Kahawai Submission BOPCB

Kahawai Submission

Bay of Plenty Conservation Board

16 April 2004

Bay of Plenty Conservation Board

Te Poari O Te Papa Atawhai O Te Rohe O Te Waiariki

c/o Department of Conservation

PO Box 1146

Ministry of Fisheries

PO Box 1020

Wellington

Attn: Emma Knight

16 April 2004

Dear Emma

Re: Submission on Kahawai introduction into the QMS on 1 October 2004

Thank you for the opportunity to comment on the position paper which includes proposals for the introduction of kahawai into the Quota management system.

1. The Board is a statutory body, the members of which are appointed by the Minister of Conservation. Its role is to represent the community interest in the Bay of Plenty Conservancy. One of the major functions of Bay of Plenty Conservation Board is to approve and review the Conservation Management Strategy (CMS) for the Bay of Plenty Conservancy and advise on its implementation.
2. The Department of Conservation is responsible for ensuring the conservation of natural and historic resources and the protection of biological diversity is regarded as an all embracing principle. This has arisen from the International Convention on Biological Diversity (United Nations Environment Programme, 1992) which was signed by 153 governments including New Zealand.
3. In managing and conserving New Zealand's physical, biological and cultural heritage the Department is charged with:

• Conserving indigenous biodiversity at national and local levels;
• Maintenance of the representative biodiversity as the "touchstone" of preserving the natural character of New Zealand; and
• Advocating for the conservation of natural fisheries resources by liaising with the Ministry of Fisheries (MFish).

For ecosystems and species in decline, it involves total commitment to the biodiversity objective and to ecological restoration.

4. The Fisheries Act 1996 in part reflects these views. As part of the guidelines for setting Total Allowable Catches (TACs) in the reference document, the effects of harvesting the stock on the aquatic environment for the new species are to be considered. Interactions with protected species and areas of high biodiversity need to be actively managed. Consideration of predator – prey relationships is an important factor. The document further states that the interests of future generations is an important social factor that is reflected in consideration of the TAC option adopted, the level at which the TAC is set, and the effects of fishing for the stock on the aquatic environment. Treaty obligations in respect of a stock are encompassed within relevant cultural factors.
5. MFish acknowledges that information on which to base catch limits in a number of non-QMS fisheries is deficient. This was a major criticism of the Parliamentary Commissioner for the Environment report on the management of the NZ marine environment in 1999. The lack of knowledge about marine species and their role in maintaining the integrity and resilience of marine ecosystems was considered by the PCE as a serious risk for NZ (97: 1999) (from PCE 1999 Report – Setting Course for a Sustainable Future: The Management of New Zealand's Marine Environment).
6. Of particular concern to the Board is the TAC for Kahawai in Quota Management Area 1 (KAH1) which includes the waters of the Bay of Plenty. The rationale for the proposed TAC states inter alia that given the history of exploitation, the kahawai stock is not likely to be at or near its virgin biomass (Bo) and that modelling suggests that the fishery was at approximately 50% of Bo in 1996. It further states that there is uncertainty about the level of current biomass levels and the applicability, for setting current yields, of using the 1996 stock assessment. This is because the assessment is not only uncertain but also some seven years out of date.
7. The Boards concern about kahawai relates to the unique role they play in terms of both real and visible biodiversity and the interdependence of a broad range of other species including both marine and bird and possibly mammal for their survival. Kahawai are a unique feature of the New Zealand marinescape and an historic and important food source for Maori. Importantly they are also a valued recreational fishery.
8. One of our Board members has had a long maritime career and prolonged observation at sea of schools of kahawai in the area Cape Brett to Bream Head and also in the northern Bay of Plenty between 1962 and 1994. In his opinion, kahawai had reduced to, at most, one quarter of the 1962 level over that period.
9. The reference document states that recreational interests believe that the overall reduction in kahawai schools might be having an effect on interdependent stocks of predators such as marlin and tuna. These interests also consider that the number of kahawai available to them and the average size of the fish has decreased over time. The document states that the importance of species such as kahawai as a food source suggests the need for caution when setting catch limits. It is also stated that there is consensus among stakeholders that the long term sustainability of the fishery is the key issue and that management changes are overdue. Clearly there are concerns relating to the fishing down of the species.
10. Notwithstanding the foregoing MFish proposes that TACs in area KAH1 be based on estimates of current utilisation and in fact exceeds the current purse seine limit. This proposal is inconsistent with the declining population trends of kahawai. It is also inconsistent with the overriding purpose of the Fisheries Act 1996 to provide for the utilisation of NZ's fisheries resources while ensuring sustainability and adverse effects of fishing on the environment are avoided, remedied or mitigated.
11. The reference document states that in setting the TAC, an overlying consideration is the importance of kahawai as a shared fishery between commercial and non-commercial interests and this is reflected in the proposed quotas. Yet the document also acknowledges that kahawai is much more greatly valued by the recreational sector and, in financial terms, has a very low commercial value.
12. This Board strongly urges a precautionary approach to setting and maintaining quotas for kahawai. It is our opinion that there is a significant threat to the sustainability of the kahawai fishstock. The Board further considers that a drastic reduction of existing catch levels is essential in area KAH1 to assist the kahawai stock to maintain a level that will ensure its long term viability and ecological status. It is further recommended that the existing voluntary purse seine closure in the Bay of Plenty be continued and accompanied by a halving of the daily recreational allowance of twenty kahawai per person.