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Kahawai Submission Sealord


Submission

Sealord Group Ltd

27 February 2004

 

Sealord Submission on setting of sustainability and other management controls for stocks to be introduced into the QMS on 1 October 2004 

 

Introduction

Sealord Group Ltd has taken note of the proposals for new species into the QMS on 1 October this year. Our major concerns relate to the introduction of Kahawai and Look Down Dory and the financial impact this will have on our business. Our comments will relate primarily to these 2 stocks, and we wish to note that we support the submissions by SeaFIC.

 

Lookdown Dory

We note the proposal to bring Look Down Dory into the QMS, and that it will primarily impact the factory trawler fleet that operates on Hoki. Lookdown Dory is taken primarily as a by-catch in this fishery. you note in the background about the biological attributes suggesting this species is vulnerable to the effects of fishing and that there is no stock assessment information on this species. however it is also noted that relative biomass estimates from trawl surveys on the Chatham Rise show the estimates of biomass for Lookdown Dory have been increasing in recent years. The conclusion from this would be that the current catches are unlikely to be having an adverse effect on the species.

It is unclear to us as to why this species would be brought into the QMS in this situation. We believe it is highly likely that the Crown will attach most of this TACC to itself, and then tender it out to the highest bidder. In this case, the introduction of this species would seem to us to be simply a revenue gathering mechanism for the Crown. You will be forcing the Industry to purchase quota for a low value species, simply to maintain current target fishing operations. This will be at a time when the Industry is suffering severe financial conditions.

We do not believe that Look Down Dory should be brought into the QMS at this time. if it is, ITQ should then be allocated on the basis of catch history over recent years.

We also believe the deemed value is too high for this bycatch species. although there may be a limited market for some Lookdown dory, which then defines the port price, we think it highly unlikely that $720 per tonne (the deemed value) could be achieved for 800 tonnes of frozen at sea lookdown dory. The deemed value should be set at a much lower figure.

 

Kahawai

Our major concerns relate to KAH3 and the proposal of the Crown to substantially diminish our property right. Sealord Group currently holds the entitlement to catch 900 tonnes of kahawai per year. We believe there is absolutely no justification for removing the current CCL for KAH3 while accepting it for KAH1   and 2. as described in paragraph 87, you have totally misread the nature of this fishery. the majority of the catch historically from this area was taken by Sealord Group Ltd, which supplied the cannery based in Nelson for a market in Australia. The landings reduced when this cannery was closed, and the sale of our purse seine vessel Shemera .

Commercial utilisation of this species is an option we may exercise in the near future. We do not believe the Ministry should be taking steps to define our commercial utilisation.

We do not believe there is any evidence of a sustainability issue with the current CCL for KAH3. the comments about the recreational sector believing that the number of kahawai available to them relates to surveys prior to 1997, and since that time the commercial catch of KAH3 has been significantly reduced.

We do not believe that the TACC should be reduced to the proposed level, and that the CCL which has existed for the past 7 years be ratified as TACC and be allocated to current permit holders.

 

Other Species

We also note that a range of other species such as Rays Bream will be brought into the QMS and most of the TAC allocated to the Crown. This species is also taken primarily as by-catch, and there are no sustainability concerns. We strongly believe that you should allocate ITQ on the basis of the catch history over recent years for this species and others like it.

 

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