| option4
Rebuttal of Kahawai Initial
Position
Paper 2004
Part
Four
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 kahawai 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
divided 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
Four
TACC's
Quota management
areas
Other
management methods
- Localised depletion on a massive scale.
More »
- Our second principle of excluding bulk
commercial fishing methods should be applied to the kahawai fishery
now. More »
- This is about marginal purse seining interests
versus 1 Million New Zealanders. More »
- Serial depletion. More
»
- Your catch rates have declined as the
kahawai have been stolen from you. More
»
- Why special management is required.
More »
TACCs
- Proposed TACCs in tonnes for each QMA are set out in Table
1.
- The proposed TACC has been calculated using average commercial
landings for the period between 1997 and 2002. This may understate
or overstate current commercial utilisation in terms of the period
chosen for some management areas. MFish notes that commercial
landings of KAH 1, KAH 2 and KAH 3 were greater between 1988 and
1997 and accordingly extending the years used to calculate average
commercial landings could potentially increase estimates of current
commercial utilisation.
So what! This is totally
irrelevant. The TACC is the remainder of the TAC after the Minister
has allowed for non commercial and other mortality associated
with fishing.
Any potential impact from adopting different estimates of current
utilisation can be measured as direct opportunity costs. A tonne
of kahawai has a value and any reduction in tonnage for the commercial
sector as a result of a lower TACC can be measured in terms of
a forgone value. MFish considers that any such impacts can best
be measured by forgone annual earnings as provided by the port
price of kahawai ($430 / tonne) .
- The commercial kahawai fishery is seasonal primarily because
it is the off-season target of other species and subject to voluntary
seasonal fishing arrangements. It is likely that within a QMS
management regime this pattern of the fishery will not change.
However, quota for kahawai will need to be retained to cover the
bycatch of fishing for other species.
Voluntary agreements
tend to be ignored when there is money to be made. Voluntary agreements
in place now only apply to purse seining in certain areas and
the BOP from 1 Dec to after Easter. Reports of fishing activity
so close to shore that conversations on fishing boats can be overheard
from shore are not uncommon. They tried telling that to the SNA
2 quota owners and fishers. Totally ignored then and now –
what makes us want to believe that industry will behave any differently
with kahawai?
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KAH 1
- There is one TACC option proposed for KAH 1. Based on the average
of the last five years commercial landings from this management
area it is proposed that the TACC be set at 1 480 tonnes.
This proposed TACC exceeds the current purse seine limit of 1 200
tonnes and provides for anticipated bycatch levels. MFish assesses
there will be little if any socio-economic impact associated with
adoption of this option because it is based on current levels
of commercial utilisation.
If MFish can anticipate
bycatch levels then why can’t they anticipate catch levels
for recreational and customary harvest? Taking into consideration
our reduced current catch levels due to over exploitation of the
kahawai fishery by purse seiners and our inability to provide
for our needs. Also the Feldman
report indicates this “utilisation” has almost
destroyed the kahawai fishery in the BOP, see reduction in CPUE
from 2.55 kahawai per hour for visitors and 4.17 (locals of Motu
River mouth) in 1982 to the results of the survey in 1991 showing
CPUE was 0.1 kahawai per hour.
KAH 2
- There is one TACC option proposed for KAH 2. Based on the average
of the last five years commercial landings from this management
area it is proposed that the TACC be set at 710 tonnes. Although
based on average landings, the proposed TACC is less than the
current purse seine limit of 851 tonnes and the most recent years
catch of 832 tonnes. MFish assesses there is likely to be little
($52 030 forgone earnings on the 2001-02 catch) socio-economic
impact associated with adoption of this option because it is based
on current levels of commercial utilisation.
KAH 3
- There is one TACC option proposed for KAH 3. Based on the average
of the five years commercial landings from this management area
it is proposed that the TACC be set at 490 tonnes. This proposed
TACC is less than the current purse seine limit of 1 500
tonnes. MFish notes that declining catches in QMA 3 is associated
with reduced purse seining in this area. MFish assesses
there is likely to be little if any socio -economic impact associated
with adoption of this option based on current levels of commercial
utilisation.
KAH 4
- There is one TACC option proposed for KAH 4. Based on a nominal
value it is proposed that the TACC for this management area be
set at 10 tonnes. MFish considers this TACC appropriately reflects
the current level of use in this fishery.
KAH 8
- There is one TACC option proposed for KIN
8 KAH8?. Based on the average of the five years commercial
landings from this management area it is proposed that the TACC
be set at 635 tonnes. This proposed TACC provides for current
levels of bycatch. MFish assesses there will be little if any
socio-economic impact associated with adoption of this option
because it is based on current levels of commercial utilisation.
The 635 tonnes is
based on the average of the 5 years catch. The average of the
last 9 years catch is 560 tonnes. When did MFish indicate kahawai
would be entering the QMS? Is there a case to say the commercail
fleet were establishing a catch history in anticipation of the
alloaction of quota?
KIN 10
- There is one TACC option proposed for KAH 10. Based on a nominal
value it is proposed that the TACC for this management area be
set at 10 tonnes. MFish considers this TACC appropriately reflects
the current level of use in this fishery.
Allowance
for other sources of mortality
- There is no information on the current level of illegal catch.
Accordingly, it is suggested that no allowance is made to cover
illegal catch at this time.
- The Report from the Fishery Assessment Plenary states that there
is no information on other sources of mortality apart from juvenile
kahawai, which may suffer from habitat degradation in estuarine
areas. Nevertheless, MFish notes that the majority of kahawai
is taken by purse seine (a bulk fishing method). There are a number
of sets where the purse is set but no catches are recorded, possibly
because of gear failure or other related factors. Some incidental
fishing related mortality is likely especially in instances of
gear failure. MFish proposes that a nominal allowance of 5% of
the average purse seine reported landings for the last five years
be set in accordance with the legislative requirement to provide
for an allowance of other sources of fishing relating mortality.
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Other
Management Measures
Method Restriction
- The recreational sector believes that there is conflict with
commercial fishing for kahawai, particularly with purse seiners
and set netters. These concerns are currently mitigated by voluntary
agreements [2] and by an outcome of the set net
review [3].
Low current kahawai
catch levels by non commercial fishers and the inability of the
purse seine fleet to catch their allowable tonnage would suggest
the current closures are far too small to have a significant impact
on improving the ability of non commercial fishers to catch the
kahawai they are targeting.
[2]
There are voluntary purse seine closures in place in Parengarenga
Harbour, Rangaunu Bay, Doubtless Bay, Cavalli Island, The Bay
of Islands, Rimariki Island to Bream Head, the Hauraki Gulf,
the Bay of Plenty, Cape Runaway to East Cape, Waikahawai Point
to Poverty Bay and Hawke Bay to spatially separate non-commercial
and commercial sectors. In addition a voluntary moratorium
was placed on targeting kahawai by purse seine in the Bay of
Plenty between 1 December and the Tuesday after Easter.
[3]
An outcome of the set net review was that commercial set
netting was prohibited by regulation from 26 locations.
- There is currently no provision for considering
spatial allocation within the process of setting sustainability
measures and therefore continued voluntary arrangement between
sectors to retain these measures for kahawai might be necessary
with kahawai in the QMS.
The purse seine fishery
is focused on a few large areas of prime kahawai habitat that
are intensivly fished. This results in localised depletion
on a massive scale. The worst affected areas are within the range
where it is economically viable to operate an economically marginal
fleet of purse seiners from the port they are domiciled in. Any
school of kahawai that strays into one of these areas has the
potential to be instantly annihilated – the complete, entire
school is destroyed. Fishing continues in the area until most
or all of the schools of kahawai are caught. The area becomes
entirely depleted and has an adverse affect on non commercial
fishers catch rates. Most of the areas fished by the purse seine
fleet are close to areas of high population. Over the next 7 or
8 months kahawai from outside the area migrate into the depleted
prime kahawai habitat just in time for the purse seine fleet to
return and take them all away again. These areas act as a sink
hole soaking up the kahawai biomass from the wider fishery management
area and causing depletion over a much wider area than the area
the purse seine fleet operates in.
We are appalled that the Ministry has elected to not include the
kahawai purse seine catch by stat area or over a sufficiently
long time frame. Stat areas are a much smaller scale than entire
quota management areas. Had the Ministry elected to declare and
use this information, which they possess, it would be obvious
why the non commercial sectors are suffering massive reductions
in their catch – contentions that are clearly and demonstrably
supported by Ministry diary and ramp surveys.
STOP – THINK – SIMPLE LOGIC
STUFF – If it is in range of the marginally economic industrial
spotter plane/purse seine fishers, by definition it is in range
of us, the non commercial fishers. What is the good of abundance
off the West Coast of the South Island to a non commercial fisher
north of East Cape. Where, coincidentally, 75% of us happen to
live. Add to this the “Radius of doom” centered on
Nelson and we are looking at almost all of us being directly disenfranchised
from the kahawai fishery by bulk industrial commercial methods.
Remember the second principle that has been endorsed not only
by an overwhelming majority of people and organisations that submitted
to Soundings but also the consensus and signed policy of NZRFC,
NZBGFC, NZACA and option4 “The ability to exclude
commercial bulk fishing methods that deplete important non commercial
areas.” If there is any fishery that demands this
principle be implemented, it is the kahawai fishery and the time
is now!
The public and their representative organisations are unanimous
on this principle. We question how the Minister can allow for
non commercial fishers when the advice he is getting fronm his
Ministry (in this IPP) fails to acknowledge the conflict, suppresses
the readily available and vital information that proves beyond
any doubt that the non commercial sectors have been disenfranchised
by the purse seine fleet close to the significant main population
areas and then has the audacity to claim there is no scarcity
of kahawai.
This
is the fishery of PRIMARY importance to ALL
non commercial fishers in New Zealand. It is truly a national
fishery. This decision will effect each and every one of us.
Summary - This decision is about a couple of
corporates and a handful of marginal purse seiners
fishing a down time versus 1,000,000 New Zealanders
who value kahawai as toanga, great eating, more often than not
their childrens first moment of sheer delight and triumph.
We used to be able to catch reasonable sized
fish. Lew Ritchie, an ex MFish scientist saw the decline as far
back as 1987. Read Kahawai
in Trouble
This advice paper proves yet again that the Ministry’s sole
agenda is to develop commercial fisheries regardless of the consequences
to you, the non commercial fisher.
This covers localised depletion – now lets discuss serial
depletion. The Ministry’s management strategy where
we set a target stock size (say 20% of virgin biomass) As we take
half the fish out of the water it becomes twice as hard to catch
a reasonable sized fish. When we look at non commercial CPUE and
see that it has declined 90% we then realise the interrelationship
between the size of the biomass and the availability of those
fish to the non commercial sectors.
Historically in New Zealand the Ministry has a target biomass
somewhere between 20 and 25% of the virgin biomass and in seeking
to achieve this target poor information, reporting/assessment
delays, inadequate research prioritorising often leads to fish
stocks declining well below 20% before meaningful management is
applied. Kahawai is a classic case of this syndrome. It is unarguable
that the non commercial fishers have been disenfranchised as the
additional commercial fishing effort applied through the development
of the purse seine fishery annihilated the standing biomass.
Mark Feldman coined the term “theft” in a recent article
– we concur. The kahawai fishery was stable, bycatch levels
were stable, the local market was well supplied, we enjoyed good
catch rates. We considered that in the 1970’s the kahawai
fishery was well balanced and developed – it was in harmony.
In that harmonius fishery the Ministry allowed this sick experiment
to see what happens if you take everyones fish away from them
and give it all to a marginal purse seine fleet. Well you know
what happened, your catch rates declined as the fish were
stolen from under your noses. Most of us objected and
until now have been totally ignored. And now the Ministry is recommending
legitimising the blunder and giving our kahawai to the purse seine
fleet in perpetuity as a reward for the grief and havoc they have
wreaked on the kahawai fishery.
To base a recommendation on current utilisation is absurd, unjust
and unfair. It is a callous, shallow attempt to legitimise not
only the theft of your fish but also their failed management
of your fishery. The thieves get their catch history based on
current utlisation granted to them as a property right in perpetuity
and get to repeat the crime annually.
The evidence of stock overfishing can be seen from the catch returns.
Particularly obvious in areas hardest hit by the purse seiners..
As one would expect, industry are contending that their declining
catch is driven by market forces. We contest this. We contend
that it is clear evidence of overfishing. The time series is now
sufficiently long to overrule these claims of market forces being
the cause of the decline in catches. We suggest it points directly
to massive overfishing of the stock.
Had this level of reallocation been permited
in the other direction, the fishing industry would have been seeking
compensation from the Crown.
The Ministry of Fisheries has a target of 20-25% of the virgin
biomass. In seeking to achieve this target, reporting and assessment
delays and poor research funding on this commercially low value
species will undoubtedly lead to the fish stocks falling well
below this mark before meaningful management is applied.
This is a fishery that requires special management.
Why? Kahawai are:
1. Available from the shore
2. The peoples fish
3. Low value export
4. High value non commercial
5. Vital food source
6. Unparalled sport opportunity
7. Available year round in harbours and estuaries.
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Consequential
amendment to regulation
- As a consequence of the introduction of kahawai into the QMS,
MFish proposes to revoke certain fishing permit conditions. These
conditions relate to the closing of the purse seine fishery once
purse seine limits for kahawai have been reached. In addition,
MFish proposes to introduce a number of amendments to the reporting
regulations to ensure the effective and efficient operation of
the QMS. Details of the proposed amendments are set out in a generic
section of this paper.
Schedule 5A
- MFish does not propose to list any kahawai stock on Schedule
5A of the Act and proposes to allow under-fishing rights to be
carried forward.
Deemed values
and Over-fishing threshold
- A separate section of this document sets out generic information
on the setting of interim and annual deemed values.
- Application of the policy framework for deemed values would
mean kahawai falls within the "all others" fishstock category.
The port price for kahawai is $0.43 (early 2003 MFish port price
survey). The standard factor of the port price for species in
this category is 75%. The proposed annual deemed value would therefore
be $0.32, while the interim deemed value would be set at $0.16.
- MFish acknowledges, however, that overcatch of the kahawai TACCs
will affect the interests of the non-commercial fishers in a fishery
they highly value. MFish also notes the following influences upon
the kahawai port price:
- Lower port prices reported by vertically integrated companies
(those that catch, process and market).
- There are niche markets such as those for smoked kahawai that
attract substantially more than average prices.
- Accordingly, MFish recommends an additional option of applying
a factor of 200% to the port price, which would derive an annual
deemed value of $0.86. Although a departure from the deemed values
policy framework, this option would reinforce the importance of
ensuring that catch of kahawai is not landed in excess of ACE
(a statutory consideration) in light of the importance of kahawai
to the non-commercial sector.
- A provisional figure from the November/December 2003 MFish port
price survey indicates that the port price for kahawai in areas
1, 2 and 3 could be as high as $3.50. MFish will review the proposed
port price in light of submissions on the IPP and any further
port price information that becomes available.
- MFish proposes to set differential deemed values for kahawai
stocks. MFish does not propose to set an overfishing threshold
for kahawai. MFish considers that the combination of the
deemed values proposed and the proportionally increasing deemed
values for fishers who exceed their ACE should be an effective
set of balancing provisions.
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kahawai IPP rebuttal index page for more
info »
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