Randall Bess
Ministry of Fisheries
PO Box 14
Nelson
11 July
2002
NZ
Big Game Fishing Council
Submission on the introduction of new species
to the Quota Management System 1 October 2003
1. Please
accept the following submission on behalf of the NZ Big Game
Fishing Council. We are a national organisation representing
61 fishing clubs with a total of 31,000 financial members.
For many years the New Zealand recreational fishery for kingfish
has been acknowledged as world class. However we have been
concerned for some time about the declining quality of the
fishery.
Overview
2. Kingfish are an icon non-commercial species. They are an
important traditional food fish for Maori (Muriwhenua Fishing
Report 1988) and one of the most prized recreational catches.
Annual recreational harvest estimates from the 1999/2000 national
marine recreational fishing survey have not been released
but will be around 700 tonnes (Recreational Working Group
discussions) while reported commercial landings in 1999/2000
were 270 tonnes. Non-commercial fishers are the major stakeholders
in this fishery and as such our views must not be ignored.
3. The
management of the kingfish fishery is very important to us.
NZ Big Game Fishing Council was instrumental in proposing
the recreational Minimum Legal Size (MLS) and bag limit which
were adopted in 1993. We actively promoted the re-instatement
of a minimum mesh size for kingfish and the removal of the
size limit exemption for trawlers. We have supported and promoted
tag and release of kingfish and buy all NZ gamefish tags ourselves.
Most of our clubs now have a 100 cm minimum size for kingfish
in their contests.
4. In
January the NZ Big Game Fishing Council put forward a proposal
for inclusion in the Review of Management Controls for the
2002-03 Fishing Year. The objective was to improve the quality
of the non-commercial kingfish fishery by prohibiting the
landing of wild kingfish by commercial fishers. We felt that
this process may be our last chance to discuss non-QMS management
options. Five months later we have heard nothing. Apparently
the proposal was rejected, with out so much as a phone call
or email from the policy makers concerned.
5. The
QMS will allocate commercial fishers kingfish quota in perpetuity.
The QMS will also allow targeting by commercial fishers who
hold enough quota and deeming of catch not covered by quota.
Under the QMS recreational fishers would "be provided
with an explicit quantitative allowance" (in effect a
cap on recreational harvest). Introduction to the QMS will
not resolve issues of local depletion or the fact that the
commercial fishery is based on the harvest of immature kingfish,
or help assess stock size and yeild. We would have dearly
loved to have discussed the implications of these changes
before they are forced upon us.
6. We
represent the major stakeholders in this fishery and have
driven most of the management initiatives for kingfish to
date. We believe there are sound social, scientific and economic
reasons to manage this fishery outside the QMS. As an absolute
minimum we need our concerns acknowledged and discussed. How
else can we influence the process through our legal right
to be consulted?
7. The
NZBGFC recognises there are commercial fishers and Maori commercial
groups with legitimate expectations of a share in the kingfish
TACC if it was introduced into the QMS. In our view the Crown
should be prepared to compensate these groups for the loss
of access to this fishery. Restraining commercial catch to
by-catch levels is a difficult and expensive regime to have
in place. Allowing commercial targeting under the QMS will
bring a whole raft of local management issues and disputes.
The most cost effect management regime is to accept the one
off cost of non-commercial status.
Kingfish
8. We submit that Yellowtail Kingfish should be managed as
a non-commercial species. This means that the emphasis in
management would shift from quantity of fish killed to quality
of fishing. There is no doubt that the quality of kingfish
fishing has declined, right around the coast, in the last
15 years as commercial fishers took the opportunity to expand
into non-QMS species.
9. The
quality of fishing will not improve at current catch levels,
therefore a reduction in harvest is required. Recreational
fishers are contributing by instigating a bag limit of three
and size limit of 65 cm (quite radical limits in 1993), encouraging
tag and release and recently supported voluntary size limits
of 100cm and voluntary bag limits of one fish per day. To
improve the quality of fishing commercial catch will also
have to come down.
10. We
have seen the problems associated with by-catch species such
as frostfish entering the QMS at low tonnages. It is a headache
for the fisher, the quota owner and the Ministry. Deemed values
have to set and paid, research cost have to be met and in
the case of kingfish time and money spent resolving local
management issues. We believe it would be cheaper for all
concerned to compensate for the loss of commercial rights
and declare kingfish a non-commercial fishery.
11. If
the commercial bycatch is not reduced the only means of improving
the quality of fishing would be for recreational and customary
fishers to reduce their target fishing and catch - while commercial
fishers contribute nothing. We find this totally unacceptable
for this fishery.
12. If
the Ministry want an example of how over fishing can effect
a kingfish fishery they need only look as far as New South
Wales, which had the largest kingfish catch in Australia.
Prior to the Mid 1980s commercial catches in NSW were between
200 and 300 tonnes per annum. The fishery expanded with the
use of pelagic fish traps to around 500 to 600 tonnes. During
the 1990s the recreational and commercial fisheries seriously
declined, and in March 1996 fishing with pelagic traps was
prohibited. Despite this measure, the fishery has not recovered
and commercial catch has remained about 100 tonnes per annum
(Figure 1).
Figure
1. New South Wales commercial kingfish catch. (NSW Fisheries
status report 2000/01)
13. A
recent report by NSW fisheries (FRDC Project No. 97/126) concludes,
"mortality rates and yield per recruit estimates suggest
that kingfish are currently growth overfished. Total mortality
estimates suggest that between 35% and 55% of kingfish may
die each year due to both natural and fishing mortality".
It is obvious that this fishery is in serious trouble. The
warning must be heeded and a precautionary approach taken
to kingfish management in New Zealand.
14. During
the period of the Australian study commercial fishers took
90% of kingfish under the average size that female breed for
the first time (which is 70 cm fork length in Australia).
Over 40% of catch were two year old fish, a further 30% were
three years old while just 8% were 4 year olds. Kingfish are
mostly taken in target commercial line fishing and generally
they are caught at sizes smaller than that which would provide
the optimum biological yield.
15. The
Australians are obviously concerned about the future of this
fishery and are considering an increase in the current Minimum
Legal Size and the introduction of a maximum legal length
to help protect the spawning population of kingfish. We are
deeply concerned that this fishery appears to have collapsed
at these catch levels. We must not allow a similar situation
to develop in New Zealand.
16. The
Ministry supposedly has done a cost benefit analysis for the
introduction Kingfish into the QMS. Yet we are puzzled that
the main reason given for turning down our proposal of a non-commercial
fishery (paragraph 11) was "that the species is also
highly valued as a commercial product". We would like
the Ministry to substantiate this claim.
17. The
facts are that, by the Ministries own definition, kingfish
is only a medium value species. The surveyed port price of
$3.71 per kg is under the Ministries threshold for high value
species which it uses in setting deemed values. SeaFIC have
published an average price (excluding GST) of $3,073 per tonne
for 1999, 2000, and 2001 fishing years. This equates to $3.07
per kg, which is less again.
18. Data
from reports on kingfish by-catch by trawlers in the North,
FMA1 east coast, and FMA9 west coast show that kingfish is
a very minor component of their catch. Only 326 kingfish were
caught from 489 trawl shots observed in FMA1, less than one
per shot. In the west coast trevally trawl fishery 587 kingfish
were caught from 129 shots observed an average of 4.5 kingfish
per shot while the average trevally catch observed was 510
kg per shot. These reports do not indicate that kingfish is
a particularly valuable component of the trawl catch.
19. There
were also 183 danish seine shots observed in FMA1 as part
of the Ministries SNA9802 project. The total number of kingfish
caught from 183 shots was just eight fish, an average of 0.04
kingfish per shot. These reports do not indicate that kingfish
is a particularly valuable component of the danish seine catch.
20. Since
1991, targeting of non-QMS species has been prohibited unless
the species is identified on a fishers permit. According to
this years Plenary Report on kingfish a few permit holders
are authorized to target kingfish and most of their catch
is taken using setnets. Reported target landings are currently
less than 1% of total landings. This does not indicate that
kingfish is a particularly valuable commercial target species.
21. Given
the scale of the commercial fishing industry, which exports
over $1.5 billion worth of fish per year, we cannot see how
a 300 tonne by-catch kingfish fishery can be so highly valued.
22. Kingfish
is a highly valued recreational species. The results of the
Ministry contracted project on the Value of New Zealand Recreational
Fishing (REC9801), show that kingfish add $180 to the Average
Willingness To Pay for a fishing trip. This was three times
higher than the AWTP for kahawai and rock lobster and five
times higher than snapper or blue cod. While these figures
cannot be compared directly with commercial values they show
the relative value of recreational species. The survey also
estimated that recreational fishers spent $128 million dollars
on kingfish fishing per year without including capital expendature.
A significant proportion of this would come from tourists
that come to New Zealand to fish.
Assessment of Costs and Benefits
23. As stated in our submission on the introduction of New
Species for October 2001 we are unhappy with the weightings
used and the independence of "MFish officials and analysts"
who used their expert judgment in this assessment. MFish and
SeaFIC actively promote property rights and the QMS as the
preferred management regime. In our view there is large degree
of predetermination in the assessment and supporting arguments.
24. The
Ministry say they have assessed the costs and benefits of
the current non-QMS situation, and an imaginary Competitive
Catch Limit (CCL) scenario, against their theoretical QMS
option. However they could not bring themselves to assess
our alternative of non-commercial status for kingfish.
25. We
share the concern expressed by option4 that the central methodology
used to conduct the cost-benefit analysis for making fisheries
management decisions has been devised and manipulated by a
commercial fishing industry group with little, if any, meaningful
input from other stakeholders, and no peer review by any truly
independent suitably-qualified authority.
26. We
no faith in the process when we read, in the report titled
'Analysis of Costs and Benefits in Making Fisheries Management
Decisions', that during the critical weighting exercise by
five unidentified parties, one party commented:
"During the 3 July cost-benefit exercise it was apparent
that the consultant (SeaFIC) facilitating the exercise had
a conflict of interest as he did not stay neutral in his role.
Instead, on several occasions he attempted to influence participant's
decisions. It should be noted that the methodology and criteria
in its final form was not presented until the cost-benefit
exercise. These should have been finalised and agreed to well
before 3 July. The two main reasons for this were (1) change
in priorities by MFish to bring more species into the QMS
in a short amount of time, and (2) one consultant's ongoing
efforts to unilaterally influence the direction and therefore
the methodology of the exercise. This influence included threats
of legal action if MFish failed to agree with him. It was
clear that the consultant continued to influence the exercise
in favour of the fishing industry."
Environmental
Sustainability
27. MFish have not considered a real alternative to the QMS
in there discussion on each criterion category. Why compare
the QMS to a Competitive Catch Limit (CCL) when it is not
the current system, has not been proposed by anyone and plainly
would work. Commercial catch is not constrained under current
management but it would be constrained to the absolute minimum,
under our proposed alternative, if they were not allowed to
land them.
28. Kingfish
are apex predators in the New Zealand marine environment.
Having large sized predators is an important part of the biodiversity
and marine ecosystem. Fishing down the adult population as
they have (in a short time) in Australia is not sustainable
management. We are deeply concerned about the disappearance
of large fish that has been observed in this fishery over
the last 15 years. The TAC must be set lower than historical
catch levels.
Treaty
of Waitangi
29. Maori exercising their customary non-commercial right
have priority access to the kingfish fishery and their ability
exercise this right must be a consideration under the Treaty
of Waitangi. The ToWFC will want their share of the kingfish
fishery but with a TACC set at 100 tonnes their share would
be 20 tonnes of quota. That isn't going to get many Maori
better commercial fishing opportunities is it. On the other
hand, customary may be better served by having more and larger
kingfish available under a non-commercial regime. Yet the
weighting for Treaty of Waitangi was 0.750.
Social
30. This criterion category should include the recreational
views and their requested management regime. The poor old
recreational fisher, (combined harvest of 700 tonnes per annum)
get their preference for a non-commercial fishery lost in
the Social section along with "incentives to work together
for mutual benefit"; "no discernable difference
for coastal communities"; "perhaps better recognised
in a fisheries plan"; "incentives for enhancement"
(the benefits of enhancement is rubbish until a stock recruitment
relationship can be demonstrated); and "opportunities
for Maori participation in the commercial sector". We
challenge the Ministry to demonstrate where the views of the
recreational sector have been included in the cost benefit
analysis. Where is the discussion of an alternative that will
deliver a better quality fishery instead of locking in catch
allocations at current levels under the QMS?
Conclusion
Recreational
fishers believe that New Zealands world-class kingfish sport
fishery is under threat. We have evidence that the NSW fishery
has been overfished and is in decline. If we can implement
a management regime that will improve the quality of the non-commercial
kingfish fishery the economic benefits from increased tourism,
the social benefits of improved access to customary and recreational
fishers, the intrinsic value of having large kingfish in the
water and the ecologic value of maintaining the population
of apex predators out way the importance of providing a 100
tonnes of by-catch to commercial fishers.
The discussion
document has not demonstrated how the QMS could improve the
quality of this fishery. In fact if the quality of this fishery
was improved the incidental commercial by-catch would naturally
increase. Therefore the more fish conserved by recreational
fishers the higher the industries deemed value bill.
Kingfish
are hardy. They survive tag and release well. With prompt
return to the sea we would expect the survival of kingfish
caught by trawl, beach seine, Danish seine purse seine and
line methods to be high. The issue of dead by-catch may need
to be addressed but there would be far less kingfish wasted
than the amount of dead undersize snapper or trevally that
is dumped every year.
Jeff Romeril
President
NZ Big Game Fishing Council
