Submission on: SNA 1 Initial Position Paper 2013
On behalf of: Ashley, Susan, James (7 years) and Kimberley
Harris (5 years) of Whangarei Heads
Supporters
of Legasea.
Date: 23rd August 2013
Signed:
Ashley Harris Susan Harris
Table of Contents
1 Introduction.......................................................................................................................... 3
2 Parties to this submission...................................................................................................... 3
3 Key issues............................................................................................................................. 3
3.1 Vulnerability of the fishery............................................................................................. 3
3.2 Glacial and fragile stock recovery.................................................................................... 4
3.3 Overly optimistic scenarios............................................................................................. 4
3.4 Critical information gaps................................................................................................. 5
3.5 Unsustainable current management by all parties.......................................................... 6
3.6 Competitive attitudes.................................................................................................... 6
3.7 Need for change............................................................................................................ 7
4 Relief sought - recommended strategy.................................................................................. 7
5 Conclusion............................................................................................................................ 8
6 Appendix 1: Key observations............................................................................................... 9
7 Appendix 2: References...................................................................................................... 15
1
Introduction
This is a submission on the Ministry of Primary Industries’
(MPI’s) Initial Position Paper on proposals for sustainability measures and
other management controls for SNA 1 for the October 2013/2014 fishing year, MPI
Discussion Paper No: 2013/31, July 2013 (IPP).
The submission comprises the following sections:
Section 2:
Parties to the submission
Section 3:
Key issues
Section 4:
Relief sought – recommended strategy
Section 5:
Conclusions.
2
Parties to this submission
This submission has been prepared by GreenXperts Limited
(GreenXperts) for and on behalf of:
·
Ashley and Susan Harris of Whangarei Heads;
·
Their children, James (7 years) and Kimberley
Harris (5 years) of Whangarei Heads;
·
Any descendants of Ashley and Susan Harris; and
·
Members, affiliates and supporters of Legasea.
The professional analysis, advice, opinions and
recommendations contained within this submission have been prepared for the
information of the parties to this submission, and are consistent with
Legasea’s policy to promote the rebuild of snapper stocks in SNA 1. However they do not represent the official
position of Legasea or the New Zealand Sport Fishing Council (NZSFC).
3
Key issues
3.1
Vulnerability of the fishery
The science summarised in the IPP informs us that:
·
Snapper are a low productivity stock, and
therefore vulnerable to over-fishing;
·
SNA 1 snapper grow the slowest in all of New
Zealand, and they have weaknesses in their age class structure (certain age classes
are missing);
·
Snapper growth rates are declining;
·
SNA 1 stocks are severely depleted, having
suffered an 85% decrease from 1900 to 1997;
·
Some discernible recovery in the stocks has
occurred in the past ten years following restrictions in total allowable catch
(TAC);
·
However long term trends indicate that snapper
stocks are still declining;
·
Habitats of particular importance to snapper are
known to exist, but are not well described or protected;
·
Snapper experience commercial and recreational
fishing pressure when spawning;
·
Land use activities pose threats to snapper
nursery habitats in estuaries and harbours; and
·
Snapper are the most intensively sought after
commercial and recreational marine fish in SNA 1.
It can be concluded that the SNA 1 snapper fishery is a very
vulnerable fishery that continues to experience intensive predatory pressure
from commercial and recreational fishers.
3.2
Glacial and fragile stock recovery
The 2013 spawning stock biomass (Bx) assessment
reported in the IPP informs us that:
·
There was a massive 85% drop in stocks from 1900
to about 2000, almost to collapse levels.
The fishery was decimated over a period of 100 years, particularly by
foreign commercial vessels in the period 1960-1980;
·
A very slow recovery occurred from about 1997
onward, following the imposition of catch limits. This recovery has been at a rate of about
0.25% per year;
·
At this
rate, it would take another 80 years (2093) to recover to target B40
level. That is, a recovery period of
about 150 years from the last time the stock was at B40 (pre-WWII[1]);
·
Statistically speaking, it could be argued from
the presented error and uncertainty analyses that there has actually been very
little recovery since 1997, and therefore the fishery is still in a critically
vulnerable state;
·
It could also be argued that anecdotal reports
of recovery in estuaries and harbours are the result of reduced commercial
fishing pressure (due to catch limits imposed in 1997), temporary favourable weather
conditions within harbours (targeted by recreational fishers), an increasing
recreational fishing population (more people on the water therefore more
anecdotal reporting), and the enthusiasm of fishers; and,
·
The 2013 expert opinion on stock status is that
the stock remains over-fished by all fishers.
The data shows that the stock recovery is glacial and
fragile, and probably highly sensitive to seasonal environmental conditions and
fishing pressure.
3.3
Overly optimistic scenarios
Despite the very competent summary and presentation of
fisheries science in the IPP (which includes statistical information,
modelling, and caveats encouraging caution), some overly optimistic scenarios and
management options are proposed, with the science being misapplied.
In particular, a TAC of 9,000 tonnes is proposed over next
five years, with a claim that there would be minimal impacts upon the East
Northland and Hauraki-Bay of Plenty sub-stocks, since this level of TAC would
only last five years. This projection is
based upon “recent average recruitment levels”, which are themselves a product
of a TAC of 7,550 tonnes (less fishing pressure). A TAC based on long term recruitment levels
suggests 3,800 tonnes might be sustainable, so it is extremely unlikely that a
TAC of 9,000 tonnes would represent a Maximum Sustainable Yield (MSY) for the
fishery.
Within the context of the high demand and high expectations
on the fishery, it is considered dangerously irresponsible to make such a
suggestion. The precautionary principle,
an important and accepted principle of sustainability management, should be
part of the MPI ethos when managing vulnerable natural resources. Overly optimistic scenarios should not be
proposed, as they could create dangerously unrealistic expectations in many
quarters.
3.4
Critical information gaps
The summary of science reveals a number of critical
information gaps that need to be addressed before adequately informed
management decisions can be made. The
most important gaps are summarised below in Table 1.
Table 1: Critical information gaps
|
Topic
|
Information gap
|
|
1. Snapper growth
and productivity
|
Why do snapper in SNA 1 grow the slowest in NZ?
Why are snapper growth rates declining?
|
|
2. Effects of
climate change[2]
|
Better recruitment in warmer weather - positive impact of climate change
(warming sea)? Balanced against
negative impacts of ocean acidification?
|
|
3. Value of
commercial fishery
|
Probably under-reported as no work on industry economic multipliers,
opportunity costs, asset replacements and influence of technology, export and
domestic market demand trends appears to have been done. These are standard economic analyses, and
it is surprising that they have not be completed and presented.
|
|
4. Value of
recreational fishery
|
Value of the recreational fishery in SNA 1 is extraordinarily
under-studied and under-reported given its scientific and political
significance. A proper economic assessment
of the full economic and social value of recreational fishing to the NZ
economy and its community is needed.
These demands need to be monitored on a year-by-year basis, and
matched to demographic studies on projected population growth and recreational
fishing demand.
|
|
5. Demographics
of recreational fishery – future demand assessments
|
Research needed on demographics of SNA 1 to help project future fishing
demand, in particular recreational demand.
It is remarkable that to date, no proper demographic studies have been
completed on this critical social and economic aspect.
|
|
6. Fishing
mortality – non-harvest
|
Is commercial and recreational non-harvest mortality similar?
Can industry-led research on fishing methods help discover ways to reduce
unintentional non-harvest mortality?
|
|
7. Habitats of
particular significance for fisheries management
|
Critical to research location and extent of these areas and protect them.
|
|
8. Effects of
fishing on spawning
|
Critical to research these effects and protect key spawning areas.
|
|
9. Benthic
interactions
|
Critical to research these effects and make management adjustments where
necessary.
|
|
10. Ecosystem
indicators – eg. maximum size of fish in Hauraki Gulf decreasing, declines in
fish diversity in shallow waters – these are bad signs
|
Critical to research these indicators and make management adjustments
where necessary.
|
Source: Appendix 1
Fortunately many of these
gaps could be closed fairly quickly over the next two years. Considerable research is already underway,
and the topics in Table 1 could be added to existing research projects where
practical, or additional research projects commissioned to run alongside
them. Some of the topics are relatively
short term projects (eg. full value of commercial fishery); others are long
term with management monitoring elements (eg. ecosystem indicators). If not covered by existing projects,
topics 7-10 could be combined into one research project.
3.5
Unsustainable current management by all parties
The 2013 expert assessment provided by the 2013 Fisheries
Assessment Plenary concludes that the SNA 1 stock is over-fished by all fishers
– commercial and recreational. All
parties are responsible for the unsustainable management of the SNA 1 snapper
stocks.
The IPP states that there needs to be a 56% reduction in TAC
to rebuild the fishery to B40 levels in a 16-24 year period. If such is achieved, it would be towards the
end of Ashley and Susan Harris’ lifetimes.
Their children James Harris would be 26-34 years old, and Kimberley
Harris 21-29 years old.
Tragically, based on past fisheries management performance,
Ashley and Susan Harris, their children, and grand-children, will not see
stocks achieve this level in their lifetimes. That is, it could take four generations to
rebuild the stocks to B40.
What an appalling legacy.
That is the prime reason why we are making this submission –
we want to make sure that we pass on a better legacy to our children.
3.6
Competitive attitudes
A short review of the information and draft submissions on
the IPP from Government, commercial fishing and recreational fishing sources
reveals unfortunate competitive and blame-shifting attitudes between the
commercial and recreational industries: “us versus them”, “it’s their fault,
not ours”, “this policy position “X” will ruin our industry (commercial or
recreational)”, and so on. The
Government position seems to oscillate between appearing to favour the
commercial fishers or the recreational fishers, depending upon levels of
lobbying and publicity at various times.
Fortunately the current 2013 IPP strikes a reasonable
balance between the two.
However it needs to be said that the competitive attitude
between the two major stakeholders is frustrating the sustainable management of
the resource. It doesn’t matter to the
fish whose hook kills it – the fish is dead either way and is no longer part of
the spawning stock biomass.
Stock depletion issues are so severe with the SNA 1 snapper
fishery that if a cooperative attitude is not adopted then the fishery will
inevitably collapse and everybody will miss out.
3.7
Need for change
All the best science and policy pretentions will not save
the fishery if fishery managers (MPI) and fishery stakeholders (commercial and
recreational fishers[3])
do not acknowledge that the stock is currently over-fished by ALL fishers, and
agree to take effective action to rebuild the stock over an acceptable time
period.
In short, a cooperative attitude is an essential
pre-requisite to effective sustainable management of the resource. For this reason we support the MPI proposals
to encourage stakeholder input, encourage field research, and develop a long
term management strategy over the next two years.
However, we do not support Options 2 or 3, as a 7% increase
or decrease in the TAC short term is not likely to benefit the fishery. Nor do we support management options based on
recent recruitment levels. Time needs to
be allowed to receive critical research results, and then a long term plan must
be agreed upon before the first short term steps can safely and sensibly be
made.
The SNA 1 snapper stock is probably stable enough at present
levels for a two year “pause” to be called to give time for a better informed
and united[4]
long term management strategy to be devised and actioned. This would not prevent stakeholders from
taking voluntary actions (provided these are environmentally, economically and
socially sound) to improve the sustainability performance of their
industry. Nor would it prevent MPI from
taking more effective enforcement actions where required.
4
Relief sought - recommended strategy
The relief we seek from the Minister is as follows:
1. That
the Minister delay making a decision to change the TAC, TACC and recreational
allowances for two years.
2. That
the Minister adopts Option 1 (Status quo) for the 2013-2015 fishing years.
3. That
the Minister encourage all parties to adopt a cooperative approach to the
management of the SNA 1 snapper resource.
4. That
the Minister commission research into the critical information gaps recommended
in Table 1 above.
5. That
the Minister advises stakeholders that he intends to adopt a long term
management plan (LTMP) for the fishery to be actioned from the 2015 fishing
year onward.
6. That
in the meantime, the Minister calls for public proposals from stakeholders for
voluntary sustainability programmes, including how their effectiveness will be
measured over the next two years.
7. That
the Minister advises that he intends to host an “open book” Sustainable Snapper
Plenary for the SNA 1 area in August 2015, where the latest research will be
presented, and where stakeholders will be invited to present their latest
information and views on a Long Term Management Strategy (LTMS) for SNA 1.
8. That
the Minister invites all stakeholders to enter discussions with MPI and submit
proposals on a possible LTMS by late August 2014. Further cooperative discussions and meetings
would occur, with a Draft LTMS to be published in May 2015.
9. That
the Minister provides more resources for enforcement activities in targeted
areas of known non-compliance.
5
Conclusion
We would like to thank the Minister for the opportunity to
present this submission. If we can be of
any further assistance, or if further information is required, please contact
our representative Mrs Susan Harris of GreenXperts, contact details below.
We look forward to the Minister making decisions that will
ensure our children and grand-children are able to enjoy fishing for snapper as
we have within our lifetimes, and to a greater extent within theirs.
Contact:
Mrs Susan Harris
Principal Scientist
Mob: 022 1544 958
GreenXperts Limited
Clean Technology Centre
47 Miro Street, Otaki
5512
PO Box 52, Paraparaumu
5254
Wellington
New Zealand
|
|
6
Appendix 1: Key observations
Table 2:
Summary of observations
|
Page
|
Paragraph
|
Topic
|
Observation
|
|
BIOLOGY
|
|
||
|
11
|
23
|
Snapper growth and productivity
|
i Snapper a low productivity stock – therefore particularly vulnerable to
overfishing
|
|
11
|
25
|
SNA 1 snapper grow the slowest of all in NZ
|
êWhy?
|
|
11
|
29
|
Importance of snapper as a food source for other predators poorly
understood
|
êResearch need
|
|
12
|
30
|
Snapper abundant predator in inshore ecosystem – their importance poorly
understood
|
êResearch need
|
|
12
|
32
|
Warmer water has positive effects on snapper recruitment
|
ê Positive
impact of climate change (warming sea)?
Balanced against negative impacts of ocean acidification?
|
|
12
|
33
|
Weakness in age class structure - fewer age classes in SNA 1
|
i SNA 1
recruitment vulnerable because of fewer age classes present?
|
|
COMMERCIAL FISHERY
|
|||
|
13
|
34
|
Extensive controls already on commercial fishers
|
Are these effective? Can they be
simplified?
|
|
15
|
37
|
ACE entitlements don’t seem to be flexible or financially fair to
commercial fishers
|
Market failure of ACE? Can a better economic instrument be designed? Consult with commercial fishers.
|
|
16
|
38
|
Figure 3.2 Commercial catch exceeds TACC in most years
|
i But what are the error limits on
this data? Extent of under-reporting
and dump at sea?
|
|
16
|
38
|
TACC
|
TACC hasn’t changed in 16 years (since 1997)
|
|
16
|
41
|
Drop in commercial fleet to around 200 vessels since 1993
|
Fleet reduction a result of over-fishing, and introduction of more
efficient vessels, not as a result of the QMS! The QMS followed collapse of the fishery[5].
|
|
18
|
47
|
Value of the commercial fishery
|
This value is under-stated, as it does not include the value of the
domestic market (snapper wet fish in supermarkets presently sold at $40/kg+),
or any estimates of economic multipliers to the NZ economy.
|
|
RECREATIONAL FISHERY
|
|||
|
19
|
53
|
Recreational fishing 85% by boat
|
|
|
21
|
57
|
Data quality
|
Data prior to 2000 may still be useful for trend analysis.
|
|
22
|
63
|
Table 3.4 Recreational catch estimates 2004-2012
|
Surprisingly good correlation between aerial access and panel surveys.
|
|
24
|
73
|
Value of the recreational fishery
|
ê Value of the
recreational fishery in SNA 1 is extraordinarily under-studied and
under-reported given its scientific and political significance. The postulate in the IPP that recreational
fishing is roughly equivalent in value to commercial fishing has very little
support in the scientific literature.[7]
|
|
26
|
81
|
Fishing mortality
|
ê Commercial and
recreational fishing mortality similar?
|
|
2013 STOCK ASSESSMENT
|
|||
|
28
|
88
|
Snapper growth rates declining
|
ê Urgent
research need
|
|
29
|
91
|
Interim biomass target B40
|
Acceptable target
|
|
30
|
93
|
Spawning stock biomass (Bx) history from 1900 to about 2000.
|
Massive 85% drop in Bx from 1900 to about 2000. Fishery decimated over a period of 100
years, particularly by foreign commercial vessels in the period 1960-1980.[8]
|
|
30
|
94
|
Bx from 2000 onward
|
Very slow recovery from about 1997 onward, at a rate of about 0.25% per
year[9]. At this rate, it would take another 80
years (2093) to recover to target B40 level. That is, a recovery period of about 150
years from the last time the stock was at B40 (pre-WWII).
|
|
32
|
97
|
2013 expert opinion on stock status
|
Stock overfished by all fishers.
|
|
32
|
99
|
Matching scenarios to options:
Status quo -current actual catch
Option 1 - current legal catch
Option 2 – increase TAC
Option 3 – decrease TAC
No fishing
|
Scenario number and effect:
2 commercial – recreational˜ POS —
3 commercial — recreational ˜ POS —
4 commercial ˜ recreational ˜ POS ˜
5 commercial ˜ recreational ˜ POS ˜
|
|
33
|
103
|
Bx recovery 1-4% over 5 years
|
No real change if error levels and uncertainty analysis considered
|
|
33
|
104
|
Five year projections based on “well above average” recruitment levels in
most recent ten years
|
Dangerously optimistic position given all the relevant caveats stated
previously in the IPP.
|
|
34
|
107
|
“No fishing” leads to recovery to B40 in eight years
|
Won’t happen.
|
|
36
|
110
|
Recovery rate glacial
|
Cf. page 30, paragraph 94.
|
|
36
|
113
|
Harvest Strategy Standard (HSS) guideline on stock recovery timeframe
|
Snapper a depleted stock. Under
HSS, need to reduce TAC 56% to achieve rebuild in 16-24 year range. Such a reduction unlikely without major
fisher commitment.
|
|
OTHER KEY CONSIDERATIONS
|
|||
|
37
|
117
|
Habitat of particular significance for fisheries management
|
ê Critical to
research location and extent of these areas and protect them.
|
|
37
|
119
|
Effects of fishing on spawning
|
ê Critical to
research these effects and protect key spawning areas.
|
|
39
|
128
|
Benthic interactions
|
ê Critical to
research these effects and make management adjustments where necessary.
|
|
39
|
129
|
Ecosystem indicators – eg. maximum size of fish in Hauraki Gulf
decreasing, declines in fish diversity in shallow waters – these are bad
signs
|
ê Critical to
research these indicators and make management adjustments where necessary.
If not covered by existing research projects, these four items could be
combined into one research project.
|
|
PROPOSED RESPONSE
|
|||
|
42
|
145
|
Proposed interim target B40
|
OK
|
|
44
|
155
|
Recovery projections
|
Recovery slow and fragile.
|
|
44
|
156
|
TAC of 9,000 tonnes over next five years with minimal impact on
sub-stocks - projection based on
“recent average recruitment levels”.
TAC based on long term levels suggests 3,800 tonnes
|
TAC of 9,000 tonnes is an outrageous and dangerously irresponsible
suggestion, given all the previous information and caveats stated in the
IPP.
|
|
46
|
161
|
SNA 1 high value shared fishery
|
Yes
|
|
46
|
162,164
|
SNA 1 is a fully utilized stock
|
Actually over-utilised. Demand
will go up with population growth.
êResearch
needed on demographics of SNA 1 to help project future fishing demand, in
particular recreational demand. It is
remarkable that to date, no proper demographic studies have been completed on
this critical social and economic aspect.
|
|
48
|
172
|
Recreational catch histories, Figure 6.1.
|
The Global Financial Crisis (GFC) appears to have had no negative effect
on recreational fishing activity.
|
|
49
|
177
|
Estimates of commercial value
|
These values are likely to be understated, as no work on industry
economic multipliers, opportunity costs, asset replacements and influence of
technology, export and domestic market demand trends appears to have been
done. These are standard economic
analyses, and it is surprising that they have not be completed and presented.
|
|
49
|
178
|
Estimates of recreational value
|
Cf page 24, paragraph 73.
êCritical
research needed to provide a proper economic assessment of the full economic
and social value of recreational fishing to the NZ economy and its
community. These demands need to be
monitored on a year-by-year basis, and matched to demographic studies on
projected population growth and recreational fishing demand.
|
|
52
|
192
|
Remove commercial MLS and require all catch to be landed
|
Warrants serious consideration
|
|
53
|
194
|
Fishing method mortality
|
êResearch need
– industry led
|
|
PROPOSED SNA 1 MANAGEMENT OPTIONS
|
|||
|
54
|
198
|
Long term trend shows stock levels still going down
|
Current management clearly not sustainable.
|
|
54
|
199
|
Long term Bx will continue to decline unless TAC reduced by
approximately 20%
|
Current commercial and recreational fishing pressures are continuing to
deplete the fishery. This is not a
“commercial” or “recreational’ problem, it is everybody’s problem.
|
|
55
|
203
|
Only Option 3 – reduce TAC by 500 tonnes – decreases pressure on the
fishery
|
Cf page 32, paragraph 99. However,
the biology and uncertainties involved make this reduction of no
consequence. A reduction of at least
20% (1,500 tonnes) would be required to be effective.
|
|
56-76
|
205-311
|
Discussion of Options 1-3
Option 1 - no change
Option 2 – increase TAC 7%
Option3 – decrease TAC 7%
|
|
|
|
211
|
Short term projections on recruitment levels used again, despite previous
caveats
|
The precautionary principle, an important accepted principle of
sustainability management, does not appear to be part of the MPI ethos when
managing vulnerable natural resources.
|
|
|
221
|
Recreational catch exceeds allowance by 31%
|
Commercial fishers have a right to complain if recreational over-catch is
not constrained by MPI!
|
|
|
234
|
Recreational bag limit and recreational MLS tools to manage recreational
fishing impacts on the resource
|
Various combinations possible.
|
|
|
293
|
Proportional allocations of TAC
|
Various combinations possible.
|
|
FUTURE MANAGEMENT OF SNA 1
|
|||
|
76
|
313
|
Stakeholder input critical
|
Agree
|
|
76
|
314
|
Development of long term management strategy
|
Top priority
|
|
76
|
315
|
Research underway to source important information for decision-making
|
Support extension of research efforts, given the national priorities
associated with the SNA 1 snapper fishery.
|
|
77
|
317
|
Long term management strategy develop over next two years
|
Agree with 2015 target date.
|
Key: iKey information
ê Research need
Source:
MPI 2013a,b,c
7
Appendix 2: References
Economic Research Associates Pty Ltd (2010): Cutting the
Cake in a Shared Fishery with a Minimally Managed Non Commercial Sector, April
2010, Nedlands, Western Australia.
Bruce W. Hartill, Tim G. Watson & Richard Bian (2011)
Refining and Applying a Maximum-Count Aerial-Access Survey Design to Estimate
the Harvest Taken from New Zealand's Largest Recreational Fishery, North
American Journal of Fisheries Management, 31:6, 1197-1210, DOI: 10.1080/02755947.2011.646454
Kerr G N and Latham N (2011): “The Value of Recreational
Inshore Marine Fishing”, 2011.
Proceedings of the New Zealand Agricultural and Resource Economics
Society Annual Conference, August 2011, Nelson.
Ministry for Fisheries (2008): Harvest Strategy Standard for
New Zealand Fisheries, Ministry of Fisheries — October 2008, Wellington.
Ministry for Primary Industries (2012): Aquatic Environment and Biodiversity Annual Review
(2012), Wellington.
Ministry for Primary Industries (2013a): Fisheries Assessment Plenary May 2013: Stock Assessments and
Yield Estimates, June 2013 (087_SNA_2013), Wellington.
Ministry for Primary Industries (2013b): Fisheries Assessment Plenary May
2013: Stock Assessments and Yield Estimates Volume 1, Wellington.
Ministry for Primary Industries (2013c): Review of sustainability and other management controls for
snapper 1 (SNA 1), MPI
Discussion Paper No: 2013/31, July 2013, Wellington.
South
Australian Centre for Economic Studies (1999): Value of New Zealand
Recreational Fishing, November 1999, Adelaide and Flinders Universities.
[1]
World War II 1939-1945
[2]
95% certainty of human-induced climate change in latest draft IPCC report IPPC
2013 Draft Report [informal]
[3]
Customary fishers are included as recreational fishers
[4]
Generally agreed by all stakeholders
[5]
Figure 4, MPI 087_SNA_2013
[8]
Figure 4, MPI 087_SNA_2013
[9] 4%
recovery over 16 years calculated from paragraphs 5 and 146.
