option4 Soundings Submission

Soundings Submission - Parts 2 & 3

option4 draft

2000

This is how option4.co.nz is expressing the 4 Principles in its full submission. This is the result of many days work by a number of very experienced authors.

option4 Submission to Rights Working Group on Soundings

PART 2

The interface between Public Rights in the fishery and the Commercial sector, and the 3 Options in "Soundings."
The Soundings document states:
"The Vision has healthy coastal fisheries as a central component. There is also a desire to have cooperative working relationships with customary and commercial fishers, and involvement of the public in fisheries management. Improving the management of recreational fishing will need to recognise:

• customary fishing rights for managing the taking of seafood for customary purposes
• the government's sustainability, environmental and Treaty obligations
• the quota management system because the government will not abolish this system for managing commercial fisheries
• the need to consider costs and benefits (economic and environmental) of any proposals."

Nothing in this submission is intended to affect customary fishing rights for managing the taking of seafood for customary purposes.

option4 does, however, have grave concerns over the current interpretation (in Soundings) of the strength of the commercial rights for species managed under the QMS and those fisheries managed outside the QMS.

Both Options 2 & 3 of Soundings promotes a proportional public share integrated with commercial fishers under the QMS.

option4 has grave concerns regarding the compatibility and suitability of a system designed to control commercial fishing (the QMS) to deliver outcomes favourable to the various existing public rights to harvest seafood. These rights cannot be expressed as a simple minor shareholding in a privately held property right.

The following examples of continued erosion of noncommercial fisheries have happened while the government has been charged with the responsibility of management. option4 knows there is no chance the noncommercial sector could resolve these issues as 2% stakeholders in New Zealand's fisheries as proposed in Soundings.

During the 1970's and up until the inception of the QMS, inshore fishstocks were massively overfished by an overcapitalised inshore commercial fishery. The public were disenfranchised from their fishery through this period as prime inshore stocks were fished near to collapse. Catch rates for amateur and sustenance fishers plummeted during these years.

It is clear from the preliminary documentation and original interpretation of the ITQ right that concerns raised by noncommercial fishers at the time were ignored, as were those of Maori.

Initially, quotas were set at the upper limits of fishing, that would, according to the science of the day, allow the stocks to recover. Despite being compensated $46 million to reduce effort in these depleted fisheries, the industry found several ways of increasing their profits and quota holdings which circumvented the intent of the QMS.

The Quota appeals authority(QAA), which was set up to hear claims from fishers dissatisfied with their allocations, was subject to a rush of claims from commercial fishers. Most were successful and quota on some important inshore species like snapper were inflated by around 30%. The quotas generated by the successful QAA appeals should have been absorbed into the Total Allowable Commercial Catch (TACC) but were allowed to accumulate above the scientifically set levels the industry had been compensated to accept. While some snapper quotas were eventually cut back to near the original quota levels, most QAA issued quota is still held by the fishing industry, unjustly inflating the commercial share at the expense of the access of all noncommercial users interested in those fisheries.

Quotas on many shared inshore stocks are set so high they do no constrain commercial effort whatsoever. Blue cod, flatfish, grey mullet, gurnard, hapuku, bass, john dory, tarakihi, trevally are in this category. At best this confounds the allocation issue. Is the commercial share, under Options Two and Three in Soundings, to be based on an amount of fish the commercial sector cannot currently catch just because they have quota for it? At worst this leaves noncommercial fishers competing against commercial fishers who can deplete a harbour or whole Quota Management Area (QMA ) until it is no longer economically viable to commercially fish there. This can leave amateur fishers to struggle trying to catch any legal sized fish missed by the commercial sector. In the following year, as the fishery is starting to recover the commercial fishers can return and repeat the exercise. Scallops, the Tauranga harbour dragnetting saga, the Kaipara, Manukau, Raglan, Kawhia and Aotea Harbour's flounder and mullet conflicts are examples of this flaw in the QMS.

Since the inception of the QMS other commercial methods of increasing their profits at the expense of other users have been well documented and are covered elsewhere in this document.

In "Soundings," Option 1 allows for the continual erosion of the public right to recreationally fish and harvest seafood. Options 2 and 3 will make the public a minor shareholder in a commercial fishery. option4 rejects options 1, 2 and 3.

option4 considers implementing the following two principles the only just way to resolve the above issues:

1. A priority public right that is equal to or, in recognition of the Crown's Treaty of Waitangi obligations, slightly lesser than Maori Traditional rights while being above, or in priority to, Commercial fishing rights.
2. An area right which will allow for the exclusion of Commercial methods that deplete fish stocks in areas important to the non-commercial fishing public, or hinders their ability to reasonably access those fish stocks in which they have an interest.
   

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The Public and the Quota Management System

Overview - Threats to the publics harvest.
The Introduction of the Quota Management System (QMS) in 1986 was a major change in the way fisheries were managed and lead to a restructure of commercial fishing. There were many winners, who were gifted valuable catch rights based on their catch history and many losers, such as hundreds of part time fishers, who got nothing. Many commercial fishers, disenchanted with the QMS and the new paper work sold their quota to the corporate fishing companies or Government and looked for other work.

The initial allocation of fishing rights under the Quota Management System had not made provision for Maori. The Muriwhenua claim to the Waitangi Tribunal successfully established the political right to a share of fisheries resources for Maori. Considerable effort and expense was involved in allocating Maori commercial and customary rights. There is an ongoing commitment by Government and the Treaty of Waitangi Fisheries Commission to the implementation of Maori fishing rights.

Claims have been made that the New Zealand QMS is the best fisheries management system in the world, the envy of many nations. Yet in the 14 years since its introduction no other country has embraced Individual Transferable Quota (ITQ) so fully. It is a economic model based on individual property rights deriving from the objective of commercial utilisation of the resource.

There are a number of assumptions, pointed out by the Parliamentary Commissioner for the Environment (December 1999), that have had a marked influence on the evolution of fisheries management and the Quota Management System in New Zealand. These include:

The belief that clearly defined property rights will lead to sustainability

That within such property rights frameworks, sustainability can be achieved by focusing on a few target species and thus working the system on a species by species basis.

The expectation that defining property rights will lead to effective collaboration between rights holders The political belief that clearer property rights will reduce the costs and risks to the state.

The Commissioner for the Environment also points out that there is ample evidence from land and forest management experience world wide that the existence of property rights to natural resources does not guarantee that they will be managed in a way that ensures the resources are sustained in the long term.

option4 also rejects Options 2 and 3 on the following grounds:
Recreational and subsistence fishers are not convinced that a property rights regime will meet their long term objectives for maintaining and improving the quality of the public fishery and their individual rights.

option4 is specifically concerned with the following risks associated with the QMS and the potential to cause further erosion of the public share. option4 believes that the closer the public right is aligned with the commercial rights under the QMS, the greater these risks will become.


DUMPING
Dumping of commercial catch in excess of quota.
Dumping of unwanted commercial by-catch.
Dumping of commercial overcatch catch through lack of vessel holding capacity.
Highgrading of commercial target catches for economic and quality reasons.

INFLATED QUOTAS
Quotas issued through the Quota Appeals Authority inflating commercial quota at the expense of other users and sustainability.  

THEFT
Blackmarketing of unreported commercial catches. Fisher fraud, misreporting of catches by commercial fisherman. Corporate fraud, misreporting or non-reporting by large quota holding entities and exporters.

OVERCATCH
Deeming of catch to the Crown, in excess of sustainable limits, caused by an inappropriate quota holding or quota lease for the method or fishery the vessel is operating in.

WASTAGE
Wastage caused by inefficient fishing gear.
Wastage caused by non-selective fishing gear.
Wastage caused by the loss of experienced fishers, and their replacement with inexperienced novices, through high costs of leasing quota and low landed prices.

TARGETING OF BYCATCH SPECIES
Targeting of species important to noncommercial fishers, which are outside the QMS to avoid quota costs and retain profitability and build catch histories.

LOSSES IN YIELD
Loss of yield through harvesting important species, shared with other users, at sizes that are well below the sizes that will produce the maximum yield per recruit.

GENERAL PROBLEMS
Lack of incentives in the QMS for individual commercial fishers and/or quota holders to conserve and enhance fishstocks.

The preference of the fishing industry toward high-risk harvesting strategies instead of a precautionary approach in species managed within the QMS.

The race to build catch history in fisheries outside the QMS often leading to overfishing and a stock depleted below MSY

Recreational quota or shareholdings like the proportional share system promoted in Options 2 and 3, linked in any form to Commercial rights, or able to be negatively impacted on by Commercial behaviour and / or harvest strategies, is totally and completely rejected by option4 as an unnecessarily high risk strategy. Recreational quota will require extensive bureaucracy, policing and rules for little or no real gains. Quota-based or proportional options have a real chance of outcomes for noncommercial fishers directly opposite to the rosy picture painted in the"Soundings" document.

Managing a Fisheries Property Right
The cornerstone of the QMS is the setting of an annual Total Allowable Catch (TAC) for a species and then the ability to manage the fishery within that limit. As any commercial fisher will tell you, managing the QMS is not simple. There are lists of reporting requirements and ways of covering catch when you don't have the quota. These include: Catch and Effort forms, Licensed Fish Receiver Forms, Quota Management Reports, Quota Lease agreements, Fish Against Another's Quota (FAAQ) forms and Catch Against Another's Quota (CAAQ) forms and if they still can't balance quota and catch, fishers can pay the Deemed Value for any excess.

A very expensive database was created to store this information and a validation system was set up to check what is put in. In fact, because of the legal status of the information entered on the forms they have to be entered exactly as written, errors and all. This means that when pulling data out of the system it must be carefully groomed before it can be believed. All this effort (and more) goes into estimating one part of the equation: "what commercial fishers catch". But even this is an assumption. The whole commercial Quota Management Database only records "what commercial fishers tell you they catch".

"The principal effect of the various administrative systems, and now statutory amendments to the Fisheries Act 1996, has been to allow commercial fishers to avoid the ultimate point of the QMS, namely to limit the quantity of fish taken to the quantity of quota held." (from the report of the Parliamentary Commissioner for the Environment page 53) The option4 group sees that after 14 years the assumptions of commercial rights based model are still not being met for the commercial sector. option4 certainly does not want to see the Public rights in the fishery to be expressed as a minor shareholding in such a system as is proposed in Options 2 and 3 of Soundings.

Information and Decision Making
We recognise it is the Minister of Fisheries who is ultimately responsible for setting sustainable limits for our fisheries resources. He or she will do this based on the best available biological information and estimates of the total commercial catch, estimates of the total recreational catch, and estimates of the Maori customary catch provided by the Ministry. Where that information is uncertain, unreliable or inadequate the Minister must act cautiously.

Snapper is the most researched species in NZ. Some of the top fishery researchers have fed more and more data into increasingly complex mathematical models, yet there is still considerable uncertainty about what the current biomass is and what the maximum sustainable yield is, hence the need for another tagging programme for the North Island west coast (SNA8), and more importantly for SNA1 (BOP, Hauraki Gulf and east Northland).

For many of the other key recreational species in New Zealand there is only limited knowledge of customary, commercial and recreational harvest, natural mortality, biomass and Maximum Sustainable Yield and there is considerable uncertainty in the TAC's set for these species. The Minister must take a more precautionary approach and manage conservatively especially when potential overfishing will adversely affect the public share.

The QMS needs good quality scientific and harvest data to work. Incorporating recreational and subsistence fishing into the QMS would require frequent expensive surveys to monitor harvest plus more intensive management. Much more money would be needed for education and enforcement as rules and restrictions change.

option4 group knows that there is considerable uncertainty in the stock assessments and yield estimates. The Minister should take a precautionary approach to fisheries management considering the quality of data that he or she receives. The Public do not want an expensive QMS style management system for recreational fisheries.


Maximum Sustainable Yield

Is a system designed to extract the maximum commercial meatweight from a fishery capable of fulfilling the needs of non-commercial users.

The focus of the Fisheries Act 1996 is "sustainable utilisation". In the Act sustainability is described by Maximum Sustainable Yield (MSY). However there is no single number that defines MSY for any fishery. Although open to interpretation MSY is a useful tool for defining a level of fishing pressure that (in theory) maximises the annual growth (yield) in that stock. Having a high proportion of young fish that grow fast, and are quickly replaced if caught, produces a higher annual yield than large old fish.

Fisheries managed with the goal of maximising the biological yield will seldom produce quality recreational and sustenance fisheries, particularly when the best estimates of harvest or sustainable yield for many species are poor.

For example: Kingfish and kahawai are both important gamefish/ sportfish as well as being highly sought after by most other noncommercial and customary users. Managing fisheries such as these under the Maximum Sustainable Yield harvest strategy removes 75% of the biomass during the fish-down phase at best, or will leave the fishery near collapse at worst. The larger fish, removed during the fish-down phase, represent a critical loss of value to noncommercial fishers. Our kingfish fishery used to be one of the best in the world, now sadly most of these world record class fish have been exported to Japan for sushi; returning the commercial fishermen $5.00 or $6.00 per kilogram. Despite the fact that commercial fishers are not supposed to target kingfish, unless they have an endorsement on their permit which allows them to do so, a large portion of the fish have been taken by commercial fishers with no such endorsement. The recreational sector has gone to great lengths to try to preserve this fishery by introducing very low bag limits, large size limits and promoting tag and release fishing. Still the quality of this fishery declines.

In the case of kahawai the commercial fishing industry have used spotter planes to remove 75% of the once abundant schools, leaving the recreational fisher, on average, to travel four times as far as they used to in order to encounter a school of kahawai. In areas where commercial effort has been concentrated, many recreational and customary fishers seldom see any schools of kahawai.

The recreational and subsistence fishers want statutory input into the setting of clear management objectives that include the quality of key fisheries, not simply the weight of the harvest. Management objectives such as increasing recreational catch rates or the number of fish caught over a certain size will be required to change the focus of fisheries management.

In shared fisheries the option4 group want social, economic and cultural goals to be addressed when setting Total Allowable Catches. It is not enough to look at Maximum Sustainable Yield without considering Maximum Social Yield (benefit), Maximum Economic Yield or Maximum Cultural Benefit. Legislation must allow for an Optimum Yield to replace an estimate of Maximum Sustainable Yield when setting quotas for key inshore and pelagic species.

"Soundings," admits Option 1 will allow for the continual erosion of the public right to recreationally fish and harvest seafood. Options 2 and 3 will make the public a minor shareholder in a commercial fishery. It is unrealistic to expect the public to be able to resolve the above issue.

option4 totally rejects Options 1, 2 and 3 as presented in "Soundings", because they are incapable of protecting, let alone enhancing the public right to fish around New Zealand.

The Crown Position and Public Priority
The Crown, through the Ministry of Fisheries, has allowed the erosion of public fishing rights through the historical bias it has shown toward the fishing industry. Initially this erosion occurred through the Government encouraging and giving assistance to the commercial sector during the 1970s.

This assistance resulted in gross commercial overfishing of important inshore stocks in which the public also had an interest. In order to save the inshore stocks from collapse, and the fishing industry from destroying itself, the Government introduced the Quota management system (QMS) in 1986. Despite massive compensation being given to the commercial sector to reduce fishing effort, the fishing industry managed to circumvent this limitation by using the Quota Appeals Authority to inflate their quotas above the scientifically set level, which Government's own scientists said was the maximum level to allow the stocks to recover. Serious flaws in the implementation and enforcement of the QMS has allowed the fishing industry to exploit a myriad of loopholes which have seriously undermined the potential of the QMS . Many of these loopholes still exist today.

The New Zealand public is skeptical when the Government boasts of the QMS being a world leader in fisheries management. While the QMS may have some benefits in managing commercial fishing, many of these benefits are at the expense of the rights of all New Zealanders. The Crown did not question that Traditional Maori Fishing rights were seriously eroded by the introduction of the QMS, and has subsequently legislated a priority right in the Total Allowable Catch (TAC) setting process, and area rights to protect such traditional harvest. The crown has yet to acknowledge and address the injustice created by its favouritism of the commercial fishing industry over public access and harvesting rights in the sea.

The previous Labour Governments' interpretation of the commercial fishing right under the QMS, and how it interacts with recreational fishing, appeared to offer redress to the above situation. The following quote is from Labours' National Policy for Marine Recreational Fisheries: "Government's position is clear, where a species of fish is not sufficiently abundant to support both commercial and noncommercial fishing, preference will be given to noncommercial fishing. This position reflects Government's resolve to ensure all New Zealanders can enjoy and benefit from our fisheries."

It now appears that, Government's position is NOT clear. A recent ministerial reply to a letter from option4 seeking clarification regarding the status of the statements in the National Policy for Marine Recreational Fisheries informs us "There is some confusion about the 1989 fishing policy and I welcome the opportunity to provide some clarification. The previous Labour Government's fisheries Minister approved the policy. As Cabinet did not consider it, the policy does not have the status of a Labour government policy."
If cabinet did not consider it why does the policy infer full Government support, ie "Government's position is clear," and "This position reflects Government's resolve."
The recent ministerial reply also states "The situation is that neither recreational nor commercial have priority over one another."

The "Soundings "document initiated under a National Government makes exactly the same comment on page 6. Do both National and Labour parties have exactly the same fisheries policy, or is this mirroring of policy an example of strategic policy advisors in the Ministry of Fisheries driving their own privatisation agenda forward at the expense of the democratic process?

Whatever the reason for these mixed messages, it is seen by the overwhelming majority of noncommercial fishers as yet another attempt to further degrade the public's rights to fish and harvest seafood as progressive Governments continue to fail to address the fundamental issue of public fishing rights.


Labours' current fisheries policy ABRIDGED
Greater involvement of all stakeholders in management of the resource, which is the common heritage of all New Zealanders;
sustainable growth in employment and investment opportunities for New Zealanders; protecting and enhancing the quality of recreational fishing available around New Zealand

Recreational fishing is part of the New Zealand way of life.
Labour will:

• ensure New Zealanders continue to enjoy access to the recreational fishery;
• not impose a recreational sea fishing licence as a condition of exercising the individual right to go fishing;
• not require the recreational sector to operate within a quota, as though it was a commercial fisher;
• recognise the value of recreational fishing to New Zealand©ˆs tourism industry.

option4 cannot see how the Labour Government can possibly achieve its policy through Options 1,2 and 3 of the Soundings document. Option 1 allows further erosion of the public right while the other two options are quota-based and will require some form of compulsory levy or licence to provide the necessary level of compliance with that quota. The fishing industry would accept no less under a privatised, quota-based system. The NZ public are also skeptical that successive Governments would be able to retain compulsory fees or levies for fisheries management purposes, or resist the temptation to charge recreational and sustenance fishers for core Government services such as research and compliance costs.

The NZ public are no longer naive enough to be fooled into believing any compulsory tax, levy, tagging scheme, compulsory membership or membership which grants additional fishing rights to members, or any other compulsory scheme, is any different to licensing. The fishing public are also aware that the Option 2 and 3 proposals in "Soundings" are an initial step toward the privatising of the public's rights to harvest from the nations fisheries resources. Options 2 and 3 will also allow the Government to abdicate one of its core responsibilities, to ensure the public rights in fisheries are protected, and also to avoid compensation issues where the Crown has given fish needed by the public, to the commercial sector.

Any such attempts at privatisation are, and will continue to be, fiercely opposed by option4.

option4 holds the view that recreational fishing is indeed a right, which needs to be recognised as such. Such rights have priorities over other activities, a principle well established by Government with other rights-holders. Rights are not shares.

Some form of public priority must also be given for "protecting and enhancing the quality of recreational fishing available around New Zealand" if Labour is to deliver on its "NEW" fisheries policy!

The time has come where the Crown must face up to it responsibilities and resolve the injustices inflicted on the public's fishing rights created through the prior mismanagement and excessive favouritism shown to the fishing industry.

Leaving the allocation of the public right to the discretion of successive Ministers, (Option 1 in "Soundings") is not supported by option4.

We consider that the public of New Zealand have a "right to fish". We find the concept of a "recreational share" unacceptable, and probably unsustainable in law. We don't believe that it is, or should be, a political decision made by a Minister, but a preferential right defined in law. Furthermore we believe it has already been defined in government policy, we simply await the delivery on that promise.

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PART 3

Management, Funding and Representation

The Soundings document suggests the following management objectives (the order has been altered for clarity):
1. Recreational fishers can actively participate in management (fisheries and environmental).
2. A flexible dynamic management system is in place.
3. Good research/recreational harvest information.
4. Good enforcement and high levels of recreational compliance.
5. Sufficient funding exists for recreational fishing management.
6. Productive and cooperative working relationships between fishing sectors.
7. The public is involved in processes like research, management and compliance.
8. There is a statutory-backed network of mandated recreational groups.
9. Collective rights of future generations are protected.

option4 makes the following comments on management:
Objectives I to 5 are seen by option4 as essential in any future management structure.

Objective 6 can only evolve over time if the management objectives of each group are similar. Issues raised in this submission indicate they are not, and we cannot see how they can be made so under the three options presented in "Soundings."

Objective 7. The public is already involved through general taxation, used in funding research and compliance through the Ministry of Fisheries, and the employment of a Minister of Fisheries at the taxpayers expense. option4 considers this is appropriate and should continue.

Objective 8. While option4 agrees that there should be a network of mandated "recreational" groups we feel it is critical that these groups should be representative of all noncommercial users including diving, shellfish gathering, set netting, longlining, and also encompass food gathering/harvesting interests. It should not be compulsory for citizens to associate themselves with recreational fishing groups for basic sustenance rights to be recognised and protected. Most recreational fishing groups are currently relevant only for those enthusiasts who make a sport or recreational pursuit out of catching or gathering seafood. It is critical to broaden the consultative network to include all sectors who could be affected by decisions made by the consultative group.

We are unconvinced that such bodies need statutory backing and suspect this is proposed only to allow such statutory bodies to levy or licence those it would represent.

Objective 9. option4 does not consider the rights of future generations to be a collective right or a shareholding in a collective, but a fundamental individual right.

option4 has the following management principles:

• That the priority of recreational and sustenance fishers over commercial fishers be reinstated.
• That recreational and sustenance fishers be given an area right capable of excluding bulk commercial methods that deplete important noncommercial fishing and harvesting areas.
• A planning right that would ensure any fish conserved by recreational and sustenance fishers could be preserved for future generations and not be made available to be taken by the commercial sector.
• No licensing, levy or other compulsory funding scheme.

option4 has the additional objectives of:

1. Ensuring the development of a funding base sufficient for an independent representative body to undertake all of its roles and represent the interests of all non-commercial fishers and harvesters.
2. Ensuring the development of an effective and efficient national communication and decision making structure.

Management Representation
The Ministry, as agent for the Crown, has demonstrated itself incapable of, and unwilling to, represent the interests of the public sector who benefits either directly or indirectly from noncommercial fishing.

As the Ministry now wants to divest itself of any representational function, option4 advocates a national, independent, publicly elected body to represent the recreational anglers interests to Government.


Management Funding
It is the strong opinion of option4 that such an independent, non-governmental body (representing the interests of recreational anglers) should be funded through central government. We see the advocacy, management and protection of public rights as a proper function of government, and there are many different models of allocating funds to achieve this. We suggest that an activity undertaken by such a large portion of the population (which also directly benefits the wider public through the sharing of food gathered), to be at least, if not more important than, arts for example.

We would point out that through normal taxation large amounts of GST on recreational equipment and other activities associated with the fishing public are collected.

Recreational fishers also contribute large sums of road tax and GST on that road tax from petrol purchased for motors on boats that don't run on roads. This revenue stream is enough to support funding this representative group in the activities associated with managing their interests.

Government profits from, and has a vested interest in, commercial overfishing to the extent that it receives revenue through overcatch that is deemed to the Crown. This is effectively a tax on overfishing by the commercial sector. All fishing in excess of quota depletes the resource to a greater extent than the scientifically assessed safe limit. This overfishing will affect sustainability and any rebuild strategy in place at the time. The rights of other users will also be eroded to the extent of the overcatch. The punitive taxes gathered from commercial overfishing are also an appropriate source of funding for a recreational representative body.

The fishing industry received compensation of 46 million dollars in 1986 as a reward for massive overfishing. The fishing industry is due to receive another round of compensation as a reward for developing the kingfish and kahawai species as commercial fisheries, in spite of prior recreational claims that these fisheries were world class sport and big game fisheries. While this favouritism of the commercial sector and its associated costs are accepted by the Government, we cannot understand why the recreational and sustenance sector has not received financial support for a representative organisation. It is long past time that they did so.

Maori Traditional harvest will likely increase over time. The Government will have to ensure fish are available for these purposes and if necessary, will have to compensate the fishing industry for this increased harvest, or take it directly from the public share. The Government seldom resists providing resources for Maori Traditional harvest, why can it not show the same commitment to the rest of New Zealanders, including the "many Maori who cannot or choose not to fish under customary provisions" mentioned in Soundings.

Alternatively the funds could be split directly off from the Fisheries vote itself.

Soundings discusses the possibility of the Crown assisting with set up costs of a recreational representative body. Set up costs without secure ongoing funding will only result in a failure to achieve the management objectives as discussed.

A variety of additional funding mechanisms are discussed in Appendices 3 and 4.

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