Advice to the
Minister on Feedback Tabled at MCG
Ministry
of Fisheries
July 2001
Released Under the Official Information Act - Feb 2002
ASB Bank House,
101-103 The Terrace,
PO Box 1020,
Wellington,
New Zealand.
MINISTRY OF FISHERIES Te Tautiaki i nga tini a Tangaroa
Ref 211412
9 July 2001
Minister of Fisheries
SECOND MEETING OF THE MINISTERIAL CONSULTATIVE GROUP
- You have received a submission from the Ministerial Consultative
Group (MCG) providing comment on the policy papers released to
the group on 25 June. The submissions are in general critical
of every aspect of the policy papers package and do not offer
proposals to move forward.
- The MCG submitters appear to desire complete open access arrangement
for recreational fishers. Virtually any form of management that
may lead to a limitation on the harvest of recreational fishers
is rejected.
- In discussing their response, and considering options for reforms,
it will be important to outline to them the overarching framework
of fisheries management In New Zealand we do set a TAC that has
been very successful in limiting commercial fishing and restoring
recreational fishing to a level not seen since the seventies To
destabilise the process that manages commercial fishing is to
jeopardise all of these gains and threaten sustainability (and
therefore recreational fishing).
- Their criticism of the quota system is unjustified. It has for
the most part been extremely successful in addressing the problems
for which it was designed to address; namely, inshore depletion,
overcapitalisation and inefficiency. The submission lists a series
of fisheries management issues that are dealt with in various
ways with various degrees of success, but fails to acknowledge
that recreational fishing is the best it has been for a long time
due to the management framework that is employed.
- The submission is not internally consistent. There are also
some misconceptions about the nature of what is being considered
in the policy papers. Comment on several of the issues in the
submission is provided in Annex 1.
Further Meetings
- It may be necessary to have a further meeting with the MCG.
This could be arranged for the evening of Thursday 26 of July
following another commitment you have in Auckland. A further meeting
could be used to outline your intended course of action and conclude
the process.
The 1989 Policy
- At the first meeting there was a request for a reinstatement
of the 1989 Policy on marine recreational fishing. The submission
also considers the 1989 policy.
- The 1989 National Policy for Marine Recreational Fishing has
a very good set of aims, principles and objectives. These are
still reasonable as the high level goals of management and any
policy reform. But the current proposals are looking for mechanisms
to effect these principles - this requires legislative amendment
- However, the fisheries management environment has evolved a
lot since 1989. The Deed of Settlement was signed, centralised
planning processes were abandoned, we have introduced a more ecosystems
based approach and Fisheries Plans are bringing a new methodology
for local management.
- In order to implement the objectives for recreational fishing
the current fisheries management framework must be taken into
account. This includes;
- The total removals from any fishery must be constrained to a
sustainable level
- The QMS provides good economic and biological outcomes for fisheries
management
- Amendments to the regime should not undermine the Deed of Settlement
- The current recreational right is based on a right to access
and use, but does not guarantee any amount of fish
- The submitters see the 1989 Policy as establishing a priority
right for recreational fishers.
On allocation the 1989 Policy stated:
To ensure that recreational users have access to a reasonable
share of fishery resources
Allocation of fishery resources should reflect the most beneficial
use of the resource. Historically, many fishery resources have
supported recreational fisheries. The objective recognises the
benefits of maintaining recreational fisheries by means of an
allocation to recreational users. This allocation may take the
form of a share of the sustainable yield or as areas set aside
primarily for recreational fishing.
Preference will be given to non-commercial fishing in areas readily
accessible to and popular with the public, where a species is
not sufficiently abundant to support both non-commercial and commercial
fishing.
- In promoting this objective, the MCG tend to drop the reference
to areas and maintain that it refers to a share of the TAC. (These
are clearly distinguished in the policy) in fact this was a very
qualified form of preference. It does not provide priority to
an ever-increasing share of the TAC. The priority refers more
to method exclusions of commercial operators in the inshore. This
is not similar to the priority share noted as one option in soundings
and sought by option4.
Conclusion
- These comments are provided to assist your discussion with the
MCG in the meeting tomorrow evening.
Recommendation
- It is recommended that you;
- Note the contents of this paper.
Mark Edwards
For Chief Executive
Ministry of Fisheries
NOTED
Hon Pete Hodgson
Minister of Fisheries
/ /2001
ANNEX 1
Issues raised in the submission
1. Information Requirements
In general no new issues are raised here. The submission questions
the scientific merit of doubling the estimate frequency. It should
be noted that this is a management objective not a scientific objective.
Once the management objective is decided upon, for example two yearly
estimates for fisheries management purposes, then we can look at
the best method for determining the estimates. Over time the methodology
will change a lot but we would expect the objective of at least
two yearly estimates should remain (Continuous estimation would
achieve this obviously).
The submission suggests a technical review by the working party
on estimation methods. However all working parties work to achieve
a management objective. At present there is an absence of any such
objective.
We admit that accuracy is a problem just as much as frequency. Nevertheless,
a two yearly cycle for major fish stocks where change is apparent
is a reasonable management goal; similarly a greater focus on areas
where estimates are unreliable is also a reasonable goal. Establishing
the management objective will require a focus on both of these.
2. Charter Boat reporting
The issue of safety and non-compliance is raised. One assumes that
by safety they mean that if reporting is required, boats will not
obtain a license. This would lead to prosecution. In our view it
is unlikely that a small compliance cost would lead to jeopardising
an entire business.
The package of reforms needs to be looked at as a whole. It is also
proposed that charter boat operators effectively propose their own
rules through the management groups. It is difficult to understand
why operators would lie to themselves. We recognise the potential
for incentives to provide false returns, but given that there is
no intention to use this information to limit charter boat activities
it is not expected that this will be a significant problem. This
will mitigate the incentive to make false returns. (It will also
be an offence)
The purpose of the proposal is primarily to provide the information
that charter boat operators need to manage their businesses in an
environment of growth. Over time we would expect the charter sector
would come to see the value of the information.
It would not generally be possible to know how the information each
boat was providing would affect the overall estimates of catch in
any case. This would further remove the incentives to create false
returns. However we freely admit that this will be an
evolutionary process. The time series that is collated will be an
invaluable management tool however.
In general these people are making money from a public resource.
They have an obligation to participate in the management of that
resource from which they ultimately benefit.
3. Defined rights
The criticism tends to reject the possibility that recreational
harvest is capped. This is not a sustainable position. It must ultimately
be capped irrespective of whether there is any commercial fishing.
In doing so it must always be recognised that there is a need to
consider the impacts on the commercial industry.
The submission suggests that a fundamental change in the mindset
of the ministry is required. We recognise that more effort is required
in recreational fishing management. We agree that it is important
that management be informed of and take into account recreational
objectives. Independent managers to address recreational concerns
are where the gains to recreational fishing will come from. So in
this sense, the package is designed explicitly to create the ability
to incorporate recreational objectives directly into management.
These managers must however recognise the fisheries management framework
in which they operate and not be merely lobbyists for one sector.
Recognising this framework will include recognising the need to
limit the catch from all sectors (no matter what you call it: share,
allowance etc). There must also be recognition that a framework
for allocating between sectors is required. The Working Papers provide
a range of options to achieve this. To reject limiting and allocating
is to reject fisheries management and therefore sustainability.
The policy papers outline the argument that we do not recommend
management structures without a defined share. Unless explicit recognition
is given to the fact that all harvest must ultimately be capped
for sustainability reasons then we do not recommend responsibility
for fisheries management be passed to these groups. This is due
to the fact that to not accept this is to not accept the framework
of fisheries management in which they will have to operate.
Whether allocation decisions are made in favour of the recreational
sector, or in favour of the commercial sector, is a second order
question. The primary issue is recognising that these decisions
must be made. Setting a TAC and a TACC that is effective in limiting
commercial catch implies that a proportion is allocated to the recreational
sector.
"If one sector has created the decline why should other sectors
be reduced?" We agree and we do not think that this should
be the case. The policy papers should include reference to the cause
of a decline being relevant in considering who should bear the cost
of reductions.
4. Inconsistencies
There are contradictory claims that managing to MSY and not managing
to MSY are both undesirable.
For example it is claimed that leaving fish in the water in the
case of a recreational share that was not fully utilised (i.e. managed
above MSY) is inefficient and undesirable.
" ...if the TAC was increased and the recreational sector could
not take the increase it would create inefficient use of the resource.
"
There is also the claim that managing to MSY is the Ministry's only
focus and a change in mindset is required.
"...the legislation it works under is centred around extracting
the greatest meat weight from the commercial fishery"
These positions are not immediately reconcilable. However, it does
imply that there are trade offs to be made here.
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