal by the steering committee of killing only one kingfish per trip at the Volkner Rocks would be acceptable to all charter boat operators. It is unfortunate that this proposal wasn’t followed through because it would have made the marine reserve process for this site far more acceptable to our sector.

A further option that has not been offered for consideration would be the tag and release only of kingfish caught at the Volkners. Whilst we have not discussed this option with the charter boat operators that work the Volkner or have their approval, it would still allow the kingfish tagging programme in the area to continue, and is an alternative to the one fish per trip for consideration. The only disadvantage with this proposal is that it would not allow the present aging programme that is being carried out for the Ministry of Fisheries to continue.

We have been able to do a breakdown of kingfish catch and tagged fish over the past ten years and the numbers are significant considering the numbers of anglers that visit the area. Whilst we do not have a breakdown of actual catches at the Volkner Rocks we do have a breakdown of tagged fish at the Volkners. We know that the releases at the Volkners are 35% of the total releases at White Island and the Volkners. These figures do not take into account small kingfish that are too small to tag, so they are treated as releases not tag and releases.

The kept fish over the past ten years were 713 kingfish and these were from a high 101 fish in 1993/94 to a low of 28 in 1996/97. Tagged kingfish numbered 4,075 fish over the same period, and we are aware that only approximately 40% of released fish are tagged.
This would equate out to approximately 6,000 fish were released without tagging due to their size. In more recent years fish have had to be a minimum of 1.0 metre before they are tagged. Of the numbers kept and the numbers released and tagged and released approximately only 7% of fish captured are killed.

We believe that no other fish stock in New Zealand is offered the same protection and management, and the bulk of these fish are caught in Bay of Plenty waters.

Conclusions:

Our Council is prepared to consider a smaller sized, more practical, more logical reserve at either the Volkner Rocks or White Island.

We have concerns relating to a coloured brochure that has been distributed around the Bay of Plenty. Investigations that we have carried out indicate that not all households received these brochures. Although we cannot lay the blame for this on the steering committee, we wish to have the fact known.

We are also aware that people could use the brochure to lodge a submission, and our concern is that submitters using this form did not have to supply an address or phone number as did other preprinted submission forms.

From the Steering Committee minutes it was decided to check 10% of all submissions for authenticity and due to the brochures not having an address or phone number adjacent to the signature, not all of these submissions are able to be checked, and we have difficulty with this outcome. We have had insufficient time to check with our executive regarding this failure, but if necessary we will follow it up at later stage.

Our Council is concerned that DOC are using a DOC contractor Mr Iain Haggarty to analyse the submissions, and believe that this work should be tendered out to an independent company, not associated with DOC. We intend following up on this procedure throughout the process.

Our Council under the Official Information Act seeks copies of all submission forms, whether they be brochures, letters, E letters, or printed submission forms, after the official analysis has been completed. This information was made available to us by the Government after the Soundings process and allowed us to carry out our own analyses of submissions received.

Ross Gildon
President

Attachments: Stu Davidsons comments.

c.c. Minister of Fisheries.
Minister of the Environment