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