Republic of Namibia Ministry of Fisheries and Marine Resources DRAFT. Management Plan for the Namibian Hake Fishery

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1 Republic of Namibia Ministry of Fisheries and Marine Resources DRAFT Management Plan for the Namibian Hake Fishery for the period May 2011 to April March 2011

2 Foreword The hake fishery is the most valuable fishery in Namibia. It generates almost half of the final value of all Namibian fisheries. The fishery is the largest provider of employment in the fishing industry and generates a considerable amount of foreign currency. It is vital for Namibia as a nation to manage this fishery properly. In particular we need to ensure the responsible and sustainable utilisation of the resource itself. Without the hake, there will be no industry, no employment and no benefits to Namibia. This management plan brings together in one document all of the relevant policies for the hake fishery. It explains how we will manage the hake fishery during the next few years and identifies where we would like the fishery to be in the future. The plan outlines the goals we have for this fishery, using Vision 2030 as its basis, and sets objectives and strategies for us to achieve these goals. The development of this management plan represents a new beginning in our fisheries. Most of our policies were created when Namibia was a new nation. When we had no local fishing industry to speak of. At that time we needed to set in place a fisheries management system that would create a Namibian fishing industry. An industry that would contribute significantly to the Namibian economy, both through income and employment. An industry that would bring valuable foreign exchange into our country. This we have successfully done. We have put in place a management system in Namibian fisheries that is praised by most outside observers, and the hake fishery is no exception. In spite of our success, the time has come to look carefully at our policies and review them. There is no doubt that the current policies have achieved many of the objectives that were set out in the beginning. In fact, I am of the opinion that given the situation at Independence, these policies were excellent. However, 21 years have passed since our Independence. We are not the same country as back then. The hake industry is not the same industry as back then. We have developed. Therefore, the policies that have served us well in the past may not be the best policies for our future. The development of the management plan for the hake fishery represents the first step in our assessment of our policies as they relate to the hake fishery. It will give us an overview of the fishery, allowing us to identify gaps in our policies and areas that may need adjustment and improvement. Once the plan is in place we will begin assessment of the policies. Are they in fact achieving what we want them to achieve? Once we have answered that question we will look for ways to improve our policies and our management plan. This is a long term process. In fact it will never end as our environment constantly changes. Honourable Bernard Esau Minister of Fisheries and Marine Resources DRAFT Management Plan for the Namibian Hake Fishery

3 Acknowledgements The preparation of this management plan for the Namibian hake fishery was funded by the 9 th cycle of the European Development Fund (EDF) Strengthening Fisheries Management in ACP Countries (9 ACP RPR 12), known as ACP-Fish II, project CU/PE1/MZ/10/005. The compilation of the plan was undertaken by Vilhjálmur Wiium and Dave Boyer on behalf of NFDS Africa. We would like to acknowledge the cooperation and interest from the Namibia Hake Association and other members of the fishing industry, and the many other stakeholders who participated in the workshops and consultative meetings. The Honourable Minister gave personal guidance which we appreciate greatly. Personnel of the Ministry of Fisheries and Marine Resources provided valuable inputs, guidance and information to the consultants. In particular, our thanks go to Anna Erastus, Titus Iilende, Carola Kirchner and the Technical Team from the Ministry: Lucia Haufiku, Paul Kainge, John Kathena, Sam Goreseb and Victor Pea. DRAFT Management Plan for the Namibian Hake Fishery

4 Table of contents Foreword... i Acknowledgements... ii List of tables... v List of acronyms... vi 1 Purpose Current situation Biology of hake Distribution Spawning Diet and predation Growth Influence of the physical environment on hake Stock Assessment TACs and harvesting levels The fishing industry Holders of exploitation rights Fishing fleet Employment Hake bycatch in other fisheries Bycatch of other species in hake fishery Processing and marketing Current management measures Management goals and objectives... 9 Goal 1: Responsible and sustainable utilisation of the hake resource Objective 1.1: Recovery of the hake stocks to the MSY level Objective 1.2: Management measures based on best available scientific evidence Objective 1.3: New assessment of the hake stocks Objective 1.4: Sufficient institutional capacity, skills, equipment and funding Goal 2: Minimal impact on the ecosystem Objective 2.1: Maintain biodiversity and ecosystem functioning Objective 2.2: Minimise bycatches including incidental mortality of non-commercial species Objective 2.3: Mitigate habitat and substrate damage Objective 2.4: Sufficient institutional capacity, skills, equipment and funding Goal 3: Stable business environment established conducive to the promotion of economic efficiency Objective 3.1: The hake industry can respond effectively to external changes Objective 3.2: Appropriate investments are undertaken by the industry Objective 3.3: Promote increased level of value addition by hake fishing and processing companies. 24 Goal 4: Hake fishery benefits a large number of Namibians, directly and indirectly Objective 4.1: Quota fees provide revenue to government Objective 4.2: Hake industry provides sustainable and quality employment to Namibians Objective 4.3: Increased Namibian ownership in the hake industry Objective 4.4: Support to community initiatives encouraged Goal 5: Efficient, cost-effective and participatory management of the hake fishery Objective 5.1: MFMR provides the required management services cost-effectively Objective 5.2: Consultations with stakeholders and wider community Objective 5.3: Industry contributes to research and compliance Objective 5.4: Management measures are complied with Summary of research and reviews DRAFT Management Plan for the Namibian Hake Fishery

5 4 Summary of management measures Total allowable catch Limited entry into fishery Quota system Fees Technical measures Management capacity Response of management Review of the management plan Bibliography DRAFT Management Plan for the Namibian Hake Fishery

6 List of tables Table 1: TACs and landings of hake, (tonnes)... 5 Table 2: Allocation of hake quotas to others (tonnes)... 6 Table 3: Hake as bycatch, (tonnes)... 7 Table 4: Exports of hake, country shares Table 5: Strategies for Objective 1.1: Recovery of the hake stocks to MSY level Table 6: Strategies for Objective 1.2: Management measures based on best available scientific evidence.. 13 Table 7: Strategies for Objective 1.3: New assessment of the hake stocks Table 8: Strategies for Objective 1.4: Sufficient institutional capacity, skills, equipment and funding Table 9: Strategies for Objective 2.1: Maintain biodiversity and ecosystem functioning Table 10: Strategies for Objective 2.2: Minimise bycatches including incidental mortality of noncommercial species Table 11: Strategies for Objective 2.3: Mitigate habitat and substrate damage Table 12: Strategies for Objective 2.4: Sufficient institutional capacity, skills, equipment and funding Table 13: Strategies for Objective 3.1: The industry can respond effectively to external changes Table 14: Strategies for Objective 3.2: Appropriate investments are undertaken by the industry Table 15: Strategies for Objective 3.4: Promote increased level of value addition by hake fishing and processing companies Table 16: Strategies for Objective 4.1: Quota fees provide revenue to government Table 17: Strategies for Objective 4.2: Hake industry provides sustainable employment to Namibians Table 18: Strategies for Objective 4.3: Increased Namibian ownership in the hake industry Table 19: Strategies for Objective 4.4: Support to community initiatives encouraged Table 20: Strategies for Objective 5.1: MFMR provides required management services cost-effectively Table 21: Strategies for Objective 5.2: Consultations with stakeholders and wider community Table 22: Strategies for Objective 5.3: Industry contributes to research and compliance Table 23: Strategies and performance indicators for Goal 5 objectives Table 24: List of research and reviews Table 25: Important milestones regarding review DRAFT Management Plan for the Namibian Hake Fishery

7 List of acronyms BCC Benguela Current Commission BCLME Benguela Current Large Marine Ecosystem Programme BENEFIT Benguela Environment Fisheries Interaction and Training Programme CPUE Catch per unit effort DOP Directorate of Operations DPPE Directorate of Policy, Planning and Economics DRM Directorate of Resource Management EAF Ecosystem approach to fisheries management FAO Food and Agricultural Organization of the United Nations FCPT Fish Consumption Promotion Trust FOA Fisheries Observer Agency IMP Interim management procedure IQ Individual quota ITQ Individual transferable quota MCS Monitoring, control and surveillance MFMR Ministry of Fisheries and Marine Resources MSY Maximum sustainable yield NAMFI Namibian Maritime Fisheries Institute NHA Namibian Hake Association NPOA National plan of action OMP Operational management procedure SADC Southern African Development Community TAC Total allowable catch VMS Vessel monitoring system DRAFT Management Plan for the Namibian Hake Fishery

8 1 Purpose A prosperous and industrialised Namibia, developed by her human resources, enjoying peace, harmony and political stability is the Vision of Namibia for 2030 (Office of the President 2004). The sub-vision for marine resources states that by 2030 Namibia s marine species and habitats significantly contribute to the economy without threatening biodiversity or the functioning of natural ecosystems, in a dynamic external environment. This management plan sets goals, objectives and management measures for the hake fishery that should bring Namibia closer to the above sub-vision during This includes three fishing seasons, from May 2011 to April The management plan brings together in one document the relevant legal provisions and policies that currently govern the management of the hake resource. In the development of this plan, no significant changes in policy were made. However, the plan highlights issues that need reviewing and further evaluation during the plan s time frame and beyond. Access to the hake resource comes with certain obligations for the right holders regarding the proper management and care of the resource and the environment. Where appropriate, these obligations are set out in this management plan. While the recovery and long term sustainability of the hake resource is the first priority of the plan, additional goals relate to ecosystem management; to establishing a stable business environment promoting economic efficiency; to ensuring that benefits from the hake fishery accrue to a wide number of Namibian nationals; and to providing cost effective and participatory management of the hake fishery. Consequently, this plan is an important step in the direction of an ecosystem approach to fisheries management (EAF). It should be kept in mind that sometimes these goals contradict each other, in which case compromises need to be made. The plan refers to the hake resource as two separate stocks as one of the important objectives during the coming years is to assess and manage the two species separately. This is the first management plan for the hake fishery. It has two main aims. Firstly, to bring together in one plan all the current management measures and policies that apply to the hake fishery. These measures and policies are currently found in different documents, making it hard to obtain an overview of the fishery and its management. Secondly, to identify aspects of the current management measures and policies that need attention and perhaps improvement in the coming years. In order to incorporate many of the management measures discussed in this plan a number of reviews and investigations are needed to identify the most appropriate strategies. This is entirely to be expected and as the plan evolves, particularly at the nominated review dates, more specific management measures, indicators and time frames will be incorporated. The following section (Chapter 2) briefly describes the status of knowledge of the hake stocks, some important aspects of the industry and the current management strategies. Chapter 3, the core section of this document, defines five goals; each goal having a number of objectives. These objectives set out several strategies and key performance indicators to allow for assessment of whether management objectives are being achieved. Chapter 4 summarises the main management measures and any new actions that will be required to achieve the defined goals. Chapters 5 and 6 set out the time frame of the plan, including the review process, and describe the procedure to be followed if any performance indicators are not being achieved. Hake Management Plan Page 1

9 2 Current situation This section of the management plan gives a brief synopsis of the current situation in the fishery, providing a historical background as needed. Much of the biological information was taken from MFMR 2010; the data on the fishery coming from the annual reports and the economic model used to calculate the contribution of the fishing sector to the gross domestic product. 2.1 Biology of hake Three species of hake occur in Namibian waters: Cape hake (Merluccius capensis), deep-water hake (M. paradoxus) and Benguela hake (M. polli) 1. Benguela hake has a maximum total length of 80 cm, but Namibia is at the extreme southern limit of its distribution where only much smaller fish occur. The industry has no interest in this species and it is therefore not included in this management plan Distribution The two species of commercially important hake occur on the continental shelf in Namibian waters: Cape hake at depths from about 100 m to 350 m, overlapping with the shallow end of the distribution range of deep-water hake, which occurs mainly at depths of 300 m to 600 m. Both species occur in Namibian and South African waters, but the degree of stock separation, if any, is unclear. In particular, it has been suggested that deep-water hake is shared with South Africa as there is no recent evidence of this species spawning in Namibian waters. The transboundary nature of this species is the subject of a cooperative research project between Namibia and South Africa, previously under BCLME and BENEFIT and now under BCC. The distribution of Cape hake extends into southern Angola, but the portion of the stock is believed to be small and the impact on the stock of any catches is likely to be limited Spawning Spawning of Cape hake occurs primarily in winter, mainly between 100 m and 400 m depending on environmental conditions. Juvenile fish are pelagic, becoming demersal at about 2 years of age (at around 23 cm total length). Deep-water hake has not been recorded spawning in Namibian waters (Kainge et al. 2007) Diet and predation Hake are piscivorous, feeding on a range of fish species. No data on diet from the pre- Independence period exists, but a comparison between the recent diet of hakes in South Africa, where the small pelagic stocks of sardine and anchovy are still abundant, and Namibia show a larger component of small pelagics in South Africa. In Namibia a greater proportion of lower quality fish are eaten, such as gobies. This suggests that the diet of Namibia hakes may, historically, have contained more small 1 Note that M. capensis and M. paradoxus are sometimes referred to as shallow-water Cape hake and deep-water Cape hake, respectively. Hake Management Plan Page 2

10 pelagics, which with their higher energy content (per gram) may have allowed higher productivity faster growth, better survival and higher levels of recruitment. The effects of predation on the hake stocks is largely unknown. This is likely to be low for adult hake, being top predators themselves, but juvenile hake are more susceptible and are known to be preyed on by a range of fish and mammals, including seals and adult hake (cannibalism) Growth Hake may grow to more than 100 cm in length, although the largest found since trawl surveys started in 1990 was 92 cm, but hake of up to 112 cm are still being landed by long-line boats. Both species may live up to 12 years, but few of that age are found in trawler samples. Cape hake and deep-water hake grow at different rates. Males mature earlier than females in both species and have a lower average maximum length and a higher growth rate. According to the latest trawl survey results (2010), 50% of the Cape hake population reaches maturity at about 21 cm, as compared to 35 cm for deep-water hake, at 1.7 and 2.5 years respectively (but see next paragraph). There is a large amount of annual variation in growth, possibly caused by feeding conditions or by environmental factors. Growth and maturity may also vary with species abundance. Current age validation research suggests that the age of Cape hake has previously been overestimated and hence growth underestimated. This work still needs to be peer-reviewed, but if accepted means that Cape hake at least are shorter-lived and faster growing than reported above (Wilhelm pers. comm.) Influence of the physical environment on hake A regime shift is believed to have occurred in the northern Benguela during the 1980s and 1990s, at least partially driven by fishing. Very low biomass levels of exploited fish stocks associated with changes in the transfer of energy between predators and prey may have resulted in a less efficient energy transfer (Cury and Shannon 2004). This is believed to have reduced the productivity of top predators such as hake (Roux pers. comm.) Being demersal fish the adult portion of the stocks are partially buffered from most environmental anomalies, which generally have the highest impact on the inshore and near-surface pelagic zone. It is generally accepted that the low oxygen event in the central area of the Namibian shelf had a negative effect on both demersal and pelagic fish stocks. While no clear link has been established between the occurrence of Benguela Niños (warm and saline surface water intrusions) and the productivity of adult hake, pre-recruits were severely affected during the 1995 Benguela Niño through poor growth and high natural mortality. The impacts of climate change are currently unknown and various scenarios are possible. These range from a decrease in upwelling, and hence productivity, of the system, through to an increase in upwelling and productivity. An increase in the frequency and severity of adverse conditions, such as Benguela Niño events, is also considered likely. It is probably safe to speculate that any changes will have severe effects on the Namibian fishing industry, although predicting which sectors will be most affected is difficult. Hake Management Plan Page 3

11 2.2 Stock Assessment An important aspect of the current approach to stock assessment is that the two hake species are treated as a single stock, since separate data for the two species has only been collected during research surveys since Catch, and hence the commercial catch rate data, is not differentiated between the two species, although the proportion of each species, and their length frequency, has been recorded from sampled catches by on-board fisheries observers since Given that growth and maturity rates are significantly different for the two species this is far from ideal. During the years 1991 to 1996, hake TAC recommendations were based on the biomass estimated by annual combined swept-area/acoustic research surveys. It was assumed that these surveys estimated the absolute abundance of Namibian hake and a recommended TAC was calculated as 20% of the fishable biomass 2. This resulted in the TAC increasing from t in 1990 to t in Between 1997 and 2000 TAC recommendations were based on an Interim Management Procedure (IMP); this adjusted the recommended TAC up or down depending on trends in the research survey and the commercial CPUE data. This procedure was introduced at a time when there was great uncertainty about the status of the hake resource. This IMP should have been replaced in 2001, but the process of developing and testing a new procedure was not completed. Therefore, the TAC recommendation for the 2001/02 season was based on an assessment which looked at the effect that different catch levels were predicted to have on the future state of the stock. Note that until 1999 the hake fishing season followed the calendar year. In 1999 the fishing season was changed, starting on 1 May and ending 30 April the following year. The TACs for the 2002/03 to 2004/05 seasons were based on an Operational Management Procedure (OMP). From 2005/06 to 2008/09, the recommended TACs were based on an age-structured production model with future projections of the stock status using various models and assuming different levels of catch. The recommended annual TAC was t in 2006/07, decreasing to t by 2009/10, but the actual TACs were set at a constant level of t for three seasons. Since 1997 the main population indicators estimated were virgin biomass, current biomass, MSY and depletion. Due to the imprecise (and in some cases unreliable) data and different methods used to calculate these, large year-to-year variations in recommended TACs made decision-making a difficult task. Since 2008, a reference year of 1990 has been used as a baseline, this being the first time that reliable data became available. Although, the absolute abundance of the stock in 1990 is unknown, it is well-recognised that the resource was in a critical state at that time. Since 2009 the stock was again evaluated using an age-structured production model. As with the OMP this model integrates all the available reliable information from both the commercial fishery and the research surveys on the state of resource: historic catches, indices of abundance, age and length composition data, but calculates the likely yield, on which TAC recommendations are based. In addition seal scat information provides an index of recruitment. Despite the fact that the stock was assessed at 2 Note that fishable biomass refers to fish larger than 35 cm total length and is a management term. Spawning biomass, a biological term, refers to Cape hake larger than about 21 cm and deep-water hake larger than 35 cm when 50% of the fish reach maturity; these lengths refer to 2010 and vary according to environmental and other conditions. Hake Management Plan Page 4

12 being around 90% of the 1990 biomass, the TAC was increased to in 2009/ TACs and harvesting levels Table 1 gives an overview of TACs and landings in the hake fishery from the 1990 fishing season. Note that until 1999 the hake fishing season followed the calendar year; then the season was changed, starting on 1 May and ending 30 April the following year. However, in the tables below landings are reported for the calendar year, making comparison with the TAC problematic after The landings data reported here come from the economic model used to calculate official national account statistics as published annually by the National Planning Commission. Table 1: TACs and landings of hake, (tonnes) Season TAC Year Landings (to May) / / / / / / / / / / / Analysis of the fishing seasons between 2002/03 and 2009/10 shows that on average about 10% of the annual quota allocated to the hake industry remained uncaught; ranging from 81.1% in 2005/06 to 99.3% in 2003/ The fishing industry Holders of exploitation rights Currently, 38 companies hold rights of exploitation for hake. Of these 24 companies are fully Namibian owned and only one has less than 50% Namibian ownership. That company is in fact fully foreign owned. 3 See Kirchner & Ianelli (2010) for more information on stock assessment of hakes. Hake Management Plan Page 5

13 In addition to the hake right holders, small amounts of hake (as shown in Table 2) are also allocated to large pelagic right holders, for research, to the Fish Consumption Promotion Trust and to Lüderitz Town Council. Table 2: Allocation of hake quotas to others (tonnes) Recipient of quota 2008/ /10 Large Pelagic Right Holders Research Fish Consumption Trust Lüderitz Town Council Total , Fishing fleet The hake fishing fleet consists of three different types of vessels. Firstly, there are freezer trawlers which have processing facilities onboard. In most cases their catches are exported directly without any additional processing on-shore. Secondly, wet-fish trawlers land their catches for further processing on-shore. Thirdly, long-line vessels target larger fish which are exported fresh to European markets. The long-line catches are a relatively small share of total catches, averaging 5.5% from 1998 and never exceeding 8%. The number of vessels licensed to harvest hake fluctuates year from year, during the past few years varying from 78 to 121 vessels. However, since vessels are often only licensed for a part of the season these figures do not reflect the actual effort used. In fact, vessels are often licensed, but not used for harvesting (Kirchner 2010). During the 2009/2010 fishing season, 62% of the wet-fish trawlers are older than 30 years, with 64% of the freezer vessels also falling into that category. The long-line fleet was somewhat younger, with an average age of 25, although 33% were older than 30 years. Little renewal of vessels has taken place in recent years, resulting in a fleet that is inefficient in many respects. The Fisheries and Aquaculture Conference held in Swakopmund in 2008 recommended that it was imperative to address the problem of Namibia s aging fleet (MFMR 2008). Since the hake fishery is managed with quotas, effort is not usually considered a major concern for the management of the fishery. It is normally logical for the fishing companies to minimise the effort they use to catch their quota by adapting the effort to the quota allocated to them. However, as quota allocation depends partly on the level of investments, including in vessels, some excess capacity has developed Employment The hake industry is the major provider of employment in the fishing sector, employing around people in the 2008/2009 fishing season (MFMR 2009b). The numbers employed on fishing vessels has decreased slightly during the past six years, but this has been more than compensated by number of people working on-shore. About 98% of people working in the hake industry are Namibians and 44% are women. Of the total, 95% have permanent jobs in the industry. It is worth noting that even though the TAC has been highly variable in recent years, for example falling by 27% in 2006, employment has remained relatively stable (MFMR 2009b). Hake Management Plan Page 6

14 2.4.4 Hake bycatch in other fisheries Small amounts of hake are caught as bycatch in other fisheries as shown in Table 3. Table 3: Hake as bycatch, (tonnes) Fishery 2007/8 2008/9 Monk Mid-water Orange Roughy 27 0 Total Bycatch of other species in hake fishery The hake fleets catch other commercial species, including orange roughy and horse mackerel. By far the greatest amount is monk. Between 1994 and 2001 the average catch was around tonnes, representing almost 30% of the total monk catch. However, monk as a percentage of the hake caught is relatively trivial, generally less than 3% Processing and marketing In the first years following Independence all hake catches were taken by freezer vessels, processed at sea and exported directly without any on-shore processing. However, soon policies were introduced aimed at reducing offshore processing and giving priority to the more labour intensive on-shore processing. These policies had the desired effect, resulting in ever decreasing proportion of the catch processed at sea. As the proportion of on-shore processing has increased, the number of factories has also increased. Twenty years after Independence sixteen factories in Lüderitz and Walvis Bay process hake with an overall capacity of over tonnes per year. Namibian hake products are primarily exported to Europe, with Spain traditionally being by far the largest market. However, due to the recent financial crisis in Spain, the exports have reduced drastically since 2007 with a greater proportion going to South Africa and Italy. Table 4: Exports of hake, country shares Country Spain 71% 61% 49% South Africa 12% 16% 24% Italy 2% 4% 14% Other countries 15% 19% 13% Total 100% 100% 100% 2.5 Current management measures The management of the hake fishery consists of a combination of exploitation rights, TACs, individual quotas (IQs), quota fees, bycatch fees, a number of technical measures, and a comprehensive MCS and observer system. The backbone of Namibian fisheries management is the right of exploitation. Anyone not holding a right is strictly forbidden from fishing in Namibian waters. Rights are issued for different time periods, ranging from seven to twenty years, depending on Hake Management Plan Page 7

15 various factors specified in the Marine Resources Act, 2000, such as level of Namibian ownership, investments and fishing experience. TACs are set in order to ensure that the fishery is sustainable. These are determined annually and are based on a comprehensive scientific assessment of the state of the stocks. Recommendations from DRM are considered by the Marine Resources Advisory Council who make their own recommendations. Both sets of recommendations are forwarded to the Minister, who then sets the TAC. IQs are allocated in order to ensure economic viability of the fishing industry. Quotas are issued to right holders and can be caught by any vessel licensed to fish in Namibian waters. These quotas are not permanently transferable, but can be leased between right holders within a fishing season. Even if leased, it is the original right holder that is responsible for the use of the quota and payments of fees. Right holders must pay quota fees on the quota allocated to them. This represents the resource rent and must be paid regardless of whether the quota is caught or not, thus encouraging rights holders to make full use of their allocated quota. Quota fees have proved an effective management tool to achieve a number of government objectives. Firstly, the level of the fee is constructed in such a way that those utilising Namibian vessels pay lower fees than those utilising foreign vessels. Secondly, hake rights holders using Namibian vessels carrying over 90% Namibian crew pay a more favourable fee than those using crews that are less Namibian. Thirdly, to promote local employment, fish landed for on-shore processing is subject to lower quota fees than fish processed at sea. During a fishing trip, a vessel can only carry a quota for one species. Any other species that is caught is labelled bycatch and a penalty fee must be paid on any such harvest. The bycatch fees are carefully constructed, recognising that some bycatch will always be taken, so some bycatch is exempt from the fee. However, once the fee comes into effect, it creates a considerable incentive to reduce the level of bycatch, but without encouraging discarding. Various technical measures are in place, first and foremost with the aim of protecting the hake resource and the environment. These measures specify the allowed fishing gear for the harvesting of hake. For instance, a bottom trawl may not have a cod-end mesh size under 110 mm, while area and time closures are used primarily to protect spawning grounds. All hake vessels have been banned from fishing within the 200 m depth line since the early 1990s in order to protect both the small pelagic stocks and juvenile hake. More recently this has been extended south of 25 ; since 2006 wet-fish vessels have been banned from fishing within the 300 m isobath, and freezer vessels within 350 m, to protect juvenile hake. Since 2006, fishing for hake is not allowed during the month of October, once again to protect juvenile hake which are perceived to move offshore, and so become mixed with the adult fish, at that time. A full list of technical measures, such as these, are published in relevant regulations and licences and will not be listed in this management plan (see MFMR 2001). Finally, all Namibian vessels must carry an observer on board when fishing. The primary role of the observer is to monitor that the at-sea provisions of the Marine Resources Act and Regulations are adhered to. For instance, it is forbidden by law to discard fish, so all fish caught must be landed and it is the observer s role to report any discarding that may take place. The observers also play an important role in collecting scientific information, primarily length frequency data, of catches. Hake Management Plan Page 8

16 3 Management goals and objectives The mission of the Ministry of Fisheries and Marine Resources is to responsibly manage living aquatic resources to continuously ensure a conducive environment for the fishing and aquaculture sector to prosper (MFMR 2009). This mission statement and MFMR s core values of transparency, accountability, equity, honesty, loyalty and diligence form the foundation for the goals and objectives outlined in this management plan. In the plan the more general laws, regulations and policies of the Namibian government relating to marine resources provide the basis to many of the specific objectives for the hake fishery. In addition, Namibia is a party to a number of regional and international legal instruments and agreements. These include the United Nations Convention on the Law of the Sea, 1982, the United Nations Fish Stocks Agreement, 1995, the FAO Compliance Agreement, 1993, the Code of Conduct for Responsible Fisheries and its associated International Plans of Action and the SADC Regional Protocol on Fisheries, the 2001 Reykjavik Declaration on Responsible Fisheries in the Marine Ecosystem and the Rio (1992) and Johannesburg (2002) declarations on sustainable development. These have all been considered in the development of this management plan. While the plan is specifically designed for the hake fishery, due cognisance is taken of the EAF (FAO 2003). The incorporation of the EAF into a fisheries management system should typically be an iterative process, building on the existing system. This plan is a first step in this process and an important objective for the first revision of the plan (in 2014) should be to have reviewed the management system such that the EAF can be more fully integrated at that point in time. The BCC will play an important role in this regard (BCC 2010). Indeed, for the forthcoming 5 years, the BCC has an ambitious suite of projects planned, although to be successfully achieved a large commitment from MFMR will be required. It is not clear whether DRM and PPE have the capacity to fully participate in this work. MFMR will still remain responsible to implement any of the outputs from these projects. As noted above, a considerable amount of biological and ecological research is currently being directed at hake. The plan includes many of these studies as strategies to provide information on the most appropriate measures for the management of the hake stocks. As these studies are completed the plan will be updated to include the recommendations as strategies with precise indicators and time frames. The management of the hake fishery is already well developed in Namibia and this plan records the existing structures and measures. Some inconsistencies were identified by MFMR and other stakeholders and these are either aligned or reviews are recommended. A number of changes were also proposed during the consultation process and reviews to investigate these have been included. The five major management goals for the hake fishery are the following: 1. Responsible and sustainable utilisation of the hake resource. 2. Minimal impact on the ecosystem. 3. Stable business environment conducive to the promotion of economic efficiency. Hake Management Plan Page 9

17 4. Benefits from the fishery accrue to a large number of Namibians, both directly and indirectly. 5. Efficient, cost-effective and participatory management of the fishery. Sometimes these goals contradict each other. For instance, increasing quota fees in order to increase the benefits accruing to Namibians as a whole, may negatively impact the business environment. Also, increased employment often results in decreased efficiency, which in turn means lower taxes and resource rents accrue to the government (e.g., Kirchner 2010). This highlights the need for prioritisation allowing informed decisions to be taken. However, the recovery and sustainable utilisation of the hake resource is first priority. For each goal a number of objectives have been identified. A set of strategies is linked to each objective to ensure that the objectives are pursued effectively during the time frame of the management plan and beyond. Each objective has an associated indicator or output which will show whether the strategy has been completed successfully. Hake Management Plan Page 10

18 Goal 1: Responsible and sustainable utilisation of the hake resource The hake stocks yielded annual catches in excess of tonnes for most years between 1967 and 1988, the level calculated to have been the sustainable yield. The hake stocks are currently assessed as being overexploited 4 and indeed even below the biomass at Independence in 1990, which at that time was considered to be an historic low. There are some indications of a slight recovery in the Cape hake stock since The decline of the hake stocks in the decades between the mid-1960s and 1990 is believed to be primarily due to prolonged annual catches in excess of the sustainable yield level and up to t in 1973 (unofficial reports suggest that the catches were considerably higher); depletion of many of the key prey species, especially the small pelagic stocks of sardine and anchovy; and possibly a change in the ecosystem functioning. The reasons for the failure to recover during the past two decades are less clear. TACs set above the recommended levels (catch was higher than estimated yield in 10 of the past 20 years), partly due to a lack of data and hence uncertainties in the assessments, may have been compounded by ecosystem anomalies resulting in high levels of juvenile mortality and subsequent poor recruitment. The lack of high quality prey seems to have forced the hake to switch to other lower quality food types such as gobies, which together with increased levels of cannibalism, may have further contributed to the lack of a recovery of the stocks. It is highly unlikely that catches of historical levels will be achievable in the future; the functioning of the ecosystem is believed to have changed, and as a result the productivity of the hake stocks may have been reduced. Preliminary assessments suggest that sustained catches in the order of t may be the maximum possible. Four broad objectives are defined which it is believed will lead to the achievement of this first goal. Objective 1.1: Recovery of the hake stocks to the MSY level The biological goal for the hake stocks is to provide an optimal yield on a sustainable basis. The primary biological objective is to manage the stocks to enhance the chances of a recovery in the stocks to the biomass at which the MSY is reached. This optimal utilisation level can only be achieved by first allowing a sustainable improvements in the state of the stocks, including an increase in the spawning biomass of Cape hake and an improved age structure of both species. An indicator previously applied (to 2010) to monitor the recovery of the hake stocks was that the combined spawning biomass of the stocks should reach the 1990 level. This was being achieved by setting TAC levels somewhat below the average yield (net growth), thereby allowing any excess production to grow the stock. Whether the biomass in 1990 is an appropriate indicator is contentious given that the stock was in such a depleted state at that time and that some abundance indicators suggest that the 4 Overexploited, according to the FAO classification scheme means that the fishery is being exploited above the optimal yield/effort which is believed to be sustainable in the long term, with no potential room for further expansion and a higher risk of stock depletion/collapse. Some may argue that the stocks are actually depleted, i.e. catches are well below historical optimal yields, irrespective of the amount of fishing effort exerted. Hake Management Plan Page 11

19 stock has reached or is beyond this level. However interim indicators to monitor the recovery of the stocks would clearly be useful to assess the success, or otherwise, of management actions. In the longer term, once the stock sizes approximate the MSY biomass, management measures (primarily TACs) will be set slightly below MSY to ensure long-term sustainable yield. Existing population indicators (such as MSY) for the hake stocks (as a single unit) at least partially refer to the stock from the pre-independence era. It is likely that the productivity of hake has changed and hence, if used as reference points, these indicators may be misleading. As proposed in strategy (c), updated target and limit reference points applicable to the new productivity regime are needed. Table 5: Strategies for Objective 1.1: Recovery of the hake stocks to MSY level (a) (b) (c) Strategy Indicators / Outputs Time frame To set the TAC at 80% of the average biological yield of the previous 5 years, until strategy (c) introduces a different strategy To assess the appropriateness of 1990 as a baseline year, and define alternative interim indicators to monitor the recovery of the stock To implement new management measures in order to enhance the recovery of stock beyond 1990 baseline Spawning biomass reaches 1990 level Alternative indicators introduced New management measures in place TAC set annually Completed before end of 2011/12 season Measures implemented within 3 years (2013) Objective 1.2: Management measures based on best available scientific evidence The first objective is to manage the stocks in order to enable a recovery to a level approaching the MSY biomass. In order for this to be achieved internationally accepted good fisheries management practices should be used, notably management measures.. should be based on the best scientific evidence available and be designed to ensure the long-term sustainability of the resource. to maintain or restore stocks at levels capable of producing maximum sustainable yield. (taken from Articles 7.11 and 7.21 of the Code of Conduct for Responsible Fisheries). This is confirmed in the Marine Resources Act, 2000, paragraph 38 (2) which states that TACs shall be determined on the basis of the best scientific advice available. Scientifically determined TACs will be considered as maximum levels of harvest. Note that during exceptional circumstances recommended TACs may need to be set below this. For example, during periods of severe adverse environmental anomalies the TAC may need to be decreased at rates greater than allowed under 3.1 (a), thus applying the precautionary approach. Note that the Code of Conduct refers to this as emergency action (FAO 1995). Catches should not exceed recommended TACs. These first two objectives are relevant during both the rebuilding phases and once the stock has recovered to the MSY level. The ecosystem approach to fisheries (EAF) has in recently years been adopted as a recognised and formal management protocol. This plan incorporates the EAF but to more fully implement this approach some of the current legislation, policies and strategies may need adapting. As part of this multispecies, bio-economic and social Hake Management Plan Page 12

20 models will be developed and incorporated into management advice. These actions will be supported by the BCC programme Development of ecological sustainable fisheries practices in the Benguela Large Marine Ecosystem ECOFISH. (BCC 2010). Table 6: Strategies for Objective 1.2: Management measures based on best available scientific evidence (a) (b) (c) Strategy Indicators / Outputs Time frame To set TACs and other management measures according to scientific recommendations To implement emergency measures during exceptional circumstances, notably to reduce the TAC beyond the level defined in Objective 1.1 To review legal, policy and strategic changes to the management of hake that will be needed for the further application of the EAF Scientific advice forms the baseline to management decisions Only used during severe environmental anomalies and similar events HMP changed to fully incorporate EAF Continuous Rarely applied Incrementally applied during next 5 years Objective 1.3: New assessment of the hake stocks The two hake species are currently assessed as a single stock, despite having different growth, distributional and other biological characteristics. An important objective to achieve the overall goal is to assess the two species independently and to develop management protocols that will allow catches to be adjusted separately. Achieving this objective in not a trivial development and will require adequate resources, and time, to achieve. The development of regional stock assessment through BCC is planned by the end of 2015 (BCC 2010), although, as previously noted, with all BCC projects it will remain the responsibility of the national governments to accept and implement outputs. Given the importance of the hake resource to the Namibian economy, and both the risks and potential lost catches through inappropriate assessments, all efforts will be made to develop single stock assessments and the other strategies listed below much sooner than this. Cooperation with assessment experts from outside the region, for example with the ICES Demersal Working Group, will be considered. Once single species assessments are developed, the outputs will need to be incorporated into management measures. As the two stocks are harvested by the same fishery, and often both species are found in the same trawl, this will be far from simple. Setting separate TACs will in all likelihood not be feasible. Effort could be used as a blunt tool to control the amount of each species, possibly through forcing vessels to fish in specific areas, this will be complicated by the species co-occurring in some regions (notably around the 350 m bathymetric line) and annual changes in the distributions. Despite the difficulties of implementing separate species management measures, this will not be used to avoid developing the best practices possible. The current assessment uses abundance indices spanning the history of the fishery. The productivity of the system is believed to have changed between mid-1980s and mid-1990s (Cury and Shannon 2004) and therefore these historical indices may no longer be relevant. These new assessments will be based on the current system, only using data from 1990 onwards. Hake Management Plan Page 13

21 Recent ageing research suggests that at least Cape hake age-length keys have overestimated age and hence underestimated growth (Wilhelm In prep.). Ageing validation of both species needs to be completed and the assessments updated accordingly. However, until these age-length keys have been fully validated the precautionary approach will be applied and the more conservation keys used, i.e. the current ones. The migration patterns of hakes are poorly understood, but it is generally accepted that at least deep-water hake is a shared stock with South Africa. Each country currently manages their fishery independently and harvesting strategies and management rules of one country could have a major impact on the stock status in the other country. Ascertaining the precise transboundary nature of both stocks (but especially deepwater hake) and agreeing on joint management protocols are crucial. This research will include both surveys and genetic analysis. The genetic work is planned through BCC (BCC 2010), while the surveys are already part of an EAF-Nansen project. Note that many of the strategies listed to achieve this objective are currently being, or will soon be, researched. Once this research has been completed it will be necessary to define new strategies based on the outputs of the research. Until then, the indicators, or outputs as they actually are, will be the results of these research projects. It is also worth noting that this section of the management plan will be updated as and when new information becomes available and not necessarily solely at the review period in Table 7: Strategies for Objective 1.3: New assessment of the hake stocks (a) (b) (c) Strategy Indicators / Outputs Time frame To develop separate species assessments. Assessments to be peer-reviewed To investigate procedures to manage each species independently To incorporate into new assessments assumptions that the ecosystem has changed Assessments to be peer-reviewed Outputs of assessments available to enable management of each species independently If feasible, management measures implemented Availability of reliable estimates of MSY and other target and limit reference points in new productivity regime. By 2016, but ideally sooner 5 As above As above (d) (e) (f) (g) To validate new ageing research and incorporate into assessments To research transboundary shared stock levels through BCC projects To agree transboundary management protocols with Government of S Africa To assess transboundary status of Cape hake with Angola Age-length keys incorporated into assessments, but only if keys validated Sufficient information available to negotiate management protocols with S. Africa Implementation of agreed management protocols If necessary, agree and implement joint management protocols with the Government of Angola As above As above 31/12/ years 5 BCC will be developing this over a 5-year project, but all efforts should be made to implement this much earlier Hake Management Plan Page 14

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