Kahawai Submission TOKM

TOKM Submission

New Species into Quota Management System

26 February 2004

26 February 2004

Initial Position Paper

Introduction of New Species into QMS on 1 October 2004

Mike Arbuckle

Ministry of Fisheries

PO Box 1020

Wellington

OTHER SPECIES

15. Kahawai (KAH)    

TAC, Allowances, TACC  

The latest Stock Assessment Plenary Report of 2003 indicates that ... while there may have been some decline in biomass, the current biomass level is still well above the size that will support maximum sustainable yield (p.284). As such we can see little justification for the IPP proposal (para 16) tor the two principal KAH fishing areas   FMAs 1 and 2 – to calculate a TAC based on average commercial landings for the 1997 – 2002   period, particularly when the alleged high non-commercial interest in KAH is taken into account. That period reflects a reduction in the commercial harvest of KAH. In our view a much more appropriate period would be the 5 years 1992/93 to 1996/97 when commercial catches were relatively stable.

We can accept the later period for the southern and western areas, although we note that commercial activity in FMAs 3, 7 and 8 has considerably diminished since 1998/99 with the departure of the Nelson-based purse seine vessels.

We also note the considerable differences between the commercial catch data included in the Plenary report and those in the IPP. There is no explanation of those differences given in the IPP and we find it difficult to understand how such variations for past years could occur. We have chosen to apply the Plenary numbers in the calculations below.

Te Ohu Kai Moana has previously, and again now, flatly rejects the concept of "utility" in calculating the recreational fishing component of any TAC established for KAH. The concept has been the subject of severe academic criticism in the past and does not meet the requirements of the Fisheries Act. To see it again put forward by MFish in this IPP (paras 20-23) after its earlier rejection is disappointing in the extreme.

In our view the TAC, Allowances and TACC set for KAH should be as follows (mt)

Schedules       

Te Ohu Kai Moana agrees there is no need to include KAH on the Third or Sixth Schedules, or on Schedule 5A. We have noted above our view that KAH should be included on the Fifth Schedule also.

Deemed Values and Overfishing Thresholds   

Te Ohu Kai Moana flatly rejects the IPP (para 62) to "fiddle" with the KAH port price in support of the earlier "utility" arguments relative to recreational fishing. We have already stated our strong rejection of that academically unsound concept and again object to its inclusion in clearly defined statutory processes.

TOP

Supplementary Submission

TE OHU KAI MOANA

TREATY OF WAITANGI FISHERIES COMMISSION

Q108 – 14 - 06  

16 April 2004

Ministry of Fisheries

PO Box 1020

Wellington

Attention: Emma Knight

Introduction of kahawai into the Quota Management System on 1 October 2004   

Te Ohu Kai Moana has already made a submission on the MFish advice paper released in January 2004 containing management proposals for kahawai (see attached). We would like to add some supplementary comments to that submission, given the additional time that MFish has provided for submissions.

KAH3

Te Ohu Kai Moana has reconsidered our original view in respect of the TACC for KAH3.

We note that there appear to be few sustainability concerns about kahawai in   KAH3. Consistent with our comments on KAH1 and 2, there would appear little reason not to take the average catch of the fishing years 1992/93 to 1996/97 (when commercial catches were relatively stable) in establishing the TACC. We note that the new KAH 3 is different from the original KAH 3 (established for the purse seine fishery), which makes evaluation of historical catch information for TAC and TACC purposes complicated. However, using catch information provided in the IPP, an average of the fishing years 1993/94 - 1996/97 would suggest that the TACC should be in the order of 1500 tonnes, rather than 490 tonnes. We therefore consider that the allowances should be set along the following lines:

Utility approach to allocation of the TAC

Te Ohu Kai Moana supports the approach that has been taken to allocating catch between sectors. However we do have some concern, particularly given the considerable publicity generated by the recreational sector since the   original deadline extended, that the "utility" approach to allocation is still   considered by MFish to be an option. Our concerns about the "utility" approach were set out in some detail in our submission, dated 20 June 2003, on the introduction of Kingfish into the QMS. A copy is attached for your   information.  

Thank you for the opportunity to provide further comments on the introduction of kahawai.

Craig Lawson