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Firstly, congratulations
to the group, for producing a good site that is providing people
with an opportunity to air their views and carry on the debate.
I am pleased to hear that option4 is now declared to be "at a preliminary
stage", and "embryonic" and the admission "that there is much to
be done before a fully-fledged proposal is developed". This is in
a much different place than as first claimed, i.e. being "The Answer".
I am also pleased to hear that the group wants "to remain open minded
through the consultation process" however this statement is somewhat
at odds with the statement that "option4 representatives are not
negotiable on the following objectives and will demand the following."
There has been
the suggestion that an option4 representative should be part of
the group that reviews the submissions to Soundings. "Not negotiable"
is not a suitable qualification for any member of any review group.
In replying
to those people who replied to my response, let me say that I agree
with all of them that a clear definition of the Public Marine Fishing
Right is the first and foremost requirement to come from this consultation.
I guess that I took that as read and moved on into the nuts and
bolts of protection, management and enhancement of that Right. That
has been described as putting the cart before the horse, however
what the Soundings discussion has initiated includes, the cart,
the horse, the load, the destination, and the itinerary of overnight
stops and provisioning required, for a really long journey.
I also agree, therefore, that it would be very appropriate, as suggested
in the option4 Group response, that a two tier round of consultation
take place, to first have the Public Marine Fishing Right clarified
and approved by Cabinet. Then a follow up round on; a structure
to represent it, the resources required and how they will be obtained.
However there
are other aspects of the replies that need some further discussion.
- All replies
that suggest that the Soundings Document has nothing to do with
defining recreational rights are wrong. A defined share, proportional,
priority, or any other form of share, of the TAC, is a definition
of the recreational right. Just as the QMS, and in particular
ITQ, i.e. a defined share of a fishery, defines the commercial
right.
- Despite
the option4 group's belief that the '89 Policy gives recreational
a priority over commercial, that is quite simply not true, unless
the particular fishery is reduced to a state which cannot support
both sectors. So in all our shared fisheries, we are entitled
to a "reasonable share" as stated in that Policy. We never had
priority, we have not lost a priority, and we are unlikely to
get a priority unless we are prepared to buy commercial out of
their share.
The '89 Policy with it's "reasonable share" is no more defined
than the Soundings discussion on a "fair share" and option4 has
not made any proposal on an improvement of that definition. The
clearest definition of the Right can only come from a specific
share, in the shared fisheries.
Of course, defining that share has to include allowance for growth
in the population and acknowledgment that noncommercial goals
in the fishery are different to commercial because, in any year,
we want some fish in our share to be not caught so that they can
grow to be bigger ones.
Also if noncommercial and commercial are declared to be 50/50
stakeholders in the shared fisheries there is no need for a priority
for noncommercial. Each half of the stakeholding has to be equally
cognisant of the other's objectives in the fishery. More on this
when we get back into the SNA1 discussion.
- Licensing
is neither a red herring nor is it in the Soundings Document "to
divert attention away from the real issues.." In Soundings, it
is merely one of six suggestions on possible ways that recreational
representation could be funded. It is the option4 group that
has pushed it up to being the number one issue. More importantly,
if the Fish and Game model of licensing were used, it would provide
much more than just a way of equitably obtaining funding from
all fishers. It also provides a statutory status for a defined,
accountable structure to represent recreational fishers and the
best possible database to supply a mandate for that structure.
In this model licence fees do not go to the Government, they belong
to the structure which sets them.
I have been to three Soundings meetings in the BOP and heard the
loud and clear call for no licensing, however manipulated that
was. OK. We can settle for something less than the best way of
providing our equitable funding, statutory status and the mandate
from a database of all people who go fishing. But if there is
to be no compulsory form of funding then there must be considerable
improvement in voluntary funding. I hope you will all come out
in droves to join the NZRFC. And not just as some $1 per head
levy from clubs but as individual $25 members. There are other
funding options to explore and they are coming forward, all of
them will be more achievable if we have shown that we care enough
about our fishing to come up with sustainable self-funding.
- There was
also comment in the replies on whether we do or don't want to
participate in management, or, if we do, how much. WE DO. WE MUST.
We already do, under the status quo, to our voluntary, under-funded
best. I repeat my statement from my first response. ALL OPTIONS
(INCLUDING ANY OTHERS THAT COME FORWARD IN THE PROCESS) REQUIRE
RECREATIONAL REPRESENTATION TO ACHIEVE BETTER REPRESENTATION OF,
AND PROTECTION FOR, THIS VERY IMPORTANT RIGHT AND SHARE OF THE
FISH, THAN WE ARE CURRENTLY ACHIEVING. At all of the meetings
that I have attended, there was a clear call for our involvement
in management.
- Many people
have been very quick to be critical of the performance of the
NZRFC, of its place in producing the discussion document and of
its current performance in endeavouring to represent the public
fishing right in the MFish management process. Well, it is a council
formed from its constituent membership and will only ever achieve
to the level that it is supported. By people who are prepared
to step up to the mark and get involved. By people who are prepared
to provide the financial backing that it needs. Anybody can stand
around and criticise from ringside but the people who are stepping
up to the mark to represent the NZRFC are volunteers, untrained,
unpaid, prepared to contribute their time and resources to get
the job done. Any of the critics who think that they can do the
job better are more than welcome to step up and add to the team.
- Much has
been made of the issue of the Crown not wishing to raise compensation
issues with commercial, as if this was some kind of dodge of responsibility.
Any responsible Government should do its utmost to avoid compensation
because it is taxpayer money "gone down the drain". It is taxpayer
money paid to a few individuals, money that will come off the
budgets for police, education, hospitals, doctors, nurses, mental
health, victim support, etc. The other point on this issue is
that if commercial and noncommercial are declared to be 50/50
stakeholders in the shared fisheries there is no need for compensation
at all.
- My comment
on Orange Roughy were not meant to belittle the problems and issues
in that fishery, it's just that there are more than enough issues
in the fisheries that we do fish in.
- Which brings
us back to the Snapper 1 discussion. The replies suggest that
there was not a clear understanding of my proposal, maybe that
was my fault in not providing a clear enough explanation. I know
that the current noncommercial share of the total harvest is about
36%. What I suggested was that the commercial and noncommercial
sectors could be declared to be 50/50 stakeholders in that (and
maybe any other) fishery. This is regardless of what the proportion
is in the harvests. That 50/50 relationship would need to be declared
in the Fisheries Act.
There is the
requirement in the Fisheries Act to operate all fisheries at or
above Bmsy. Snapper 1 is expected to be there by 2020 and then able
to support a 10,000t harvest. Commercial, at 4,500t, already has
most of their half of that fishery so will not get any further increase
in TACC until it can be shown that their half share equals more
than 4,500t (i.e. when the fishery is back at Bmsy).
If the noncommercial (recreational and customary maori) harvest
is currently at about 2600t and our half share is 5,000t then we
will have almost double the current fishery to accommodate our future
requirements. We will not necessarily increase our rate of harvest
at any greater rate than is current so the rate of rebuild is not
affected. (There has been little done in the way of forecasting
how our rate of harvest might increase when there are more fish
in the water but we have to deal with that whether under the status
quo in management or any other option) However we are still unlikely
to be harvesting up to our entire share until a long way past 2020.
I agree with the comments that operating the fishery above Bmsy
does not increase the total yield but it does allow more fish to
become another year older and therefore the fishery contains more
fish that are bigger. This is one of the noncommercial objectives
in the management of the fishery.
So a declared
50/50 stakeholding in this fishery, of up to 5,000t each, does fit
within the known sustainable yield, does not require any TACC reduction
(dependent on future stock assessment advice), does not require
compensation, does not require a priority for either share and can
meet the objectives of both sets of stakeholders.
Once again thanks
to the group for providing this forum to debate the issues. I still
believe that there is a long way to go in working out how to implement
a defined Public Marine Fishing Right and that a structure and the
resources required to protect, manage and enhance that Right are
as important as the definition.
Peter Ellery
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