• Hoki is managed as one stock when there are known to be two spawning stocks, East and West. • Hoki fishers have not promoted measures to split the hoki total allowable commercial catch (TACC) or to set a precautionary catch limit for the Eastern hoki stock; • Over-catch of ling, hake and silver warehou on the West Coast of the South Island caused by the hoki catch has not been controlled. Sustainable yields of these species have not been estimated. The assessment claims the “overcatch of quota species is relatively low” (page 23) but, for example, ling 7 TACC was overcaught by 50% in 1998-99. On the West Coast of the South Island the average over-catch for last five years for ling 7 was 138 percent, hake 7 was 114 percent and silver warehou of 121 percent. • Around 1000 fur seals are killed annually by the hoki fishery (see appendix 2). Fur seals populations are around 5 percent of the level they were in 1800 and populations adjacent to the West Coast hoki fishery have declined in recent years (see appendix 3). No steps are being taken to minimise this bycatch despite the development of seal excluder devices over the last 5 years which could be used and trialled in this fishery. • Around 1100 seabirds are caught annually by hoki fishery trawlers (see appendix 1). Over 60 percent of this catch are albatross species - principally white-capped, Buller’s and Salvin’s which are all listed by IUCN as vulnerable threatened species. No steps are being taken to reduce this bycatch. Four of the albatross species and one of the petrel species observed caught in this fishery are recognised as threatened species in the latest IUCN Red list of threatened species (see Appendix 1). On page 12 of the assessment there is a claim that these species are “vulnerable, but not endangered or threatened”. This is a ridiculous claim, the “threatened species” criteria of IUCN includes “critically endangered”, “endangered”, and “vulnerable” (see www.redlist.org). Any species finally and authoritatively tested by IUCN as vulnerable is a threatened species. • There is no strategic assessment of the environmental effects of the fishery nor is there an assessment of the impacts on non-target species or information to comply with the full requirements of the Fisheries Act 1996. • There is no agreed management plan for the fishery. The Hoki Fishery Management Company Ltd (HFMC) plans have not been discussed with other stakeholders nor have they any status under the Fisheries Act 1996, the Wildlife Act or the Marine Mammals Protection Act. • The HFMC have not got procedures to enforce resolutions of disputes. As stated in the assessment document “there is limited evidence shown of effective implementation of the HFMC agreed procedures. The link between the HFMC and its members are weak to compel compliance in part due to the voluntary nature of the membership.” (Indicator 3D).
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