During his recent (5th April) visit to Brixham, the following questions were put to the Fisheries Minister, Richard Benyon MP. His verbal responses are summarised in our (SWFPO) words and are not to be considered direct quotations:
1. Catch Quotas / Discards / Sustainable fishing in mixed-fisheries. (Recent SWFPO briefing note to Minister attached).
In his response to this question, we now understand that the Minister went the extra mile for the SW UK industry at the December 2010 Council of Ministers, securing unexpected additional quota opportunities in, for example Channel Plaice and that he pushed hard to secure the 7e sole “catch quotas” against opposition.
For these reasons, SWFPO in return is supporting the Minister by ensuring there are sufficient beam trawler applicants for the trials.
He knows we have reservations about the use of data gathered under such experimental circumstances and that we do not want wider assumptions to be made on the basis of such a narrow trial conducted over less than a year.
We have made clear to him that discards do not have 100% mortality rate and he has agreed to support our application for CEFAS trials to establish survival rates using SWFPO commercial voyages.
He knows we are serious about demonstrating our commitment to sustainable fisheries through MSC Accreditation etc. We will continue to encourage the use of P50% type beam trawls where and when appropriate.
We will also work with those who are trying to establish valuable markets for species that would otherwise be discarded as commercially insignificant, such as Pout Whitings, Flounders, Dabs and Gurnards.
2. Displacement of effort to the channel from N S Cod and other displaced fisheries. Noted that Dutch Government has requested from UK transfer of Western Waters Effort.
The Minister was left with no doubt that this matter is of grave concern. The UK fleet has shrunk through decommissioning and self-funded re-structuring at great expense over a period of more than a decade. There is a resulting benefit for the Channel stocks, both quota and non-TAC, with evident signs of recovery and growth. There is now some slack in the Western Waters effort allocations because of the fleet changes, but this should not now be squandered in swaps to Holland or other Member States, even though there might be temptation in the form of quotas offered to benefit the under 10m fleet. The UK industry must be allowed first to enjoy the fruits resulting from many years of belt-tightening before the larder is opened to others!
The Minister agreed to ask his officials to ensure that Dutch Fly-draggers in the Channel are not adding to discards. They are operating in waters where they have only limited quota opportunities and are claiming to have a clean non-quota catch, despite working alongside French and UK vessels that do take quotas.
3. MCZs and discrimination.
The Minister has already given written assurance that no MCZ will be implemented outside of the 6 mile before EU agreement has been reach. In order that you do not discriminate between inshore and offshore sectors of our own UK fleet, will you also give us the assurance that you will not implement any MCZ inside of 6 mile, prior to those outside of this arbitrary line?
His response gave rise to more concern. Although the Minister seemed to reiterate his commitment to avoid discriminatory management restrictions in MCZs outside of 6 miles, he was less than clear about inshore MCZs.
We think he said effectively that there would be a set of rules covering MCZs established within 6 miles that could and would only apply to UK vessels. These would be under Marine & Coastal Access Act (MACAA) 2009.
Furthermore, there would be MCZs delineated outside of 6 miles, but these would have no applicable rules until adopted by EU.
This to us is not good enough!
We must insist that his network of ecologically coherent MCZs cannot be instigated in stages, just as one cannot be a little bit pregnant!
We are sure that displacement, discrimination and degradation will happen especially to the detriment of the UK inshore fleet. This would be an “own goal” when he is trying to assist the inshore sector and provide them with some security.
We seek further reassurance on this point and will press through our involvement in the MPAFC.
4. English Scallop Order. SWFPO Response to non-formal consultation attached.
The Minister met members of SWFPO and the Scallop Association in Brixham on board SWFPO member Neil Watson’s vessel Korenbloem.
The total landings of scallops into Brixham between January – December 2010 (inclusive) was 4,509 tonnes and the value was £6,369,424. If you need figures for any other species they’re available on MMO website.
http://www.marinemanagement.org.uk/fisheries/statistics/documents/monthly/2010/december.pdf
He knows now how important it is that new management measures he is proposing for English Scallop stocks are of international enforcement applicability, are appropriate to ensure sustainability of scallops and are introduced promptly without discrimination amongst all UK and other vessels.
5. FQAs, policy on Under10s, SAIF policy.
Minister launched consultation to coincide with his visit to Brixham.
The SWFPO members made it clear to the Minister they consider that FQAs give rise to legitimate expectation of quota opportunities. Although we understand there are self-inflicted difficulties in the under10m sector caused by over-expansion in unregulated times, exposed by the introduction of Registration of Fish Buyers and Sellers (RBS), we would expect the Minister to avoid uncertainty in the over 10m sector rather than create it. Vessel owners need to provide assurances to banks and other financial institutions that underpin existing investments, including of FQAs and licenses.
The Minister’s proposals would not solve the issues in the under 10m sector. These can be solved only with fleet restructuring by permanent removal of excess capacity and capping latent capacity, as has been achieved in the over 10m fleets over a decade of reform. “Robbing Peter to pay Paul” should not be part of the range of solutions in a matrix of measures that require further development through the joint UKAFPO/ NFFO/ NUTFA working group.
SWFPO will consider fully its responses to the consultation, but also reserves the right with colleagues in UKAFPO to seek further legal advice on the possibility of taking action should the Minister decide nevertheless to top-slice English FQAs and to redeploy what he describes as “underutilised” quotas.
From SWFPO Ltd. 21 March 2011:
On the complex subjects of reform of the CFP, Western Waters mixed fisheries, effort limitation, economic viability, discards, survival rates, camera trials & catch quotas in 7e Sole:
The Commission, MEPs and Fisheries Ministers have made some announcements/ pronouncements in recent times about “discards”, using pretty strong rhetoric, some in response to the HFW “Fish Fight” campaign on TV and others in more measured tones in response to the gathering pace of progress towards 2013 and the new CFP. Other drivers in this debate are the goals of Good Environmental Status (GES) and Maximum Sustainable Yield (MSY) for (assessed) fish stocks by 2015.
All-in-all, the messages from the Commission and MEPs are uncompromising and point to elimination of discards by one method or another. The Commissioner has resorted sadly to using dubious and certainly out-dated statistics from reports that pre-date by several years the previous CFP Review of 2002 to make an unjustified point about discards in the N Sea flatfish sector. Such tactics must not be allowed to drive policy.
Thankfully the UK Fisheries Minister, Richard Benyon MP with 3 other Ministers (Denmark, France & Germany) has taken a more considered look at the subject. They published (1st March 2011) a “joint declaration” that is to be applauded for its clarity of view of this very complex subject area. Although the focus for their document is the North Sea and Cod fishery recovery and management, there is much that can be applied to our Western Waters mixed-fisheries, especially those that also are the subjects of long-term and multi-annual plans.
So what is the SWFPO Ltd view? What are our drivers? What are our responses? Where do we see our members sitting amongst the flotsam and jetsam of the “stakeholder consultations” that litter the trail of structural and technical changes that we call “progress” towards reform of the Common Fisheries Policy (CFP)?
• Our manifesto is clear and obligatory. South Western Fish Producer Organisation Ltd, Registered 21071R in 1974 as a Mutual Society under the Industrial and Provident Societies Act 1965.
Amongst other aims the PO must “a) Ensure that fishing is carried out along rational lines and that conditions for the sale of members’ produce are maximised, b) Take such measures as will promote for the benefit of members the implementation of fishing plans…in full accord with the objectives contained in the Common Fisheries Policy and c) Apply production and marketing rules adopted to maximise produce quality and to adopt the volume of supply to market requirements.”
Our members are in the business of fishing as an economic activity and the Organisation must do all in its powers to maximise their production, consistent with tenets of the CFP. In 2010 our members produced fish to the value of £21 million of which £12 million was from non-quota species.
Mixed fisheries: Our members operate in some of the most diverse and mixed fisheries in European waters. 40 or more species of commercial value are taken regularly and are landed from these “Western Waters”. However, of these 40 species only 18 are on EU quotas, namely SOL, ANG, COD, GFB, HAD, HER, LIN, MEG, NEP, PLA, POL, SAI, WHI, HAK, SKA, SPR, HOM & MAC.
Furthermore, in their routine demersal beam-trawling and otter-trawling activities, using minimum mesh size (MMS) 80mm gears throughout ICES Area VII, our members have very low by-catches of COD, HAD, LIN, POL, and SKA. It should be noted that they have almost zero by-catches of the pelagic species HER, SPR, HOM and MAC and of GFB, SAI and HAK.
It is important to note that, on average about 60% of all our members’ catch is not on quota, such as cuttlefish and pouting. It is also fact acknowledged by CEFAS and ICES that the MMS (80mm) for area VII trawlers is highly successful at selecting Soles for maturity, with very low levels of undersized discards. It has been noted also in official trials that, since the introduction of the Omega Gauge for measuring cod-end meshs, the selectivity of towed gear has improved by 5% or more.
The 80mm towed-gear Area VII fishery is defined in the Technical Conservation Regulation and although designed to “target” SOL or MEG depending on location and season there is a long list of by-catch species that together must make up 70% of the total catch, including such as PLA, ANG, TUR, BLL, BSE, DAB, FLE and SKA. Landings regularly comprise 20 or more different species, with a wide spectrum of values and in varying amounts to complete a voyage “grossing”. With fuel at record levels, nowadays crew cannot afford to discard anything that has a value at auction!
So confident are we that our methods of fishing are sustainable that our Channel SOL, MEG and ANG beam trawler fisheries are in the process for MSC Accreditation in 2011. (Channel and West Sustainable Trawling Group (C and WSTG) comprises SWFPO Ltd, CFPO Ltd and IFLPO.)
Our inshore “Otter” trawlers fish to target any and all species available on the trawl grounds, with PLA and; WHG highest amongst those on quota. 80% of all they catch is not on quota, such as Lemon Sole, Squid & Red Mullet.
Seasonally, the trawlers often change over to Scallop Dredging, with its maximum 5% by-catch of non-bivalve mollusc fish. Scallops are not only valuable, but they are non-quota and believed by CEFAS to be sustainably fished. Channel Scallops are in process for MSC Accreditation through the Channel Scallop Group, a consortium of SWFPO Ltd, SWIFA, Scallop Association and major UK Scallop processors.
Pelagic species are fished in winter seasons by “mid-water” trawlers that search mainly for shoals of Sprats (SPR). These vessels take also the PO’s quota of Herrings (HER). Mackerel (MAC) cannot be targeted in the SW “Mackerel Box” and is a small by-catch along with Horse Mackerel (HOM). Channel Sprats are in process for MSC Accreditation through the Channel Sprats Management and Marketing Group of SWFPO Ltd and local Sprats processors.
Examples of non-quota species are: Pouting, Scallops, Cuttlefish, Squid, Lemon Sole, Gurnard, Sand Soles, Dabs, Flounders, Turbot, Brill, Conger, Red Mullet, Bass, Crab, Lobster, Dragonet, Black Bream, John Dory, Dogfish, Pilchards and Whelks. These species make up 60% by value of our members’ catches!
What are “discards”? In essence discards are the living marine biota that come up on deck in the fishing gear and that “Regulations” and “Markets” require the crew to throw back immediately into the sea.
Regulatory discards are those for which the boat has no remaining quota, or those that are below the minimum size laid down in conservation and/ or marketing rules, or those determined by catch composition rules (e.g. when scalloping). The minimum landing sizes (MLS) and minimum marketing sizes (mms) apply to quota and non-quota species. The minimum marketing sizes refer only to the human consumption market.
Market-based discards are of those living things that have no known economic value, such as sea urchins and starfish that simply flow into the trawls, are separated from the commercial catch on deck and are swept back promptly into the sea.
In volume and weight terms, over-quota discards from these Western Waters vary according to the levels of Total Allowable Catch (TAC) set in Brussels, but at present are believed to amount to less than 20% of the retained catch. Under-sized and too-small-for-the-market discards of commercial species amount also to less than 20% of the retained catch.
Since nets were re-designed for the 50% Project and since the introduction of the Omega gauge, selectivity for maturity has improved and there are fewer small fish and other marine biota brought up to deck. Discarding is much reduced and today the majority of remaining discards in these regional seas are of species for which there is as yet no known market.
Ultimately, we believe that discards bans would not be well-suited to these Western Waters mixed fisheries, especially because of the various and many species for which the discarding survival rates would be high.
Policy of no discards? The assumption made by Fisheries Scientists at ICES is that all discards die. Why?
It is because it is easier to factor 100% mortality into the stock assessment process, adding estimates of all discards to the Fishing Mortality (F).
However, not all discards are of quota species and certainly not all discards die! Because of the death-rate assumption, “F” is often over-estimated and must be retrospectively amended, sometimes years later. We are very concerned that, if there was to be a ban on discards, in many cases and perversely there would be increase in mortality with corresponding reduction in biota and stock biomass.
We know already that some fish survive well despite the trauma of capture and release. If that was not the case, there would be no benefit gained by anglers engaging “catch and release” practices.
Species caught by trawlers that survive well are, for examples, soles, plaice, skates and rays and other elasmobranches, scallops, crabs, lobsters and most flatfish. The rate of survival is influenced by the depth of the fishing grounds, handling on board, flow of water at the handling areas, speed of return to the sea, etc., but in general terms it is believed that most species discarded for our trawlers swim away strongly to contribute to spawning stock biomass (B). In some documented “tagging” surveys, 100% survival rates have been recorded.
Estimating survival rates: Our support has been offered to CEFAS to conduct experiments during commercial voyages. We believe survival rates of discards must be assessed properly such that factors of survival can be added to biomass (B) estimates and removed from Fishing Mortality (F) estimates. This is important for assessed stocks and those for which data is deficient. Tag and release surveys, under-water video surveys and on-board handling improvements can help to build a better understanding of the processes involved.
We agree with our Minister that “data on the overall rate of mortality” must be gathered and we stand ready to provide vessel platforms for that research to be conducted before proposals about future discards policies are tabled for consideration. A graduated, evidence-based approach is essential to consider all manner and causes of discards and to consider wisely the measures appropriate to deal with them. We believe that many of the concerns about fish discards would be calmed once their survival rates are revealed after suitable trials. The data gained by such trials would be most helpful to the CEFAS, ICES and STECF stock assessment processes.
Catch-quotas: We believe that catch-quotas, as described by the Minister in the recent joint declaration, if properly formulated, allocated, monitored and assessed might be the appropriate vehicle, particularly in single-species “targeted” fisheries for providing fleet owners with sufficiency and certainty of opportunity on which to plan year-on-year profitable operations. Economic uncertainty in the form of rising fuel costs cannot be factored readily into business equations, but stable quotas are essential and at levels high enough to support the fleets without resort to discards.
However, we are not convinced that catch-quotas are appropriate for our mixed “non-targeted” fisheries where the majority of the catch each voyage is of non-quota species and where also it is essential that skippers retain flexibility to allow them to change over to other fishing activity.
We agree with the Minister that during trials to determine the efficacy or not of catch-quotas, effort limits should be suspended. Furthermore, each trial must be conducted over at least a full annual cycle of seasons for adequate and useful data to be collected. Lessons from one trial covering one fishery must not be applied to other fisheries, especially in other areas and using other gear types. Such assumptions have dogged the industry throughout the history of the CFP. Account must be taken in each trial area to provide flexibility, seasonality and to allow for mechanical emergency.
Working with scientists at CEFAS and ICES: Already our members have a good record of co-operation, providing platforms for surveys and providing industry data to improve stock assessments. We believe it is essential that the Minister backs-up his “strong commitment to the sustainable use of fisheries resources based on the best available scientific knowledge” by providing financial support for continuing the Fisheries/ Science Partnerships (FSP) voyages.
In particular, the SW industry is keen to ensure FSP Western Channel (7e) Sole/Plaice/Angler surveys continue. We will provide all necessary support to ensure this happens. We believe that catch-quotas may trigger faster than expected stock recovery rates. It is critical that data is collected and applied to stock assessments in timely fashion to aid robust decision making.
Author: Jim Portus. Chief Executive SWFPO Ltd.
Iain Mathieson 31 March 2011
Shellfish Policy Team
Sustainable Fisheries
Area 2C Nobel House
17 Smith Square
London
SW1P 3JR
Dear Iain,
Herewith the response from SWFPO to the non-formal consultation on an English Scallop Order:
• SWFPO members’ landings of King Scallops in 2010 were 8,000t with a first sale value of £11million (Defra landing statistics). This is about 25% of UK production.
• Many of the so-called “industrial-sized” scallopers belong to our members. Some of them own so-called “nomadic ‘super-scallopers’”
• SWFPO is a key partner in EFF funded initiatives to roll out the Scallop Good Practice Guide and to secure an MSC accreditation for the English Channel Scallop Fishery.
• SWFPO has demonstrated a clear commitment to the long-term sustainable management of the Scallop stocks within UK waters and to the appropriate protection of the habitats on which they depend.
• UK Scallop vessels, inshore and offshore are faced with growing exclusions from key fishing grounds due to the implementation of Fishing Restricted Areas and Renewable Energy “farms”.
• Ever-growing oil and steel costs mean these vessels will struggle to remain viable. We believe this important and valuable sector deserves our full support to remain competitive in a global seafood market.
1. We are disappointed with a for-shortened consultation period. This matter is not urgent insofar as conservation of scallop stocks is concerned and a normal 12-week period could have been allowed, without detriment.
2. We look forward to being provided with a full Regulatory, Economic and Strategic Environmental Impact Assessment of the intended legislation.
3. We implore the Minister to provide CEFAS scientists with all necessary means to conduct their research into the state of scallop stocks and into mapping properly the locations of scallop beds, so that this prized resource can be harvested efficiently and effectively with minimized risk of harm to other parts of the marine ecosystem. Our members stand ready to take CEFAS scientists on voyages to use their commercial vessels as marine laboratory platforms.
4. We urge that DEFRA seeks the earliest amendment to the Technical Conservation Regulation 850/98 to remove the word “bi-valve” from the Article about “Dredges”, such that other mollusc species, such as Cuttlefish can be counted as part of the 95%.
QUESTION 1: Do you support the introduction of dredge per side limits in the 6-12nm zone and outside 12nm in English waters?
Yes. However, we have serious concerns that this is a unilateral measure in what is a multi-national fishery and discriminates against British fishermen. As with his position with respect to MCZs, we believe that the Minister should not introduce measures that put UK fishers at competitive disadvantage next to those of other Member States.
QUESTION 2: Do you support the harmonisation of dredge per side limits with another UK Fisheries Administration?
Yes. We support the extension of the Scottish regime to English waters. We believe that bar length should be regulated to coincide with maximum dredge numbers.
QUESTION 3: What dredge per side limits would you support?
The Scottish Regulation.
QUESTION 4: Would you support the introduction of this engine power restriction within the English 12nm limit?
No. We support the extension of the Scottish regime to English waters.
QUESTION 5: Would you support the introduction of this measure to ensure compliance with the two Minimum Landing Sizes in the English Channel?
Yes. We support the proposal at 5.3
QUESTION 6: Would you support this clarification by specifying what attachments are exempted?
Yes. Devices designed simply to improve the safety and speed of handling / tipping dredges should be authorised within the overall 150Kgs weight per dredge. MCA and gear manufacturers input should be sought on why certain attachments are important from a safety perspective and what the design criteria should be.
Yours sincerely,
Jim Portus,
Chief Executive.
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