| option4
Rebuttal of Kahawai Initial
Position
Paper 2004
Part
Two
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 Two
TACs
TAC management strategy
Rationale
for proposed TACs
- We
find it incomprehensible that such a vastly important fishery
should be allocated on such uncertain stock assessments...
More »
- The purse seine catch history should be
disallowed for the purposes of setting a TACC. More
»
- The worst depletion is in... More
»
- This form of status quo allocation is
not about fisheries management it is about issuing perpetual property
rights...based on current utilisation. More
»
Kahawai
by Quota Management Area
TAC management
strategy
- Section 13 of the Act represents the default management option
that is to be applied when setting a TAC for a QMS stock, unless
the stock size is considered highly variable from year to year
or it qualifies for management under the criteria outlined in
s14 or s14A of the 1996 Act. MFish does not consider that
kahawai stock sizes are highly variable from year to year. In
order for a stock to be added to the Third Schedule under the
provisions of s 14, the biological characteristics of the species
must prevent the estimation of Bmsy, the catch limit for any of
the stock must form part of an international agreement, or the
stock must be managed on a rotational or enhanced basis.
Kahawai does not meet any of these criteria. Section 14A
enables the Minister to set a TAC that maintains the stock at
a level that ensures its long-term viability, while other inter-related
stocks can be taken at TAC and TACC levels based on Bmsy. MFish
does not consider that section 14A is applicable to kahawai fisheries
because:
- there is no associated species that requires commercial fishing
to that level;
- there would be detrimental effects on non-commercial fishing
interests; and
- of the potential for adverse ecosystem effects.
- MFish believes that the s13 management arrangements are appropriate
for kahawai. Under s13 there is a requirement to maintain a fishstock
at a target stock level, being at, or above, a level that can
produce the MSY, having regard to the interdependence of stocks.
MSY is defined, in relation to any fishstock, as being the greatest
yield that can be achieved over time while maintaining the stock's
productive capacity, having regard to the population dynamics
of the stock and any environmental factors that influence the
stock.
MFish should also
note that Section 13(3) requires the Minister to have regard to
such social, cultural and economic factors as he or she considers
relevant when moving towards a level at or above the Maximum Sustainable
Yield (MSY).
- As outlined in the Statutory Obligations and Policy Guidelines
section, there are guidelines for setting TACs for new species.
Among the more important considerations for kahawai are the level
of current utilisation, existing stock assessment information,
the current commercial purse seine limits, the biological and
fishery characteristics of the stock, implications for interdependent
stocks, and whether the target level for the TAC can provide benefits
that will improve utility from the available harvest. An overlying
consideration is the importance of kahawai as a shared fishery
between commercial and non-commercial fishing interests.
How can the Ministry
purport above “An overlying consideration is the importance
of kahawai as a shared fishery between commercial and non-commercial
fishing interests “ and then completely ignore the massive
CPUE decline suffered by non commercial fishers due to the development
and ongoing impact of the purse seine fishery?
Why have they failed to register as an important consideration
the brutal fishdown of the stock by commercial fishers?
TOP
Rationale
for proposed TACs
- Policy guidelines have constructed an hierarchal approach in
respect of the information for setting TACs and hence the weighting
to be assigned to that information. Stock assessment information
is afforded greater weight than a non-QMS catch limit set for
the stock. A CCL may be afforded greater weight than information
about historical and current catch levels.
- Estimates of virgin and 1996 biomasses, and an estimate of maximum
constant yield (MCY) for a single nationwide kahawai stock are
available. MCY and its relevance to the setting of TACs
are discussed in the Report from the Fishery Assessment Plenary
[1].
[1]Guide to Biological Reference
Points for the 2002-2003 Fisheries assessment Meetings in Report
from the Fishery Assessment Plenary, May 2003: stock assessments
and yield estimates Part 1: Albacore to Ling. J Annala et al Comps
and eds
- A discussion of the stock assessment model for kahawai is provided
in the Fisheries Assessment section in Annex
Two. Given the history of exploitation, the kahawai stock
is not likely to be at or near its virgin biomass (Bo). Modelling
suggests that the fishery was at approximately 50% of Bo in 1996.
The above figure is
highly uncertain and dependant on many assumptions made for this
species.
The introduction of purse seine limits has been effective in limiting
commercial catches since 1993-94 and the biomass may have stabilised
since that time.
The purse seine catch
limit has not been reached for at least the last three years.
However, trends in non-commercial catch during this period are
unknown. Recreational catch is a significant proportion
of the fishery.
Remember, the public
can only catch a kahawai if it is available to be caught. The
massive overfishing by the purse seiners in 1989
-1993 denied the public the opportunity to ever have an accurate
estimate of non commercial catch as by the time these estimates
were taken our catch was a shadow of its former glory.
- There is uncertainty about the level of
current biomass levels and the applicability, for setting current
yields, of using the 1996 stock assessment. This is because the
assessment is not only uncertain but also some seven years out
of date.
We find it incomprehensible
that such a vastly important national non commercial fishery should
enter the QMS and be allocated to commercial interests based on
such uncertain stock assessments and catch records.
Surely the biggest problem is there is no reliable index of relative
abundance for kahawai. Because of this, even a brand new stock
assessment will still be highly uncertain. It is widely accepted
by stock assessment scientists that decreasing fork length, declining
CPUE for commercial vessels and poor recreational catch rates
are the early signs of a declining fishery. We believe that all
these factors now apply to kahawai (Annex
3).
- For the 1990-91 fishing year, the Minister agreed that a total
commercial catch limit should be 6 500 tonnes
Why? MFish should
explain why it was felt necessary to limit the commercial catch.
It was because of the rapid increase in commercial catch
and the perception from recreational and customary fishers that
one of the last abundant inshore fish stock was being hammered
(fished unsustainably) and non-commercial fishers where finding
their catch rates had declined significantly.
(based on a value derived from a compromise between the average
commercial landings for 1983-86 of 5 000 tonnes and the average
commercial landings for 1986-89 of 8 500 tones) with 650
tonnes of this total set aside for Maori. As an interim measure
until introduction of kahawai into the QMS, the Minister decided
to set specific limits pertaining only to purse seining. Commercial
catch limits (CCL) were set by dividing the 5 850 tonne catch
limit amongst the FMAs in proportion to the average purse seine
landings relative to the other commercial fishing method landings
reported during the period 1987-89: 1 666 tonnes for FMA 1,
851 tonnes for FMA 2, 2 339 tonnes for FMAs 3-8
and 0 tonnes for FMA 9.
- While national catches decreased during 1991-92, landings in
FMA 1 increased and for 1993-94 the competitive catch limit for
purse seining in FMA 1 was reduced from 1 666 tonnes to 1 200
tonnes and any purse seine catches reported for FMA 9 were included
in this catch limit.
Why? It is important
for MFish to acknowledge that there was so much public concern
over the continued decline in kahawai that the
Minister felt that a further reduction in the purse seine limits
were necessary at that time.
No changes have been made to the purse seine limit of 851 tonnes
for FMA 2. The purse seine catch limit for FMAs 3-8 was
reduced from 2 339 to 1 500 tonnes from 1995-96.
Again Why?
- MFish does not support using the current CCLs as a basis for
setting TACs. This is because the CCLs pertain only to purse seining,
have no stock assessment as their basis, and are based on landings
data.
We agree that the
CCL should not be rolled over into quota and so perpetuate management
measures of the past. Exactly the same could be said of the TAC
proposed by MFish in this paper “have no stock assessment
as their basis, and are based on landings data.”
- In the instance of a commercial fishery that is stable, but
variable, guidelines suggest criteria to set catch limits on the
basis of either the current commercial catch or on average catches
when landings have been stable in excess of three years. Commercial
landings of kahawai declined between 1988 and 1998 and have stabilised
thereafter, particularly in the important management areas QMA
1 and QMA 2. Accordingly, the proposed TACs have been calculated
using average commercial landings for the period between 1997
and 2002 as MFish considers this relatively stable period provides
the best available information on current levels of commercial
utilisation.
This is exactly the
technique that is not supported in para 15 above.
It is also broadly consistent with the method for evaluating the
current recreational utilisation.
Are the “guidelines
that suggest criteria to set catch limits on the basis of either
the current commercial catch or on average catches when landings
have been stable in excess of three years” appropriate for
such an important non commercial fishery. What fisheries management
decisions and species form the basis for these “guidelines
and criteria”? Are they appropriate?
- The average of the two most recent estimates of recreational
landings has been used to estimate current recreational utilisation
of the fishery.
Why? What justification
is there for using the results from 1996 when it is accepted that
there were fundamental flaws in the estimate of the number of
people that fished that year. Totally unacceptable. Far too simplistic.
Arrogant and lazy!
- For species and stocks where there is some
catch, but the stock is not considered of importance to customary
Maori, then current utilisation may be estimated on the basis
of half the recreational catch. Kahawai is of considerable interest
to Maori in some areas, however there is no information on customary
harvest. MFish considers that, even though it is important as
a customary fishery, the level is unlikely to equal the level
of the recreational fishery and proposes to use 50% of the current
level of recreational utilisation as an estimate of current customary
harvest.
It is farcical for the Ministry to suggest that it can fairly
allow for either Maori customary or recreational/sustenance fishers.
Regardless of the amount allowed all non commercial fishers are
constrained by the absence of the numbers of fish they historically
had access to. The lack of fish availability can be solely traced
to the massive purse seine catches as this commercial fishery
was developed through trampling on the rights of existing users.
The purse seine catch history should be disallowed for
the purposes of setting a TACC.
Recognition should be given to the fact that the fishery has been
exploited to the stage where recreational and customary fishers
can no longer catch what they are targeting and the numbers targeted.
FAP 2002 pt 11.- A consideration of foremost importance is the
unique nature of the Maori customary non-commercial interest in
a fishery. The Fisheries Act 1996 and the customary fishing regulations
made pursuant to the Act, do not provide for the Crown to place
limitations on customary fishing, apart from ensuring the sustainability
of a particular stock. The customary allowance can be capped only
where the level of catch is likely to exceed the TAC.
option4 submission 2001 - The inshore fisheries belong to the
people of this country. The part of the fishery that is for commercial
harvest and sale (primarily export) is only what we, the non-commercial
sector, do not take to feed ourselves.
We support a fair allocation to cover what the
customary catch was before catch rates in important fisheries
around river mouths dropped. This may be considerably more than
what customary fishers take today. Here we see a classic piece
of inconsistency from Ministry. It is they who have drawn up the
ever changing set of “criteria” to determine how many
tonnes of fish to allow for customary Maori non commercial fishers.
If ever there was a fishery of fundamental importance to customary
Maori, kahawai is it. The criteria
clearly state that where the fishery is of significance to customary
Maori, then allow for the equivalent of the recreational harvest.
This is good as far as we are concerned. The fact that more often
than not customary Maori harvest cannot possibly amount to the
equivalent of the entire recreational catch (which of course includes
all of the fish Maori harvest when not fishing with a permit for
the purposes of their customary event requirements) serves as
a de facto “insurance” for all participants in the
fishery. Remember, when industry are allocated a tonnage that
becomes a property right (quota) they catch it. No more, no less
in fisheries where the QMS in fact constrains commercial fishers.
(As opposed to those fisheries where the quota has been set far
too high and the commercial fishers cannot catch their quota –
consistently, year after year – e.g. gurnard, GUR1; flounder,
FLA1, FLA2, FLA3; mullet, GMU1 etc, etc, etc
However, it is not clear how Ministry think about customary Maori
allowances. If they are in fact thinking (wishfully) that they
can make an allocation and make it a big one while they are at
it then we are in trouble. As far as we are concerned there is
no legislation that stated that the Minister makes an allocation
for anybody, other than the fishing industry. The legislation
(law of the country agreed upon by Parliament) clearly states
that when the Minister sets or varies a TACC (the allocation for
commercial) he shall ALLOW FOR non commercial
fishers. It does not say he shall make an allocation. It does
not say he shall allow for once and nor does it discuss changes
to an allocation. It simply states that he shall allow for –
now and forever.
- Combined estimates of current utilisation for the non-commercial
and commercial sectors are currently assessed to be about 7 600
tonnes.
This also may be an
underestimate because of the underestimate of
current recreational catch.
- Another consideration for TAC setting is
that recreational fishers value kahawai far greater than commercial
fishers (see Social, Cultural and Economic factors in Annex
Two). Current recreational perceptions are of a decline in
the availability of kahawai. The current proposal to set TACs
at the level of current utilisation assumes that these perceptions
are associated with a reduction in the kahawai stock to a level
at or above Bmsy and not below that level.
It is certainly the
view of most non-commercial fishers that kahawai in some areas
have been fished below a socially and culturally acceptable level.
This is not a recent occurrence but has been evident since the
late 1980s. The worst depletion appears to be
in FMA 1 where most of the purse seiners operate in direct competition
with the largest recreational, subsistence and customary fisheries.
Estimates of a sustainable yield, for what the Ministry assume
to be a single nationwide stock, may not reveal the large decline
in biomass we have seen in KAH1. This dramatic decline in the
size and number of kahawai schools is supported by strong anecdotal
information.
Does Ministry perceive/believe there is a decline in availability?
If so, they must say so. Or is it only “recreational perceptions.”
Certainly, the inability of industry to currently catch their
limits would suggest availability has declined. We hear talk of
industry only catching to order and various other explanations
as to why they are only landing x%
of what they are allowed to land. Are we to conclude that we,
the domestic market can’t eat any more commercially caught
smoked kahawai? Who are they trying to fool? Why can’t Ministry
just get real and clearly state that availability has obviously
declined and make honest fishery management decisions based on
this assertion. If the fishery is in trouble, let’s sort
it out. If that means last man in first man out then so be it.
Ban purse seining for kahawai, disallow purse seine catch history
developed over the top of the rights of others.
- Recreational interests are most likely best served by stocks
that are maintained above Bmsy as size and availability of fish
is increased in comparison to those available at a smaller biomass.
The stock assessment is uncertain and outdated and targets
above Bmsy are
not proposed.
In the absence of a stock assessment, the MFish
preferred policy is to use current utilisation as a basis
for determining both TACs and allocation. However, the shared
nature of the fishery is relevant when considering the risks with
respect to the uncertain information for setting sustainable yields
for the stock.
Bizarre beauracratic
hogwash!!!!!!!!!!!!!! Earlier the Ministry states, “An overlying
consideration is the importance of kahawai as a shared fishery
between commercial and non-commercial fishing interests”
Where are the non commercial values recognised in the above paragraph?
Clearly the Ministry has put much greater weight on running it
as a primarily commercial fishery.
When will they start treating us with respect?
It is not only recreational interests that “are most likely
best served by stocks that are maintained above BMSY as size and
availability of fish is increased in comparison to those available
at a smaller biomass”. Obviously customary Maori interests
are MOST DEFINITELY best served etc. Secondly, if the stock assessment
is both uncertain and out of date then why should they seemingly
automatically rule out “targets above BMSY”? To then
go on to state that “In the absence of a stock assessment,
the MFish preferred policy is to use current utilisation as a
basis for determining both TAC’s and allocation.”
is without basis or substance. This whole section offers no valid
reason why a) we should not be aiming for a stock size above BMSY
and b) why we should be determining TAC and allocation of a property
right on current utilisation. Not good enough!
FA 1996 s13 states “(2)The Minister shall set a total allowable
catch that (a)Maintains the stock at or above a level that can
produce the maximum sustainable yield, having regard to the interdependence
of stocks; or…”
This form of status quo allocation is not
about fisheries management it is about issuing perpetual
property rights at the expense of the public’s
access to their fish. When will the Ministry do the work to better
manage fisheries rather than rewarding those with the biggest
boats for being the most efficient at striping the ocean of kahawai?
Once the quota rewards have been issued it will be too late.
- Recreational interests believe the overall reduction in kahawai
schools might be having on effect on interdependent stocks of
predators such as marlin and tuna. MFish notes that the factors
influencing the distribution of highly migratory stocks of species
such as marlin and tuna is complex and not well understood. While
the availability of prey might be one important factor in the
seasonal availability of these species, kahawai may provide only
a component of any potential food source. Nevertheless, the importance
of species such as kahawai as a food source suggests the need
for caution when setting catch limits.
There is no doubt
that kahawai are an important link in the food chain
and the inshore marine ecology. Kahawai drive small fish and krill
to the surface and make them available to seabirds. Where does
this element of caution actually manifest itself in the Ministry
recommendations? Sadly, more hollow words.
- In summary, MFish proposes that TACs be based on estimates of
current utilisation. Although relevant,
the stock assessment information is uncertain and dated. The CCLs
pertain only to purse seining, are based on dated landings data
and have no stock assessment basis. While commercial landings
have been relatively stable, trends in non-commercial catch are
unknown. Estimates of utility suggest that kahawai is much more
greatly valued by the recreational sector. However, rather than
suggesting alternative stock targets, MFish considers that the
disparity in relative value between the sectors supports the need
for caution in setting catch limits for the fishery.
So MFish propose that
it is best to cautiously do nothing. Set perpetual property rights
at current level of catch and hope that one day someone will take
the time to manage this fishery better. Whilst landings may appear
stable, we believe that it is taking much more effort for industry
to take these landings. Ministry make the claim – let them
back it up with evidence of quality analysis. Wait, there’s
more. We see a brief reference to “disparity in value between
the sectors” here as being of support for the need for caution
in setting catch limits. More hollow words. Where does this element
of caution manifest itself in the management recommendations?
- MFish notes that combined estimates of non-commercial and commercial
utilisation for kahawai stocks are currently just within the range
of the estimates for MCY (7 600-8 200 tonnes). MFish
proposes setting TACs that coincidently lie on the lower bound
of the MCY estimate (ie, 7 600 tonnes).
We have yet to agree
with the analysis of all relevant available material to support
the assertion that MCY range of 7600 – 8200 tonnes per annum.
TOP
Quota
Management Areas
KAH
1
- MFish proposes a TAC for KAH 1 of 3 910 tonnes based
on current utilisation of the fishery.
Is there an obligation
to base all QMA TAC decisions on the same basis, i.e. current
utilisation? If ever there was a case to have a more complex,
empathetic basis for calculating a TAC it has to be for KAH
1 – the QMA with by far the greatest population per kilometre
of coast.
KAH
2
- MFish proposes a TAC for KAH 2 of 1 510 tonnes based
on current utilisation of the fishery.
KAH
3
- MFish proposes a TAC for KAH 3 of 960 tonnes based on current
utilisation of the fishery.
KAH
4
- Only very small amounts of catch have been reported in FMA
4. MFish proposes a nominal TAC of 18 tonnes for KAH 4.
KAH
8
- MFish proposes a TAC for KAH 8 of 1 210 tonnes based
on current utilisation of the fishery. MFish notes that
ACE will primarily be required to cover the bycatch of fishing
for other species in KAH 8.
What is this supposed
to mean? – A full explanation is required. A good question
to put to officials at the public meetings.
KAH
10
-
No catch has been reported in FMA 10. MFish
proposes a nominal TAC of 18 tonnes for KAH10.
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