Serious potential impacts on recreational bag limits are possible under the Ministry of Fisheries recent management options due to be implemented in October this year. The proposals include recommendations for reductions to west coast snapper bag limits and northern North Island mullet and flounder bag limits. Consultation on the proposals is underway now and a public meeting is to be held this Wednesday night at the Mangere Boating Club. (Meeting details and map at the bottom of this page)  

Once again the Ministry is using a very poor consultation process. They have failed to adequately advertise the management initiatives to all those who will be adversely affected by the proposals and they have imposed a very short timeframe for those who have an interest in the fisheries to respond.

option4 has sent this communication to you to ensure that you can participate, be kept informed, have your views heard and have these views taken into account in the decision making process.

If you know of any other people who are likely to be affected by reduced bag limits in these fisheries please forward a link to this notice to them, it may be the only way they find out about these proposals.

The Proposals

The Ministry of Fisheries (MFish) are proposing to cut snapper catches in SNA8 (west coast North Island), Flounder catches in FLA1 (Cape Runaway to New Plymouth) and grey mullet catches in GMU1 (Cape Runaway to New Plymouth).

The Ministry are proposing two options for reducing the total catch in these fisheries:

1. A proportional cut where non-commercial and commercial fishers catches are purportedly cut by the same percentage, but they are not. This option could see recreational catch bag limits slashed by more than two thirds.
   
2. A non-proportional reduction that could result in recreational catches bag limits being slashed by up to two thirds.

option4 has grave concerns regarding all of the proposals and their potential impacts on non-commercial fishers now and into the future. The summary below sets out the main concerns in more detail.

Proportional Cuts

Under the proportional cut option non-commercial fishers would initially be allocated a tonnage based on a flawed 1996 harvest survey which may underestimate recreational catch by as much as two thirds.

This could mean we will only get one third of what we actually catch now as an initial allocation. Any cuts would then come from this massively reduced recreational allowance.

If the initial recreational catch is capped at this lower level then cuts in total recreational take in excess of 50% could be required when better information is available.

Bag limits of one or two fish per person would be required to reduce the total recreational catch by this amount.

Non-Proportional Cuts

As above, under the non-proportional option non-commercial fishers would be initially allocated a tonnage based on a flawed research 1996 harvest survey which may underestimate recreational catch by as much as two thirds.

This could mean we will only get one third of what we actually catch now, as an initial allocation. Again, if the initial allowance is insufficient to cover current recreational catch then cuts in total recreational take would require huge reductions in bag limits.

Ministry Comment

The Ministry has stated that under either of the above options, “steps will need to be taken to ensure that the recreational catch does not exceed the reduced allowance”.

There is also a warning in the Ministry proposal that the bag limit reductions proposed are noted as being ‘a first step' in reducing recreational take, clearly this means that further cuts are highly likely!

The History of Proportional Allocation

The Ministry's agenda to allocate fisheries resources proportionately between stakeholders was first raised in the Soundings document. The Ministry of Fisheries and the NZ Recreational Fishing Council produced Soundings back in July 2000. Soundings was all about proportional allocation and gave three options for achieving it.

During public consultation on Soundings Jenni McMurran, from MFish policy division, was asked what the objectives of the Ministry were. She replied that it was to cap the recreational catch and avoid compensation issues for the Crown.

So there we have it, proportional allocations are not about fairness, not about what is right, it is all about protecting the Crown from compensation where fisheries have been misallocated between sectors, mismanaged or both.

Proportionality is about using recreational catch as a bank from which the Crown takes fish and gives it to the commercial sector when commercial fishing has become unsustainable.

Recreational Fishers in Double Jeopardy

Proportional allocation inevitably puts recreational fishers in a double jeopardy situation when fisheries are in poor shape and allocation decisions are being made.

Our catches are eroded in the first instance by the low stock size. We end up catching smaller fish, fewer fish, or both as the fish stock declines. The overall tonnage of recreational catch drops as the biomass falls.

When we are allocated our "share" it is usually based on our current catch in a depleted fishery. Consequently, under the current proposals we are allocated the minimum possible amount.  

Then the Ministry have the audacity to ask us to take further catch reductions under the proportionate options under consideration.

This is clearly unfair and unacceptable. To add insult to injury, the Ministry, in this years proposals, has knowingly used flawed research to argue recreational catches down even further.

If these proposals are not challenged non-commercial fishers could wind up being seriously under-allocated in these fisheries. Bag limits will need to be slashed to constrain recreational fishers within the tonnage allowed.

The commercial allocation is largely unaffected by the health of the fishery, they simply apply more effort or more efficient methods to maintain their catches and "proportion" in a declining fishery. They have also used the Courts to inflate their quotas and "proportion" by up to 30% above the scientifically determined safe level of harvest.

West Coast Snapper Fishery

The Ministry have a long record of failing to constrain commercial fishers to a sustainable harvest level in the fisheries being reviewed this year. In the west coast snapper 8 fishery (SNA8), which runs from Wellington to North Cape, the fishing industry have taken in excess of their already inflated quotas by using the deeming provisions of the Fisheries Act in almost every year since 1987.

Over and above all of this, the Ministry notes that dumping and high grading of commercial catch (an unforgivable waste of a precious resource) is more widespread in the SNA8 commercial fishery than in any of the other snapper fisheries.

If recreational fishers want a fair and just allowance in the snapper fishery it has become obvious that they will have fight for it. The Ministry is far more concerned with avoiding compensation than it is with fairness, truth or making a just allocation.

Mullet and Flounder

The allocation models for the flatfish (flounder) and mullet fisheries demonstrate the lunacy of previous allocation decisions. In the flounder fishery the commercial sector have been allocated so much quota that they have been unable to catch it in any single year since the introduction of the Quota Management System in 1986.

The mullet allocations for commercial fishers are equivalently high. Concerns about the sustainability of both fisheries have been raised in the Ministry's papers this year.

MFish has proposed to reduce the quotas on both species to the level that reflects current commercial catches in these fisheries. Commercial fishers will continue to take the same level of catch that has caused the sustainability problem in the first place.

This appears to contradict the Ministry's own advice that clearly says a reduction in actual catch is necessary. Obviously if commercial catches are not reduced these proposed cuts to quotas will have no effect on improving these fisheries.

However, the proposals could have serious impacts on recreational catch. Again the Ministry seeks to set allocations based on flawed research which could under estimate actual recreational catch by two thirds. As the Ministry follow through with their promise to constrain recreational catch to the allowance massive bag limit cuts will be required.

The proportional proposals for mullet and flounder will effectively cut recreational catch even further.

An urgent meeting has been called for Wednesday night 20th July at the Mangere Boating Club, Kiwi Esplanade, Mangere Bridge 7 – 9pm, to discuss the Ministry proposals and the way forward for recreational fishers.

For further information please call Trish Rea on 09 8186205 or email trish@option4.co.nz  

The outcome of this meeting is not a foregone conclusion and differing views on the way forward for recreational fishers will be expressed.

It is imperative that if you have any interest in the west coast snapper fishery, the northern mullet or flounder fisheries that you attend this meeting. Your attendance at the meeting will ensure that your views are taken into account by option4 as it develops its response to these proposals.

If you cannot make it to the meeting then please go to https://option4.co.nz/register.php and subscribe to the option4 Updates to be kept fully informed of further developments.

option4 is currently developing an online submission facility to ensure you can have your say (within the next week) in the management of fisheries that are important to you.

Don't forget, please forward this email to anyone you believe has an interest in these fisheries. It may be the only way they find out about it!

If you value the work option4 do on your behalf please make a donation. There is so much more we could do to maintain and improve the advocacy we provide. Please give generously.

If you are having problems reading this format of the Newsflash please consider changing your email options to the text version. Change your details here.

2005