It is a pity that Peter Ellery was not in attendance at the public meeting concerning Soundings at the Papatoetoe High School on Wednesday 6th September, 2000.

At this particular meeting a question was posed to Jennie McMurran who works for the Ministry of Fisheries Strategic Policy Unit. Jennie was also heavily involved in creating the Soundings Document. Jennie was asked

'What are the primary objectives of MFish Strategic Policy in the Soundings Document and in the redefinition of the publics right to fish in the sea?'

Jennie clearly stated that their primary objective was to cap or limit the recreational catch.

Jennie also confirmed that the Policy Units' secondary objective was to accomplish this capping of the publics catch without raising compensation issues which would be created if the Crown had to purchase back commercial fishing quota to satisfy increasing public needs in our inshore fisheries.

The above admission from the Strategic Policy Unit completely confirms the worst fears of the option4 group. The Policy Unit clearly wants to limit our catches to current levels at best, or to a lesser level at worst.

Unquestionably, it turns out that the option4 action groups' "alarmist and confrontational response" as Peter Ellery puts it, is right on the money! In my opinion, this also clarifies why the Soundings Document does not deal with the fundamental issue of "What is the recreational right?" or "How will we define the individual recreational fishing right?"

As far as the Document is concerned, this definition is already resolved. Either we will have a "Proportional Share" (Option 2 and Option 3), or we will have the Status Quo (Option 1).

All three options allow the continued erosion of non-commercial rights and in reality there is little difference between the three of them. If we do not unite and tell Fisheries Managers exactly what we want, either the Status Quo or a fixed Proportional Share will be forced onto us and our individual rights will diminish forever.

A divided voice of varied submissions is exactly what the Ministry is trying to achieve, and I believe the Licensing issue is only raised in the Soundings Document to divert attention away from the real issues stated above.

I note that Peter Ellery suggests "option4 is merely a statement of policy intent for implementing Option 3 from Soundings". I can only assume that either he has not read option4, or when he read Soundings he has not fully understood that Soundings has nothing to do with recreational rights, or the improvement of those rights. It is all about processes. These processes are focused on a single objective, which is to constrain or limit recreational catch, and prevent any future growth in that catch.!!!

option4 is completely and unquestionably different from Option 3 in Soundings.

I am concerned, considering Peter Ellery's position in the Recreational Fishing Council, that he appears to be prepared to accept a management structure or change in the way recreational fishing is managed prior to, and regardless of, how our rights are to be expressed or defined.

I also note that in his opinion, "the Soundings Document asks us how we want to manage our fisheries rights into the future." I disagree. The Document asks "if we want to participate in management, and if we do, at what level that participation might be". Options 1 and 2 are certainly not about non-commercial participation in management.

The option4 action group is clear that the objective of defining the recreational right must be separated from the management and funding issues associated with that right. To do otherwise allows the Government to simultaneously determine both the extent of the non-commercial right, and the associated management of that right, a very risky proposition. We could easily be lumbered with a weaker right than we currently have, complete with a huge beauracracy to manage it, which we will be asked to pay for!!!

I agree with Peter that 28D in the 1989 policy statement is weak, this is why option4 has a set of principles to guide the formulation of the non-commercial right.

In response to Peter Ellery's comment "We do not need to discuss Orange Roughy, we don't catch them", I feel that demonstrating the fishing industry's inability to sustainably manage a fishery, in which they are the only user, should act as a warning to non-commercial fishers who may not realise the risks of becoming minor shareholders in a commercial fishery. I could have used Snapper, Kingfish, Kahawai, Scallops, Broadbill or a variety of other fisheries as an example of the dangers of either a proportional share or the status quo as proposed in Soundings.

I note that Peter Ellery has attempted to use a snapper 1 (Sna1) management plan to demonstrate his views on how to manage this important fishery and to provide for the future needs of non-commercial fishers. I make the following comments on Peter's plan. The recreational sector are not 50/50 stakeholders in the Snapper 1 fishery. The commercial sector has a 4500 Tonne TACC, Maori Traditional have a 300 Tonne allowance and recreational fishers have a 2300 Tonne allowance. The total allowable catch is 7100 Tonnes. The recreational sector currently have just above a 30 percent stake holding in the Snapper 1 fishery.

If the MoF Policy statements reported elsewhere in this reply concerning the Crown's reluctance to purchase commercial quota to allow for future increases in non-commercial demand are valid, the non-commercial sector will not become 50/50 stakeholders in the Sna1 fishery unless the fishing industry gives quota to the recreational sector.

Peter Ellery suggests that the recreational sector can reap the benefits from the rebuilding of the Sna1 stock until their catch is equal to that of the commercial sector at 4500 Tonnes. The Snapper 1 fishery is currently at around 60% of Bmsy and, it is predicted that at current catch levels, this fishery will rebuild to Bmsy by 2018. Peter Ellery's plan allows recreational fishers to benefit from the rebuild through increased harvesting during the rebuild until their catch equals 4500 tonnes. This means that recreational fishers will harvest additional catch. As the 2018 rebuild to Bmsy is predicted only under current harvest strategies the rebuild of the Sna1 fishery will be further delayed beyond 2018 by this increased catch level which in fact, is likely to prevent a rebuild to Bmsy within our lifetimes.

Peter Ellery's proposed catch level of 4500t commercial and 4500t recreational plus the present Maori traditional catch of 300t considerably exceeds the maximum yield available under any scientifically assessed sustainable management strategy that will allow for rebuilding the Sna1 fishery.

Peter Ellery then predicts that even under this unsustainably high catch level the fishery will continue to grow and exceed Bmsy to fulfil the management objectives of both commercial and recreational fishers. Surely Peter is not suggesting we can harvest more than the maximum sustainable yield? This is impossible in a sustainably run fishery!

I note that Peter Ellery has omitted Maori Traditional fishers from his plan. Where will the additional fish required to meet increased demand from Maori Traditional users come from? I believe that Peter Ellery's Sna1 plan is incapable of delivering a recreational catch of 4500 tonnes in the foreseeable future Peter Ellery's statement in his snapper plan that "We have nearly double the current fishery to grow into, this can go a long way in compensating us for catch history reductions and providing for growth of the sector harvest into the future," is obviously seriously flawed. How then does he propose the recreational sector be compensated for the past commercial over fishing and recreational catch reductions in the Sna1 fishery.

Peter Ellery notes in his plan that "each sector has to equally consider each others objectives because they are equal stakeholders." He then suggests the recreational sector be made 50/50 shareholders in every fishery they have an interest in.

While Peter Ellery incorrectly proposes no compensation issues will arise from his "snapper plan" how does he propose to avoid the compensation issues with other species? Crayfish quota is valued at $130,000 plus per tonne and Paua in excess of $200,000 per tonne. Will these commercial fishers also willingly give up their quota? The only practical ways of increasing the available yield in a fully developed fishery which is at Bmsy is to either, change the harvest strategy to reduce wastage, or improve compliance with the total allowable catch (TAC).

In the Sna 1 fishery serious incidents of dumping, black-marketing, highrading, deeming and non-reporting of catches have all occurred. Many undersized snapper are also killed. While both commercial and non-commercial fishers are guilty of wastage and theft, the potential for the commercial sector to threaten the rebuild of Sna1 is far greater than any current threat posed by the non-commercial sector. The easiest way of achieving yields above the currently predicted maximum, is to improve the harvesting strategy by either reducing wastage or improving compliance with the TAC.

Unless each sector has an incentive to improve compliance or reduce wastage it is unlikely this will ever happen.