| Annex
5
option4 Rebuttal of Kahawai IPP 2004
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 are concerned about the inconsistency in the Statutory Considerations
section of the IPP regarding the availability of kahawai to fishers.
Information supplied in the kahawai IPP does not equate to information
from the Minister's comments in the kingfish Final Advice Paper
(FAP) 2003. The following is an extract from the kingfish FAP Setting
the TAC section. Of particular interest is the Minister's comments
in paragraph 10.
Kingfish FAP 2003
Paragraphs 3 -10
Setting the TAC
- There is limited information on the current status of kingfish
stocks and no quantitative assessment to determine whether stocks
are above or below the biomass that will support the maximum sustainable
yield (BMSY). Given the limited information available I have decided
that it is not necessary to set a target level (such as above
BMSY) for kingfish stocks at this time.
- Uncertainty in the status of current biomass is a factor that
I have taken into account in my consideration of TAC options identified
in MFish advice and in stakeholder submissions. I am required
to make a decision on TACs and allowances despite the uncertainty
in current stock status. Having regard to the importance of the
stock to all sectors, and therefore the socio-economic benefits
associated with harvesting, I wish to take management steps that
will at least maintain, if not improve, current biomass.
- I have noted that the Report from the Fishery Assessment Plenary
concludes that it is not known whether the current combined commercial
and recreational catch is sustainable for any kingfish stock.
Anecdotal information from recreational fishers suggests that
there has been a decline in abundance. Commercial landings have
declined in KIN 1 and KIN 2 but the reason for this decline is
not clear. While accepting that the information on landings is
uncertain, I consider that the available data suggests that there
is a risk attached to current levels of catch for some kingfish
stocks, in particular KIN 1, KIN 2 and KIN 8.
- In the absence of reliable yield information, the starting point
for calculating the TAC for each stock is the best estimate of
average landings for each sector group. I have noted that a number
of submissions disputed the estimates of average landings provided
in the MFish Initial Position Paper (IPP) and suggested alternative
data and/or time periods of data that should be used to calculate
the TAC options.
- In final advice to me, MFish has confirmed its view that the
average of the two most recent harvest estimates, while uncertain,
is the best available information on recreational kingfish landings
at this time. MFish did not accept the industry proposition to
extend the period used to derive commercial average landings on
sustainability grounds. After consideration of submissions, MFish
also proposed adjustments to the estimates of commercial average
landings provided in its initial proposals to take into account:
- the fact that the Minimum Legal Size, did not apply to all commercial
fishing methods until December 2000; and
- the declining trend in commercial landings in KIN 1 since 1993
by reducing the period of time used to derive an average of these
landings.
- I have considered the MFish advice and the submissions related
to this issue. I am not so concerned about the basis for the TAC
calculation, which I recognise in the absence of yield information
is to a degree subjective, but rather whether the overall TAC
for each stock is sustainable. After analysis of submissions and
consideration of available information MFish have assessed that
the TACs outlined in the IPP may be unsustainable given uncertainty
over current stock status. Accordingly I have determined that
the TAC options presented in the MFish final advice present less
risk to the stock than those outlined in the IPP.
- The MFish Final Advice Paper (FAP) outlined two TAC options
for KIN 1, KIN 2, and KIN 8, one based on average landings, the
other based on a 20% reduction to average landings. In reaching
a decision on which TAC option should apply in each kingfish stock
I have carefully considered the socio-economic impacts and advice
outlined in the MFish FAP and the issues raised in submissions
including:
- the uncertainty in information on the status of kingfish stocks;
- information that may indicate a decline in biomass over time;
- my desire to at least maintain and hopefully improve current
biomass; and
- socio-economic information including the potential impacts and
benefits to all sectors.
- I am not satisfied that a TAC based on average landings in
KIN 1, KIN 2 and KIN 8 appropriately mitigates the risk that abundance
may have declined over time and further decline is possible at
levels based on average landings. 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. I have therefore decided to set a
TAC for kingfish in KIN 1, KIN 2 and KIN 8 that is 20% below revised
estimates of average landings. TACs in other areas are to be based
on the best estimate of average landings. TACs for all stocks
are outlined in Table 1.
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