Kahawai
Submission
by
Rick Pollock
April
2004
Submission
to the Introduction of Kahawai into the Quota Management System
(QMS)
Thank you for allowing extra
time to put forward this submission. I know I, as well as many others,
would not have been in a position to do so at the originally allowed
date.
While the health of kahawai
stocks in our normal area of activity (Bay of Plenty) is of vital
interest to both our business and on a personal basis, the overall
state of this fishery to the nation as a whole is of far more importance.
Although my experience at sea spans 250 days at sea per year, I
would not qualify as a fisheries scientist or marine biologist.
My viewpoints will be that of a layperson despite this experience
level.
First and foremost I can
not stress the importance of kahawai stocks and their subsequent
health too much. They are truly the "people's fish" with their relative
abundance, range and availability throughout the inshore region.
Many recreational and sustenance anglers rely heavily upon kahawai
for sport and food, particularly when other possibly more desirable
species cannot be found.
Another issue is their obvious
association with various species of sea birds. Due to their schooling
nature they often force small baitfish to the surface in masse,
thus making some available to predatory birds. Without this activity
many birds would find feeding much more difficult or, in some cases,
impossible.
Additionally, kahawai are
well documented as an integral food source for larger fish. Included,
but not specifically limited, to this list are the following:
Yellowfin Tuna |
Bronze Whaler Sharks |
Striped Marlin |
Tope |
Black Marlin |
Yellowtail Kingfish |
Mako Sharks |
Hammerhead sharks |
Cetaceans also feed on kahawai
and can commonly be seen doing so. Among these are:
Bottlenose Dolphin |
Common Dolphin |
Killer Whales |
So, a healthy, sustainable
kahawai stock is obviously important to an overview of the situation,
not just for man's benefit.
While thoroughly reading
the Initial Position Paper (IPP) I have come across several anomalies
which I would like to point out. These come in the way of contradictions
and poor/outdated research.
Primarily are the respective
statements "stock assessment is uncertain and outdated" and also
continually referring to date relating back to 1996. These two idioms
are a continuing saga right throughout the entire report. For something
as important as affixing tonnage for kahawai admission to QMS and
judging this by incomplete or outdated statistics/research is irresponsible.
Considering the ramifications this decision (and it could last virtually
forever) has on many people, not to mention animals, the best and
most current information must be utilised to reach a fair and responsible
outcome.
Contradictions also abound
with statements such as 2b "kahawai biomass has declined to about
50% of the virgin biomass" followed by "current biomass is unknown".
How can one know one without the other?! Also later in that
some point is "commercial landings are currently just within the
range of MCY". How can this be known without certainty of the biomass?!
Further along in 2e is the
statement "Recreational catch is about 83% of commercial landings".
This made by not using the latest recreational diary/ramp
survey information or commercial catch records since 1996, why?
Then in item #12 the incredulous
truth is reaffirmed. If one read only this statement it can only
lead to one conclusion. How can the minister, or anyone else, make
such a difficult and important decision based on such poor and antiquated
information that even they admit to????
Item #20 is also quite amazing.
How can the proposers/advisers assume anything about recreational
anglers or their preceptors when they do/will not utilise current
statistics?
Again in #'s 21 ("stock assessment
is uncertain and outdated"), 22 ("importance of kahawai as a food
source suggests the need for caution") and 23 ("stock assessment
information is uncertain and dated") – all these reiterate
the severe need for more current information to be made available
to the minister in this matter. Failing this eventuality then the
minister has no course but to act very cautiously.
SOURCES OF MORTALITY
I find item #53 to be an
interesting one. Why, when virtually every fishery in New Zealand
suffers to some extent at the hands of illegal fishing would kahawai
not suffer the same fate? I can't tell you how many times I've seen
smoked kahawai fillets for sale out of the back of a vehicle, at
school rugby games and raffled off in a pub. All these activities
are highly illegal but go undetected and unpunished. While not on
the grandiose magnitude of paua for example, to suggest there is
no illegal activity within the kahawai fishery is no illegal activity
within the kahawai fishery is nothing more than burying one's head
in the sand. To not allow for mortality here is a big mistake.
METHOD RESTRICTION
In item #55 we are told conflict
is being "mitigated by voluntary agreements". Unfortunately the
vast majority of these agreements are breached over and again across
the board. If there is no law involved then commercial fishers repeatedly
transgresses these agreements since they have no teeth. These VA's
are great in theory but poor in practicality.
STATUTORY CONSIDERATIONS
Item b) again states the
incredulous truth. "MFish considers the stock assessment to be uncertain
and outdated. Nonetheless the assessment suggests that the TAC's
proposed based on current levels of utilisation, are likely to be
at or above BMSY". How, in all honesty, can the ministry make such
a statement based on poor/bad information! Again in c) we have the
same two idioms reappear – "1996" and "uncertainty about this
assessment"!
PRELIMINARY RECOMMENDATIONS
In item g) I would urge the
minister to accept and implement the higher of the two (2) deemed
values prescribed for kahawai. Even at this level there may be some
"gravy" left over for the fisher, inducing them into actively and
profitably over fishing the source.
SUMMARY
Here I will be brief. With
so much uncertainty and old information clouding this entire issue
I believe the minister must err on the side of caution. With such
imprecise advice from those who repeatedly state as much, he must
be very careful in his decision making.
Thank you for the ability
to present this submission.
Yours faithfully
Richard Pollock
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