Kahawai Submission SeaFIC

SeaFIC Submission

Setting of Sustainability Measures for Stock to be Introduced into the QMS on 1 October 2004

27 February 2004

27 February 2004

Setting of Sustainability Measures for Stock to be Introduced into the QMS on 1 October 2004

28. Two options are proposed for kahawai and swordfish with deemed values set at either 75% or 200% port price. Kahawai clearly should not be placed the "high value" category as it is not a high value species, a significant proportion is taken as incidental catch when taking other QMS species, and it cannot be returned to the sea if caught unintentionally. Again we suggest that the port prices of the species is a less important factor. However the fact that this species is not solely taken in a single species target fishery and can not be released alive should disqualify it from this categorization and the associated punitive deemed value of 200% of port price. We believe that the deemed value for this species should be set high enough to remove any economic incentives for targeting it without sufficient ACE to cover catches. However the deemed values proposed could create strong incentives for illegal discarding and may be counterproductive if that degrades catch statistics. Furthermore, this high deemed value in conjunction with setting a TACC that is likely to be constraining is likely to bias the tender process (see discussion below). SeaFIC contends that a deemed value of 75% (option A) should provide a sufficient disincentive to target kahawai without ACE and is the appropriate basis for setting deemed value for this species.

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Supplementary Submission

The New Zealand Seafood Industry Council Ltd

Fishing Industry House

74 Cambridge Terrace

Private Bag 24-901

14 April 2004

Ministry of Fisheries

PO Box 1020

Wellington

Attention: Kristin Philbert

Setting of Sustainability and Other Management Controls for Stocks to be introduced into the QMS on 1 October 2004.

1. Thank you for the opportunity to provide feedback on proposed sustainability measures and other management controls for stocks being introduced into the QMS on 1 October 2004. This submission is presented by the New Zealand Seafood Industry Council Ltd. (SeaFIC) on behalf on the New Zealand seafood industry. SeaFIC's submission has been developed in consultation with the commercial seafood industry and supplements submissions presented by commercial stakeholder organizations and the wider seafood industry.

Kahawai: Catch allocation model

2. SeaFIC's supports the Ministry's decision to use catch history rather than a utility model as a basis for allocation between sectors. SeaFIC note that this decision was based on a lack of comparable detailed information on utility values. SeaFIC is concerned that MFish still consider a utility based allocation model as a legitimate polity tool to guide allocation at time of QMS introduction. SeaFIC does not support the use of a utility based allocation model as a means to determine catch allocations at the time of introducing a stock in to the QMS. We maintain that the "claims based allocation model" based on proportionally of catch history, subsequent to determination of customary allowance delivers objective and practical outcomes consistent with the Fisheries Act 1996 and fisheries management objectives. SeaFIC's submission on Kingfish last year provided a detailed explanation of our concerns with the utility model. The main points raised in SeaFIC's Kingfish submission are equally pertinent for Kahawai as recreational submitters have introduced results (and failings) from the same SACE study in support of their Kahawai submissions. The main   points are summarized below.
3. The valuation methodology underpinning the utility model in not consistent across sectors and fails to provide robust value estimates for both the recreational and commercial fisheries. The use of proxy species to value quota of species not yet in the QMS is problematic, particularly for mulitspecies fisheries. Value of a species taken as incidental catch may have little to do with export price or port price. Quota value is more likely to be determined by the individual characteristics of the fisheries including: value of the target fisheries; relationship between the incidental and target species; opportunity to avoid incidental catch; and the deemed value regime.
4. The valuation of recreational catch is flawed. SeaFIC contracted Dr. Gardner Brown to review the study done by the South Australian Centre for Economic Studies (SACE) that MFish used as the basis for determining value of recreational catch. Dr. Brown is a professor of economics at the University of Washington and is an internationally respected expert in the field of non-market valuation of natural resources. Dr. Brown found a number of critical problems with the study that bring into question the validity of results and the way they are being used to inform policy making. His review of this study and his curriculum vitae were attached to our submission on kingfish last year. SeaFIC would be happy to provide them again upon request.
5. SeaFIC also submits that the utility allocation model is inconsistent with the Treaty of Waitangi commercial fisheries settlement. Reducing the commercial share of available yield in favour of the recreational sector suggests a priority of recreational interests over the Crown's obligation to protect the value of the commercial fisheries settlement.

Spiny Dog Fish

If you would like to discuss points raised in this submission, please don't hesitate to contact me.

Yours sincerely

John Willmer

Policy analyst