15/9/02
The Minister of Fisheries
The Honourable Pete Hodgson

Dear Minister

We realise that this letter will arrive after the closure date for Stakeholder Submissions. However new, critically important and very material information has just come to hand. On Friday, 12/9/02 we received an email (from a member of the NZRFC Executive) that would indicate that the 1999/2000 NMRFS has been “confirmed”.

We were relieved to read in your Preliminary Views statement, dated 9/7/02, where you wrote “I note that the results of the 2000 recreational survey have not been confirmed as yet. I propose to take into account the results of that survey if the information is confirmed prior to the time of my final decision. I request stakeholders to provide specific comment on the issue of the recreational allowance for SNA 2.”

We note in the “new estimate” recreational catch from SNA2 may be as high as 720 tonnes.

The vast difference between the recreational catch estimates now on the table, 40 tonne advise/recommendation from the Ministry and 700 plus tonnes from the latest available information (1999/2000 NMRFS) must generate serious doubt about where to set the critically important TAC for SNA 2 and what if any surplus is available to increase the TACC.

Minister, when you directed your Ministry to re-run the stock assessment model with a higher recreational allowance, which recreational allowances did they run? If they did not run 360 tonne (1/2 of the highest estimate available) and 720 tonnes (the highest available estimate of recreational catch) we ask that you do this before you make your decision, so that the full range of catch estimates can be adequately considered in your decision.

At this juncture we would also draw your attention to the warning offered by the reviewer, Bob Kearney (paragraph 6.2 page 20):- “I also caution against the presumption that because some of the harvest estimates from the national surveys appear high they are, by necessity, incorrect. In the absence of quality data perceptions of the magnitude of recreational fish catches have, world-wide, tended to under-estimates”

We interpret this to mean that the recreational catch of snapper in SNA 2 could be at the upper end of the new estimates.

We also ask that, at the forefront of your decision, you bear in mind that the whole proposal to increase the TACC in SNA 2 is based on the unobserved and unvalidated claims of commercial fishers that their incessant overcatching of the TACC has been unavoidable. We ask that you direct your Ministry to tally up this years Commercial Catch Returns received to date, to see if the overcatch has persisted in the light of the new ACE regime in place for this current fishing year. We believe that the constant, historic problem of overcatch should have been largely addressed by this new regime.

Furthermore , we believe it prudent to get a better estimate of the recreational catch to remove this additional uncertainty from your decision. We strongly believe it is wrong to use, seriously flawed recreational catch estimates from 1996 when considering increasing a TACC increase.

We ask that you follow the precautionary principles of the Act and do not increase the TACC until the estimates of recreational catch for snapper in SNA 2 have been determined with acceptably low CV’s (sampling error).

We ask you, once again, Minister, to reject Ministry proposal and to not increase the SNA 2 TACC in the light of such uncertainties.

Yours faithfully

Scott Macindoe
option4 spokesperson