| Kahawai
Submission
option4
10
August 2005
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The
impact of past unsustainable commercial kahawai catch
4.13 Figure
1 in MFish's 2004 FAP does not portray the full picture with
respect to past commercial catch. In light of this information,
the high levels of past commercial kahawai catch are likely to have
had a greater impact on the present biomass of kahawai stocks and
non-commercial catch.
4.14 The estimated additional 53,000 tonnes of misreported kahawai
catch plus other non-reported catch are likely to have had significant
adverse effects on kahawai biomass and non-commercial catch in each
QMA. This impact continues to be more apparent in some QMAs than
in others.
4.15 This additional 50,000 tonnes of kahawai taken out of the fishery
was not factored into MFish's national estimate of MSY which was
used as a reference point for TAC setting in 2004.
4.16 The 2005 kahawai
FAP should properly evaluate the impact of this past high commercial
catch on the biomass of kahawai stocks and non-commercial catch
in each QMA.
4.17 The past high commercial
catch of kahawai should be properly accounted for and attributed
to the commercial sector.
4.18 The non-commercial
part of Figure 1
in the 2004 FAP should also be reconsidered. The graph should show
the non-commercial catch clearly, without confounding the graph
with incompatible data series (as was the case in the 2004 FAP).
4.19 option4 notes the conclusion of the Recreational Technical
Working Group in the 2005 IPP para 132
“The Recreational Technical Working Group recommends
that the harvest estimates from the diary surveys should be used
only with the following qualifications: a) they may be very inaccurate;
b) the 1996 and earlier surveys contain a methodological error;
and, c) the 2000 and 2001 estimates are implausibly high for many
important fisheries.”
4.20 These warnings apply to the recreational catch series used
in the 2004 FAP. We ask that MFish choose a current upper and lower
bound for modelling recreational catch and model both figures as
separate series back until 1970 as a proportion of the expected
biomass.
4.21 As it stands Figure
1 above shows a halving of the recreational catch by the early
1990s based on the low commercial catch figures used. The decline
in recreational catch would be greater when the additional commercial
catch is included in the data series.
4.22 An example of the type of national line chart that would more
accurately show trends in commercial and non-commercial catch is
given below. We ask the Ministry to include this type of information
for the Minister to consider in the FAP.
4.23 An evaluation
should be made of the effects of the interaction between commercial
and non-commercial interests as the purse seine fishery was developed.
This evaluation needs to include the following points:
- how the non-commercial catch was reduced by half or more, prior
to 1991;
- where these fish have gone and who is now harvesting the other
half of the non-commercial kahawai catch;
- how those fish can be returned to non-commercial fishers.
4.24 option4 believe the kahawai fishery was delivering sustainable
yields and well developed prior to the introduction of the purse
seine fleet.
Comparisons of recreational catch after the peak commercial
catch
4.25 The
2005 IPP stated at paragraph 24:
“MFish notes that in the main recreational fisheries
in KAH 1, recreational claims of declining sizes of kahawai are
not supported by catch sampling and age structure data from the
recreational fishery, which has been closely monitored since 2000-01.
The size and age of the fish sampled has remained relatively constant
since 2000-01 with a broad age structure evident in the catches.
These results are not consistent with a rapid decline in abundance.
However, MFish notes that catch selectivity may influence these
indicators.”
4.26 Comparisons by MFish
of recreational catch rates and sizes of fish since January 2001
are somewhat short sighted. This is not when the rapid decline in
abundance occurred; in fact if existing management measures were
effective this is when the stock should show a rebuilding trend.
We note that despite extensive boat ramp sampling over the peak
months in the recreational fishery NIWA were frequently unable to
meet their target sample size if 1500 fish per region in these surveys
due to low catch rates.
4.27 To evaluate
the impact of commercial fishing on kahawai stocks, or to allocate
catch between sectors based on research since January 1991 is not
a good basis for informed decision making. This is because the peak
level of commercial fishing preceded 1991 and this is when the most
damage to non-commercial fishing occurred.
4.28 The
peak level of commercial fishing and the rapid decline in abundance
preceded 1991. A number of submissions last year stated that 1991
was when the non-commercial fishery was in a very poor state - so
poor that the then Minister imposed catch limits on purse seine
as an interim measure to halt the decline.
4.29 The
comparison of catch rate and size data post 1991 shows that the
non-commercial fishery has not improved since the period of peak
commercial catch, even under commercial catch limits imposed since
1991.
4.30 The
size and age structure of kahawai in the main recreational fishery
in KAH 1 (Hauraki Gulf) is certainly not broad. In other regions
targeting of kahawai in surface schools may indeed result in selective
fishing for larger adult fish.
TOP
5. TACs
5.1 A precautionary approach favouring the setting of lower TACs
should be taken to ensure sustainability in each QMA because there
is an information deficit in relation to kahawai stocks.
5.2 Basing
TACs solely on catch history across all QMAs has the effect of concentrating
allowances in areas of highest past fishing pressure, and is likely
to result in some QMAs being over-utilised and others under-utilised.
5.3 As discussed
above, the suggestion of management of kahawai above BMSY is supported.
6. The Fisheries Act’s Information
Principles
6.1 When
setting TACs and TACCs/non-commercial allowances the Minister should
take into account a range of information (as the best available
information) including the information:
- History of the Fishery;
- The reasons management is required;
- Historic reliance;
- Time taken to catch fish;
- Other measures of trends in fish availability, in each QMA;
- The relative value of kahawai to each sector;
- The rationale for pre QMS management measures;
- Indications of the effectiveness of pre QMS management;
- Evidence of regional depletion;
- The relative size of QMAs;
- The distribution of fishing effort (and fishing method) across
QMAs;
- Direct observations of fishing clubs/experienced fishers;
- Fish size.
6.2 Such
information would allow the Minister to more readily understand
the true state of the kahawai fisheries confronting individual fishers.
7. Individual QMA Assessment Required
7.1 When setting the kahawai TACs and TACCs/non-commercial allowances,
the Minister should undertake an individual assessment of each QMA
and take into account specific factors relating to each QMA.
7.2 A uniform, national approach of proportional reductions should
not be taken.
7.3 For example, basing TACs solely on catch history in each QMA
solely on catch history is likely to leave some QMAs over-utilised
and others under-utilised. This is inconsistent with "ensuring
sustainability".
7.4 Different QMAs have undergone different histories and different
pressures. KAH1, for example, has been subject to the greatest fishing
pressure.
7.5 Appendix 1 to this submission undertakes an individual
evaluation of key QMAs: KAH1, KAH2, KAH3, KAH8.
8. Non-commercial Interests
8.1 In allowing for non-commercial "interests" the Minister
should evaluate the true nature and scope of those interests and
allow for them in a way that provides for those interests (i.e.
taking into account the history of the fishery, and criteria which
measure the quality of the recreational fishing experience e.g.
CPUE or fish size).
8.2 It needs to be expressly recognised that non commercial fishing
in New Zealand is as much about putting food on the table as it
is about "recreation".
8.3 Non-commercial fishers are currently experiencing disappointingly
low catch rates, which are particularly low in some QMAs. For example,
a recent NIWA survey indicated that it currently takes an angler
8 boat trips on average to catch a kahawai in the Hauraki Gulf.
8.4 Non-commercial interests should not be measured by recent catch
history alone when there is a significant risk that the non-commercial
catch has been eroded by past high levels of commercial catch.
8.5 When the fishery rebuilds, the low current non-commercial catch
rates and/or small size of fish are likely to improve in many key
fisheries. Only if non-commercial allocations allow for possible
increased harvest will future problems be avoided. The restoration
of this important non-commercial fishery should something to be
celebrated, not punished.
TOP
9. MFish’s Proportional Allocation
Policy Preference
9.1 option4 opposes MFish's policy preference for proportional allocation
stated at paragraph 66 of the 2005 IPP as follows:
"Kahawai is a shared resource. Non-commercial removals
contribute approximately 58% percent of the existing TAC. MFish
generally supports a proportional approach to
allocation of shared fisheries on the basis that all stakeholders
should contribute to the increasing the abundance of the resource.
This position assumes that all sectors are to a lesser
or greater degree responsible for the present state of the fishery.
Further, it assumes that the level of catch reduction achieved
from each contributing sector is of some consequence to the overall
reduction required. However, the Act allows the Minister broad
discretion. A preference may be provided to one sector over another
when making a determination on the allowances that should be set
before a decision on the TACC." [Emphasis added]
9.2 It is incorrect to assume that the non-commercial sector and
commercial sector are equally responsible for the decline in kahawai
biomass. Rather, the alarming decline in kahawai is overwhelmingly
attributable to the commercial sector.
9.3 In light of the information on high commercial catch of kahawai
described above, it is clear that the kahawai fishery was severely
and unsustainably fished by commercial interests prior to the first
recreational survey.
9.4 The commercial harvest of kahawai prior to 1990 has reduced
the biomass of kahawai stocks to a point where it has had serious
impacts on non-commercial fishers ability to catch kahawai.
9.5 Figure 1 in
the 2004 kahawai FAP showed that non-commercial catch had declined
from around 4000 tonne to around 2000 tonne per annum.
9.6 Commercial Catch Limits (CCL’s) were introduced in 1991
in response to concerns from both recreational and Maori customary
fishers about the low catch rates and poor state of the kahawai
fishery. There is no evidence that the CCL’s have achieved
their purpose, which was to improve non-commercial catch. In such
circumstances, a precautionary approach should be adopted.
9.7 The large commercial catches of the purse seine fishery were
achieved by fishing down the standing stock of kahawai to low levels.
The low levels of kahawai biomass have suppressed the non-commercial
catch. The following statement from Sanford appeared in the 2004
kahawai FAP at paragraph 71 suggest the impacts of commercial catch
on non-commercial catch:
“MFish notes the Sanford submission that it is axiomatic
that harvesting will have led to a reduction in biomass. With
a species such as kahawai that is highly visible because of its
surface habit, it will be more noticeable to recreational fishers
as the size of the stock is reduced towards BMSY. Further, a reduction
in the size of fish might be expected as larger older fish are
removed during harvesting and replaced by smaller more productive
fish. At issue is whether the biomass has declined to a point
that a rebuild of the stock is necessary or desirable.”
9.8 Proportional allocation improperly subordinates non-commercial
fishing rights to the commercial sector where biomass has been reduced
significantly, and consequently, the non-commercial catch is suppressed.
The attached proportional document (Appendix
Three) is a critical part of this submission, it explains in
detail how this occurs and needs to be read in conjunction with
this submission.
9.9 A status quo catch history approach with fixed proportional
reductions does not address the long-standing management issues
in some QMAs.
9.10 A non-proportional approach is now the only way non-commercial
fishers have of getting back the access to the kahawai they lost
when commercial fishers fished down kahawai stocks.
9.11 In order to rebuild the fishery quickly and provide for intergenerational
equity TACCs should be set at the maximum commercial kahawai by-catch
in each QMA over the last 5 years.
9.12 While the CCLs may have slowed further decline in the fish
stock, there is no evidence available that non-commercial catch
rates, size of fish or the biomass has improved over the last 14
years in many key areas, particularly in KAH1, KAH2 and KAH3. Some
re-allocation back to non-commercial fishers is now required to
address this problem.
9.13 The only way of actually improving non-commercial catch is
to increase the biomass while allowing a sufficient portion of the
TAC to non-commercial fishing interests to cover the increased catch.
9.14 option4 submit that the development of the purse seine fishery
has lead to the re-allocation of around 2000 tonnes of non-commercial
fish per year to the purse seine fishery. This was achieved by suppressing
non-commercial catch through commercial purse seine fishers massively
reducing the kahawai biomass pre 1990.
9.15 If past high commercial kahawai catch is left unaccounted for,
it distorts the critical historic information necessary for the
Minister to make an informed decision on whether a proportional
management decision is appropriate.
9.16 The commercial sector, being responsible for the alarming declines
in kahawai stocks, should bear the cost of the need to rebuild those
stocks.
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