Kahawai Submission TNIFCL

Submission

The Northern Inshore Fisheries Company Ltd

26 February 2004

26 February 2004

Emma Knight

Ministry of Fisheries

P O Box 1020

WELLINGTON

Dear Emma

Introduction of New Species into the Quota Management System on 1 October 2004.

This submission is made by the Northern Inshore Fisheries Company Ltd (TNIFCL) in response to the Ministry of Fisheries consultation document on the proposed management frameworks for fishstocks gazetted for introduction into the QMS on 1 October 2004. The comments in this submission are based on:

• Consultation with key TNIFCL stakeholders
• TNIFCL's analysis of the consultation document
• Evaluation of the New Zealand Seafood Industry Council's submission.

TNIFCL thank you for the opportunity to provide comment on the consultation document. This submission focuses primarily on those species specifically relevant to TNIFCL. These species are:

• Kahawai
• Parore
• Porae
• Red snapper

The TNIFCL opinion on each species will be given separately.

Kahawai

TNIFCL supports the setting of TACs for kahawai under Section 13 of the Fisheries Act (the Act).

TNIFCL endorse the approach taken not to use the current CCLs as a basis for setting the TACCs and supports the caution adopted to the use of the historic stock assessment information. It also supports the view of MFish that a utility based model is inappropriate for this fishery on the basis of both uncertain knowledge and the absence of any tradeable rights between sectors and the reasonable certainty that the fishstock is above Bmsy at current catch levels. We support the use of catch history years. In the instance that MFish chose to reconsider a utility based model then it will need to adopt a different approach to assigning a value to kahawai as part of a portfolio of seasonal fishstocks rather than rely on port price information. we would welcome engagement with MFish on the establishment of a value to commercial fishers should it be required.

TNIFCL recognises the inherent problems with the recreational diary surveys and believe that MFish should qualify any advice to the Minister over the robustness and acceptance of the presumed recreational catch of each survey.

TNIFCL have significant concerns over the catch history data provided in the IPP. This differs from the data used in the MFish Stock Assessment process and in the data published by Clement. As a solution to the confusion in data on the kahawai fishery, TNIFCL believe that the catch records used and approved through the stock assessment process and plenary should be the basis for setting the TACCs and TACs for all kahawai fishstocks. This data is listed below for kahawai 1.

Based on average of the five years of commercial landings for the period between 1997 and 2002 TNIFCL propose the minimum TACC should be set at 1601 t for KAH1 and not 1480 t as proposed by MFish. Some additional allocation needs to be made as the stock assessment data does not include estimates of mislabelled fish, dumped fish or fish landed as bait. Kahawai has also been a bycatch species and is likely to be under-reported for other methods than purse seining. This revised figure should give a better assessment of current utilisation. The TAC and other allocations should be revised on this basis.

TNIFCL support the removal of fishing permit conditions relating to the closure of the purse seine fishery once limits for kahawai have been reached. These are no longer required following introduction to the QMS.

TNIFCL strongly opposes the unilateral departure from the deemed values policy framework to apply a factor of 200% to the port price for deemed values. It fully endorsee the comments raised in the SeaFIC submission. Kahawai clearly falls within the "all others" fishstock category and the standard factor of 75% of the port price should apply to this species. It should be the responsibility and right of the quota holders to negotiate with MFish appropriate deemed values to prevent the landing of kahawai in excess of ACE, in order to protect their property right. An existing example is the deemed value for SNA1 which was agreed upon by the quota holders.

TNIFCL are aware that MFish have concerns over trends in population growth in the Northern areas and subsequent impact on levels of recreational effort. TNIFCL therefore believe MFish should show consideration towards constraining recreational effort through reductions in the daily bag limit and setting a minimum legal assize for kahawai.

TOP

Parore

TNIFCL support the setting of TACs for Parore under section 13 of the Act. It agrees to the use of the catch history years 1993-94 to 2002-03 as a method of setting the TACC in PAR1. It endorses the inclusion of Parore in the amateur daily bag limit for North Island recreational fishers and accepts the inclusion of Parore in the low knowledge fishstock category for deemed values.

Porae

TNIFCL support the setting of TACs for Porae under section 13 of the   Fisheries Act (the Act). It agrees to the use of the catch history years 1997-98 to 2002-03 as a method of setting the TACC in POR1. It endorses the inclusion of Porae in the amateur daily bag limit for North Island recreational fishers and accepts the inclusion of Porae in the low knowledge fishstock category for deemed values.

Red snapper

TNIFCL support the setting of TACs for red snapper under section 13 of the Act.

In its earlier submission on the introduction of red snapper into the QMS, TNIFCL supported the inclusion of this fishstock as it believes that there is a development potential for this fishery. We are disappointed that MFish have failed to make consideration for the future utilisation of this fishery. The initial TACs proposed by MFish are not providing for opportunity for development of the fishery or more some level of initial development as an incentive for the industry to invest in the collection of additional information of the impacts of fishing on the stock through adaptive management programmes or fishery plans. We wish to make the following points:

The biology and abundance of the red snapper is not well understood however it is known that as well as a reef habitat this species is also relatively commonly found in open water much like snapper (Pagrus auratus) which allows for open water migration and replacement of populations as well as the slower reef fish larval replacement. This would indicate that the population could sustain higher levels of catch than reef habitat restricted species.

Anecdotal evidence from commercial fishers is that red snapper are not uncommon in open water habitats between 100m to 400m. They are caught as bycatch in trawl in open space above stony ground and by longline in open areas. This would support the observations that red snapper is not a reef habitat restricted species.

There appears to be strong concern that increase in TACC would result in an increase in set net activity on northern reefs. The industry intent is to develop the fishery through longline and trawl methods over existing grounds as such it is unlikely that there would be significant increase in set net activity on reefs as a result of introduction of this species into the QMS.

TNIFCL dispute the selection of catch years for the averaging of current catch and question why catch data from the 2002-03 fishing year have not been included in the consideration of catch history as with Parore and Porae. The data provided through MFish give the catch for RSN1 in 2002-03 as 11.8 tonnes and for RSN2 as 41.2 tonnes. If the full catch history is plotted for RSN1 (Figure 1) then it is clearly apparent that there was a significant shift in average catch history from 1995-96 onwards as the fishery began development. TNIFCL believe that the period 1995 to 2002 is more representative of current catch levels and should be used for setting the TACC. The average of this period is 135 t rather than 125 t based on 1993 to 2002 catch history years and that the TAC and other allocations should be adjusted accordingly.

For RSN2 a similar significant shift is seen in 1996 (Figure 2) followed by a further increase in 1999 as the fishery started development. TNIFCL believe that a more accurate estimate of recent catch history is derived at an average of the fishing years 1999 to 2002. On this basis TNIFCL believe the TACC should be a minimum of 40 tonnes rather than 19 tonnes, and that the TAC and other allocations should be adjusted accordingly.