NZBGFC SUBMISSION May 2004

NZ Big Game Fishing Council Submission on the

Fisheries Amendment Bill (No. 3)

May 2004

NZBGFC

PO Box 93

Whangarei

Northland

Primary Production Committee

Parliament House

WELLINGTON

3 May 2004

NZ Big Game Fishing Council Submission on the

Fisheries Amendment Bill (No. 3)

NZ Big Game Fishing Council

1. 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 the nation wide fishing tournament, which has evolved over time and remains successful.
2. NZBGFC compile and publish the New Zealand records for fish caught in saltwater by recreational anglers and are members of the International Game Fish Association who compile world record catches.
3. In the early 1980's the NZBGFC helped establish and fund the NZ Recreational Fishing Council to ensure better representation of non-commercial fishers at the national level. The NZRFC continues to be recognised in this role.
4. In 1996 NZBGFC helped establish the NZ Marine Research Foundation, which aims to sponsor research on marine species and fisheries, for the benefit of all New Zealanders, including participants in ocean recreation.
5. Many of our most established fishing clubs have a focus on fishing for large pelagic species such as marlin, tuna, broadbill swordfish and sharks. In recent years our membership has expanded beyond the traditional deep sea angling clubs to include many local clubs targeting a range of species.

Identifying and introducing stocks into the QMS

6. NZBGFC and the NZ Recreational Fishing Council are two national organisations that have, for a long time, promoted the management of kahawai and kingfish as non-commercial species, outside the quota management system (QMS). The Minister has decided that the aspirations of recreational and customary fishers for better access to kahawai and kingfish could be addressed within the QMS framework. We accept that decision and we are optimistic that kingfish stocks will start to rebuild under the management regime introduced last year. We remain deeply concerned about the fate of kahawai as the only TAC option proposed by MFish is based on a continuation of the status quo.
7. The QMS is a tool designed for managing commercial fisheries via TACC, ITQ and ACE.   The Minister must also allow for recreational and customary fishers, but the QMS can not be used for allocating shares within the recreational fishery. Therefore there is no benefit from having a non-commercial species in the QMS. The only practical reason for introducing a species to the QMS would be to manage the commercial harvest.
8. There are a number of non-commercial species that are critically important to the survival of or northern fishing clubs. Pre-eminent amongst these is striped marlin which comprises about 90% of recreational billfish catch along with blue marlin, black marlin and shortbilled spearfish. The Billfish Moratorium and subsequent regulations have protected these species from commercial exploitation since 1987. Similar regulations for some marlin species are in place in Australia, some states in the USA and parts of Mexico.
9. At the end of an extensive review of the gillnet fishery in the early 1990s 19 species of reef fish were classified as non-commercial in the north half of the North Island. These were mostly slow growing, long lived, resident, fish that could be wiped out in quite a short time by the gillnet method.
10. The NZBGFC opposed the criteria originally proposed by MFish to determine if a species should be introduced to the QMS because they could have forced almost all species caught by fishers, including non-commercial species, into the QMS.
11. NZBGFC support the current wording proposed in this Bill for section 17B of the Fisheries Act 1996. The criteria for introduction in 17B (1) state that the Minister must be satisfied that the current management of a stock or species -

1. is resulting in unsustainable fishing; or
2. is not enabling utilisation of the stock or species"

These criteria are broad enough to include species that should be introduced. However, it is important we believe, that stocks that meet these criteria are not automatically put up for entry to the QMS.   There must be due process and a determination by the Minister.

12. NZBGFC support the next stage in the process (section 17B (2)) which allows the Minister to consult and consider an alternative to QMS management if he or she " determines that the purpose of this Act would be better met by setting one or more of the sustainability measures set out in section 11(3) ". These measures could be: c atch limits; size limits; area restrictions; method restrictions; fishing season. This would allow recreational fishers, Maori fishers or environmental groups to promote the use of existing controls for non-commercial fish species if they were proposed by the fishing industry or MFish for quota management.
13. There is no mechanism for removing species from the QMS. Once they are in they are there for ever. It is important that for species of particular interest to one or more sectors that there is a transparent process, which they can participate in, to determine if that species would be better managed in the QMS or not.
14. The old Cost Benefit criteria were not transparent and in our opinion highly subjective. Having said that we believe that commercial fishers may be justified in wanting the Minister and Ministry to consider the compliance cost of introducing low value or minor bycatch species into the QMS.

15. The Bill proposes to place all the important highly migratory species (HMS) into the QMS including catch by New Zealand vessels in international waters. Fishers outside the EEZ would be required to report their catch in the same way as those fishing inside the EEZ, and they would be required to hold annual catch entitlement (ACE) to cover the fish they catch. They would also be able to build up catch history in international waters prior to allocation of quota.
16. We strongly oppose the possibility that quota generated by distant water fishing fleets could be transferred into the New Zealand EEZ. There would have to be quota management areas (QMAs) established for areas across the Pacific Ocean and Tasman Sea and quota would have to be specific to those QMAs. The New Zealand EEZ must be treated as a separate quota management area.
17. In the explanatory note to the Bill we are told that New Zealand exports about 8 000 tonnes of tuna a year and another 20 000 tonnes of skipjack, yellowfin and bigeye tuna (they forgot to mention the bycatch of juvenile bigeye tuna in this fishery) is taken in international waters. What we do not want is for all or part of the 20 000 tonne of tuna quota that this Bill will generate to be transferred and targeted in the New Zealand EEZ. The potential for such a massive increase in tuna catch is not good management and would impact on the availability of tuna to non-commercial fishers.
18. The term highly migratory is a general term. It should not be used to imply that tuna, marlin and sharks are always on the move. Many of these species show a seasonal migration into New Zealand waters along with warm currents in spring and summer. It is likely that they come to feed on the plentiful supply of baitfish and squid off our coast. Tagging studies supported by NZBGFC and New Zealand recreational fishers show that these "highly migratory" fish can stay several months in the EEZ. If the same fish return every year then they may end up spending a significant proportion of there lives in New Zealand.
19. Recent studies in Australia have shown that the commercial catch rate of broadbill swordfish is much lower in areas that have been fished for some time and that fishers are travelling further and further to maintain there catches. Broadbill swordfish is a highly prized component of the recreational catch that has been over exploited in northern New Zealand by tuna longliners. Our members will not support changes to the Fisheries Act that would increase the commercial exploitation on broadbill in New Zealand waters.

20. NZBGFC supports the criteria and process to determine if a species should be introduced to the QMS in clause 5 of the Bill section 17(B). It is a significant improvement on the criteria circulated in the MFish discussion document. We do not want non-commercial species such as marlin or protected reef species forced into the QMS by this legislation.
21. If quota is issued to New Zealand vessels for HM species taken in international waters this quota must only be valid for QMAs in the area that the fish was taken. The New Zealand EEZ must be a separate QMA for management purposes.

Thank you for considering our submission.

Jeff Romeril

PRESIDENT

TOP