Submission on the Initial
Position Paper released 14 May 2003 on Setting of Sustainability
and Other Management Controls for Kingfish Stocks to be
introduced into the QMS on 1 October 2003.
TOLAGA BAY EAST CAPE CHARTERS
Postal Agency
Tolaga Bay
bert@charterfishing.co.nz
www.charterfishing.co.nz
31 May 2003
Randall Bess
Ministry of Fisheries
P O Box 1020
Wellington
Stakeholder status and experience in the KIN2 fishery.
I have been involved in the KIN2 fishery since before the
inception of the QMS, initially as a commercial fisher (I
am eligible for PCH) and for the last eight years as a charter
operator.
In my eight years as a charter operator I have made a speciality
of guiding clients both local and from overseas to recreational
catches of kingfish. It should be noted that this recreational
fishery is mainly catch and release with larger fish tagged
for research.
This experience of target fishing for, and tagging large
kingfish has given me an understanding and appreciation
of the movements and dynamics of kingfish in area 2 that
I suggest would be rivalled by few others, either recreational
or commercial fishers or scientists.
I been involved in collecting gonad samples for NIWA research
and tag a considerable proportion of the kingfish tagged
each year (one year 69%).
KIN2
Over the last eight years and in particular in the last
three, I have become increasingly concerned by a sharp decline
in Kingfish numbers locally.
Experience has shown that the kingfish schools we get here
off Tolaga Bay are migrating south and north following the
warming and cooling of the water in the East Cape current.
My observation, backed up by tag returns, is that schools
of mixed size fish appear to move from reef to reef stopping
for a few days then moving on.
The schools are now only a fraction of their former size
and stocks must be very close to collapse.
Kingfish numbers have been declining rapidly over the years
and it has now got to the point where the schools are at
times so small it can be difficult to pick them out on the
sounder.
The method I use to target Kingfish is to use a sounder
to identify schools over off shore reefs, an acoustic survey
the scientists would call it. This means I actually see
the size of the schools as we fish them, what concerns me
is the decline in numbers of fish in the schools.
This past summer I estimate that fish numbers were about
25% of five years ago, one reef, which has always in the
past attracted large numbers of fish, has for the last three
years been abandoned completely by Kingfish.
My contention of a stock decline is supported by:
-
Reports of lower than normal recreational
catches from around the country over the past few years
and a decline in the size and number of fish taken in
fishing club contests.
-
A decrease in estimated recreational
catch from MFish surveys between 1991 and 1996 which appears
to be a continuing trend. The 2001-02 survey has thrown
doubt on the accuracy of previous surveys and more work
needs to be done to establish trends.
-
Fishery assessment plenary reports show
a drop in commercial catch from 427 tons in 1997 to 222
tons in 2001-02. No doubt those who deny a stock decline
will find some excuses for this drop in catch
-
NZ game fish tagging results from NIWA
show a marked decrease in the number of Kingfish tagged
and released over the same period.
Managing to MSY
The advisability of attempting to manage a fish stock that
is not numerically abundant compared to major NZ species
such as snapper, tarakihi and hoki at MSY would appear to
be dangerous. Attempting to take out the maximum sustainable
catch leaves little room for error on a numerically small
population particularly one that is as poorly researched
as kingfish.
We see the results of overestimation of MSY on stocks such
as North Island East Coast Orange Roughy and Gem Fish where
quotas have been cut year after year till now they are almost
non-existent.
These fisheries are purely commercial so attempting to
manage a shared fishery in a similar manner would only compound
the problem.
MSY for kingfish will only be a best guess as MFish admit
in stock assessment plenary reports that they have no estimates
of abundance, biomass, sustainability or current annual
yield and maximum constant yield is still based on the northern
subspecies assuming a life span of 12 years.
This situation is exacerbated when MSY is based on historical
commercial catch that is almost double the present commercial
catch making any MSY estimate somewhere between very doubtful
and useless.
Keeping the management target well above estimated MSY
would be prudent and in line with MFish stated policy of
caution where uncertainty exists.
It is noted in:
41.
The Report from the Fishery Assessment Plenary, May 2002,
notes that it is not known if recent combined commercial
and recreational catch levels are sustainable or at levels
that will allow the stocks to move towards a size that will
support the MSY. The report also notes that recreational
fishers are concerned about the perceived decline in the
quality of the fishery.
Setting of MLS
The IPP suggests a MLS of 75cm
114 states:
Current scientific information suggests that 65 cm is
below the size of maturity for most kingfish. The size at
which 50% of the fish of a given species achieves sexual
maturity is a common target for a MLS in order to provide
the opportunity for fish (on average) to reproduce at least
once. Current information suggests that 50% of females reach
maturity at 97 cm and 50% of males reach maturity at 70
cm.
The MSL needs to reflect the biological standard now; there
is little point of retaining mature males while taking females
before size of maturity.
The MLS should be based on the biological standard for females
and set at either 97cm or rounded to 1 metre.
It is my experience that the vast majority of recreational
fishers respect kingfish as a top game fish and will accept
a 1 metre MLS and any decrease in the number of fish they
can take home to see a quicker stock rebuild.
Kingfish are generally not considered to be a premier food
fish by most recreational anglers I take fishing, and as
there are usually better eating fish available (tarakihi,
snapper, hapuku), most anglers will release even fish over
1m.
However there are some anglers who are only fishing for
food and will keep any oversize fish they can catch, those
are the anglers that need to be constrained by a size limit
132 states:
The proposed increase in the MLS for recreational fishers
is expected to increase the level of incidental mortality
because the new MLS will result in more fish being returned
to the sea.
This assumes that at present all fish over 65cm are kept,
this is not the case.
Overseas anglers who come here to fish for sport release
all kingfish they catch and local anglers who fish from
charter boats targeting kingfish will release most of the
fish they catch.
To most recreational anglers a kingfish is a rare and exciting
catch and while a big fish will sometimes be kept the number
caught per angler is small.
The majority of recreational anglers will respect a size
limit.
115. Talks of optimise
yield by delaying recruitment
This is another good reason to increase MLS to 1m however
the primary objective of setting a MLS must be to achieve
the biological standard for females.
32.
Following a review of MLS for trawl caught kingfish in 2000
the Minister of Fisheries considered that concern about
sustainability, the need for equity between stakeholders
for size limits, the biological reproductive data and compliance
considerations, outweighed the concerns about wastage and
economic loss to the industry. Accordingly, the regulatory
exception provided in 1993 that enabled trawl operators
to retain undersized kingfish was revoked in December 2000.
The anomaly this move corrected was because of misinformation
supplied by the trawl sector at the time of implication
of MSL.
125 Discusses practices
in the trawl fishery
Obviously education and a change to practises are needed
in the trawl sector to emphasise the value of the resource
in the sea and not just in the hold.
118 discusses the impact
on subsistence fishers
There are easier fish for subsistence fishers to catch than
kingfish, there is nowhere in the country where anyone should
have to rely on kingfish to feed themselves.
The MSL needs to reflect the biological standard now. Most
recreational and subsistence fishers will be happy to put
up with a short-term reduction in fish they can kill to
see a quicker stock rebuild.
135.
Tells us it is unlawful
in the commercial fishery to discard fish, dead or alive,
over MLS whether ACE is held or not.
This being the case the only constraint on landing commercial
catch whether under ACE or deemed value is MLS.
This provision of the act means that all fish over MLS
must be retained, it means that returning a live fish over
MLS to the water is unlawful and if ACE is not held or can't
be obtained then deemed value must be paid for any fish
retained.
This leaves a commercial fisherman without sufficient ACE
who would prefer to release a live fish over MLS in a no-win
situation.
As kingfish is and will always be a largely by-catch species
for commercial fishers with only 3 tons spread over 7 vessels
caught as a target species in 2001-02. With the remaining
by-catch of 219 tons spread over a large number of fishers
and a large area the deemed value payments required from
individual fishers when ACE is exhausted should be small.
This means that the only true restraint on commercial catch
will be MLS.
Another compelling reason to set MLS at 1 metre.
Starting point for TAC
Using the average commercial catch over the last 10 years
as a starting point for setting TAC is in fact putting management
back five years.
With a declining commercial catch in a numerically small
stock the only starting point that should be considered
is the present catch.
If you were dealing with a stable commercial only stock
an average would be fine, however this is not the case.
What we have is a declining shared fishery where the recreational
catch is of very high value to anglers, not only from within
the country, but an increasing number from overseas who
are paying a high price to catch and release kingfish.
In order to increase the value of the stock to the country
it must be rebuilt to where large fish are readily available.
Kingfish is not a developing fishery in a commercial sense
rather it is fully to over-fished right now and needs to
be rebuilt rather than fished down.
This being the case the starting
point must be the present catch or a further decline will
occur.
Comments on Preliminary Recommendation
145 a
Favour option 11.
145 b.
It is noted that both options 1 and 11 will provide commercial
fishers with a TACC that is higher than the present 2001-02
catch and will reduce recreational allowance below estimates
of present catch. In other words a relocation of catch at
present catch level from recreational to commercial.
This is curious considering:
2. MFish notes
that this fishery is highly valued by recreational fishers.
Most current commercial catch is taken as a bycatch. An
assessment of utility (social, cultural and economic well
being) suggests that greater benefit could be obtained by
improving recreational opportunity in the fishery.
Changes in KIN 2 would be:
On Average landings,
commercial + 32 tons on 2001-02 catch
Recreational - 53 tons based on 1999-2000 estimates
48. Notes
A TAC based on average levels of recent landings therefore
presents a risk to sustainability and is unlikely to result
in any fishery rebuild toward the proposed target level.
On proportional reductions,
commercial + 11 tons on 2001-02 catch
Recreational - 19 tons based on 1999-2000 estimates
50.
It is incorrect to say there will be any short-term loss
in value to commercial fishers as proposed TACC under this
option will be above present catch. However there will be
a loss to recreational.
Utility option gives
a decrease to both however it is still a smaller decrease
to commercial than recreational based on present catch.
Again a relocation of catch at present catch level from
recreational to commercial.
145 d.
1.
Doing nothing is not an option the 65cm size was set before
knowledge of maturity was available, now we have that knowledge
it should be acted on.
11.
The MSL should be immediately lifted to either 97 cm or
preferably rounded to 1m
111.
No commercial MLS
Not an option
1. Quota would be filled in a short time under any of the
options in b.
2. Unacceptable to recreational fishers
3. If this was a sensible option why has it not been used
before for other species?
4. It would not be needed if a 1m MLS were in place
145 e.
This should be done anyway and not just for kingfish but
for all species. We are told that the commercial industry
prides itself on quality by maintaining a cold chain however
this quality should also extend to fish under MLS that can
be returned alive.
145 f.
As previously stated MSL should be 1m
Conclusions
The base point for TAC
Should be the present catch with TACC set at the 2001-02
level of 222 tons and recreation catch at the 1999-2000
estimates with customary and other mortality factored in
to be added up to give a TAC.
This approach is simple there is no need for percentages
or computer models. It is working with reality, as things
are now.
MLS should be set at 1
metre.
To reflect the female biological standard
Setting it lower then raising it again later is only dicking
around and will cause "Pain" more than once to
fishers and do the sustainability of the fishery no good.
MLS
Should apply to all, recreational, commercial and customary.
This will immediately drop the number of fish extracted
from the stock ensuring a rapid stock rebuild.
There will be some associated mortality, however if good
practices are promoted and maintained this should be able
to be kept to a minimum.
Kingfish could be placed
on the Sixth Schedule of the 1996 Act
101 to 104
Using this provision would mean any live commercially caught
kingfish could be returned to the water if a fisher was
unable to cover the by-catch with ACE.
This would seem a sensible measure for a hardy species such
as kingfish.
As noted there is a possibility of dead fish above MLS
also being discarded, however this can happen without a
species being on the sixth schedule. In fact it is more
likely to happen if punitive deemed value payments are the
result of retaining fish.
Other measures
33.
There is a regulatory provision that specifies a minimum
net mesh size of 100 mm when taking kingfish.
-
A requirement will be to raise the mesh
size of set nets to reflect the MLS. The present 100 mm
mesh size will gill and kill a very small kingfish.
An alternative would be to ban taking kingfish by set
net.
-
Permits for targeting kingfish should
be phased out by non-renewal when a fisher retires or
leaves the fishery.
Notes
-
The increasing production of kingfish
by aquaculture (at present 170,000 tons in Japan, over
2000 tons in Australia and with interest in this country)
is likely to devalue any catch of small wild fish.
This has already happened overseas in the salmon and prawn
fisheries where the production of farmed fish can be tailored
to the clients needs.
However there should still be a niche market for large
fish that take too long and are too expensive to produce
by farming.
Having a 1m MLS should leave the NZ industry in a position
to develop and exploit such a niche.
-
Quota may be left at the present 2001-02
level then when over the years as the number of large
fish increases the commercial catch should "Grow
into" the quota as the stock rebuilds.
When the commercial catch reaches the TACC then it may
be possible to consider raising the TACC to reflect the
state of the stock.
-
Trying to treat all new species being
brought into the QMS the same by using averages of historical
catch and computer modelling is never going to work. Each
stock has different dynamics, relationships and requirements
and should be treated accordingly.
-
A requirement of present legislation
and international obligations is to maximise the value
New Zealanders obtain through the sustainable use of fisheries
resources and protection of the aquatic environment.
The falling commercial catch would indicate that there
is little development possible for a commercial kingfish
fishery.
Conversely there is great potential to develop the international
tourist market with international anglers willing to pay
to catch bigger kingfish than can be obtained anywhere else
in the world.
It is noted that studies of the worth of kingfish as a
recreational catch only covered domestic anglers and have
not included the overseas funds generated by anglers visiting
from other countries.
I understand Tourism NZ have the results of studies done
on the value of visiting anglers to the economy. Have MFish
obtained the results of these studies?
Bert Lee
Tolaga Bay
