for the opportunity to submit on the 2005 kahawai IPP.
MFish's new policy initiative of managing the biomass of important
shared fisheries at, or significantly above, the level required
to produce the maximum sustainable yield (BMSY).
kahawai are an obvious candidate for management above BMSY .
2004 kahawai decisions, which were made in error, create a new baseline
from which the 2005 decisions will be made.
A key issue
is MFish's policy preference for "proportional" allocation
between the commercial and non-commercial sector. The attached option4
submission on proportional allocation is part of this submission
on kahawai and should be read in conjunction with it.
non-commercial fishers submitted that past purse seine target catch
had depleted the kahawai stock to unacceptably low levels. The fishery
has not recovered and this depletion continues to adversely affect
the ability of amateur and customary fishers to catch kahawai.
Many of the
key issues raised in non-commercial fishers' 2004 submissions were
not adequately addressed by MFish or the Minister and should be
remedied in 2005.
paper on Proportional Allocation of Fisheries Resources in NZ (Appendix
Three) is a major part of this submission and must be read in
conjunction with it. We ask that the issues raised in the Proportional
Allocation of Fisheries document along with the fishery specific
issues raised in this document be addressed by the Ministry in the
Final Advice Paper on which the Minister bases his decision.
The following are option4's key objectives for kahawai:
That kahawai stocks
be managed above Bmsy such that "more fish are left in
That the Minister
not allocate "proportionally" between the commercial
and non-commercial sectors which subordinates non-commercial
That the Minister
undertake an evaluation of the true nature and scope of non-commercial
fishing interests and how those interests can best be allowed
for taking into account all relevant factors;
That, when setting
TACs and TACCs/non-commercial allowances, the Minister should
take a range of information into account (as the best available
information) to make more sophisticated decisions, rather
than being solely reliant on recent catch history information;
That, when setting
TACs and TACCs/non-commercial allowances, the Minister undertake
an individual assessment of each QMA taking into account factors
relevant to individual QMAs.
MFish Policy Supported in 2005 IPP
3.1 option4 supports
the management of stocks above Bmsy.
Fisheries Act 1996 requires the Minister to set TACs such that
the biomass in each QMAis at
or above Bmsy. This should occur where (as examples):
- Stakeholders agree to manage fish stocks above Bmsy (as stated
at paragraph 17 of the 2005 kahawai IPP);
- Where the available information suggests that a greater utilisation
benefit would result and could be achieved by managing according
to the preference of the sector that values the resource the most
(as stated at paragraph 17 of the 2005 kahawai IPP);
- Where the scientific information on the status of stocks is
uncertain. Applying the precautionary principle (which is mandatory
under New Zealand's international obligations) stocks should be
managed above Bmsy where stock information is uncertain;
- Where there are reports from fishing clubs and experienced fishers
of a decline in catch rates;
- Where there is a significant non-commercial component to the
- Where the environmental adverse effects of high volume commercial
fishing are unknown;
- Species have a relatively low commercial value.
option4 agrees with paragraph 13 of the 2005 kahawai IPP which
states that the key benefits of management of stocks above Bmsy
- The increased availability of fish; and
- The increased size of fish.
3.4 option4 agrees with
MFish's (at paragraph 15) that increased availability and fish
size would benefit the recreational sector.
3.5 option4 also agrees
with MFish (at paragraph 19 of the 2005 IPP) to the extent that:
The non-commercial sector values kahawai more
highly than the commercial sector;
- Kahawai is a relatively low value commercial species.
submits that the Minister should place greater weight on the factors
identified in paragraph 29 of the 2005 IPP in deciding TACs.
submits that this is typical of the lack of certainty surrounding
the scientific information on the status of kahawai stocks.
agrees with MFish's statements at paragraph 110(c)(i) of the 2005
IPP to the effect that there is a need for caution given the interdependence
of other stocks on kahawai.
agrees with MFish's statement at paragraph 130 of the 2005 IPP
anglers are characterised as follows: they go fishing significantly
more times per year and are more likely to fish for eating
purposes. They are more likely to fish from jetty or land
platforms and are slightly more likely to catch and keep additional
fish. They have a lower average fishing expenditure, have
a higher male participation and are more likely to be a member
of a fishing club."
3.10 While these agreements are a positive development,
many issues remain to be resolved and are discussed below.
Problems with past Kahawai Management
4.1 The history of kahawai management has created problems. Most
recently, the 2004 kahawai decisions created an incorrect baseline
from which the 2005 decisions will be made. There are serious
omissions with the 2004 decisions which should be remedied.
Past high purse seine catch
4.2 Non-commercial fishers submitted in 2004 that past high purse
seine target catch had depleted the kahawai stocks and they have
not recovered. This depletion continues to adversely affect the
quality of amateur and customary fisheries. In particular to catch
kahawai at reasonable catch rates and of reasonable size.
4.3 In response to these claims, MFish provided the following
information in their 2004 Final Advice Paper (FAP) on which the
Minister based his decision. The MFish 2004 FAP stated at paragraphs
117 to 121:
“Figure 1 shows a representation of combined landings by
sector groups over time. The figure is based on reported commercial
landings data, recreational harvest estimates up to 1996 are those
data reported for the sensitivity analysis version of the 1996
stock assessment and the two point sources graphed for 1999-00
and 2000-01 are based on recreational harvest estimates as reported
in table 3. Customary landings are included in the non-commercial
estimates until 1996. After that, customary harvest is shown separately
based on 25% of the recreational estimates. The combined commercial
purse seine catch limits (CCL) are shown. Also depicted are the
1996 estimates of MCY based on a natural mortality of M=0.2 (7,600
tonnes and 8,200 tonnes).
MFish notes recreational
submissions suggesting unsustainable levels of commercial fishing.
Figure 1 does suggest the level of commercial fishing alone
was in excess of MCY estimates between 1987 and 1991. However,
MFish does not share submitters views that management of the
kahawai fishery after 1991 was ineffective and that as a result
any kahawai stock is depleted due to commercial fishing.
As shown in Figure 1, the introduction of purse seine limits
was effective in limiting commercial catches. The reported number
of annual purse seining target sets on kahawai was reduced from
about 250 sets in 1987-88 prior to the introduction of catch
limits to average about 60 sets after their introduction. Commercial
catches have declined after peaking at 9 600 tonnes in 1987-88
to 2 900 tonnes in 2002-03.
MFish notes that commercial purse seine catch limits currently
apply only to purse seining when kahawai is the target species.
Landings in some years in excess of CCLs as shown in Figure
1 are due to landings of kahawai as bycatch.
Commercial landings from KAH 3 have declined by more than 5
000 tonnes between 1980 and 2003. Most of the early part of
this reduction in landings is due to imposing purse seine catch
limits, however these have not constrained commercial landings
since 1995-96. MFish notes the reasons given for declining commercial
landings provided in submissions. Industry submits that profitability
of this fishery has been eroded by measures that they have voluntarily
agreed to and the closure of a cannery, which have resulted
in a changed distribution of the purse seine fleet. Recreational
fishers submit that declining catch rates are a more likely
cause of the cessation of purse seine fishing in KAH 3.
Trends in non-commercial catch, while developed for the 1996
assessment model, are unknown. The two most recent harvest estimates
suggest recreational fishers currently account for a much greater
component of total landings than the commercial sector. Whether
this is the result of a more recent increase in recreational
catches or recreational catches of kahawai have been substantially
higher than previously thought in the past is unknown. Most
recreational submissions claim that recreational catches of
kahawai have declined. If this were to be the case then historical
catches may have been substantial.”
4.4 option4 has concerns regarding the way in which the above
information has been presented, the accuracy of the information,
and the conclusions MFish have drawn from the information.
Mis-reported and non-reported commercial kahawai catch
4.5 The chart above (Figure 1 under paragraph
117 of MFish's 2004 kahawai FAP) does not show the full extent
of the commercial catch because there was a large amount of under-reporting
and misreporting of commercial kahawai catch during the period.
This was discussed in MFish's 1988, 1989 and 1990 Plenary reports
which MFish produced to analyse the status of kahawai stocks from
4.6 It is necessary to take commercial misreporting and under-reporting
into account in order to accurately evaluate the impact of the
dramatic rise in commercial catch during 1974 – 1987/88
on non-commercial fishers. During the late 1980s, commercial fishers
had an incentive to "fish for quota" in anticipation
of kahawai being introduced to the quota management system and
commercial quota being allocated according to catch history.
4.7 The adverse effects of this large scale commercial purse seining
of kahawai during this period has not been fully addressed by
4.8 MFish's depiction of historical catch rates in the graph shown
above (Figure 1 under paragraph 117 of MFish's 2004 FAP) did not
include estimates of under-reported and misreported catch.
4.9 For instance, the total catch in 1984 was believed to be 8000
tonnes as opposed to the reported 4400 tonnes. From 1983-1986
MFish estimated that the commercial catch was 6000 tonnes to 9000
tonnes annually when the reported catch was only 3700 tonnes –
4800 tonnes. Three main sources of commercial under-reporting
were noted in MFish's 1990 Plenary report:
dumped at sea;
for line and rock lobster fisheries; and
reported as mixed fish by the purse seine fishery.
4.10 It was thought
that large-scale dumping declined by about 1983 because it became
preferable to land kahawai rather than dump them at sea as more
valuable commercial species became scarcer.
4.11 However, some purse seine fishers continued to misreport
kahawai catch as, for example, “mixed fish”, “rejects”
or “felix” throughout the 1980s. This practice occurred
where kahawai and other species like jack mackerel were caught
in mixed schools and were not readily identifiable because of
the large amount of fish caught. When MFish's estimates of the
amount of kahawai taken as "mixed fish" are added to
the reported commercial catch, the commercial catch is actually
much higher. The graph below displays reported commercial catch
compared to reported commercial catch with MFish's estimates of
mis-reported commercial catch (taken from Table 2 of MFish's 1990
4.12 The new graph does
not include estimates of the tonnages of commercially caught kahawai
dumped at sea, used as bait or the large-scale non -reporting.
Submission - Printable
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