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

  1. In evaluating the management options the following statutory considerations have been taken into account.
  1. 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.
  2. While there is a national stock assessment available for kahawai, MFish considers it to be uncertain and outdated.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.
  3. 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?
  4. Recruitment of kahawai is not known to be particularly variable at the current levels of stock biomass.
  5. 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.
  6. There are no known effects of purse seine fishing on the aquatic environment.
  7. 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.
  8. 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.
  9. 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.
  10. 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)).
  11. 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.
  12. 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.
  13. 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?

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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.

 

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Preliminary Recommendations

  1. MFish recommends that the Minister:
  1. Agrees to set a TAC of 3 910 tonnes for KAH 1 and within that TAC set:
  1. A customary allowance of 790 tonnes;
  2. A recreational allowance of 1 580 tonnes;
  3. An allowance for other fishing-related mortality of 60 tonnes; and
  4. A TACC of 1 480 tonnes.
  1. Agrees to set a TAC of 1 510 tonnes for KAH 2 and within that TAC set:
  1. A customary allowance of 255 tonnes;
  2. A recreational allowance of 510 tonnes;
  3. An allowance for other fishing-related mortality of 35 tonnes; and
  4. A TACC of 710 tonnes.
  1. Agrees to set a TAC of 960 tonnes for KAH 3 and within that TAC set:
  1. A customary allowance of 150 tonnes;
  2. A recreational allowance of 300 tonnes;
  3. An allowance for other fishing-related mortality of 20 tonnes; and
  4. A TACC of 490 tonnes.
  1. Agrees to set a TAC of 18 tonnes for KAH 4 and within that TAC set:
  1. A customary allowance of 3 tonnes;
  2. A recreational allowance of 5 tonnes;
  3. An allowance for other fishing-related mortality of 0 tonne; and
  4. A TACC of 10 tonnes.
  1. Agrees to set a TAC of 1 210 tonnes for KAH 8 and within that TAC set:
  1. A customary allowance of 190 tonnes;
  2. A recreational allowance of 380 tonnes;
  3. An allowance for other fishing-related mortality of 5 tonnes; and
  4. A TACC of 635 tonnes.
  1. Agrees to set a TAC of 18 tonnes for KAH 10 and within that TAC set:
  1. A customary allowance of 3 tonnes;
  2. A recreational allowance of 5 tonnes;
  3. An allowance for other fishing-related mortality of 0 tonne; and
  4. A TACC of 10 tonnes.
  1. Agrees to set an annual deemed value for kahawai of:

EITHER

  1. $0 .32 /kg;

OR

  1. $0.86 / kg.
  1. Agrees that differential deemed values apply
  1. Agrees to amend the Fisheries (Reporting) Regulations 2001 to outline the codes to be used by fishers when completing their statutory catch returns
  2. 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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