KAHAWAI SUBMISSION RICK POLLOCK 2004

Kahawai Submission

by Rick Pollock

April 2004

Submission to the Introduction of Kahawai into the Quota Management System (QMS)

Thank you for allowing extra time to put forward this submission. I know I, as well as many others, would not have been in a position to do so at the originally allowed date.

While the health of kahawai stocks in our normal area of activity (Bay of Plenty) is of vital interest to both our business and on a personal basis, the overall state of this fishery to the nation as a whole is of far more importance. Although my experience at sea spans 250 days at sea per year, I would not qualify as a fisheries scientist or marine biologist. My viewpoints will be that of a layperson despite this experience level.

First and foremost I can not stress the importance of kahawai stocks and their subsequent health too much. They are truly the "people's fish" with their relative abundance, range and availability throughout the inshore region. Many recreational and sustenance anglers rely heavily upon kahawai for sport and food, particularly when other possibly more desirable species cannot be found.

Another issue is their obvious association with various species of sea birds. Due to their schooling nature they often force small baitfish to the surface in masse, thus making some available to predatory birds. Without this activity many birds would find feeding much more difficult or, in some cases, impossible.

Additionally, kahawai are well documented as an integral food source for larger fish. Included, but not specifically limited, to this list are the following:

Cetaceans also feed on kahawai and can commonly be seen doing so. Among these are:

So, a healthy, sustainable kahawai stock is obviously important to an overview of the situation, not just for man's benefit.

While thoroughly reading the Initial Position Paper (IPP) I have come across several anomalies which I would like to point out. These come in the way of contradictions and poor/outdated research.

Primarily are the respective statements "stock assessment is uncertain and outdated" and also continually referring to date relating back to 1996. These two idioms are a continuing saga right throughout the entire report. For something as important as affixing tonnage for kahawai admission to QMS and judging this by incomplete or outdated statistics/research is irresponsible. Considering the ramifications this decision (and it could last virtually forever) has on many people, not to mention animals, the best and most current information must be utilised to reach a fair and responsible outcome.

Contradictions also abound with statements such as 2b "kahawai biomass has declined to about 50% of the virgin biomass" followed by "current biomass is unknown". How can one know one without the other?!  Also later in that some point is "commercial landings are currently just within the range of MCY". How can this be known without certainty of the biomass?!

Further along in 2e is the statement "Recreational catch is about 83% of commercial landings".   This made by not using the latest recreational diary/ramp survey information or commercial catch records since 1996, why?

Then in item #12 the incredulous truth is reaffirmed. If one read only this statement it can only lead to one conclusion. How can the minister, or anyone else, make such a difficult and important decision based on such poor and antiquated information that even they admit to????

Item #20 is also quite amazing. How can the proposers/advisers assume anything about recreational anglers or their preceptors when they do/will not utilise current statistics?

Again in #'s 21 ("stock assessment is uncertain and outdated"), 22 ("importance of kahawai as a food source suggests the need for caution") and 23 ("stock assessment information is uncertain and dated") – all these reiterate the severe need for more current information to be made available to the minister in this matter. Failing this eventuality then the minister has no course but to act very cautiously.

SOURCES OF MORTALITY

I find item #53 to be an interesting one. Why, when virtually every fishery in New Zealand suffers to some extent at the hands of illegal fishing would kahawai not suffer the same fate? I can't tell you how many times I've seen smoked kahawai fillets for sale out of the back of a vehicle, at school rugby games and raffled off in a pub. All these activities are highly illegal but go undetected and unpunished. While not on the grandiose magnitude of paua for example, to suggest there is no illegal activity within the kahawai fishery is no illegal activity within the kahawai fishery is nothing more than burying one's head in the sand. To not allow for mortality here is a big mistake.

METHOD RESTRICTION

In item #55 we are told conflict is being "mitigated by voluntary agreements". Unfortunately the vast majority of these agreements are breached over and again across the board. If there is no law involved then commercial fishers repeatedly transgresses these agreements since they have no teeth. These VA's are great in theory but poor in practicality.

STATUTORY CONSIDERATIONS

Item b) again states the incredulous truth. "MFish considers the stock assessment to be uncertain and outdated. Nonetheless the assessment suggests that the TAC's proposed based on current levels of utilisation, are likely to be at or above BMSY". How, in all honesty, can the ministry make such a statement based on poor/bad information! Again in c) we have the same two idioms reappear – "1996" and "uncertainty about this assessment"!

PRELIMINARY RECOMMENDATIONS

In item g) I would urge the minister to accept and implement the higher of the two (2) deemed values prescribed for kahawai. Even at this level there may be some "gravy" left over for the fisher, inducing them into actively and profitably over fishing the source.

SUMMARY

Here I will be brief. With so much uncertainty and old information clouding this entire issue I believe the minister must err on the side of caution. With such imprecise advice from those who repeatedly state as much, he must be very careful in his decision making.

Thank you for the ability to present this submission.

Yours faithfully

Richard Pollock

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