Submission: Review of sustainability measures for BCO3 for 2021/22

Addressed to Inshore Fisheries Management, Fisheries New Zealand, FMSubmissions@mpi.govt.nz on 27 July 2021

Introduction

Fish Mainland is an incorporated not-for-profit organisation whose purpose is to coordinate and assist the South Island marine fishing community in restoring and sustaining fisheries resources for the benefit of all who fish in South Island waters.

Fish Mainland is a member-based organisation. The Members have democratic control over the organisation through the power to nominate, elect and remove 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.

Submission

Fish Mainland supports Fisheries New Zealand in proposing options for setting a TAC and allowances (customary, recreational and other sources of mortality caused by fishing) for this important South Island shared fishery.

Considering the limited available information and the unknown status of the stock, we support the more conservative Option 2 in setting the TAC at 243 tonnes, Māori customary non-commercial fishing allowance at 20 tonnes, recreational fishing allowance at 83 tonnes, allowance for other sources of mortality at 10 tonnes and reducing the TACC to 130 tonnes.

However, we oppose Option 2 reducing the recreational allowance after the Blue Cod Strategy’s recent implementation imposed traffic-light colours on specific areas (without consultation) and associated reductions in daily bag limits, which already reduced the recreational allowance.

Finally, we submit that deemed values should increase to reduce the incentive commercial fishers would have to use them to balance over catching.

Thank you for the opportunity to provide input into these important and significant decisions.

Yours sincerely,

James Crossland

Chair of the Board