NEW ZEALAND BIG GAME FISHING COUNCIL

Patron: G S Traill
Chairman: J A Romeril
Secretary: R T Nelson (Mrs)
Telephone: 09 433 9648
Fax: 09 433 9640
PO Box 93
WHANGAREI
E-mail: nzbgfc@ihug.co.nz
Website: www.fishing.net.nz

1 February 2002

Randall Bess
Ministry of Fisheries
Private Bag 14
NELSON

Email: Bessr@fish.govt.nz

Dear Sir,

Introduction of New Species or Stocks into the QMS

1. Please accept the following submission on behalf of the NZ Big Game Fishing Council. We are a national organisation representing 58 fishing clubs with a total of 31,000 financial members. In recent years our membership has expanded beyond the traditional deep sea angling clubs to include many local clubs targeting inshore species.
2. Kingfish and kahawai are very important non-commercial species in New Zealand. Recreational fishers report a marked decline in availability since the introduction of the QMS. As fishing companies bought up quota and leased it back to fishermen this produced incentives to catch non-QMS species. Prior to the Fisheries Act 1996 there was also the incentive of establishing catch history to a larger share of future quota allocations.
3. For several years NZBGFC has been asking for the Ministry to help develop a harvest strategy for kingfish and kahawai before they are introduced to the quota system.
   1. In 1999 we made written and oral submissions on the Fisheries Amendment Act (No. 2) to the Primary Production Select Committee asking that the underlying management issues in the kingfish and kahawai fisheries be addressed before allocating commercial fishing rights in perpetuity.
   2. The Minister stated in his Preliminary View letter of 22 June 2000 "In regard to kingfish, I acknowledge that the proposed regulatory changes "(removal of the trawl exemption to MLS) "will assist the management of this fishery. However, I am aware that they will not be regarded as sufficient to address some of the issues raised by fishers concerning kingfish. Putting aside the issue of whether or not kingfish should be introduced into the QMS, I would like to receive submissions from stakeholders on other possible management actions that could be taken in the near future to ensure the sustainability of this valuable species. For example, should research be conducted to determine the value of increasing the minimum legal size beyond 65cm?"
   3. The NZBGFC submission to the Minister on the Review of Sustainability Measures that year asked for a "new management approach to the kingfish fishery. Specifically, moving away from Maximum Sustainable Yield (MSY) as a management goal" and developing a harvest strategy based on Optimum Yield. We also asked "that kingfish be managed as a recreational fishery"
   4. The furor over the large kingfish "by-catch" by some pilchard purse seine vessels prompted the Ministry to introduce regulatory controls in that fishery but did not go further and develop a harvest strategy for kingfish.
4. As part of a policy development project at the NZBGFC AGM in 2000 delegates from all 50 clubs represented at that meeting determined that the Council should pursue non-commercial status for kingfish and kahawai.
   Kingfish proposed introduction to the QMS 2003
5. Non-commercial status for kingfish is the preferred management approach because it is a long-lived top predator and an icon species for customary, recreational and tourist fishers. The size of the non-commercial harvest and its economic value is greater than the commercial catch but these values are threatened as the size of kingfish available declines. The Quota Management System (QMS) is good at allocating property rights among commercial fishers but is useless at stopping the fishing out of resident fish around isolated reefs (serial deletion).
6. The recreational harvest of kingfish was estimated in the 1996 National telephone / diary survey to be between 350 and 410 tonnes. The 2000 national recreational harvest survey identified a much higher fisher prevalence than in 1996 and inadequacies in the previous survey technique. Harvest estimates for 2000 are still under review but it seems likely that the recreational kingfish harvest that year was around 800 tones. Add to this the Maori customary harvest and it is clear that kingfish is predominantly a non-commercial fish. It is also clear that the commercial kingfish harvest (range 550 tonnes in 1991-92 to 270 tonnes in 1999-2000) is a very minor component of the total inshore commercial catch.
7. The recreational kingfish fishery is an important contributor to local economies in the Bay of Plenty and Northland and East Cape. There are specialist tourist charter fisheries at White Island, the Bay of Islands and Tolaga Bay in particular and potential for development in other areas. The Ministry contracted an economic survey of recreational fishers (REC9801) that estimated the annual recurrent expenditure on the kingfish fishery at $128 million. This figure does not include the purchase or maintenance of capital items - rods, reels or boats - used in the fishery.
8. A healthy recreational and customary fishery for kingfish in New Zealand is a valuable asset for the country. In our view the economic, social and cultural importance of the non-commercial kingfish fishery is greater than its commercial value. But the quality of the fishery must be maintained by adopting a harvest strategy that allows good numbers of kingfish to reach a metre in length. This is also vital to maintain the productivity of the fishery as 50% maturity of female kingfish is reached at 94 cm (McKenzie et al 2001).
9. The Ministry state in their Final Advice Paper on the introduction of species into the QMS (3 October 2001) that it is Mfish's current policy in relation to non-QMS management to introduce commercially fished species into the QMS. We note that with the introduction of anchovy, sprat and proposed introduction of seaweed and surf clam species the Ministry is also proposing to introduce species that are not commercially fished as well.
10. The Final Advice paper also refers to a number of species - referred to in the Fisheries Act 1996 as "Associated and Dependent Species" - will not be available for commercial harvest (para. 139). Mfish also point out the problems associated with competitive catch limits or Individual Catch Entitlements (ICE). Reading this document it seems clear that it would be difficult and expensive for Mfish to manage kingfish at commercial by-catch only levels (the unmanageable swordfish by-catch is further testament to this) so the simplest, most cost effective solution is to give kingfish non-commercial status, therefore, outside the quota system.
11. The QMS is rights based management system that affords the strongest rights to commercial and Maori commercial interests. The rights of recreational anglers are poor when placed alongside customary and commercial rights. We are currently engaged in a two year process to better define recreational rights. The outcome of this could have a profound effect on the utilisation of all species the public and commercial fishes compete for.
12. Under the QMS commercial rights are issued for large Quota Management Areas (QMA) but it does not generally prescribe where or how the quota may be taken. Given that tagged kingfish are frequently recaptured close to their release site, often on the same reef or headland, recreational fishers are concerned that anyone with quota can target kingfish anywhere in the QMA. Resident populations will be fished out and the commercial fisher will move on to a new area that will in turn be fished out. The QMS does nothing to prevent this sort of serial deletion and in fact may encourage it by permitting commercial targeting.
13. It is the NZBGFC firmly held view that kingfish should be managed as a prime recreational species outside the QMS. We have a proposal addressing this for consideration in the Review of Management Controls for the 2002-03 fishing year.
    Kahawai proposed introduction to the QMS 2004
14. Kahawai are one of the most publicly accessible fish. They are caught in estuaries and river mouths, from wharves, headlands and boats. Surface feeding schools are often located under diving flocks of white-fronted terns. Their accessibility makes kahawai of prime importance to recreational, subsistence and customary fishers.
15. There is plenty of anecdotal evidence of the decline in the abundance and availability of kahawai since 1986. In July 1990 the Ministry produced a discussion document that quoted recreational reports of "significant declines in catch rates, in average sizes of kahawai taken and in sightings of surface schools, particularly over the last two years in Northland, Hauraki Gulf and Bay of Plenty waters." Also "Maori consider that management of kahawai needs to recognise: that kahawai has been traditionally fished by Maori and that Maori share the same concerns about the reduced quality of fishing, sizes of kahawai and catch rates, as stated by recreational fishers. These concerns are still valid.
16. NZBGFC is concerned that past National recreational harvest surveys have under estimated the size of recreational catch and that the stock has been fished down faster than the stock assessment model predicts.
17. Commercial methods such as purse seining, trawling and set netting can be very effective. In areas of high recreational use the public should not have to compete with these methods. The QMS does not address area and method issues. We will continue to support regulations that restrict bulk harvesting methods in key areas of recreational use or juvenile fish habitat.
18. The QMS is rights based management system that affords the strongest rights to commercial and Maori commercial interests. The rights of recreational anglers are poor when placed along side customary and commercial rights. We are currently engaged in a two year process to better define recreational rights. The outcome of this could have a profound effect on the utilisation of all species the public and commercial fishers compete for.
19. The Ministry state in their Final Advice Paper on the introduction of species into the QMS (3 October 2001) that a number of species - referred to in the Fisheries Act 1996 as "Associated and Dependent Species" - will not be available for commercial harvest (para. 139). Mfish also point out the problems associated with competitive catch limits or Individual Catch Entitlements (ICE). Given the decline in the quality and accessibility of kahawai to non-commercial fishers under current catch levels management changes are required. It would be difficult and expensive for Mfish to manage kahawai at commercial by-catch only levels (the unmanageable swordfish by-catch is further testament to this) so the simplest, most cost effective solution is to give kahawai non-commercial status, therefore, outside the quota system.
    Broadbill Swordfish, Shark and Tuna Species proposed introduction to the QMS 2004
20. The tuna longline fishery that catches the majority of these species is the last of the open access, unrestricted fisheries. It has encouraged a lot of new entrants and effort has grown rapidly. In the past 2 years the southern bluefin tuna quota has been caught early and most of the fleet move north for three months to catch bigeye tuna and broadbill.
21. NZBGFC has supported the New Zealandisation of the tuna fish for many years and was involved with negotiating the Billfish Memorandum of Understanding between recreational and commercial sectors. Unfortunately we got to a point in 1999 that the fishing industry refused to listen to our concerns about the targeting of swordfish and we have had to take this issue up with the Minister and Ministry.
22. NZBGFC support the introduction of broadbill, shark and tuna species into the Quota Management System. However we are concerned that solving issues of complying with New Zealand's international obligations, legislative amendments, and probable court action over quota allocation will delay the introduction of a better management framework, possibly for several years. Therefore we have proposed a commercial catch limit for broadbill in the Review of Management Controls for the 2002-03 fishing year.
    

Thank you for the opportunity to make this submission on behalf of our members.

Yours faithfully,

Jeff Romeril
PRESIDENT