option4
Rebuttal of Kahawai Initial
Position
Paper 2004
Part
One
When
a species is introduced into the Quota Management System (QMS)
the Ministry of Fisheries issues its suggested management proposals
to the Minister in an Initial Position Paper (IPP). The Minister
uses this information to base his final decision on when setting
the TACC and allowing for the public and customary Maori fishers.
option4 have major concerns
with much of the information provided in the IPP. Also of concern
is the Ministry's position in having presented the Minister with
only one option for the future management of this most important
species. We have spent time going through the document section
by section so you can understand our concerns.
The document has been
split into manageable sections so you can quickly come to grips
with the issues option4 has identified as being of note.
KEY:
Black text is IPP
Blue text is option4 commentmment.
KAHAWAI
(KAH)
Part One
Introduction
into the QMS.
Key issues
to be considered.
-
We
are appalled at the absence of sound information regarding non
commercial catches in a fishery of such national importance.
More »
-
Why
present the Minister with only one management option for kahawai?
More »
-
The
public have been disenfranchised from their fishery.
More »
Introduction
into the QMS
- Kahawai ( Arripis trutta and A. xylabion)
has been gazetted for introduction into the QMS on 1 October 2004.
The Quota Management Areas (QMAs) for kahawai are outlined
in Figure 1. The fishing year for kahawai will be from
1 October to 30 September in the following year and
the total allowable commercial catch (TACC) and annual catch entitlement
(ACE) are to be expressed in terms of kilograms greenweight.
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Figure 1: Quota Management Areas
for kahawai
Key
Issues to be considered
- MFish considers the key issues that relate to the decisions
for setting sustainability measures for kahawai stocks are as
follows:
- There are two species of kahawai present in New Zealand waters,
kahawai and northern kahawai. A stock assessment applies to kahawai
and there is very little information available for the other species.
- Kahawai biomass had declined to about 50% of the virgin biomass
at the time of the assessment in 1996, however the current biomass
is unknown. Nationwide combined estimates of recreational
catch, customary catch and reported commercial landings are currently
just within the range of MCY estimates based on the 1996 stock
assessment.
- Background information on catch by sector and method is outlined
in Annex One.
While primarily a purse seine fishery in QMAs 1, 2 and 3,
kahawai is almost entirely taken as bycatch in QMA 8. Commercial
catch limits (CCLs) apply to kahawai, with specific limits pertaining
to purse seining.
- Since the imposition of CCLs catches, although fluctuating,
have progressively declined principally in QMA 3. Declining
catch in QMA 3 is associated with reduced purse seining in this
area.
- Recreational catch is about 83% of commercial landings as estimated
by recreational harvest surveys. Kahawai is one of the
fish species most frequently caught by recreational fishers.
-
The recreational sector
believes that the number of kahawai available to them and the
average size of kahawai has decreased over time.
-
Kahawai supports important
Maori customary fisheries but the size of the catch is unknown.
option4
comments on point d.
- option4 comments on point d. –
1. Refer Annex
3 - Feldman report p3 –“ For years now the purse-seine
vessels have been unable to catch their limit in KAH3. With two
boats operating in KAH3 the purse-seiners were able to catch up
to 5000 tonnes per year in the late 1980’s. From 1991-92,
92-93, 93-94 and 94-95 these same two boats were unable to catch
their limit at any time. This suggests their CPUE is 1/2 to 1/3
of what it used to be in the late 1980’s.
If purse-seiners, guided by airplanes, cannot land kahawai in
KAH3, it’s easy to understand why recreational fishers feel
they can no longer catch kahawai either. Given that it is much
easier to catch kahawai with an airplane and purse siener, its
reasonable to assume the recreational CPUE in KAH3 must have declined
concurrently to less than 1/3 of what it used to be in the 1980’s.”
- option4 is concerned the above list of
“key issues that relate to the decisions for setting sustainability
measures for kahawai stocks” does not include the need for
good information. If, for any reason, the information available
to base decisions on lacks adequacy or agreement, this should
be stated up front as a key issue. We are appalled at the absence
of sound information regarding non commercial catches
in a fishery of such national importance and where the non commercial
sector has expressed grave concerns for at least 20 years.
Read on and realise what sketchy information the Minister is expected
to base his decisions on for this, the most important national
non commercial species in our seas.
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List
of Management Options
- MFish proposes that the s 13 management arrangements are appropriate
for kahawai.
- MFish proposes one option for setting TACS, TACCs and allowances
for kahawai stocks as outlined below.
We would prefer to
see this sentence written as follows:
“MFish proposes one option for setting TAC’S, TACC’s
and proposes to allow for non commercial fishers as outlined below”.
As far as we are concerned the Minister does not make allocations
for non commercial fishers. Section 21 of the 1996 Fisheries Act
is quite clear “When setting a TACC the Minister shall allow
for non commercial fishers”. Nowhere in the Act does it
say “set an allocation or allowance.” How long do
we have to put up with this blatantly inaccurate interpretation
of the law?
Table 1 Proposed TAC's, TACC's, and allowances for kahawai
(tonnes greenweight).
Stock
|
TAC
|
Customary
allowance |
Recreational
allowance |
Other
sources of mortality |
TACC
|
KAH
1 |
3 910
|
790
|
1 580
|
60
|
1 480
|
KAH
2 |
1 510
|
255
|
510
|
35
|
710
|
KAH
3 |
960
|
150
|
300
|
20
|
490
|
KAH
4 |
18
|
3
|
5
|
0
|
10
|
KAH
8 |
1 210
|
190
|
380
|
5
|
635
|
KAH
10 |
18
|
3
|
5
|
0
|
10
|
Why present the Minister
with only one management option for this species
which has been the subject of public concern for at least 20 years?
Please also be very aware that the tonnages outlined are all derived
from completely different base line information. In the case of
recreational they base their recommendation on a crude averaging
exercise. For customary they grab a figure out of thin air based
on some criteria established with little or no public discussion
and the commercial figures are political. As for other sources of
mortality – the truth is they have not got a clue what this
should be.
- Additional management controls proposed include:
- setting deemed values and application of differential deemed
values;
- amending reporting regulations, and
- revoking certain fishing permit conditions. These conditions
are redundant as they relate to the closing of the purse seine
fishery once purse seine limits for kahawai have been reached.
NZRFC
and NZBGFC both have long standing policies that kahawai should
be managed as a non commercial fishery only. This makes good sense
because developing the kahawai commercial fishery has lead to a
massive decline in non commercial catch rates and also adversely
impacted on the size of fish available to those fishers.
The Fisheries Act stipulates that those fishing commercially are
not permitted to adversely impact on the existing rights of other
users of the fishery. This part of the Fisheries Act has been grossly
ignored when applied to the kahawai fishery. The public
have been disenfranchised from their fishery through the
Ministry’s preference to ignore the rights of the people and
fully support the development of the purse seine kahawai fishery.
We are appalled that the Ministry has only seen fit to include catch
histories from 1993 to 2002 in its tables. Had the tables presented
shown catches as far back as possible it would have made the IPP
document more honest and it would be easier for the Minister to
see what has happened in this fishery.
The logic of the Ministry in this case is difficult to understand
when one considers the value of recreationally caught kahawai at
$28,000 - 56,000 per tonne compared to the pitiful commercial value
of $1700 - $5100 per tonne. One eleventh to one sixteenth of the
value of non commercially caught kahawai.
Kahawai is a low value commercial species that could be released
alive from longliners or purse seiners. Placing kahawai on the 6th
Schedule would allow the commercial fisher the option of releasing
fish, otherwise every kahawai caught must be kept.
Return to the option4
kahawai IPP rebuttal index page for more
info »
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information on kahawai available here »
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