Submission: Review of Sustainability Measures for Blue Cod (BCO 7) for 2022/23
22 July 2022
Fisheries Management, Fisheries New Zealand
FMSubmissions@mpi.govt.nz
Review of Sustainability Measures for Blue Cod (BCO 7) for 2022/23
Introduction
Fish Mainland is an incorporated society with charitable status 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. In so doing, Fish Mainland works collaboratively with government, tangata whenua and others to bring about the best public outcomes.
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 more Directors and an independent Chair of the Board.
Elected and appointed Directors of the Board demonstrate Fish Mainland's mandate to represent South Island recreational fishers Recreational Fishing South Island NZ - Fish Mainland
Submission
Fish Mainland supports Option 2 that sets the Total Allowable Catch (TAC) at 157 tonnes, Total Allowable Commercial Catch at 58 tonnes, customary allowance at 27 tonnes, recreational allowance at 58 tonnes and allowance for other sources of fishing-related mortality at 14 tonnes.
We consider this more cautious option best addresses the establishment of the TAC at a time when the fishery is likely below target and indicators are pointing to fishing pressure reducing the size and abundance of blue cod, particularly in the Marlborough Sounds.
Fish Mainland supports actions that provide greater likelihood of rebuilding the stock towards the target. We acknowledge the shared nature of this important fishery, and recreational fishers’ contributions to rebuilding it (e.g., daily bag limit reductions in some parts of BCO 7).
It follows that all fishing sectors should collaborate in examining other actions for rebuilding the fishery (e.g., addressing land-based impacts on spawning and juvenile habitat and other impacts on the aquatic environment), as opposed to simply viewing the solution as another reduction in recreational effort.
Furthermore, Fish Mainland supports discussion on other management considerations, such as closed season, rotational season, and reductions in incidental mortality to reduce localised overfishing that would help to rebuild the stock, along with improving social, economic, and cultural wellbeing, which would require further consultation.
Finally, Fish Mainland supports addressing the shortcomings of the National Blue Cod Strategy, such as the Strategy not specifying the information needed to legitimise colour
changes in the traffic light system. For this purpose, Fish Mainland has promoted fisher self-reporting of catch and effort data to better inform management decision making.
Self-reported data collection provides a cost-effective solution to legitimising colour changes across any of the blue cod zones. The veracity of these changes is critical to gaining recreational fisher buy-in for the traffic light system.
Self-reported data collection could also address the shortcomings in the Strategy that make it illegal for fishers to transit from one zone with a daily bag limit to another zone with a lower daily bag limit or to be able to fillet blue cod at sea.
For these purposes, Fish Mainland has worked with Fisheries New Zealand to design and develop a self-reporting system first applied to the South Island blue cod fishery, aptly named Mainland Catch.
Mainland Catch, coupled with minor regulatory amendments, could address all the shortcomings of the Blue Cod Strategy, and greatly improve the management of this important fishery.
Yours sincerely,
James Crossland
Chair of the Board
info@fishmainland.nz
