| |
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;
a) The total
removals from any fishery must be constrained to a sustainable
level
b)) The QMS provides good economic and biological outcomes for
fisheries management
c) Amendments
to the regime should not undermine the Deed of Settlement
d) 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;
a) 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
- 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.
- 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.
- 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.
- 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.
|
