|
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.
|