Submission on the Kaikoura Paua 3A Fishery
1 February 2024
Inshore Fisheries Management
Fisheries New Zealand
Submission: Review of the Kaikōura recreational pāua fishery for 2023/24
Fisheries New Zealand Discussion Paper No: 2023/27
Introduction
Fish Mainland is a not-for-profit 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, we aim to work collaboratively with government, tangata whenua and others to bring about the best public outcomes, which often involve public access to the marine environment.
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
While recreational fishers would appreciate a higher catch level for the PAU3A fishery, the Fisheries New Zealand Discussion Paper No: 2023/27 makes a grave mistake in misleading the public; it is blatantly misleading for this Paper to ignore the statutory obligation to uphold the 5-tonne recreational allowance.
The 5-tonne allowance is not a political play thing, and officials are not above the law. This allowance must be upheld until the Minister makes any further decision about it once he has considered the available information and submissions after the scheduled review of the PAU3A TAC in 2024.
Instead, the Discussion Paper makes repeated errors in suggesting a 20-tonne recreational catch level as being ‘sustainable’ based on modelling. It is not the role of officials to ignore the recreational allowance nor prejudge what revised allowance the Minister might make after the scheduled TAC review.
We entirely support the Paua Industry Council (PIC) in stating that the recreational catch must be constrained within the statutory allowance, as it is essential for ensuring sustainability, by constraining the total catch of all sectors within the TAC.
We agree with PIC that this is particularly important in the Kaikōura pāua fishery, which is still recovering and remains vulnerable to changing environmental conditions due to the 2016 earthquakes.
As neither option 1 nor 2 aims to constrain recreational catch within the 5-tonne allowance, neither are satisfactory nor lawful. Based on past survey results, the recreational catch under these options is very likely to exceed the 5-tonne recreational allowance, with a higher risk of exceeding the allowance under option 2.
It should be glaringly obvious by now that Fisheries New Zealand continues to fail in its efforts to manage this fishery.
It should also be glaringly obvious that real-time information on recreational catch levels and locations is critical for improving the management of PAU3A. Without this information, management measures cannot be adequately adaptive, putting the pāua fishery at risk.
Improved information gathering is urgently needed and, therefore, should be a high priority outcome for opening the fishery.
Accordingly, we trust that Fisheries New Zealand will now act to address the strong local support for recreational fishers reporting their catch; local support is strongest for mandatory reporting, which provides much higher quality data than if reported voluntarily.
Fish Mainland has developed a self-reporting system with Fisheries New Zealand to collect information, and the interface with recreational fishers is the Mainland Catch app.
To support this system, Fisheries New Zealand should also act to put in place a legal framework that allows a fishery to close once the recreational catch reaches the fishery’s allowance. Such a framework is necessary to further ensure stock sustainability.
Furthermore, we urge Fisheries New Zealand to reconsider the adverse consequences of closing any fishery. The reason is that all fisheries that have been closed entirely have subsequently been over-exploited once re-opened.
Finally, as we have stated previously, emphasis should be placed on the need for a precautionary and adaptive management approach, where the recreational pāua fishery at first would be opened on a limited basis (less than what options 1 or 2 propose), and the extent of further openings based on improved recreational catch information. This way, the public can have confidence in the way this fishery is managed and more prepared for and accepting of changes as they occur.
Thank you for the opportunity to provide input into these important and significant decisions.
Yours sincerely,
Larnce Wichman NZOM
Chair of the Board
