Tuesday, 17 October 2017

Fishing for Leave's proposed system for effort control.

Here is the latest news from FFL's campaign for a better alternative to the proposed ITQ system that has seen such hardship for many sectors of the UK fishing industry:


At the recent stakeholders meeting there was a general concurrence by both environmental NGOs and FFL that the CFP is a bad policy that is damaging to fish stock health and recovery.

It was also heartening to hear the majority of NGOs express the view that fisheries resources and the marine environment are a public resource for a public good. Fishing for Leave would wholeheartedly agree with this being the only fishermen’s organisation to concur with this position.

Fisheries resources should not be corporatized, as has happened under the de-facto ITQ system we currently operate under the guise of FQAs, and as has happened in Iceland and New Zealand with their ITQ systems.

A recurring theme was that one of the primary problems of management was bad data which often provides only a snap shot of stocks at a previous timeframe. That all groups desired real-time data to facilitate real-time management. That harvesting should rebalance from quotas eschewed from reality to the stocks available and that environmental and economic resilience is key.

Fishing for Leaves system answers all these questions!

The unique, refined system of effort control we have developed and proposed would facilitate real-time data and management to allow a dynamic holistic policy that works with and responds to nature.

One that addresses and takes the British industry out the dark economic malaise all bar a minority controlling the SFF and NFFO are in.

This is achieved by providing Individual species control through the secondary system of Flexible Catch Compositions (FCCs). These deter any “race to fish” without causing a distortion of fishing effort which would misconstrue an ecology wide approach that allows landings to reflect catches/fish abundance.

What is perplexing is that many of the environmental NGOs dismissed effort control without appearing to fully comprehend what was proposed by FFL and we look forward to finally meeting with them all to explain this system in the meetings scheduled soon.

The NFFO, SFF and SWFPO dismiss effort control to maintain the status quo and quota investments – failing to care that a discard ban which the public demand will finish the majority of the fleet with choke species – what we observed was trying to keep the wheels on a bankrupt system.

Both parties argued against a system of effort control that FFL are not proposing and which our secondary systems, especially Flexible Catch Compositions & Integrated High Tech monitoring are designed to address by allowing individual species control to stop any “race to fish”.

Below we have sought to answer and address all the issues that were raised.

1).  Federation Arguments – We were delighted to hear Bertie Armstrong of the SFF fully agree with Fishing for Leave! In his dismissal of blunt Days-at-Sea alone Mr Armstrong fully vindicated all the reasoning and refinements of the British system of effort control we propose.

Neither Mr Armstrong nor Barrie Deas presented an argument against the TAC driven Flexible Catch Composition (FCC) system of effort control that FFL advocate but had a facetious against other versions of effort control – namely Faroes.

2).  Lies on Faroes - To then have to seek further justification for points that weren’t on the system proposed by telling deliberate lies.

Faroe has NOT ditched effort control – they proposed implementation of a few quotas on selected species for only the largest vessels in their fleet. This was to address a race to fish which FFLs system does with far more sophistication through FCCs. Implementation of quotas and any move from their system of Days-at-Sea was vehemently resisted in Faroe and culminated in the majority of the fleet and industry tying up and marching on Parliament.

3).  Lies On Fishing Trial – Ms Sandell of Marr incited that a trial in 2013 proved that Days-at-Sea didn’t work because the vessels on the trial didn’t have enough time to catch their haddock allocation.

This was a blatant misrepresentation of the truth. The trial conducted in 2013 was a Fully Documented Fishery (FDF) trail under a Catch Quota Discard Ban system – the trial was an abortive failure, called off after 5 weeks as the vessels could not access enough quota to avoid choke species.

The vessels problem was being forced to roam the sea in a futile mission to find only the fish they had quota for -not from any lack of time at sea. Under the proposed system of FCCs the vessels would have been able to retain the “wrong” fish – in this instance hake – in exchange for an equivalent value of time at sea.

In being able to keep all catches for less time at sea the vessels wouldn’t have needed time to steam all over nor would they have been restricted to only trying to chase fish for which they had quota. It is incredible that Ms Sandell should misrepresent the truth of this trial given that she was the author of the report which detailed its failure. http://www.seafish.org/media/1120923/dag_oct13_poconcerns.pdf

4).  Effort Control Doesn’t Limit Fishing - How anyone can seriously stand by the pretence that by curtailing the amount of time vessels are able to put to sea does not reduce effort evidently does not understand fishing.

Currently, we have unlimited fishing – vessels have unlimited time at sea and are free to catch whatever they want – it is only landings that curtailed. To compound this Quotas are currently causing a “race to fish” as vessels have to expend maximum time and effort catching more fish than necessary to then discard a large proportion of their catch in order to find what their quotas allow them to keep.

Vessels already do, and always will, seek to maximise their time, efficiency and effort at sea and have to do so currently with discarding. Curtailing the amount of time at sea necessary to be economically viable from current levels can only reduce fishing effort and mortality.

There seemed to be some sort of misconception by many that catches taken are the same as current quota limits and landings. If they were there wouldn’t be a huge discard problem.

5).  Quotas Have Rebuilt Stocks & Therefore Work – This does not portray & contorts the truth. Stocks are indeed booming but it is not the success of the CFP and quotas but its ineptitude that has culled boats from the fleet.

Stocks are up but the fleet is massively down. To argue otherwise betrays the truth that there isn’t a major fishing port left south of Peterhead. Many tried to justify the validity of quotas as an applicable management regime for British waters with this argument but it does not acknowledge the culling of the fleet.

6).  Effort Doesn’t Work With International TACs - FFL have addressed this point to Mr Deas on numerous occasions over months. It is not difficult to understand that under the provisions of UNCLOS independent coastal states agree the level and shares of TACs. Thereafter, UNCLOS provides states the discretion over the system uses to utilises its TAC share.

The fundamentals of FFLs system is that the ratio of TACs/Quotas are translated into Flexible Catch Compositions underneath an overall level of time at sea based on the overall TAC. As the ratio of TACs change so to shall the FCCs. This has been computed and modelled within FFLs database as shown to CEFAS.

7).  Choke Species – FFL have offered a system that not only means catch less but land all but in doing so avoids “choke species” where the fleet, under an individual species quota system, will have to tie up on exhaustion of its lowest quota with a majority going bankrupt – resulting in a consolidation of the fleet and coastal communities. No substantive solutions have been forthcoming from either the SFF, NFFO, Government or NGOs and none was despite FFL asking for alternatives to effort control at the meeting.
The system proposed by FFL does not get rid of TACs, FQAs or investment in them it maintains them. Far from usurping the current set up it looks to save it before choke species decimate the industry.

8).  Effort Control Will Mean Management By Lowest Common Denominator - This again argued against other systems of effort control not the variant of FCC effort control proposed by FFL. Other systems under pure Days-at-Sea either have a “race to fish” for high value species as effort is kept to an overall ecology level or see’s effort slashed to the lowest common denominator species in order to protect it.
This is precisely what FFLs system of FCCs is designed to address, it does so in the modelling thus far. FCCs provide individual species control by controlling catch composition to allow effort to be maintained at an overall ecology basis. What is certain is vessels will be managed under the lowest common denominator species under a Catch Quota Discard Ban system in 2019.

9). Effort Difficult to Set – Mr Armstrong facetiously suggested that the level at which effort is set is hard to define. This is another falsehood. It is set by combining all demersal TACs – recognising that it is unavoidable for vessels to not catch a mix. Thereafter, time at sea is determined by the time it will take the fleet to empty the pot of fish. If average catches including discards is 1000tons per day for the fleet and the combined TAC is 200,000 tons then every vessel requires 200days.
FCCs then operate to keep vessels catch composition in line with a sustainable balance of species as determined by the TACs to avoid any race to fish. Therefore, if the combined TAC is 200,00 tons – made up of 10% Cod, 20% haddocks etc then vessels should be aiming to catch this composition of species within their overall time.
Evidently this will vary depending and determined by the vessels FQA allowance and therefore traditional target of effort (i.e. some vessels are more disposed towards cod, others monks, others prawns etc.) Effort is therefore far simpler to set and far more accurate in controlling fishing effort that quotas.

10). Quotas System and Investments Have Been Good- It was argued that the fleet having had to invest heavily in quotas had been economically beneficial. This gave no justification as to why having to pour continued investment into quota had been a good thing when the monies expended could have been used for fleet and infrastructure renewal.
Quotas are priceless to active fishermen as they are not for sale as vessels require quota to fish. Therefore, the money invested is dead to the business. To keep entitlement value high quotas need to be kept the same or lowered – both are harmful to the actual business of fishing.
If the de-facto ITQ system operated in Britain has been such a roaring economic success then why has there been so much consolidation and contraction – no answer to this question was nor has been forthcoming.

11). Industry Doesn’t have A Discard Problem That Can’t Be Solved By Quotas– Both Mr Armstrong and Jim Portus tried to insinuate that choke species and discards are not a significant problem that cannot be solved within the quota system to necessitate moving to FCC effort control.
This ignores that regardless of level it is quotas that have caused discards in the first place. Quotas have had any conservation effect as it is landings that have been regulated not catches. Discards have defeated conservation not helped it, Discarding is monstrously inefficient both environmentally and economically and therefore to suggest that quotas are efficient is laughable.
No suggestion of how the industry could get around chokes with quotas when a fully enforced discard ban is enacted. Markets and consumers demand discard free fishing – the only credible way this can happen is for full CCTV enforcement which will flatten the fleet as quantified by Seafish Landing Obligation Report. www.seafish.org/media/Publications/Seafish_landing_obligation_-_FINAL_REPORT_2_seafish.pdf

12). Effort Not Being Selective  Concern was voiced by PEW foundation that Effort control does not encourage selective fishing as there is a “race to fish” for as much and as valuable as possible as fast as possible. This is true under other systems of effort control without the refinements of secondary systems proposed.
Fishing under quotas is not currently selective as vessels have to sift through fish to find what they can keep. Currently we are only selecting to hit a paper target on landing whilst discarding heavily.
FCCs ensure that vessels have to fish smart not hard as they look to maintain the correct catch composition to avoid losing time and therefore effort at sea. The system of Conservation Credits where vessels are awarded time for adopting selective fishing methods and gear also encourages selective fishing

13). Doesn’t Protect Vulnerable Species – This dynamic system with the real-time data and management response absolutely helps to identify and protect vulnerable species. Through the secondary refinements within effort control. Either by FCC time penalties and also through a Real-Time Closure System where grid square areas can be closed temporarily to protect aggregations of species, juveniles or brood stock.

14). Catch Quota Discard Ban Will Provide Real-Time Data – One proposition was that effort control is unnecessary to provide real-time data allowing real-time management as this could be provided by quotas under a fully CCTV monitored discard ban.

Sadly, as always will happen with quotas the limit of catches will only reflect the quota limit. Whether a quota is set at 2000 or 20,000 tons vessels/fleet will fish upto this limit. It shows nothing more than when you hit the buffers of a pre-determined limit – rather as with effort control the true mix and predominance of species is shown as all catches are landed in exchange for a sustainable limit of time.

15). 2010 Effort Trial A Failure – Yet again this incited a failure in another blunt system of effort control not the FCC effort control system FFL advocates. During the 2010 trial U10m vessels in the SE were put on pure Days-at-Sea and left to catch freely.
Again it was emphasised that what FFL proposes is NOT pure, blunt effort control with only an allocation of Days. The system of FCCs stops any vessels going tonto for species which they have not traditionally fished whilst allowing exchange or loss of time for the “wrong” species.
It is impossible under FCCs to have derby fishing due to the loss of time if vessels to act smart rather than fish hard.
The trial was cancelled after only months due to the volume of fish landed. It is important to realise that this “extra” fish was not extra catches but was the fish that was otherwise being discarded under inadequately low quotas.
What was seen was a true reflection of the abundance of fish on the grounds that was being caught and discarded. The trial was a failure because there was no secondary refinement like FCCs and because reality conflicted with the paper work targets.

16). Effort A Bad IdeaA Blunt Instrument - Martin Salter of the Angling Trust suggested this however effort control is anything but blunt. It allows and takes account of a true picture in sea through the technology available to give real time reporting of catches, soak time, temperature, brightness, tides, weather and position.
Due to this it data being fed ashore daily and computed to build maps of exactly what is happening it is a thoroughly responsive and dynamic system.
One can only hope that the Angling Trust will adopt a similar level of fastidious monitoring and management for its members around the coast who account for a significant proportion of catches and we welcome them working with us to adopt the system and technology we advocate which is applicable to anglers too.

17). Better Management of Quota Solves Problem – Erin Priddle of EDF suggested that quota buffer pools and a system of exchanging quota such as Iceland under an ITQ system would allow distribution of quota to fire fight choke problems.

Britain already operates a de-facto ITQ and complex pooling, swapping and renting system of quotas through the Producers Organisations (POs_ almost totally unbeknown to those outside the industry.

The quota system simply does not reflect the abundance and mixture of species due to the bad data the system produces. There is not the slack in the system to provide adequate swaps or buffers even with invoking zonal attachment.

North Sea Hake and Skates & Rays, West Coast Cod, Sou’ West Haddocks and Irish Sea everything have TACs so far out of line with stocks that even if Britain reclaimed and pooled all quota there still isn’t enough to account for abundance of these species to avoid chokes and significant reduction of the fleet and coastal communities.

The Rental of Quota and Slipper Skippers is bleeding the industry dry with Seafish identifying that 60% of profit by North Sea Whitefish vessels is being expended to source quota.

Seafish Figures on Average Costs of Quota Rental Between 2012 & 2015

With Rental Prices for North Sea Monks and Cod at around £2000 per ton with a market price of £3000 per ton it is nearly unviable to pay sich extortionate prices. This will become more exorbitant under a Catch Quota Discard ban as vessels will have to account for every tail caught.


We look forward to engaging with the environmental NGOs to properly explain and divulge how the system we propose operates. At the Stakeholders meeting there is evidently a total misunderstanding of what we propose and how it works although it answers and provides everything aspired to in the first hour of the meeting.

On the industry side the SFF and NFFO trying to downplay the economic and operational problems in quota renting, consolidation, discards and choke species along with arguing against another system of effort control to try to discredit the one that is proposed does either them or the men they are meant to represent justice.

It only vindicates that they have no argument against what FFL propose however we hope they will engage as to retain the current system or to put it on steroids under an ITQ system will finish the fleet. We hope they can see to support a trial to investigate an alternative to the on coming train that will see the ruination of the majority of the fleet.

Fishing for Leave
17th October 2017 by Njordr AB