TOKM Submission
New
Species into Quota Management System
26
February 2004
Te
Ohu Kai Moana |
PO
Box 3277 |
Wellington |
TOKM
originally submitted to the consultation process on 26 February
2004. The kahawai section from the original submission is
copied below. The Ministry of Fisheries granted an extension
to the submission period. The new deadline was 16 April.
TOKM took the opportunity to provide more information to
supplement the February submission. This additional
submission is copied below. |
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)
Stock
|
TAC
|
Recreational
|
Customary
|
Other
|
TACC
|
KAH1
|
4600
|
1580
|
790
|
60
|
2170
|
KAH2
|
1780
|
510
|
255
|
35
|
980
|
KAH3-
KAH10 |
As
in IPP |
|
|
|
|
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.
The deemed value for KAH should be set at the standard "All others"
rate of 75% of port price, an annual rate of $0.32/kg. We also see
no need for a differential rate to be set and agree no overfishing
threshold is required.
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:
|
TAC
|
Recreational
|
Customary
|
Other
|
TACC
|
KAH3
|
1970
|
300
|
150
|
20
|
1500
|
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
General Manager, Policy
|