SUBMISSION FROM MARK FELDMAN ON THE INTRODUCTION OF KINGFISH INTO THE QMS

June 25, 2003

Submission on the Introduction of Kingfish into the QMS

First of all, I would like to NOT apologize for my submission being "late." An allowance of three weeks for consultation is absolutely inadequate. Some of us that work for a living can't always stop everything else in our lives to make up for the Ministry being too slow in releasing its Initial Position Paper.

After reviewing the Initial Position Paper in detail I have the following comments.

1. All the figures for the recreational catch are crap. Although this was acknowledged the Paper goes on to use those figures. That is irrational.
   
   
2. Although the commercial catch figures are probably reasonably accurate there have been two major aspects that are not ADEQUATELY considered:
   
   
   1. lmost all the commercial catch through the 1990s was not real by-catch. Commercial fishers are good at fishing and they know how to target what they want to target. The rapid fall off in set-net kingfish catch after the introduction of the 65cm size limit and the recent growth of the mid-water trawl kingfish catch are good illustrations of that. By accepting this illegal targeting as legitimate catch the Ministry is sanctioning that illegal fishing and rewarding the men that did.
      
      
   2. The Ministry also chose to average the commercial kingfish catch over years that include what would be undersized fish today. The only relevant commercial catch figures are for the 2002 season and even those do not consider on-going target fishing like mid-water set-net and trawl.
      
      
3. With all of the past catch figures either incorrect or irrelevant there is a far better way to divide up the fishery and that is on the basis of what's best for our society. Clearly kingfish are worth a LOT more to the recreational sector so:
   
   An effort should be made to determine the true commercial by-catch (by my calculations that would have been running at around 100 tonnes per year in the 1990's and is even less now) and that should be the future TACC.