Submission on the introduction of kingfish into the QMS
Overview
Management context
5.The Minister and Ministry must be aware that all of this effort is part of a longstanding concern over the decline in quality of the kingfish fishery and the importance of kingfish as a non-commercial species.
6. There is no current commercial catch limit on kingfish. Commercial landings of kingfish were totally unconstrained until the MLS was introduced in 1993 and even then the main method of capture (bottom trawl) was exempt until December 2000.
7. Regulations introduced in 1991 prohibiting the targeting of non-QMS species unless the species is authorised on a fisher’s permit were ineffectual. We have seen with swordfish that the Ministry’s ability to limit catch or enforce non-target status for species is non-existent. It is the same with kingfish.
8. A few permit holders were authorised to target kingfish, and most of their catch was taken using set-nets. In 1990-91 (before the restricted targeting regulation) the set-net catch was 85 tonnes by 1992-93 the set-net catch had increased to 278 tonnes a 327% increase (McKenzie et al). A large part of this period is used to determine Provisional Catch History (PCH) for fishers. It is only in the last two years that the MLS has applied to all commercial methods and the pseudo-targeting with set-nets has died down. Recreational fishers are now concerned about a new method with the potential to catch whole schools of kingfish that is appearing in the catch records – midwater trawl.
Implications for management of kingfish
9. NZBGFC do not agree that current catch is best represented by the average of 9 years commercial catch that includes seven years with no MLS on trawl caught fish and significant pseudo-targeting with set-nets.
10. Commercial fishers were unaware of which years would be used for setting Provisional Catch History (PCH) until the Fisheries Act 1996 was drafted. Between 1993 and 1995 there were still incentives for fishers to target non-QMS species in a "race for quota". It is incorrect for the ministry to claim ‘using average commercial landings for the period between 1993 and 2002 as this period provides the best available information on current levels of commercial utilisation.’ (para. 38) The only valid years to use as the current level of commercial utilization are 2000-01 and 2001-02 when the MLS applied to all methods. The Minister should use the most recent fishing year as the estimate of current commercial catch as outlined in the table on page 13 of the IPP
11. The argument for increased utility is at first appealing but in the context of all the fisheries in New Zealand it as a double edged sword that could be used to reduce recreational rights to species with a high export value. In the case of kingfish there is little comparable data on values and no data on stock size, so it is hard to make a case based on utility alone. What is undeniable is that kingfish is a very important recreational target fishery (600 to 800 t) and a relatively minor commercial bycatch fishery (200 to 300 t from an inshore fishery of tens of thousands of tonnes). NZBGFC would prefer the Minister to use clear policy statements about the future of the kingfish fishery to direct management change, such as:
Total Allowable Catch and allocation options
12. NZBGFC supports the objective of managing this fishery above the biomass that will support MSY. This can only be achieved by reductions in harvest that will in fact see recreational and commercial fishers taking less kingfish.
13. Feedback from members indicates that customary harvest is not currently high and the allocation, under all options, allows for potential increases in harvest for customary purposes.
14. It is time the ministry made an effort to finalize the results of the 2000 recreational harvest survey instead of shunting them from one Fisheries Working Group to another. In the absence of an agreed estimate for kingfish the Ministry is recommending recreational and customary allocations based on wild guesswork alone.
15. MFish said ‘The uncertainty revolves around the participation rates of recreational fishers used in each survey. Those for 1999-2000 may be too high and those for 1996 may be too low.’ (Annex One para. 12) Using the average of the two estimates is a gross over simplification of the situation that has been the focus of expensive follow up surveys, independent expert advice and several meetings. An error in the 1996 survey allowed for many refusals to participate in the survey to be counted as non-fishing households. On the other hand Professor Kearney from Australia reported that harvest estimates in the 1999-2000 survey had to be self adjusting for the number of non-fishers included in the survey.
16. Under MFish’s Proportional Option the TACC (which they claim is 20% less than the current catch) will still be higher than the catch in 2001-02, which is the first full fishing season where the MLS applied to all methods. See Table 1. This "Claytons" reduction is not acceptable to recreational fishers.
Table 1. Allowances under the Ministries proportional option.
Stock Commercial Catch
2001-02 Proposed TACC Additional mortality
commercial Proposed recreational
allowance Additional mortality
recreational Customary allowance Proportional Proportional KIN1 98 119 22 460 31 76 KIN2 61 72 22 66 4 18 KIN3 1 1 1 1 KIN4 1 1 1 KIN7 8 7 1 10 1 2 KIN8 54 39 5 31 2 9 KIN10 1 Total 222 240 50 569 38 107 % of 2001-02 100% 108%
17. All the real reduction in catch under the Proportional Option would still be borne by the recreational and subsistence fisher with the size increase of 65 cm to 75 cm MLS. It is estimated that this size increase would reduce the number of kingfish currently landed by recreational fishers by 45%. Also a 65 cm kingfish is on average 3.7 kg while a 75 cm kingfish is much larger, at 5.5 kg (a 50% increase in size). A 75 cm size limit will significantly change the number and size of fish that recreational fishers can take. Therefore this option is not "proportional" at all.
18. The only option proposed that actually reduces the current commercial catch is the Reallocation Option. Even with this option the contribution made by commercial fishers to the rebuild is just 19% of the 2001-02 catch. (Table 2)
Table2. Allowances under the Ministries Reallocation Option
|
Stock |
Commercial Catch 2001-02 |
Proposed TACC |
Additional mortality commercial |
Proposed recreational allowance |
Additional mortality recreational |
Customary allowance |
|
Reallocation |
Reallocation |
|||||
|
KIN1 |
98 |
80 |
15 |
504 |
33 |
76 |
|
KIN2 |
61 |
50 |
16 |
92 |
6 |
18 |
|
KIN3 |
1 |
1 |
1 |
1 | ||
|
KIN4 |
1 |
1 |
1 | |||
|
KIN7 |
8 |
7 |
1 |
10 |
1 |
2 |
|
KIN8* |
54 |
39 |
5 |
31 |
9 | |
|
KIN10 |
1 |
|||||
|
Total |
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