Submission on re-opening the Kaikōura shellfish and seaweed fisheries

Introduction

Fish Mainland is a recently incorporated not-for-profit organisation designed by a Working Group comprising South Island and Stewart Island recreational fishers. They designed it to be a fully functioning professional organisation that coordinates, represents and promotes the diverse interests of the 100,000+ fishers who fish in the marine environment, and works to restore and sustain fisheries resources to maximise fishers’ experiences and opportunities.

Fish Mainland is a Member-based organisation. The Members have democratic control over the organisation through the power to nominate, elect and remove five Regional Directors of the Board. Also, the South Island Mandated Iwi Organisations can appoint and remove two other Directors. The Board appoints two more Directors and an independent Chair of the Board. 

Elected and appointed Directors of the Board demonstrate Fish Mainland’s mandate to represent recreational fishers. The election of Regional Directors will occur 31 October 2020, and the appointment of other Directors will occur soon afterwards.

Accordingly, this submission is made without any mandate to represent. However, it does reflect what the Working Group, as acting Directors, considers is aligned with the views of the majority of South Island and Stewart Island fishers. It is also aligned with the views of Te Korowai and the Kaikoura Marine Guardians.   

Fish Mainland highlights the re-opening of the fisheries provides the opportunity for locals to be creative with the kete of management tools and bold in trying new combinations of tools, so long as they collectively limit catch to science-based sustainable levels and the tools are adaptive as new information is made available.

Submission

Fish Mainland would like to raise three important issues for consideration, which are largely from a non-local perspective.

First, while the focus of this engagement is appropriately directed at the Kaikōura community, it is important to phrase the management challenge more broadly. This is because decisions on whether recovery has occurred sufficiently to warrant re-opening the Kaikōura fisheries must take into account a variant of the 80-20 rule; while locals may take around 20 percent of the shellfish catch in the Kaikōura area, 80 percent is taken by fishers from outside that area, particularly those who transit through or relocate for periods of time, such as over the holidays.

Accordingly, decisions about the appropriateness of the kete of management tools must consider the significant amounts of harvest by non-locals and their likely response to those tools. In other words, the decisions by locals for re-opening the fisheries can and should have a significant impact on the behaviours of and opportunities for non-locals fishers in the area.

Second, Fish Mainland does not hold sufficient knowledge on the state of the shellfish fisheries to make informed comment on whether they should re-open soon. That aside, our position is that the pāua fishery should not re-open unless it is able to sustain a daily catch limit of 4-5 pāua per person, as this amount would allow a family to have a meal. It would also adequately reflect the effort necessary to harvest them.

Furthermore, a 2-day accumulation limit would hit non-locals hardest. It is our understanding that the original 2-day limit was a response to concerns about poaching when the limit was 10 pāua per day. When stock status allows, the accumulation limit could be reviewed up to a maximum of twenty.

We applaud consideration of vehicle and vessel limits and would see them set fairly at a 4-5 pāua daily limit per person.

Our position on the MLS of pāua is that smaller catch sizes lead to less pāua being disturbed. So, we would recommend the size limit remains unchanged and be uniform across the region and without closed areas for pāua only with the aim is to simplify compliance and enforcement.

However, a closed season on pāua could be preferable if it offset a slightly higher daily limit in the open season. For example, a 5 pāua per day limit with a closed season for the period June to September might be workable.

Finally, Fish Mainland agrees entirely that information on recreational harvest levels and locations is critical for on-going management of the pāua fishery. Without this information, management tools cannot be adequately adaptive. Improved information gathering is urgently needed and, therefore, should be a high priority outcome for this consultation process.

The consultation document discusses recreational fisher self-reporting, though the discussion is mostly limited to required reporting and inherent problems in estimating total catch. 

In contrast, Fish Mainland has developed a voluntary self-reporting system with Fisheries New Zealand to collect information that indicates increases or decreases in recreational catch and effort to better inform decision making; it does not attempt to estimate total catch.

This system was initially designed to improve the management of blue cod stocks via the new traffic light system (e.g. colours change as available information suggests the state of the fishery is improving or declining). The system was developed because the National Blue Cod Strategy has not specified the information needed to legitimise colour changes across any area.

The system is like the longstanding voluntary arrangements for collecting CPUE data for the commercial rock lobster fisheries. Over time, these voluntary arrangements have continued to improve so that the data provided have become integral to stock assessments.

The system could include collecting information on pāua catch and effort and in ways that assist locals’ involvement in its development and implementation (e.g. reinforce fine-scale reporting). The intention is also to have specific reporting codes so that participating groups could regularly receive reports on their collated catch and effort information and aggregated anonymised information would be made available to the public.

A complementary way to gather information on recreational catch and effort is to undertake roving surveys along the Kaikoura coastline. While traversing the publicly accessible sites by road, surveyors could count the number of fishers and conduct interviews to gather information on the size and number of pāua harvested as fishers return to their cars. This methodology could assist in estimating total catch and verifying trends in the self-reporting system.

Fish Mainland considers these two information gathering methodologies would be more acceptable to non-local fishers and Government than a system requiring fisher registration or reporting, though such a system would provide a valuable sample frame for randomised surveys to obtain representative catch data that could be extrapolated to estimate total catch.

Fish Mainland also considers that a condition of re-opening the pāua fishery should be an annual review with reported results and stock estimates published and feedback sought before catch levels are set for the coming year.

Since charter boats already have required reporting of catch of certain species, it would be feasible to add pāua to the list for required catch reporting.

Thank you for the opportunity to provide input into this significant decision. We commend your thoughtful effort in putting together the consultation document.  We are happy to have further discussions on the above issues at your convenience.

Yours sincerely,

James Crossland - Acting Chair of the Board