Dear Minister Hodgson

I have reviewed the Kingfish Initial Position Paper and have noted two glaring errors. I would like you to intervene and instruct the Ministry to correct them. They are:

1. The figures calculating the recreational kingfish catch are of little or no value. That is freely admitted in the Position Paper but then these meaningless figures are used as a basis to calculate proposed allocations of kingfish. You know the rule: "crap in, crap out." Another possible method of allocation needs to be found.
   
   
2. There was huge amounts of targeting of kingfish through the 1990s by commercial fishers who had no permit to do so. This targeting was achieved by:
   
   
   1. Set-nets on reefs during periods when kingfish would be active there.
   2. Varying trawl speeds and net depths to capture kingfish.
   3. Using floating long-lines.
      
      
3. There is no mention of this illegal targeting in the Position Paper and no attempt to work out what proportion of the kingfish catch was illegally acquired during the 1990s. It is not going to be a good look for the Ministry to be rewarding criminal activity by giving the thieves quota in perpetuity.

I request that you instruct the Ministry to determine how much of the commercial kingfish catch was true by-catch in 2002 and then to have the Ministry present proposals that allocates the resource based on that figure. I suggest the 2002 figure because the introduction of the 65cm to trawlers in 2002 sharply decreased the motivation to target smaller kingfish, which school in large numbers and are more easily captured in groups. In addition the application of the 65cm limit to trawlers closed the loop-hole that existed since 1993 which enabled set-net fishermen to illegally pass their undersized kingfish through the sheds as trawl caught fish.

Thanks for your time,
Mark Feldman
Kerikeri
Northland