Date of submission: 26 July 2007
Submitted to: Ministry of Fisheries
Why the NZCA is submitting
The New Zealand Conservation Authority (the Authority) is established by section 6B of the Conservation Act 1987 (the Act). It has a range of functions primarily derived from the Act and the National Parks Act and the powers to advocate its interests.
The Authority supports the non-proportional option 2 for reducing TAC for both shortfin and longfin in every case.
The Authority welcomes the proposals to reduce TACs for North Island eels. It has long been of the view that the current catch level was too high for the preservation of longfin eels. It has previously sought a more conservative approach to their management.
Paragraph 4 It agrees that TACs for shortfin stocks need to be reduced and, of the two options provided by MFish, supports the reduction of TACs to levels of recent catch.
Paragraph 5 The Authority agrees that TACs for longfin stocks need to be reduced. The Authority thinks that, of the two options provided by MFish, reducing the TAC to levels of about 20% below recent catch is the more appropriate option.
Paragraph 7 The Authority supports recreational allowances being retained at their existing levels while TACCs are reduced (non-proportional approach).
Consideration of management strategy
Paragraph 27 The Authority supports the current strategy i.e. “improve the stock structure (ie, size composition) and abundance of eels over the medium term (10 years), while bringing to a halt any decline in the fishery over the short term.”
Paragraph 28 When dealing with a long-lived species like longfin eels measures to ensure that the fishery is sustainable over the long term will take a long time before they have a beneficial effect or even until the effects are known. The Authority therefore consistently advocates for a precautionary approach be taken to the management of the eel fishery and for a range of measures be taken to achieve a healthy functioning fishery into the future through well-considered integrated management
Other management measures
Paragraph 154 The Authority supports having a maximum size limit for the harvest of freshwater eels across the whole country. However, it considers that the limit of 4kg is not low enough. Because eels, particularly female longfins, are so slow-growing they are exposed to the danger of being harvested for upwards of 20 years before they attain 4 kg. The Authority considers that a lower weight should be the maximum allowable for harvest. To be effective in sustaining the fishery, it considers that ideally that maximum limit should be 1 kg.
The Authority considers that the maximum size should apply to recreational and customary fishery as well as commercial fishery.
Paragraph 156 The Authority is pleased with the approach in 156 and strongly supports an increase in the number of areas reserved from commercial eeling, including the closure of whole catchments and migration pathways.
Paragraph 157 The Authority suggests:
- That commercial eeling is encouraged in rivers upstream from hydro dams which block migration to the sea;
- The stocking of those areas (where migration is blocked) is encouraged through trap and transfer measures; and
- That the take of silver (migrating) eels should be prohibited, rather than relying on best practice to prevent the take of such eels.
The Authority’s first preference would be to see North Island eel TACCs set to a practical level of zero, until there is a better understanding of the eel fishery and the threats to its long-term sustainability and to the preservation of the species in New Zealand.
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