| option4
Rebuttal of Kahawai Initial
Position
Paper 2004
Part
Five
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 Five
Statutory considerations
- Is this enough recognition after 18 years
of concern? More »
- We need a viable alternative management
option. More »
Preliminary
recommendations
Statutory
Considerations
- In evaluating the management options the following statutory
considerations have been taken into account.
- The management options seek to ensure sustainability of the
stock by setting a TAC and other appropriate measures. Utilisation
is provided by way of setting allowances for commercial, recreational
and customary fishers.
- While there is a national stock assessment available for kahawai,
MFish considers it to be uncertain and outdated. Nonetheless this
stock assessment suggests that the TACs proposed, based on current
levels of utilisation, are likely to be at or above Bmsy.
- There are social and economic consequences from setting the
proposed TACs. Current recreational concerns with regard to the
reduction in availability of kahawai to them are not addressed
by setting TACs based on current levels of utilisation. These
proposals assume that the decline in availability is associated
with the fishing down of the stock to levels at or above Bmsy.
While there might be a number of possible economic effects those
that have been quantifiable are minor. Any opportunity costs needs
to be weighed against the uncertainty in current stock status,
the value of kahawai as a shared fishery and the importance of
this species in an ecological context as both predator and prey.
(Refer Annex
5 - Kingfish FAP 2003). “Given uncertainty in information
on stock status, I am obliged to implement measures that will
prevent the biomass declining. However, my preference is to set
a TAC that provides a reasonable opportunity for the biomass to
increase.” What has changed in one year?
- Recruitment of kahawai is not known to be particularly variable
at the current levels of stock biomass.
- Kahawai fishing is not known to pose
a risk to the long-term viability of any associated or dependent
species. However, there are recreational concerns about the effect
any reduction in kahawai schools might be having on interdependent
stocks of predators such as marlin and tuna. Unfortunately , the
factors influencing the distribution of highly migratory stocks
of these species are complex and not well understood. They do
suggest the need for caution in setting sustainability measures
for the stock.
- There are no known effects of purse seine fishing on the aquatic
environment.
- The purse seine method is not known to pose a risk to the maintenance
of biodiversity of the aquatic environment. Habitats of particular
significance for fisheries management have been identified for
KAH 3 and these have been taken into account when preparing this
advice. No other habitats of particular significance for kahawai
management have been identified.
- MFish considers issues arising under international obligations
and the provisions of the Treaty of Waitangi (Fisheries Claims)
Settlement Act 1992 (s5) are adequately addressed in the management
options for kahawai.
- MFish is not aware of any considerations in any regional policy
statement, regional plan or proposed regional plan under the Resource
Management Act 1991, or any management strategy or plan under
the Conservation Act 1987, that are relevant to setting TACs for
kahawai at this time (as required by ss 11(2)(a) and (b)).
MFish is also aware of the provisions of the Hauraki Gulf Marine
Park Act 2000. The Hauraki Gulf is defined in that Act to include
all coastal waters and offshore islands from near Te Arai Point
offshore to the Moko Hinau Islands, and south to Homunga Point
(north of Waihi Beach). This Act's objectives are to protect and
maintain the natural resources of the Hauraki Gulf as a matter
of national importance. Kahawai are known to occur within the
boundaries of the Hauraki Gulf and MFish considers that the setting
of sustainability measures for kahawai will better meet the purpose
of the Act.
- Before setting any sustainability measure the Minister must
also take into account any conservation services or fisheries
services, any relevant fisheries plan approved under the Act,
and any decisions not to require conservation services or fisheries
services. Conservation and fisheries services apply to fisheries
generally in order to assess and monitor the impacts of fishing
on non-target fish and other species. No fisheries plans exist
or are proposed for kahawai (s11 (2A)).
- Sections 21(1)(a and b) and (21)(4)(i and ii) and (21)(5) require
the Minister to allow for non-commercial fishing interests (recreational
and Maori), and other mortality to the stock caused by fishing.
The nature of the fishery and the interests
of the respective fishing sectors have been influential in recommendations
for the setting of the TACC. 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 particularly in KAH 8. Allowances have been made
for recreational and customary interests and for other sources
of mortality to the stock caused by fishing. No mataitai in the
QMA applies in the area of the fishery. No area has been closed
or fishing method restricted for customary fishing purposes in
the QMA that is likely to affect fishing for this pelagic fishery.
The voluntary restrictions that have been placed on commercial
fishing to protect recreational interests have been considered
when making recommendations.
- The information used to develop proposals for kahawai refers
to an assessment of the stock conducted in 1996. There is uncertainty
about this assessment (and it is now some seven years out of date)
however, uncertainty and the absence of information is not a reason
for failing to provide for utilisation at levels considered to
be sustainable, however MFish notes that caution is required in
this instance.
- The level of non-commercial catch within New Zealand fisheries
waters is uncertain with regard to setting allowances for recreational,
customary Maori use and other sources of fishing-related mortality.
MFish notes, however, that uncertainty in information is not a
reason for postponing or failing to take any measure to achieve
the purpose of the 1996 Act (s10 Information Principles).
Acknowledgement of
concerns
Is this enough recognition after 18 years of concern?
TOP
Kahawai is a treasured
part of New Zealand’s marine heritage. The presence of large
kahawai schools gives the impression of a healthy marine ecosystem.
On the other hand the total absence of kahawai schools for much
of the year in some areas leaves the ocean looking empty and lifeless
– something is wrong with the way this species has been managed.
MFish have recommended setting perpetual commercial property rights
at current level of catch and hope that one day someone will take
the time to manage this species better. The Ministry have presented
only one management option. This is not acceptable to the public
and we trust the Minister will agree with us.
What is needed is a viable alternative management option
that will ensure the rebuild of this stock. A lot of the commercial
catch of kahawai is taken as by-catch while fishing for other species.
The obvious place to effect better management is to reduce the purse
seine catch which is actually targeting entire kahawai schools.
We consider the practice of targeting kahawai by purse seine is
excessive and wasteful. It is a very efficient bulk fishing method
that sees fish landed and sold for a price well below what would
be economic for other methods. It has been the increase in catch
by this method that has coincided with the disappearance of kahawai
around much of the coast. Surely it is this industrial fishery that
has caused the problem, by mining the once plentiful kahawai stock
we had, the same parties should carry the cuts to rebuild this fishery.
We propose that MFish remove all the kahawai target purse seine
catch history from its calculation for setting the TACC.
The methods used in calculating the recreational harvest estimates
in 1996 have been shown to be seriously flawed. Those estimates
cannot be used in their current form by the Minister when allowing
for recreational and customary take. The 2000 and 2001 surveys provide
the best information available at this time although there is concern
that some estimates may be biased high.
Kahawai is a very important customary and subsistence food source
for Maori and non-Maori. Traditional fisheries such as those at
the mouth of the Motu River are a mere shadow of what the once were.
Many people struggle to provide fresh fish to supplement their diets
because the fishery has been so decimated. The Minister should allow
for Maori customary harvest at a level of half the revised recreational
estimates.
Allowances for incidental mortality would remain the same, as the
overall national TAC does not change much with our option.
We will be contesting the Ministry’s recommendations below.
If you have any comments to make about the recommendations please
advise us so we can consider
your view in our submission.
TOP
Preliminary
Recommendations
- MFish recommends that the Minister:
- Agrees
to set a TAC of 3 910 tonnes for KAH 1 and within that TAC
set:
- A customary allowance of 790 tonnes;
- A recreational allowance of 1 580 tonnes;
- An allowance for other fishing-related mortality of 60 tonnes;
and
- A TACC of 1 480 tonnes.
- Agrees
to set a TAC of 1 510 tonnes for KAH 2 and within that TAC
set:
- A customary allowance of 255 tonnes;
- A recreational allowance of 510 tonnes;
- An allowance for other fishing-related mortality of 35 tonnes;
and
- A TACC of 710 tonnes.
- Agrees
to set a TAC of 960 tonnes for KAH 3 and within that TAC set:
- A customary allowance of 150 tonnes;
- A recreational allowance of 300 tonnes;
- An allowance for other fishing-related mortality of 20 tonnes;
and
- A TACC of 490 tonnes.
- Agrees
to set a TAC of 18 tonnes for KAH 4 and within that TAC set:
- A customary allowance of 3 tonnes;
- A recreational allowance of 5 tonnes;
- An allowance for other fishing-related mortality of 0 tonne;
and
- A TACC of 10 tonnes.
- Agrees
to set a TAC of 1 210 tonnes for KAH 8 and within that TAC
set:
- A customary allowance of 190 tonnes;
- A recreational allowance of 380 tonnes;
- An allowance for other fishing-related mortality of 5 tonnes;
and
- A TACC of 635 tonnes.
- Agrees
to set a TAC of 18 tonnes for KAH 10 and within that TAC set:
- A customary allowance of 3 tonnes;
- A recreational allowance of 5 tonnes;
- An allowance for other fishing-related mortality of 0 tonne;
and
- A TACC of 10 tonnes.
- Agrees
to set an annual deemed value for kahawai of:
EITHER
- $0 .32 /kg;
OR
- $0.86 / kg.
- Agrees
that differential deemed values apply
- Agrees to
amend the Fisheries (Reporting) Regulations 2001 to outline the
codes to be used by fishers when completing their statutory catch
returns
- Notes that
once kahawai becomes subject to the QMS fishing permit conditions
applying purse seining catch limits and vessel restrictions on
the taking of kahawai will no longer be applicable. Accordingly,
the chief executive will need to revoke these fishing permit conditions.
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