option4 Rebuttal of Kahawai Initial

Position Paper 2004

Part One

When a species is introduced into the Quota Management System (QMS) the Ministry of Fisheries issues its suggested management proposals to the Minister in an Initial Position Paper (IPP). The Minister uses this information to base his final decision on when setting the TACC and allowing for the public and customary Maori fishers.

option4 have major concerns with much of the information provided in the IPP. Also of concern is the Ministry's position in having presented the Minister with only one option for the future management of this most important species. We have spent time going through the document section by section so you can understand our concerns.

The document has been split into manageable sections so you can quickly come to grips with the issues option4 has identified as being of note.

KEY: Black text is IPP

        Blue text is option4 commentmment.

KAHAWAI (KAH)

Part One

Introduction into the QMS.

Key issues to be considered.

  • We are appalled at the absence of sound information regarding non commercial catches in a fishery of such national importance. More »

List of management options.

  • Why present the Minister with only one management option for kahawai?  More »
  • The public have been disenfranchised from their fishery. More »

Introduction into the QMS

  1. Kahawai ( Arripis trutta and A. xylabion) has been gazetted for introduction into the QMS on 1 October 2004.   The Quota Management Areas (QMAs) for kahawai are outlined in Figure 1.   The fishing year for kahawai will be from 1 October to 30 September in the following year and the total allowable commercial catch (TACC) and annual catch entitlement (ACE) are to be expressed in terms of kilograms greenweight.

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       Figure 1: Quota Management Areas for kahawai

Key Issues to be considered

  1. MFish considers the key issues that relate to the decisions for setting sustainability measures for kahawai stocks are as follows:
  1. There are two species of kahawai present in New Zealand waters, kahawai and northern kahawai. A stock assessment applies to kahawai and there is very little information available for the other species.
  2. Kahawai biomass had declined to about 50% of the virgin biomass at the time of the assessment in 1996, however the current biomass is unknown.   Nationwide combined estimates of recreational catch, customary catch and reported commercial landings are currently just within the range of MCY estimates based on the 1996 stock assessment.
  3. Background information on catch by sector and method is outlined in Annex One.   While primarily a purse seine fishery in QMAs 1, 2 and 3, kahawai is almost entirely taken as bycatch in QMA 8.   Commercial catch limits (CCLs) apply to kahawai, with specific limits pertaining to purse seining.
  4. Since the imposition of CCLs catches, although fluctuating, have progressively declined principally in QMA 3.   Declining catch in QMA 3 is associated with reduced purse seining in this area.
  5. Recreational catch is about 83% of commercial landings as estimated by recreational harvest surveys.   Kahawai is one of the fish species most frequently caught by recreational fishers.
  6. The recreational sector believes that the number of kahawai available to them and the average size of kahawai has decreased over time.

  7. Kahawai supports important Maori customary fisheries but the size of the catch is unknown.

option4 comments on point d.

  1. option4 comments on point d. –
    1. Refer Annex 3 - Feldman report p3 –“ For years now the purse-seine vessels have been unable to catch their limit in KAH3. With two boats operating in KAH3 the purse-seiners were able to catch up to 5000 tonnes per year in the late 1980’s. From 1991-92, 92-93, 93-94 and 94-95 these same two boats were unable to catch their limit at any time. This suggests their CPUE is 1/2 to 1/3 of what it used to be in the late 1980’s.

    If purse-seiners, guided by airplanes, cannot land kahawai in KAH3, it’s easy to understand why recreational fishers feel they can no longer catch kahawai either. Given that it is much easier to catch kahawai with an airplane and purse siener, its reasonable to assume the recreational CPUE in KAH3 must have declined concurrently to less than 1/3 of what it used to be in the 1980’s.”
  2. option4 is concerned the above list of “key issues that relate to the decisions for setting sustainability measures for kahawai stocks” does not include the need for good information. If, for any reason, the information available to base decisions on lacks adequacy or agreement, this should be stated up front as a key issue. We are appalled at the absence of sound information regarding non commercial catches in a fishery of such national importance and where the non commercial sector has expressed grave concerns for at least 20 years.

    Read on and realise what sketchy information the Minister is expected to base his decisions on for this, the most important national non commercial species in our seas.

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List of Management Options

  1. MFish proposes that the s 13 management arrangements are appropriate for kahawai.
  2. MFish proposes one option for setting TACS, TACCs and allowances for kahawai stocks as outlined below.

    We would prefer to see this sentence written as follows:
    “MFish proposes one option for setting TAC’S, TACC’s and proposes to allow for non commercial fishers as outlined below”.

    As far as we are concerned the Minister does not make allocations for non commercial fishers. Section 21 of the 1996 Fisheries Act is quite clear “When setting a TACC the Minister shall allow for non commercial fishers”. Nowhere in the Act does it say “set an allocation or allowance.” How long do we have to put up with this blatantly inaccurate interpretation of the law?

   Table 1 Proposed TAC's, TACC's, and allowances for kahawai (tonnes greenweight).

Stock

TAC

Customary allowance

Recreational allowance

Other sources of mortality

TACC

KAH 1

3 910

790

1 580

60

1 480

KAH 2

1 510

255

510

35

710

KAH 3

960

150

300

20

490

KAH 4

18

3

5

0

10

KAH 8

1 210

190

380

5

635

KAH 10

18

3

5

0

10


Why present the Minister with only one management option for this species which has been the subject of public concern for at least 20 years?

Please also be very aware that the tonnages outlined are all derived from completely different base line information. In the case of recreational they base their recommendation on a crude averaging exercise. For customary they grab a figure out of thin air based on some criteria established with little or no public discussion and the commercial figures are political. As for other sources of mortality – the truth is they have not got a clue what this should be.

  1. Additional management controls proposed include:
  1. setting deemed values and application of differential deemed values;
  2. amending reporting regulations, and
  3. revoking certain fishing permit conditions.   These conditions are redundant as they relate to the closing of the purse seine fishery once purse seine limits for kahawai have been reached.

NZRFC and NZBGFC both have long standing policies that kahawai should be managed as a non commercial fishery only. This makes good sense because developing the kahawai commercial fishery has lead to a massive decline in non commercial catch rates and also adversely impacted on the size of fish available to those fishers.


The Fisheries Act stipulates that those fishing commercially are not permitted to adversely impact on the existing rights of other users of the fishery. This part of the Fisheries Act has been grossly ignored when applied to the kahawai fishery. The public have been disenfranchised from their fishery through the Ministry’s preference to ignore the rights of the people and fully support the development of the purse seine kahawai fishery.

We are appalled that the Ministry has only seen fit to include catch histories from 1993 to 2002 in its tables. Had the tables presented shown catches as far back as possible it would have made the IPP document more honest and it would be easier for the Minister to see what has happened in this fishery.


The logic of the Ministry in this case is difficult to understand when one considers the value of recreationally caught kahawai at $28,000 - 56,000 per tonne compared to the pitiful commercial value of $1700 - $5100 per tonne. One eleventh to one sixteenth of the value of non commercially caught kahawai.


Kahawai is a low value commercial species that could be released alive from longliners or purse seiners. Placing kahawai on the 6th Schedule would allow the commercial fisher the option of releasing fish, otherwise every kahawai caught must be kept.

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