Kahawai FAP

Kahawai Final Advice Paper

Ministry of Fisheries

29 June 2004

TACC

MFish initial position

231. TACCs proposed in the IPP for each QMA are set out in Table 8 below.

Stakeholder submissions

232. The Council of Outdoor Recreation Associations of New Zealand Inc and New Zealand Angling Limited submit that kahawai should be designated a recreational fish with no allocation of commercial quota. They submit that only by eliminating commercial fishing will the fishery recover to sustainable levels.
233. Non-Commercial Fishers and the RFC submit that purse seine catch history should be discounted and that the TACCs should be based on reported commercial bycatch only. Non-Commercial Fishers submit that for three of five years the purse seine fleet has exceeded the KAH 1 commercial catch limit of 1 200 tonnes and because this is illegal it should be discounted from the catch history.
234. Mark Feldman submits that as kahawai are worth a lot more to the recreational sector an effort should be made to define the true commercial bycatch and this should be used to determine TACCs. Mark Feldman is concerned that the IPP recommends an increase in the commercial fishery.
235. The Sanford submission proposes setting TACs on the basis of MCYsensitivity analysis (8,200 tonnes) and allocating TACCs on the basis of these TACs after making allowances for recreational and customary fishing.
236. The NIFCL, SeaFIC, TOKM and Sealord support basing TACCs on estimates of current commercial utilisation but differ in their proposals for defining what current utilisation is.

MFish discussion

237. The setting of TACs relies on determining a level of catch that will ensure the sustainability of kahawai stocks. The decision on TACCs is a separate one. In determining TACCs for kahawai stocks you are free to decide between MFish proposals or consider alternatives based on submissions if you so wish.
238. There have been changes to the estimates of commercial utilisation proposed in the IPP. The IPP proposed that allocation of the TACC be based on the average of the most recent five years of commercial landings data. Submissions have noted that commercial landings data used in the IPP are less than those reported by the Plenary report [10]. MFish notes that some of this discrepancy is due to data reported as being disposed to the Crown, retained on board, or seized by the Crown being excluded from total landings and kahawai reported being used for bait being included in totals derived for the IPP.
239. However of more significance, when allocating landings data to the new QMAs to apply from 1 October 2004 some of the landing data was omitted. This occurred when kahawai catch was not reported in the effort section of catch and effort landing returns (only the top five species for any fishing event are recorded in this way for some fishing methods) and could not be allocated to a fishing return area. To correct this omission, MFish has recalculated commercial landings by prorating fishstock totals that can be assigned by area up to the national landings data total. MFish has also included the most recent year of catch data in the five-year period. This was incomplete at the time of preparation of the IPP. These changes have the effect of increasing some of the estimates of commercial utilisation by about 5% (refer Table 8).
240. MFish has adjusted the quantitative estimates of current utilisation on the basis of new information and submissions. These estimates of current commercial utilisation are the basis of one option for setting TACCs. Within TACs reduced by 15% from estimated levels of current commercial and recreational utilisation MFish proposes that TACCs are based on that same proportional reduction. That is TACCs are based on the average of the most recent five years of commercial landings reduced by 15% for some key kahawai stocks (KAH 1, KAH 2, KAH 3 and KAH 8).
241. Some commercial submissions propose that a longer time series of commercial catch should be used to as a basis for determining TACCs. In recommending current landings as a basis for TACCs, MFish acknowledges that reduced commercial catches have already come about due to the introduction of purse seine catch limits. Further, MFish acknowledges that some industry participants have applied additional voluntary constraints such as voluntary closed areas and a fishing season, which have further limited opportunities for commercial catch within purse seine catch limits (KAH 3). MFish considers that these public policy considerations already in place for the fishery should be retained and therefore landings based on the current management arrangements in the fishery should be used to develop allocation options.
242. MFish is not dismissing the efforts taken by commercial fishers to conserve the fishery. Nor is MFish, by the options proposed, intending to penalise commercial fishers for any efforts that they have taken to address conflicts with recreational kahawai fishers. MFish notes that similar actions have been taken by recreational fishers, in particular the catch and release practice adopted by some recreational fishers. There is no practical way of determining the relative contribution of measures undertaken by each sector in ensuring the sustainability of kahawai stocks. By default, the baseline approach is to use estimates of current landings to reflect current reliance on the stocks.
     
     

243. While commercial purse seine catch limits currently apply to kahawai, the specific limits pertain only to purse seining when kahawai is the target species. It is therefore incorrect of Mark Feldman and other recreational submitters to compare the TACCs proposed in the IPP and the current commercial catch limits and infer that MFish proposals were to increase the level of commercial fishing. in some fishstocks. Catches by methods other than purse seine are not currently limited. TACCs will constrain all commercial landings whether caught as target or bycatch and regardless of fishing method.
244. MFish does not consider it necessary to discount any catch history for catches in excess of the KAH 1 purse seine limit as proposed by Non-Commercial fishers. This is because there is no illegal over catch reported in excess of commercial catch limits. Specific limits pertain only to purse seining when targeting kahawai. Any kahawai caught when purse seining for other species or as a target or bycatch of any other method may be legally landed over and above the purse seine limit.
245. There are economic impacts associated with adopting these proposed TACCs. MFish notes that the TACC proposed under proportional reduction is a 15% reduction in average landings taken in the five most recent fishing years for key stocks. The following section contains an assessment of possible economic impacts associated with TACC options. At your discretion, socio-economic impacts are relevant to your consideration of TACCs particularly those that involve a reduction from current levels of commercial use.