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Thursday, 19 October 2017

How Government and Fisheries Management Policy caused over-fishing in UK waters.

This is a considerably well researched overview of the fishing industry that takes in more than just the plight of the Under12m sector. Andrew Craig has provided a host of statistics and observations that are relevant to the current debate:

The British Fishing Industry looking for a way ahead


Taken from a post from the British Fishing Industry Facebook site:
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This paper has been prepared by members of the fishing industry to highlight the consequences of management conservation policies from the industry’s perspective.

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This article is not intended to criticise current management, but only highlight the effects of management policies which have had an adverse effect on stocks and industry over the last 40 years, in the hope of not repeating history post Brexit and to clarify that contrary to the propaganda, the industry is not responsible for overfishing, but government and management policies are.
All of the proven conservation measures in place today, respected by industry and management alike, have been developed by the industry to protect stocks and introduced by management at the request of the industry.

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All conservation measures introduced by management without the support of the industry to date have been unsuccessful at conserving fish stocks.
Note.

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There are 3 main categories within the fishing industry.

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• Shellfish - these boats are not affected by Total Allowable Catches (TACs) set by the Common Fisheries Policy (CFP) and quotas.

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• Pelagic (midwater species) - quotas were introduced at the request of the industry for these species as a very suitable measure to conserve stocks, as each Pelagic species such as herring, sprats and mackerel rarely mix with each other, so as an example, if fishing for herring, that’s mainly all that is caught, apart from very small bycatches (other species).

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• Whitefish - these are all the species which are on the seabed (demersal species) which are all mixed fisheries, so no matter which species are targeted, many other species are also unavoidably caught and the industry can do very little, if anything, to prevent this when using any form of line or net. So quotas are a very unsuitable means of conserving these species and directly cause widespread discarding of marketable fish as a result.

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The Whitefish category is broken down into 3 more categories known as:

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The Sector: These boats are in membership of a Producer Organisations (PO), which manage each boat’s quota, based on their previous catching track record during a DEFRA reference period 1993 – 1996.

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The non-sector: These boats are over 10 metres in length but are not members of a PO; this quota is managed by the Marine Management Organisation (MMO.)

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The under tens: These are the small inshore boats, whose quota is also managed by the MMO; these boats were not placed into the quota system until 2007.

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To break down the size of each category of the industry into Kilowatt capacity (KW engine power), which is the only recognised means to measure a fleet’s catching capacity and the share of UK quota they should receive.

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Fleet Kilowatt capacity for each sector of the UK fishing industry

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Minus 50% for part-time and shellfish boats in non sector and under tens
........................Quota.........................Quota
..................... entitlement .................received
The Sector..............70% ..........................96%
Non- sector............7.60% ........................1%
Under-tens ...........22.40% .......................3%
(Source: British Fishing Vessel Register Cardiff 2017)

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You will note, the non-sector and under-tens only receive a fraction of their legal quota entitlement.

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Management policies over the last 40 years and the adverse effect they have had on UK stocks and industry.

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Government policy.

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In 1974 Ted Heath negotiated approximately 60% of all UK waters and fish entitlement to other member states when joining the EEC (EU).

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Policy effects on stocks and industry.

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Overnight the UK fleet lost 60% of its waters to other EU fishing fleets.
By not reducing the UK fleet with decommissioning to account for this extra fleet capacity now fishing in UK waters, directly resulted in over capacity and overfishing.

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Each EEC (EU) member state had to submit its previous annual catching figures when joining the EU, in order to share out TAC and quota based on each members states catching track record, but MAFF (DEFRA) only accounted for half of UK landings. Since then, the UK only receives half of its correct Total Allowable Catch (TAC) and quota share each year from the CFP, so the UK fleet was already 50% over capacity for the future quota available, from the date we joined the EU.

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Therefore fishing capacity within our waters increases by 60% and all future UK quota entitlement reduced by 50%.

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Management policy. 

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Closing the UK Pelagic Herring fisheries in 1976.

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Policy effects on stocks and industry.

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90% loss of Herring markets, dramatic increase in effort on all UK whitefish stocks directly causing far more overcapacity.

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In 1975 the industry approached MAFF (DEFRA) concerned about our herring stocks, they needed a quota put in place to protect the stock, as this would have been an effective means of slowing down catches, enough to allow the stock to recover. MAFF chose to disregard industry advice but instead decided to close the fishery entirely after taking scientific advice. 

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This fishery accounted for around half of the entire UK fishing industry’s catch at the time, so all these herring boats (around 1000 at the time) had no choice but to migrate into the white-fish sector to earn a living, as a direct result of the closure. A year later the fishery was re-opened but by then 90% of the herring markets had collapsed due to the closure, leaving almost all of those herring boats having to continue targeting white fish. From this date, our herring stocks around the UK have been extremely healthy, but we still can’t sell them. This one policy alone directly caused more severe over capacity and therefore overfishing by the UK fleet on our white fish stocks. 

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I hope this is a clear example of the effects of fisheries management policy, when only based on theory and science alone, when industry’s advice has been disregarded.

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Management policy.

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In 1983 management introduced a Total Allowable Catch (TAC) and quota system on most demersal white fish stocks, to protect them from fleet over-capacity and over-fishing caused by previous government and the fisheries management policy.

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Policy effects on stocks and industry.

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Widespread discarding or landing over quota (black fish), as policy is considered unworkable. 
By industry, as it cannot avoid catching high levels of over-quota species, due to the UK now only receiving a fraction of its annual quota entitlement from the CFP directly causing overcapacity in the white fish sector. 
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The industry does not go to sea to kill high volumes of marketable fish for no reason, when conservation policies are only based on un-workable academic theories, which make no sense and therefore receives no industry support.

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Relations between industry and management hit an all-time low, as policy considered a direct threat to fish stocks and industry.

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Quotas for non-sector boats reduced by over 700% between 1985/1995, resulting in no longer being able to earn a basic living legally. This was not for conservation reasons but due entirely to the mismanagement of the UK quota.

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Management policy.

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Between 1993-96 the CFP/DEFRA introduced three rounds of decommissioning of over ten-metre fishing vessels, to reduce the over-capacity in the white fish sector that management policy had previously caused, which removed 578 vessels from the UK fleet.

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<12m br="" commercial=""> Policy effects on stocks and industry.
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White fish fleet reduced dramatically.

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Quota (valued today at millions of pounds) from decommissioned boats is permitted to be kept by ex-skippers (Slipper Skippers) who no longer owned boats and given to POs.

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During this time, DEFRA was aware the under-tens had to be included in the monthly quota system within twelve years (confirmed by Fisheries Minister Jonathan Shaw 2007) and there had not been sufficient quota (3%) set aside for them.

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DEFRA had every opportunity at this time to set aside a further 26% of all UK quota, for the Under-tens and non-sector boats from the decommissioned boats, which make up 30% of UK catching capacity between them, but chose not to. 

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Many non-sector skippers forced to take decommissioning and scrap perfectly good vessels, due to no longer being allocated enough quota by DEFRA to earn a living, and then having new large under-ten meter boats built (known by management as rule beaters) as the only means to earn a living outside of the quota system at the time, to prevent having to break quotas and operate illegally on a daily basis.

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Discarding of marketable fish is reduced by PO boats only.

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Management policy. 

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Introduction of Fixed Quota Allocations (FQA’s) in 1999 to PO boats only, based on a catching reference period 1994 to 1996.

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Many PO boats were able to build up huge quota track records during this reference period. 

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The majority of UK fishermen were not informed by DEFRA they had to join a PO to safe guard their future, quota entitlements or catching track records. This resulted in most vessels only receiving a very small percentage of their legal quota entitlement, making it extremely difficult for these boats to earn a living, as the majority of their quota share was given to PO’s by management.

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Policy effects on stocks and industry.

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No benefit.

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Management policy.

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DEFRA lost the Factortame case. 

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In March 2000, ninety Anglo-Spanish fishing companies accepted an offer of settlement from the Secretary of State for DEFRA and received £55 million in compensation from the UK government and a third of all future UK fishing quota entitlement.

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Policy effects on stocks and industry

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This case was regarding Dutch and Spanish fishermen, who had bought UK registered fishing
vessels and managed to build up vast quota track records during the FQA reference period, due to a loophole left in the DEFRA FQA quota policy.

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As a result, a third of all UK quota had to be given to the Dutch and Spanish fishermen, valued today at tens of millions of pounds every year. All quotas for UK boats drop by a further 33%.

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Management policy.

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In 2007 registered buyers and sellers (RBS) introduced by CFP/DEFRA, in order to make fishermen discard all over-quota marketable fish the industry catches unavoidably every year.

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Policy effects on stocks and industry

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All vessels have to stay at sea far longer than necessary, trying to catch the few individual species they are permitted to land, discarding of over-quota species increases to tens of thousands of tons each year. 

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Under-tens are added to the monthly quota system, but only receive 3% of UK quota, which is 19.4% below legal entitlement (according to fishing vessel register kw capacity) and The Centre for Environment, Fisheries and Aquaculture Science (CEFAS) scientific report, (The Environmentally Responsible Fisheries Project), this creates widespread hardship to the inshore fleet and increases the discarding of marketable fish in the UK by over 50%.

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Six respected boat building company’s forced to stop trading as a direct result.

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The discarding of skate by under-tens is presently between 1000 and 1500 tons per year in the Thames estuary alone, as historic landings for this species are 5-8 tons per month, per boat, but quotas set at just 250 Kg per boat per month. Under-tens are informed by DEFRA/MMO to lease quota from slipper skippers, or from boats that have never fished that area if they want enough quota to earn a living, but this is not financially viable.

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Management policy

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In 2007 Introduction of a decommissioning scheme for the under-tens to reduce the fleet over-capacity, caused by previous management policy.

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Policy effects on stocks and industry.

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Just 65 boats out of 182 applicants were accepted by DEFRA for decommissioning. This sector needed at least 200 boats removed by decommissioning, to ensure enough quota was gained for the remaining vessels to earn a living within this sector. 

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So the under-tens still needed many more vessels removed from it to address this over-capacity issue, or receive the correct share of UK quota to suit this sectors capacity.

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Management policy.

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In 2016 CFP/DEFRA introduce the Landing Obligation (discard ban)

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Policy effects on stocks and industry.

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Up to half of all marketable fish caught by the whitefish fleet has to be sent to landfill and removed from each boats quota, if any boat reaches their quota for any one single species caught, it is not permitted to go to sea again that year.

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Although the whitefish industry has been working hard attempting to develop new net designs to reduce discards this could never be stopped, not by a long way. This policy is considered by all UK fishermen without exception as a pointless unworkable nightmare, which has been based entirely on theory, yet again.

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Management policies Summary:

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1. 1974 The UK lost 60% of its fishing waters and 50% of all UK quota entitlement when joining the EEC.

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2. 1975 90% loss of all Herring markets causing more overcapacity in white fish sector by displaced boats.

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3. 1983 Introduce quotas on most white fish stocks, which directly cause all discarding of over quota marketable fish caught.

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4. 1993/96 Decommissioning over ten fleet, gave all quota to slipper skippers when desperately needed by non-sector and under- tens.

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5. 1999 FQA system introduced which directly discriminates against the inshore fleet, recognised by many NGOs as the most conservation minded and highest employing sector of the UK industry.

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6. 2000 Factortame case, loss of another 1/3 of all UK quota and cost to the Tax payer of £55m 

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7. 2007 Introduce Registered Buyers and Sellers, to force industry to discard thousands of tons of unavoidably caught over quota marketable fish every year.

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8. 2007 Introduce a decommissioning scheme for the under tens, only 65 boats out of 182 applicants accepted by DEFRA. 

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9. 2016 Introduce the Landing obligation (discard ban) to make the industry pay to send most over quota marketable fish unavoidably caught to landfill.


<12m br="" commercial="">Comments:
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It is clear, that since 1975 management have been continually firefighting in a blinkered manner, implementing more policies only in an attempt to correct the effects of the previous disastrous policies, which have directly caused all over-capacity and over-fishing within the UK fleet.

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Management is well known for not looking forward for any possible negative knock on effect of policies before implementing them, but try instead to use a quick fix approach to the problems previously policies have caused. Whereas the industry looks at conservation problems in a long term manner, as it naturally wishes to secure the industry’s future for years to come.

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There can be no doubt, the quota system is unworkable when applied to demersal species and no matter how much tinkering is done by management in an attempt to make this floored system work, it could never be an effective, workable conservation measure that could benefit stocks or gain industry support, unless the quotas being set are at reasonable levels, so if fishermen do everything in their power to avoid a species, they don’t go over quota.

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In summary:

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Since 1974 the UK has lost 83% of its entire TAC/quota entitlement, not due to stocks reducing or any conservation reasons, due entirely to the UK mismanagement of our quota and also, the displaced boats from the closed herring fishery which were also forced to target the remaining white fish quota, with no other fishery available to target.

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Admittedly the fleet has been reduced with decommissioning by around 50%, but this is still a third larger than the TAC and quota now available. On top of this we have quota reductions for conservation reasons as a result of over-capacity and over-fishing directly caused by pre -1976 management policy. 

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The phrase squeezing a pint into a half pint pot comes to mind.

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The conservation of our demersal species could be very effective, workable, simple and far more cost effective for the tax payer, if the Days At Sea conservation method was used in conjunction with technical measures, as proposed by the Fishing For Leave (FFL) campaign. This would allow boats to have a set number of fishing days a year depending on vessel size and nets used, but land all marketable fish caught while still protecting stocks, as far less overall fish would be caught by the fleet. Although there are concerns within the industry, if management have the knowledge base needed to implement such a system, in an effective workable manner.

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The term Over Fishing is not as the term implies, as this is NOT when a fishermen catches more than they should, in most cases it is when they land some of the over-quota dead fish they have to discard daily anyway. We should also remember quotas are not set at such low levels for conservation reasons, but only due to the UK not having sufficient quota to go around the size of fleet the UK has. So no matter how healthy our stocks become, there will never be enough quota available to stop widespread discarding unless the fleet is reduced further to suit the quota available or the quota percentage rise to a reasonable level to suit the existing stocks on the grounds, as the only means to stop discarding marketable fish.

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Instead of management addressing the one very obvious problem which could directly help correct the UK quota shortage in a positive way, it continues to operate in the same short term firefighting manner.

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As an example:

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Two herring makes a very pleasant, filling meal which costs no more than £1, our seas are full of large shoals as they have hardly been fished for over 40 years.

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The Sea Fish Industry Authority was set up to promote the fishing industry, so may we ask, why have DEFRA not requested Seafish start promoting this fish for the home market, as the industry has been requesting for decades, to develop new recipes or Swedish pickling techniques to remove all bones, so become suitable for boil in the bag and many other cooking methods to address the cooking smell and bone issue some members of the public have with this fish.

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It may require 1 or 2 boats being partly subsidised for the first year, to ensure supply across the country until the market share becomes established and increases, during an advertising campaign with TV chiefs involved. 

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European Fisheries Fund (EFF) money is available to fund the entire project.

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How beneficial would it be, if cooking techniques could be developed well enough to suit schools, so our children could have very healthy, tasty low budget meals, like most other European schools do.

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Herring fisheries using drift nets are very clean low bycatch fisheries, they can be used all around our coast line by inshore fishermen and every boat that could move into that fishery, is one less targeting and using up whitefish quota, so the long term knock on effect will benefit all other non-sector and under-ten boats in the UK, by directly reducing capacity within that sector. Such a project may take several years to reach its full market potential, but could quite easily support hundreds of boats if successful.

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We only need to look at the South West Sardine fishery which has dramatically increased its market share in recent years, due to nothing more than re-branding pilchards as Sardines; this sustainable fishery now supports dozens of boats landing thousands of tons a year. Even though Sardines have the same cooking smell and bone problems as herring do.

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Finally.

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The UK fishing industry wants effective, workable conservation measures to secure its future, but this could never be achieved using the current draconian methods.

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History has proven, Fisheries Management and Science do not have the knowledge base to manage this industry and nor could they be expected to, with the very limited training they receive on this highly complex and unique subject, which very few people outside of the industry could be expected to understand.

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Commercial fishing is more a vocation than a job, it has always required complete and total dedication for tens if not hundreds of thousands of hours at sea if a fishermen is to succeed, management need to start using this massive knowledge base more and be prepared to take and accept sensible advise on conservation issues from the industry, not continue using academic and scientific advice when only based on theory and assumptions, as normally the case. If industry advise an intended new policy won’t work, it must go back to the drawing board, not be forced into Law anyway as we so often witness. Then and only then, will we achieve true conservation for our fish stocks and industry.

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I would suggest, when an entire industry without exception disagrees with management policies, the model being used cannot be fit for purpose.

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Date: 1.10.17
Subject: Overfishing, Conservation.
Report prepared for: Education purposes.
Author: Andrew Craig
Authors experience on subject:
• 20 years (approximately 45,000 hours
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sea time) skippering <12m br="" commercial="">fishing vessels.
• A founding member of NUTFA.
• Catamaran designer.

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<12m br="" commercial="">Thoughts and feedback welcome!