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Kahawai Submission

Kahawai Submission


10 August 2005


PO Box 37951

Parnell, Auckland




1. Introduction

Thank you for the opportunity to submit on the 2005 kahawai IPP.

option4 supports 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).  

option4 believes kahawai are an obvious candidate for management above BMSY .

The Minister's 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.

In 2004, 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.

The attached 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.


2. option4 Objectives

2.1 The following are option4's key objectives for kahawai:

  1. That kahawai stocks be managed above Bmsy such that "more fish are left in the sea";

  2. That the Minister not allocate "proportionally" between the commercial and non-commercial sectors which subordinates non-commercial fishing rights;

  3. 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;

  4. 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;

  5. 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.


3. MFish Policy Supported in 2005 IPP

3.1 option4 supports the management of stocks above Bmsy.

3.2 The 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):

  1. Stakeholders agree to manage fish stocks above Bmsy (as stated at paragraph 17 of the 2005 kahawai IPP);
  2. 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);
  3. 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;
  4. Where there are reports from fishing clubs and experienced fishers of a decline in catch rates;
  5. Where there is a significant non-commercial component to the fishery;
  6. Where the environmental adverse effects of high volume commercial fishing are unknown;
  7. Species have a relatively low commercial value.

3.3 option4 agrees with paragraph 13 of the 2005 kahawai IPP which states that the key benefits of management of stocks above Bmsy are:

  1. The increased availability of fish; and
  2. 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.

3.6 option4 submits that the Minister should place greater weight on the factors identified in paragraph 29 of the 2005 IPP in deciding TACs.

3.7 option4 submits that this is typical of the lack of certainty surrounding the scientific information on the status of kahawai stocks.

3.8 option4 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.

3.9 option4 agrees with MFish's statement at paragraph 130 of the 2005 IPP that:

"Kahawai 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.


4. 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 1989 onwards.

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 MFish.

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:

  1. Kahawai dumped at sea;
  2. Bait for line and rock lobster fisheries; and
  3. Catch 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 Plenary Report).

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.


Complete Submission - Printable

The option4 team have spent almost 700 hours producing this kahawai submission. Please feel free to cut and paste, download or print off a copy.

A printable version of this document is available. (230Kb)





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