New Zealand Big Game Fishing Council
|For a printable version of this submission please
Ministry of Fisheries
PO Box 1020
27 February 2004
Big Game Fishing Council Submission on the introduction of new species
to the Quota Management System October 2004
NZ Big Game Fishing
- The NZ Big Game Fishing Council (NZBGFC) was formed in 1957
to act as an umbrella group for sport fishing clubs and to organise
a tournament that would attract anglers from around the world.
Club membership has grown steadily and we now represent over 33,000
members in 61 clubs spread throughout NZ. We still run New Zealand's
only nation-wide fishing tournament, which has evolved over time
and remains successful.
- NZBGFC compile and publish the New Zealand records for fish
caught in saltwater by recreational anglers and are affiliated
to the International Game Fish Association who compile world record
- In the early 1980's the NZBGFC was instrumental in establishing
and funding the NZ Recreational Fishing Council to ensure better
representation of non-commercial fishers at a national level.
The NZRFC continues to be recognised in this role.
- In 1996 NZBGFC helped establish the NZ Marine Research Foundation,
which aims to sponsor research on the interactions between people
and marine ecosystems to the benefit of all New Zealanders, including
participants in ocean recreation.
- Many of our most established fishing clubs have a focus on fishing
for large pelagic species such as marlin, tuna, and sharks. In
recent years our membership has expanded beyond the traditional
deep sea angling clubs to include many local clubs targeting inshore
- The Council has been concerned about the impact of an unconstrained
longline fishery on billfish for the last 20 years. In August
1987 the Minister of Fisheries Colin Moyle announced a 3 year
moratorium on foreign tuna longline vessels fishing around the
top half of the North Island between 1 October and 31 May. Domestic
vessels were required to release all billfish including broadbill
- There were annual review meetings of the moratorium and later
the Billfish Memorandum of Understanding between commercial and
recreational representatives from 1989 through 1997. As a result
of agreement at these meetings regulations were changed in April
1991 to allow domestic commercial fishers to retain and sell swordfish
caught in New Zealand waters (The Fisheries (Auckland and Kermadec
Areas Commercial Fishing) Regulations 1986, Amendment No.4). Commercial
fishers agreed not to target swordfish and to a voluntary minimum
size of 50kg or 1.6m long (lower jaw to tail fork). Also commercial
fishers agreed not to fish inside the 200 metre contour along
the east coast of the North Island (North Cape to Cape Runaway)
and not to set gear within the 1000m depth contour of four points
of particular importance to recreational fishers. Also a regulation
was passed in 1993 to prohibit the landing and sale of marlin
(blue, black, and striped) by commercial fishers in all New Zealand
waters (The Fisheries (Auckland and Kermadec Areas Commercial
Fishing) Regulations 1986, Amendment No.8).
- The Ministry were asked to monitor and report annual catch
and the average size of commercial swordfish. The commercial minimum
size was eventually dropped when markets were found for small
fish. The Billfish MOU, last signed off in 1996, still contained
agreement not to target swordfish (which was prohibited anyway)
and to stay away from recreational areas of importance.
- A meeting was held in 1997. No agreement was reached as commercial
fishers wanted an arrangement to allow the harvest of some striped
marlin which was strongly opposed by recreational fishers. Recreational
fishers wanted the targeting of swordfish using chemical light
sticks attached to the trace to stop and industry claimed that
this method was used for targeting bigeye and southern bluefin.
- It was about this time that recreational groups started appealing
to the Minister of Fisheries to take note of the extremely rapid
increase in swordfish catch and the international experience of
boom and bust commercial fisheries for this species. This was
the last open access non-quota fishery in New Zealand and it was
felt that many tuna longliners were illegally targeting swordfish.
A catch limit or other management controls were required as soon
as possible to ensure sustainable management of the stock.
- MFish chaired a meeting on tuna and billfish in March 2000 between
recreational groups, tuna fishers, industry representatives and
TOKM. It was clear that the issues raised in 1997 were still present,
the only thing that had changed was that the commercial catch
had increased 330% from 283 tonnes in 1996/97 to 939 tonnes in
1998/99 (Table 2 IPP).
- Several letters to the Minister followed this meeting and finally
we felt that we were getting somewhere when Pete Hodgson said
in his letter of 30 August 2000: " The Ministry will also
be developing a formal proposal(s) to review the sustainability
measures for swordfish for the next sustainability review round.
I believe that work towards a stock assessment will draw out the
best available biological information on swordfish in the Pacific.
Using the working group and the sustainability review processes,
all interested parties will be able to discuss that information
- MFish failed to put forward any proposal for the next sustainability
review round and so the NZBGFC developed its own proposal for
the review of management controls for the 2002-03 fishing year.
Analysis of commercial catch data had revealed a dramatic decline
in the average weight of swordfish landed in 2000 and 2001 and
a levelling off of annual catch, which raised concerns that the
stock was being over fished. The proposal simply asked the Minister
to establish a commercial catch limit for swordfish.
- The proposal was rejected. In answer to yet another letter Minister
Pete Hodgson replied, " You are concerned at delays in implementing
controls to ensure the sustainable management of broadbill swordfish
and ask for a review of sustainability measures for this species.
I too am concerned to ensure that this species, and all others,
is managed in a sustainable manner, and that the management regime
put in place provides for all interests in the fishery."
He suggested that these issues would be addressed when swordfish
was introduced to the QMS in 2004. Therefore recreational fishers
have an expectation that the IPP should provide for all interests
in the fishery.
Swordfish are important
to recreational fishers
- Catching a broadbill swordfish on rod and reel is still one
of the great challenges in the sportfishing world. Despite the
competition from tuna longliners on all the accessible seamounts
in the north, the few fish we have been able to catch have been
noticed by international anglers. Many of these anglers have lost
the opportunity to catch large swordfish in their home waters
and are coming here before the big fish disappear from New Zealand
- Numerous Charter boats have up-graded their surveys to include
the option of fishing the close Swordfish grounds and there has
been a prolific increase in suitably equipped private game launches
that attempt Swordfish targeting. We are acutely aware of commercial
fishers claim that our stake in this fishery is minimal. However
we do have a stake and believe that access to this fish species
has been denied to us, as areas accessible by recreational craft
are rapidly fished down.
- The illegal targeting of swordfish by tuna longliners and the
fact that commercial fishers have ignored the agreements made
in the Billfish Memorandum of Understanding have been an issue
for the NZBGFC for at least the last 7 years. The very rapid increase
in commercial catch in the late 1990s was a great concern to many
of our members and many feel strongly that the Minister has been
stalling on effective management in this fishery.
and proposed TACC
- Swordfish have been taken by tuna longline vessels in New Zealand
waters for many years. Japanese and Korean vessels set
millions of longline hooks each year around New Zealand in the
1980s. They often caught more bigeye tuna than swordfish because
the Japanese in particular were targeting it by setting their
lines deep and did not need chemical light sticks. In the
early and mid 1990s New Zealand domestic boats started tuna longlining
but their catch of swordfish was more than double their bigeye
tuna catch (Figure 1, MFish IPP data). Their lines were
set shallow at night with lightsticks increasingly used, just
like all the swordfish target fisheries around the world.
Surface longline catch by species and season.
- The true bycatch level of swordfish by the Japanese tuna target
fishery in New Zealand waters can be seen in the seasons 1979-80
to 1986-87. From 1988 on the billfish moratorium restricted access
to northern waters over spring and summer. If the domestic fleet
had been targeting tuna using the same methods, their by-catch
of swordfish would be about equivalent to their bigeye tuna catch.
The difference between bigeye and swordfish landings since 1995-96
is therefore mainly the result of illegal target fishing.
- Since the domestic fishery started it has been illegal to target
swordfish. Furthermore, industry leaders had signed a MOU with
recreational representatives that commercial fishers would not
target swordfish. The Minister and MFish have been asked on numerous
occasions to stop fishers who are blatantly targeting swordfish
but they seem unwilling or unable to prosecute.
- MFish have received a number of research reports indicating
that swordfish targeting has been occurring. The results of MFish
project SWO2001-01 were crystal clear. " Swordfish catch per
unit effort (CPUE) increases with increasing use of lightsticks,
moderate to high use is associated with CPUE levels about 4 times
(400%) those sets not using lightsticks; low to moderate use increases
bigeye CPUE about 40%, high levels of lightsick use reduces bigeye
- The paper concludes that " Our results point to the importance
of light and shallow sets at night as major determinants of high
swordfish CPUE in the EEZ, Evidence is also presented that indicates
that the increase in swordfish CPUE and catches is likely to be
due to the widespread use of lightsticks and that some level of
swordfish targeting has been occurring since the mid-1990s and
has likely increased despite a ban on swordfish targeting." 
- It is unacceptable for MFish and the Minister to turn a blind
eye to this illegal fishing practice, yet again, and set the TACC
at current catch levels. Furthermore the Fisheries Act does
not permit it. Part IV of the Fisheries Act (1996) is titled the
'Quota Management System' and includes Section 34 (2). This section
states " For the purposes of this Part and Part XV of this
Act, the term "eligible catch" means the total weight of all the
catch of the relevant stock lawfully taken and
lawfully reported as landed.. by a person eligible to receive
provisional catch history under section 32 of this Act. ."
So for catch to be recognised under the quota management system
it must be recognised as lawfully taken.
- Clearly a large proportion of the swordfish catch history MFish
is basing it's TACC on is not eligible catch, as it was taken
while illegally targeting swordfish. Although it may be difficult
to determine what proportion of catch was taken while targeting
by the domestic fleet MFish must not use illegally caught fish
in setting TACCs. Surely they can't ask the Minister to publicly
defend a TACC based on illegal catch history.
- The IPP proposal for the TAC is as follows.
- MFish considers that the TACC be based on the average of the
recorded landings of the last three completed fishing years. Accordingly
there is one TACC option proposed for the whole of New Zealand
(SWO 1). Based on the average of the last three years commercial
landings from this management area it is proposed that the TACC
be set at 885 tonnes. NZBGFC believe that this tonnage is too
- MFish is wrong to assume that the mortality of small swordfish
is the same as large swordfish when arguing against the benefits
of a minimum legal size (para 53). There is anecdotal evidence
that small swordfish are more likely to be alive at the boat.
It is unacceptable to our members that all swordfish have to be
retained, regardless of size, because they are a QMS species when
many small swordfish could be released alive.
- MFish is also wrong to suggest that a 90kg size limit was in
the Billfish MOU for swordfish. The 1996 Billfish MOU 90kg
minimum size related to recreational marlin only. Swordfish were
covered by Clause 8 of the 1993 Billfish MOU which states ' No
fisher should take any swordfish smaller than 50 kg greenweight
or less than 1.60 m length measured from the bottom jaw to the
fork of the tail .'
- We agree that swordfish grow rapidly in their first year to
12kg (100 cm) but they also grow just as rapidly in the second
year reaching 125 cm and 25kg so NZBGFC believe that a compulsory
minimum legal size for swordfish should be set at 25kg and 125
cm lower jaw fork length, the same as set by ICCAT in the North
- The MFish suggestion that swordfish that are alive smaller than
100 cm may be released alive will have almost no effect on the
commercial fishery. There are very few swordfish caught that are
less than 100 cm lower jaw fork length (Figure 2)
Length frequency distribution of male and female swordfish
caught in New Zealand EEZ in 2001. Length in centimetres lower
jaw fork length. 
experience and obligations
- An extensive report was recently produced by the Australian
Bureau of Rural Sciences titled 'Broadbill Swordfish, Status of
World Fisheries'. This is a migratory species so MFish and the
Minister must take note of overseas experience. " Broadbill
swordfish fisheries often show a development pattern of rapid
growth, with catches reaching a peak then declining as fishing
effort overshoots sustainable levels. The pattern highlights the
ability of commercial fisheries to rapidly expand swordfish catches
and to create problems with overcapacity. The initial high catch
rates probably reflect a fishing down of an accumulated biomass
and resident components of the population ." 
This is exactly what is happening in New Zealand. The swordfish
catch has peaked and is now starting to decline.
- The Australian review of world broadbill fisheries concludes
" An important lesson from this review is the need to put
into place a comprehensive suite of mechanisms to control fishing
effort before geographical expansion and overcapitalisation commence.
However precise limits are extremely difficult to define for developing
fisheries.For Swordfish fisheries, effective 'output controls'
(e.g. total allowable catches) need to be combined with 'input
controls' such as limits on fishing effort ." 
The open access surface longline fishery has resulted in over
capitalisation and many owners are looking to exit the fishery
now that the catch history years have been announced. The QMS
alone is not adequate to manage the spatial conflict that has
developed on the most accessible seamounts.
- New Zealand is a signatory to the FAO 'Code of Conduct for Responsible
Fishers' The development of a target fishery for swordfish is
a recent development in New Zealand waters. The Code states
that: " In the case of new or exploratory fisheries, States
should adopt as soon as possible cautious conservation and management
measures, including, inter alia, catch limits and effort limits.
Such measures should remain in force until there are sufficient
data to allow assessment of the impact of the fisheries on the
long-term sustainability of the stocks, whereupon conservation
and management measures based on that assessment should be implemented.
The latter measures should, if appropriate, allow for the gradual
development of the fisheries " MFish has allowed the rapid
development of an illegal target fishery for swordfish and is
now asking stakeholders to support legitimising this fishery by
issuing quotas at near maximum levels.
- The IPP also mentions "international obligations to exercise
reasonable restraint in the development of HMS " (highly
migratory species). This relates to resolutions passed by the
Preparatory Conference for the Commission for the Conservation
of Highly Migratory Fish Stocks in the Western and Central Pacific.
How can New Zealand ask other countries to show restraint in the
development of their HMS species when it has promoted the unconstrained
expansion of tuna fisheries (except southern bluefin) and allowed
the illegal expansion of the swordfish target fishery. Many new
entrants to the fishery have found it easier to decimate the swordfish
population and fin sharks when the tuna fishing gets a bit hard.
- The Australians have been aware of the problem of local depletion
from target swordfish fisheries for some time. Leading researchers
have said " Local depletion occurs around underwater features
when swordfish are removed at a greater rate than that which growth
and immigration can replace them. It is not known for how long
individual swordfish 'reside' around underwater features. It is
clear, however, that mixing through swordfish populations takes
several months if not years". 
- Recently a study looked at the effect of the number of years
swordfish were caught in each one degree square area in the east
Australian fishery. They found that though initial catch rates
were high there was a steady decline in catch rate the longer
the area was fished so new areas were fished and they in turn
were fished down (this is sequential local depletion).
The authors say " If the pattern of 'localised decline' in
the catch rates of swordfish off eastern Australia, especially
in the inshore regions, continues to be observed in future years
there may be negative consequences to the viability of the longline
fishery and possibly for the swordfish populations in this region.
In particular, the economic viability of smaller vessels (which
are unable to venture out to the offshore regions where swordfish
still apparently remain abundant) could be significantly impacted
if catch rates inshore continue to decline. Furthermore, if sequential
declines are seen in future years across the more recently fished
regions offshore, this would have significant management implications
and may raise the need for some form of spatial management ."
- Like New Zealand, the east Australian fishery had a long history
of mainly Japanese vessels tuna longlining in their waters which
resulted in swordfish by-catch. Despite the fact that this fishery
had been exploited at a lower level for some time the analysis
of CPUE data shows the Australian domestic fleet could 'mine'
an area and catch rates would not recover but continued to decline
as long as fishing continued in that area (to date a 7 year time
series) . This is not the behaviour
expected for what was thought to be a mobile, highly migratory
species. Clearly local depletion is occurring and there is a lot
about the residency and movement of swordfish that we do not understand.
- There has been debate about how many swordfish stocks there
are in the Pacific Ocean. For management purposes the southwest
Pacific should be considered a separate stock. Recreational groups
totally reject the view that New Zealand fishers catch just 5%
of a single Pacific wide stock and any management measures we
take would therefore be insignificant. This view is not supported
by the facts. The Secretariat of the Pacific Community (SPC) compile
catch statistics for all nations in the western central Pacific.
There figures show the swordfish catch by longline in the southwest
Pacific to be about 4,000 to 5,000 tonnes per year. New Zealand
fishers have been a major extractor in the fishery with up to
25% of the southwest Pacific commercial catch coming from a relatively
small area around the North Island. Figure 3
shows the distribution of longline swordfish catch by 5 degree
square for 2001 (SPC data ).
- Fisheries managers in Australia have been concerned about the
rapid expansion in their tuna longline fisheries. Recently new
hook quotas were introduced to cap fishing effort in the east
Australian fishery. In the 1990s blue marlin and black marlin
were made non-commercial species in order to minimise mortality
from commercial fishing and reduce conflict with recreational
fishers for those species.
- The north Atlantic fishery is an example of how quickly swordfish
populations can be fished down and how hard they can be to rebuild.
ICCAT promoted minimum size regulations of 25 kg (125 cm lower
jaw fork length) in the whole of the north Atlantic. In 1999 the
United States introduced time area closures in swordfish hot spots
to reduce juvenile swordfish mortality without a major effect
on fishing for other target species. 
- The US Department of Commerce introduced a regulation banning
imports of Atlantic swordfish less than 15kg trunked weight (~20
kg green weight) to help implement the minimum size rule. The
Food and Drug Administration regulations for mercury in swordfish
require that nations exporting to US markets reduce the number
of very large swordfish in their shipments. 
- There are also a number of reports in the literature that swordfish
populations are quite resilient to over-fishing. Although mature
females seem to be particularly susceptible to surface longline
gear when fishing new areas, catch can be maintained by harvesting
large numbers of juvenile fish. It seems likely that current catches
across the whole southwest Pacific are sustainable if the precautionary
approach is adopted. This does not however mean that the Minister
can ignore the issues of local depletion and gear conflict any
Figure 3. Distribution of commercial swordfish catch
in 2001 by 5 degree square
- NZBGFC has had a long involvement in the issue of billfish management
and swordfish has been particularly contentious over the last
7 years. As you can see we have acquired an in depth knowledge
of the performance and management of swordfish fisheries in New
Zealand and overseas. We could expand on any area MFish or the
Minister is particularly interested in.
- What we haven't achieved over the last seven years, and what
is clearly missing from the IPP, is any management action, whatsoever,
that protects our interests in this fishery. The level of frustration
is rising and the vast majority of our membership oppose the expansion
of the tuna fishery as proposed by the suite of introductions
proposed in this IPP. Frankly, the IPP proposal to discuss, "
undertaking a review of voluntary area restrictions at some
time in the future " is woefully inadequate and certainly
doesn't measure up to the Minister's promise when he wrote " I
too am concerned to ensure .. that the management regime
put in place provides for all interests in the fishery "
(Pete Hodgson 2002)
- The main points of the NZBGFC submission on swordfish are as
- Catching a large swordfish is a pinnacle of achievement for
billfish fishers worldwide
- Recreational fishers and charter boat operators want the opportunity
to access the swordfish fishery without competition from longliners
setting 1000s of hooks a night in the same areas.
- There is clear evidence of local depletion and serial depletion
by target fisheries in Australia and the USA.
- NZBGFC has been monitoring the catch of swordfish since we agreed
to allow commercial access in 1991 and sign the Billfish MOU with
- As soon as there were calls for a commercial catch limit on
swordfish and a stop to illegal targeting, the fishing industry
walked away from the voluntary agreement we had.
- NIWA research clearly shows that increased catches of swordfish
were associated with widespread use of lightsticks and targeting
which appears to have been increasing since the mid 1990's despite
- MFish have calculated the average catch and recommend a TACC
based on the catch history of many vessels illegally targeting
- For the purposes of the QMS, Part IV of the Fisheries Act (1996),
catch history must be lawfully taken to be eligible.
- There are legal and moral reasons for not including illegally
taken fish in the swordfish catch history.
- The Minister has obligations under Section 10 of the Fisheries
Act and the international Code of Conduct for Responsible Fishers
to apply the precautionary approach to managing this fishery where
information is poor or absent.
- Figure 1 shows that the foreign licence vessels, which where
targeting tuna, caught bigeye tuna and swordfish in roughly equal
proportions (1979 to 1987).
- NZBGFC submit that the bycatch level of the domestic fleet would
be about equivalent to their bigeye catch and that the TACC for
Swordfish should be 466 tonnes, equal to the best year of bigeye
- Lightsticks are primarily used for targeting
swordfish and with a 466 tonne TACC would be unnecessary and should
- Increases in commercial swordfish and tuna landings should be
dealt with using the Adaptive Management Programme for new and
- Time area closures, improved data collection and environment
standards for the surface longline fishery should be developed
within the AMP.
- NZBGFC are opposed to the retention of all swordfish, regardless
- Small swordfish up to 2 years old are fast growing and are often
brought to the boat alive. There should be a compulsory
minimum legal size of 25 kg greenweight or 125 cm LJFL.
- After 7 years of effort, and being proved right over the development
of illegal targeting, NZBGFC believe that the Minister must do
better than discussing proposals to " undertake a review of
voluntary area restrictions at some time in the future "
and implement some management of this fishery.
- It is largely irrelevant what tonnage the Minister allows for
non commercial catch if the current commercial fishing practice
is continued or expanded, as proposed in the IPP.
Murrey, T. and Griggs, L. Factors effecting swordfish(Xiphias
gladius) catch rate in the New Zealand tuna longline fishery.
Ward, P. & Elscot, S. 2000. Broadbill Swordfish, Status
of World Fisheries
Ward, P., Porter, J.M. and Elscot, S. 2000. Broadbill swordfish:
status of established fisheries and lessons for developing fisheries.
Fish and Fisheries
Campbell, R. and Hobday,A. 2003. Swordfish – Seamount
– Environment – Fishery Interactions off Eastern Australia.
Report to the 16 th meeting of the Standing Committee on Tuna and
SPC Ocean Fisheries Programme public domain data