Facing up to the Landing Obligation

With the full implementation of the Landing obligation in force from January 2019, fishers face a huge challenge to adapt. Promoting the adoption of affordable, more selective fishing gears would be a huge step in the right direction.

THE LANDING OBLIGATION - A HUGE CHANGE IN EUROPEAN FISHERIES

Introduced under EU legislation as part of the reformed Common Fisheries Policy (CFP, EU Reg. 1983/2013) The Landing Obligation has been described as ‘the biggest change in European fisheries since the introduction of quotas in 1983’.

With up to half a million tonnes of fish estimated to be thrown overboard in Europe each year, the so-called ‘discard ban’ is designed to end the practice by fishers of throwing non-target and undersized species back in the sea. From now on, all catches of regulated species will need to be landed in port.

Its introduction represents a huge change in fishing practices for fishers across Europe, and full implementation and compliance represents a major challenge.




THE FISHING INDUSTRY IS NOT PREPARED TO MEET THIS CHALLENGE
Despite the incremental introduction of the Landing Obligation over the last four years, the fisheries industry remains woefully underprepared for its implementation, and complying fully will cause real difficulty for fishers both economically and logistically.

The requirement to land all catches of regulated species will have a real financial impact, with increased handling costs both at sea (sorting, storage) and in port.

These costs are not the only issue; dealing with the landings itself will be problematic. As fish that would have been discarded cannot be sold for human consumption, they must be disposed of in other ways - for example as food for pets or aquaculture - but the facilities, logistics and markets for dealing with this are not in place. Fishers could find themselves having to pay for the destruction of these fish, as special waste of animal origin.

In addition, as of January 1st 2019, any fishers not complying with the landing obligations could be considered as acting illegally, with the EU Commission coming under increasing pressure to ensure the rules of the CFP are enforced.

BETTER SELECTIVITY IS THE BEST APPROACH - ELIMINATE DISCARDS AT SOURCE

Faced with this situation, we need to find a practical and constructive approach to the implementation of the Landing Obligation that helps fishers to adapt.

Firstly, we should encourage fishers to face reality: ultimately they will have to abide by the landing obligation. Secondly, we should provide the tools, information and funding that helps them do so.

Through our work over the last two years we have seen the willingness of fishers to collaborate and look for solutions to the discard problem. Our experience has been that they were quick to see that greater selectivity - and eliminating the problem of discards and bycatch at source - was the best way to comply with the new rules.

“It’s interesting to see the willingness of fishermen to collaborate in finding solutions to discards as they are now feeling the pressure of the landing obligation”
Sergio Vitale, CNR (MINOUW)

More selective fishing gear can bring many additional benefits to fishers, and is an affordable, practical and effective action for fishers to consider. Information about more selective gears, where and how they can be used, and funding to help fishers switch to using them will be key to a successful implementation of the landing obligation.

Research at the University of York (UK) found that the introduction of a discard ban in Norwegian cod and haddock fisheries in 1987 ultimately encouraged fishers to install more selective fishing gear. Despite some short-term economic costs, the Norwegian and Barents Sea fisheries are today among some of the most prosperous in the world.




WHAT ACTIONS SHOULD POLICY MAKERS TAKE?

1. Make selectivity the priority

The best option to eliminate discards is to avoid unwanted catches in the first place, by increasing the selectivity of fishing gears. Additionally, when unwanted catches do occur, the survival rates of the discarded fish can be improved by adapting techniques.

2. Provide funding

The more selective fishing gears successfully tested by MINOUW are inexpensive, and the use of European Maritime Fishery Funds (EMFF) could help scale up the adoption of more selective gears at regional scale, e.g. in the Mediterranean.

For more details visit our policy recommendation page.

ADDITIONAL INFORMATION
https://thefishsite.com/articles/europes-smallscale-fisheries-and-the-landing-obligation
https://www.seafoodsource.com/features/will-the-landing-obligation-change-eu-fisheries
https://gearingup.eu/resources/
http://theconversation.com/discard-ban-can-benefit-fish-and-fishers-but-sustainability-must-come-first-26769
https://www.slu.se/en/departments/aquatic-resources1/selective-fishing/

ICES - New fisheries overviews published for the Celtic Seas, Greater North Sea, and the Baltic Sea

The new Celtic Sea overview expands the mixed fisheries information which allows decision makers to compare the consequences of choices on quotas across fish stocks.

ICES fisheries overviews provide summaries of the fishing activity and impacts across the three ecoregions.

Each overview gives a historical perspective and landings over time since the 1950s, but also include contemporary information on national fleets, recent fishing effort trends, the composition of their catches, and the gears and methods used.

The overviews also highlight the current status of resources and longer term trends, including information on stocks relative to maximum sustainable yield (MSY) and the precautionary approach.

In all of the ecoregions there has been a general improvement in stock status over the last decade with mean trends in most cases showing a decline in fishing mortality towards more sustainable levels.

The wider effects of fishing activity on the ecosystem are also described – such as trawling's impact on the seabed, and bycatch of other fish species and protected seabird and marine mammal species. This marks a move by ICES to align its fisheries advice to conform to both the European Union's Common Fisheries Policy (CFP) and the Marine Strategy Framework Directive (MSFD), which is the umbrella legislation for the EU marine environmental standards.

Mixed fisheries challenge

Mixed fisheries present a challenge for sustainable management of individual fish stocks. Fisheries managers and stakeholders need to understand the various interactions; who is catching what species with what gears and in what areas.

The new Celtic Seas fisheries overview includes maps showing the spatial distribution of catches for some of the main species of commercial interest within the region. The “technical interactions" are also shown in more detail with catch composition by country, gear, target and species. Tradeoffs of moving from single stock management to mixed fisheries management are also explored through various scenarios.

A bigger picture

The three fisheries overviews follow the development of ICES ecosystem overviews that have been released for six ecoregions.

"ICES single stock advice address how much you can take of a stock next year in accordance with the agreed management objectives, but it doesn't say anything about how they are being taken, by whom and how it impacts the ecosystem. The fisheries overviews address this by ecoregion while ICES in the ecosystem overviews puts the fishing activities into the context of the trends and status of the marine ecosystem as a whole," explains the Chair of ICES Advisory Committee (ACOM) Mark Dickey-Collas.

"The overviews are for anyone with an interest in fisheries or management in the three respective sea regions."

Watch live! - MSC Landing Obligation seminar.

Watch the seminar

We are hosting a seminar on the obligation legislation in Brussels on 6 December from 10:00 CET. We will be showing the seminar live here.

The new EU landing obligation comes in to effect in 2019. The MSC is working with stakeholders to understand and prepare for this new EU law.


What is the EU landing obligation?
The EU landing obligation requires all EU catches of regulated commercial species on-board to be landed and counted against quota. These are species under TAC (Total Allowance Catch, and so called quotas) or, in the Mediterranean, species which have a MLS (minimum landing size, such as mackerel which is regulated by quotas; and gilthead sea bream regulated by size).

This new obligation comes in to effect in a phased approach during 2019.

Preparing for the EU landing obligation
MSC certified fisheries must comply with all relevant laws as a key condition of certification to the MSC Fisheries Standard. Therefore, the MSC is working with stakeholders to understand and prepare for this new EU law and ensure MSC certified fisheries can continue to be certified and maintain supplies of sustainable seafood.

Watch live today - Fishermen and conservation groups share views on EU’s ban on fish discards

Click on the play button to activate the video and adjust the volume level.

The EU Energy and Environment Sub-Committee continues their inquiry into the implementation and enforcement of the EU landing obligation.

• Parliament TV: Implementation and enforcement of the EU landing obligation
• Inquiry: Implementation and enforcement of the EU landing obligation
• EU Energy and Environment Sub-Committee

Witnesses on Wednesday 5 December 

Committee Room 2, Palace of Westminster

At 10.15am

• Jim Pettipher, CEO, Coastal Producer Organisation
• Jeremy Percy, Director, New Under Ten Fishermens Association (NUTFA)
• Graeme Searle, Fisherman
• Graham Doswell, Fisherman

At 11.15am

• Helen McLachlan, Fisheries Programme Manager, WWF-UK
• Samuel Stone, Head of Fisheries and Aquaculture, Marine Conservation Society

Background

The EU landing obligation has applied to some specific fish stocks since 2015, but from January 2019 it will apply to virtually all fish. It means fishermen will have to land all the fish they catch, rather that discarding fish they don't want back into the sea. Fishermen are concerned about the impact this will have on their livelihoods, but conservation groups say it is key to protecting the marine environment. Questions have also been raised about the Government's ability to enforce compliance with the landing obligation, given that it will require significant levels of at-sea monitoring. 

Likely areas of questioning

• How significant a change is the landing obligation, and why is it important?
• What has been the impact of the landing obligation to date, and what is the likely impact when it comes fully into force in January?
• What are the challenges posed by the landing obligation, and how might they be overcome?
• Is the UK ready to fully implement the landing obligation in January?

Watch or download and listen to the EU Landing Obligation enquiry.

Yesterday the Lords held an enquiry into EU regulations and in particular the Landing Obligation which, five years after it was announced will be fully implemented on January 1st 2018.

You can download an audio version here:




Discarding is the practice of throwing unwanted fish back into the sea. An average 1.7 million tonnes of fish and other marine life used to be discarded in the EU each year, because it was unmarketable, unprofitable, exceeded the amount of fish allowed to be caught, or was otherwise unwanted. Not only is this a waste of finite resource, as many fish do not survive discarding, it also makes it difficult to accurately measure how many fish are actually caught (which is necessary to monitor the health of fish stocks and prevent over-fishing).

The EU landing obligation seeks to gradually eliminate discards by requiring all catches of specified types of fish to be landed. It has been implemented in stages, beginning in 2015; by 1 January 2019 it will apply to all fish stocks for which the EU sets a Total Allowable Catch.

This inquiry will focus on the impact that the landing obligation has had to date, how it has been enforced and what challenges are posed by full implementation in January 2019.

At 10:12am Witnesses: Ms Hazel Curtis, Chief Economist, Seafish Dr Tom Catchpole, Principle Fisheries Advisor, Cefas

At 11:17am Witnesses: Mr Barrie Deas, Chief Executive, National Federation of Fishermen's Organisations Mr Mike Park OBE, Chief Executive, Scottish White Fish Producers Association Limited



It was cheering to see that local skipper David Stevens had taken the time and trouble to provide a written submission to the enquiry.

Skipper David Stevens – Written evidence (IEL0001)

My name is David Stevens and I skipper the 20m fishing vessel Crystal Sea SS 118, we work from Newlyn in Cornwall and I have 28 years experience working our family vessel.

Our vessel has always taken part in scientific projects throughout the years, mainly with CEFAS and the MMO but we have also worked with universities on different projects.

We believe that in undertaking a pro-active role in data gathering to help inform science, in the belief that this benefits the fishery as a whole.

In 2013 we undertook trials with REM remote electronic monitoring (CCTV) on board our vessel, we have since had the REM equipment running nonstop since, which is over 6years worth of data.

We did this in partnership at first with the MMO under the catch quota scheme (CQT) then with MMO and CEFAS.

We have learnt a great deal collectively under the scheme and I would say that the work undertaken is well placed to inform your committee of the challenges our industry will face.

We have one major choke species in our fishery of over 30 species which is Area 7B_K haddocks and we mainly focus our efforts on dealing with this species. However we also fully document all species we catch and run separate trials on skate by catch.

All of this work is undertaken by myself and my crew remotely using the REM equipment and once a year we take a CEFAS observer to sea with us to audit and verify what we are doing.

We have come up with many solutions to help minimize the impact of our discards, most have been very effective, but there is no silver bullet to solve the issue we face as it is too large a problem to solve with technical gear methods alone.

For example we reduced undersize fish being caught by 87% using a new technical measure in our nets and we have reduced overall catches of haddock our choke species by 37%. This has come in at an overall economic loss on all other species of 15%. However even with this much effort put in by our vessel we still faced a discard rate of over 70% for mature haddocks.

The main reasons for this species (area 7 B_K haddock) as a choke are The UK relative share with the EU, biologically this species resides in UK waters 60% of stock abundance yet the UK only has a 9% share of the EU TAC total allowable catch.

The main thing I have learnt whilst being involved with this project is that by supplying the transparency on the level we have done by using REM, we have massively increased the knowledge of the fishery, the missing ingredient to solve choke species as a whole is the lack of flexibility that we need in the UK’s diverse mixed fisheries.

In short industry transparency IE. REM gaining the flexibilities required from management (MMO, DEFRA, DG-MARE) = successful discards free fishery.

Questions raised

1. What has been the impact in the UK to date of the EU landing obligation? What

Challenges have there been to implementation?

So far the species chosen in our area have been fairly easy to implement, so no issues so far.



2. What do you expect the impact to be when the landing obligation is fully implemented?

In January 2019? What challenges may there be to implementation?

For our fishery in the Southwest it is expected that the haddock choke as it stands at present will tie the fleet up within 8weeks into the New Year.

The main challenge is the UK’s lack of quota due to its overall poor relative share of the EU quota and that the majority of this species resides in UK waters.



3. What steps could or should be taken between now and January to improve

Implementation?

The fleet will require far greater flexibilities in the area 7 haddock quota and other choke species, on haddock alone the UK has over 70% discard rate.



4. How effectively is the landing obligation currently enforced in the UK? What challenges

Have there been to enforcement

From our side we have REM equipment so we are fully documenting our catch and have no issues at present with the 3 species we currently have to not discard. The fleet as a whole has found this first stage fine, however these are the easy to achieve species the impossible ones are to come into force 2019.


5. What challenges may there be with enforcing the landing obligation when it is fully implemented in January 2019?

Enforcement may not be the issue with REM you know everything also the observer work undertaken will know the scale of the problem that exists already. It is weather; if it comes in as written at present under the CFP rules without the flexibilities required by the fishing fleets, is the UK government going to tie the UK fleet up by early next year for maybe one species in a fishery of 30 species.?



6. What steps could or should be taken to improve enforcement?

You could opt for 5% coverage per métier with REM on the fleets as a whole to give you the data you require however what is the point if this is simply used as enforcement and not to first improve data collection which is at the heart of the problems we face.

At present, observer data undertaken by CEFAS covers 0.5% of fleet activity, the same is true across the EU fleets. We are forming our whole data framework program at ICES level, on very small amounts of data, we are then using forecasting models to predict MSY levels at individual species levels. To manage diverse mixed fishery. You will never achieve MSY on all species at the same time in a mixed fishery without moving to flexible MSY levels.

The data being used in my opinion to achieve this is too limited and in some cases there is clear gaps in the data which is causing choke species within a fishery.



7. To what extent do you believe the UK is prepared to fully implement the landing obligation from January 2019?

The UK agencies have a good idea of the impacts of the landings obligation, it comes down to how much damage do the UK agencies want to cause the fishing industry.

By following the CFP rules on this issue as it stands at present we will face bankruptcy as an industry.


8. To what extent could the use of more selective technology by the fishing industry help fleets fish successfully under the terms of the landing obligation?

It will certainly help, we reduced juvenile catches by 87% using a SQMP panel in our cod ends also we reduced our haddock catches by 37% using a cut back headline on our trawls.

However we still faced a discard issue with haddocks and an economic loss on all other species of 15%, there are always tradeoffs, its flexibilities within the quota system at EU level that is required on top of technical gear measures to solve the choke species issues.



9. Are other EU countries facing similar challenges in implementing the landing obligation? How are they responding?

Certainly other EU states face similar issues on the same or other species, but I am sure there governments will take a pragmatic approach to this or in some cases the usual suspects will ignore the rules completely just as they do now.


15 November 2018


Make a not of these dates for your diaries when the next meetings will be:

05 December 2018 10:00 am Oral Evidence Session

"Implementation and enforcement of the EU landing obligation"

Witnesses at 10:15 am:

Mr Jim Pettipher, CEO, Coastal Producer Association

Mr Jeremy Percy, CEO, New Under Tens Fishermen's Association

and at 11:15 am

Ms Helen McLachlan, Programme Manager, fisheries governance, WWF-UK

Mr Samuel Stone, Head of fisheries and aquaculture, Marine Conservation Society

Room 2, Palace of Westminster

Then again on the 12th  December 2018 10:00 am there will be another  Oral Evidence Session

"Implementation and enforcement of the EU landing obligation"

When the witness at 10:30 am will be:

Mr George Eustice MP, Minister of State, Defra

Room 2, Palace of Westminster

Watch the live debate in Parliament on the Landing Obligation - starts at 10:15am.

Industry representatives and researchers give evidence on EU fisheries regulations

The EU Energy and Environment Sub-Committee asks fisheries researchers and representatives of the fishing industry for their views on the implementation and enforcement of the EU landing obligation.


Watch here live at 10:15am

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• Parliament TV: Implementation and enforcement of the EU landing obligation
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• Inquiry: Implementation and enforcement of the EU landing obligation
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• EU Energy and Environment Sub-Committee

Landing Obligation and other crucial EU fishing regulation debate.

Industry representatives and researchers give evidence on EU fisheries regulations

The EU Energy and Environment Sub-Committee asks fisheries researchers and representatives of the fishing industry for their views on the implementation and enforcement of the EU landing obligation.

• Parliament TV: Implementation and enforcement of the EU landing obligation
• Inquiry: Implementation and enforcement of the EU landing obligation
• EU Energy and Environment Sub-Committee

Witnesses

Wednesday 28 November in Committee Room 2, Palace of Westminster

At 10.15am

• Hazel Curtis, Chief Economist, Seafish
• Dr Tom Catchpole, Principle Fisheries Advisor, Cefas

At 11.15am

• Barrie Deas, Chief Executive, The National Federation of Fishermen’s Organisations
• Mike Park OBE, Chief Executive, Scottish White Fish Producers Association Limited

Background

The EU landing obligation seeks to gradually eliminate discarding (throwing unwanted fish back into the sea) by requiring all catches of specified types of fish to be landed. It has been implemented in stages, beginning in 2015; by 1 January 2019 it will apply to all fish stocks for which the EU sets a Total Allowable Catch.

Implementation presents challenges, particularly in relation to 'choke species'. These are species with a low volume of quota, that when reached will cause fishing operations to halt, even if quota is still available for other species, because fishermen will no longer be able to discard fish they catch over-quota. How enforcement agencies will monitor compliance with the landing obligation is another challenge that will need to be addressed.

Likely areas of discussion

• The scale of the problem 'choke species' is likely to pose.
• Whether changing fishing methods, or swapping quota with others, can alleviate this challenge.
• How enforcement agencies can best monitor compliance.
• Whether the landing obligation could result in increased levels of illegal discarding.
• What the UK could learn from other countries.

There will be a post to the live broadcast on Through the Gaps at 10:15am tomorrow - put it in your diary!

Implementation and enforcement of the EU landing obligation inquiry

Seems a bit late in the day but here is a chance for all those affected to offer some information, insight and thoughts on the subject.

In the South West, (especially ICES fishing areas VII e, h & g) haddock and sole are discarded by the ton from beam trawlers, trawlers and netters alike - the landing obligation will highlight both of these species as 'choke species'.

In the North Sea hake will feature in the eLogs of many vessels and become the choke species that forces vessels to stop fishing.

There are plenty of ways to air your thoughts to the  EU Energy and Environment Sub-Committee - see below. Read the guidance notes that go with the call for information.

Latest from Parliament:

Discarding is the practice of throwing unwanted fish back into the sea. An average 1.7 million tonnes of fish and other marine life used to be discarded in the EU each year, because it was unmarketable, unprofitable, exceeded the amount of fish allowed to be caught, or was otherwise unwanted. Not only is this a waste of finite resource, as many fish do not survive discarding, it also makes it difficult to accurately measure how many fish are actually caught (which is necessary to monitor the health of fish stocks and prevent over-fishing).

The EU landing obligation seeks to gradually eliminate discards by requiring all catches of specified types of fish to be landed. It has been implemented in stages, beginning in 2015; by 1 January 2019 it will apply to all fish stocks for which the EU sets a Total Allowable Catch.

This inquiry will focus on the impact that the landing obligation has had to date, how it has been enforced and what challenges are posed by full implementation in January 2019.

Call for Evidence:

• The EU Energy and Environment Sub-Committee launches an inquiry into the implementation of the EU landing obligation.

• Call for evidence: Implementation and enforcement of the EU landing obligation (PDF PDF 164 KB)

• Inquiry: Implementation and enforcement of the EU landing obligation

• Send a written submission

• EU Energy and Environment Sub-Committee

Background

Discarding is the practice of throwing unwanted fish back into the sea. An average 1.7 million tonnes of fish and other marine life used to be discarded in the EU each year, because it was unmarketable, unprofitable, exceeded the amount of fish allowed to be caught or was otherwise unwanted. Not only is this a waste of finite resource, as many fish do not survive discarding, it also makes it difficult to accurately measure how many fish are actually caught (which is necessary to monitor the health of fish stocks and prevent over-fishing).

The EU landing obligation seeks to gradually eliminate discards by requiring all catches of specified types of fish to be landed. It has been implemented in stages, beginning in 2015; by 1 January 2019 it will apply to all fish stocks for which the EU sets a Total Allowable Catch.

Questions

The Committee is seeking evidence on the following questions:

1. What has been the impact in the UK to date of the EU landing obligation? What challenges have there been to implementation? 

2. What do you expect the impact to be when the landing obligation is fully implemented in January 2019? What challenges may there be to implementation? 

3. What steps could or should be taken between now and January to improve implementation? 

4. How effectively is the landing obligation currently enforced in the UK? What challenges have there been to enforcement? 

5. What challenges may there be with enforcing the landing obligation when it is fully implemented in January 2019? 

6. What steps could or should be taken to improve enforcement? 

7. To what extent do you believe the UK is prepared to fully implement the landing obligation from January 2019? 

8. To what extent could the use of more selective technology by the fishing industry help fleets fish successfully under the terms of the landing obligation? 

9. Are other EU countries facing

Scope of the inquiry

The Committee are inviting individuals and organisations to share their experience of the impact that the EU landing obligation has had to date, and their views on what impact full implementation might have from January 2019. The Committee are also seeking comments on how effectively the landing obligation is being enforced and what the UK Government could do to address some of the challenges posed by the requirements of the landing obligation.

Chair’s comments

Lord Teverson, Chair of the Sub-Committee, said:

"Reducing discards is vital to protecting the health of our oceans. We know, however, that the landing obligation is a major change for the fishing industry and that there are genuine concerns about the impact it may have on fishers' livelihoods. It also requires a shift in how we monitor and enforce fishing regulations, and we know there is some doubt as to whether current arrangements are adequate. We want to understand the challenges that will need to be overcome, and potential solutions to those challenges, and would really encourage those with experience or interest in these issues to share their views with us."

Call for evidence published 15 November 2018. The deadline for submissions is 11.59pm on Thursday 13 December.

"Landing Obligation" 2019 - All you need to know.

There's plenty to take in with regard to the forthcoming Landing Obligation rules that will apply from January 1st 2019.

The first details the role to be played by ports, harbours and fish markets...

another with how to deal with 'choke species' - fish for which there is little quota (like haddock in ICES Area VII b-k)...

and those boats engaged in pelagic fishing - which includes ring net fishing.

A full list of the MMO documents covering all the fishing areas that surround the UK is available here.

SFF & NFFO & FFL - The Brexit debate heats up!

The NFFO response to the Fisheries White Paper back in July 2018.

The Government has published its long-awaited White Paper on Fisheries. Sustainable Fisheries for Future Generations outlines the Government’s vision for UK fisheries post-Brexit. Unsurprisingly, its headline objectives are those associated with the UK’s future as an independent coastal state outside the Common Fisheries Policy.

See the White Paper here

Priority is given to the pursuit of policies which promote sustainable exploitation of fish stocks. However, the Paper makes clear that the UK will control access over who is permitted to fish in UK waters and under what conditions. Rebalancing quota shares to more closely reflect the fisheries resources located in UK waters is also a top-listed priority.

The Government underlines its commitment to working cooperatively with those countries like Norway and the EU with which it shares fish stocks. However, the paper also makes plain that trade issues and fishing rights and management are separate issues, by international comparison and EU-third country precedent. This is important because the EU has signalled, in its negotiating guidelines, that it will seek to use an EU/UK free trade agreement as leverage to maintain the current asymmetric arrangements on access and fishing opportunities. The scale of those quota distortions, which work systematically to the EU’s advantage and the UK’s disadvantage, is spelt out graphically in an annex to the White Paper.

Comment

Overall, the Government has not been noticeably coherent or cohesive in its preparations for a negotiated Withdrawal Agreement with the EU. On fisheries however, its broad position is clear, cogent, and apparently uncontroversial - within the UK anyway. This White Paper will have required support across Whitehall, and it spells out what the UK wants and expects. This aligns quite closely with what the UK fishing industry wants and expects. The high attendance and level of interest at our recent NFFO lobby day in Parliament confirmed that there will also be very wide support across the parties for the broad approach outlined here.

Doubtless this unity reflects the widespread understanding in and beyond government that the entry terms in 1973 worked systematically and significantly to the detriment of the UK’s fishing interests - and have continued to do so over the intervening forty-five years. The UK’s departure from the EU gives us the long-awaited opportunity to address the distortions that arrived with the CFP.

The Federation has been working closely with Defra since the referendum and has submitted papers on all the policy main areas. It is encouraging, therefore, that our principal objectives are shared in the White Paper. These are:

1. The UK operating sustainable fisheries as an independent coastal state, with quota and access arrangements agreed in the context of annual fisheries agreements

2. Rebalancing quota shares to reflect the resources based in UK waters

3. Control over access to fish in UK waters

4. An adaptive management system tailored to the contours of our fleets

5. Unimpeded trade flows

The White Paper also reflects other industry priorities, including:

⦁ A flexible and adaptive national fisheries policy with the fishing industry closely involved in the design and implementation of policy. The frequency of unintended consequences of policy decisions and the need therefore to for a responsive management system post-CFP appears to be well understood

⦁ That safety considerations should be hard-wired into any new fisheries legislation has been taken on board

⦁ The need for a workable discard ban is emphasised

⦁ The removal of the artificial boundary between the under and over-10metre fleets is flagged

⦁ A measured and step-wise approach to trialling alternatives to quotas where this makes sense, is described

⦁ Producer Organisations will continue to deliver decentralised, tailored quota management in the ports

⦁ Throughout, there is an emphasis on a close partnership between the fishing industry and government

More Work Areas

However, below the headlines setting out the Government’s broad orientation, there remains much to discuss and work on. In particular:

⦁ How to operate a system of devolved responsibilities within an overall UK framework is underdeveloped in the White Paper. Discussions continue and is unlikely that arriving at a satisfactory agreement will be easy or straightforward, given the toxic politics involved.

⦁ Cost recovery before the institutional arrangements are in place to give the industry shared responsibility, as discussed in the White Paper, would be premature, unjustified and very controversial

⦁ Auctioning incoming quota is a new concept with some obvious disadvantages; it will need detailed scrutiny

⦁ The practicalities of a workable system of overage (permitting bycatches to be landed even though quotas are exhausted with a charge to disincentivise targeting) to address the problem of chokes under the landing obligation, will require close attention

⦁ Remote sensing undoubtedly has a future role to play in monitoring fishing activities: the question is how and where and how does it fit into a partnership approach based on trust and confidence?

Summary

On the big-ticket issues, the White Paper is clear and confident. To be sure, the EU27 will seek at every turn to blunt its application but in truth the EU only has one weapon in its armoury and that is the nuclear option of denying the UK a free trade deal unless the UK caves in on fisheries. That would hurt many businesses in the supply chain in the EU - at least as many as in the UK. Politically, such is the parliamentary arithmetic, that the UK government could not agree to a capitulation on fisheries and survive.

It is self-evident that the Government has much work to do on its own positions before the next rounds of negotiations. On fisheries, however, as the White Paper spells out, the big issues relating to jurisdiction, access and quota shares, are already settled by international law: the UK becomes an independent coastal state. Everything else flows from that.

Fishing for Leave however, have an entirely different perspective on Brexit claiming to represent the small-scale fishers who make up around 70% of the UK fleet.


If only so many knew the truth..

For two years Fishing for Leave have bit our lip for the sake of the wider cause of the industry and way of life we are fighting for.

However, after continued misrepresentations and protestations by the Scottish Fishermens Federation (SFF) and National Federation of Fishermens Organisations (NFFO) of their 'speaking for all the industry' we feel we can stay silent no more.

The tipping point is knowledge of discussions of agreements to stay mute on a transition deal, one that would prove disastrous for the majority of Britain's fishing, along with selling the industry a pup in exchange for maintaining the current system beneficial to a few.

The SFF and NFFO have become a corporate racket dominated by a few big quota holders and heavily influenced by EU owned but UK registered 'Flagships'

Rather than fight to replace the system that has ruined British fishing they continually pursued managed decline to a few. The consequence for so many fishermen and communities is heartbreakingly apparent to see.

After twenty years of supine retreat, when the chance to escape the CFP came they wouldn't back Brexit.

Hiding behind 'neutrality' after being ambivalent or hostile to British withdrawal since the 1990s - some heads are on record as having voted remain. Main stream and fishing media archives record all this.

They abandoned the industry they now purport to represent. It was left to the grassroots to initiate and fight under Fishing for Leave .

We alone were instrumental in making fishing one of the 'acid tests', from the Thames flotilla on whilst the NFFO and SFF hid at home.

Rather than come together following the vote, as FFL openly offered at meetings in Aberdeen and Peterhead, the SFF in particular resorted to attack FFL through proxies.

The two federations then did a volte face to control the Brexit dividend for a few and fend off what they saw as a threat by FFL banging the drum to replace a failed system (one with feathered nests for a few) with new British policy that would work for all from big to small.

As the Bible eludes beware wolf in sheep's clothing!

**FFLs repeated warnings that the NFFO and SFF are a cartel of big, mainly foreign interests, dominating the industry for a few to the detriment of the many they claim legitimacy from was vindicated by the Greenpeace Unearthed report.

https://unearthed.greenpeace.org/2018/10/11/fishing-quota-uk-defra-michael-gove/amp/

FFL would caution against one element of the Greenpeace report. Not all big are bad, small are good. Some of the biggest companies and Producers Organisation (POs), such as Interfish and Northern Ireland Fish PO back both Brexit and a fair distribution for all - sadly many of their contemporaries who are in the SFF and NFFOs policy is all for one none for all.


WHICH FISHERMEN...?

SO, after two years! of avoiding actual detail it would be great to finally hear exactly how the SFF (and the NFFO) propose allocating their much vaunted simple phrase #seaofopportunity?

1) Will it be through equal shares of repatriated resources to ALL fishers and communities as FFL propose? Or through the disastrous FQA allocation system (which have become the stocks and share unit currency that has made a national resource a corporately traded commodity) driven consolidation to a few, crushed the family fishing and communities the federations virtue signal about seeing revived?

2) Pelagic resources are the main bulk of what Britain regains...do the SFF and NFFO agree with FFL that half should fairly go to the 25 large vessels in the specialist pelagic fleet and half to all other vessels and communities? So as to recreate opportunity of seasonal fisheries and provide an adrenaline hit to struggling vessels and communities?

Why does Mr Armstrong of the SFF continually peddle the lie publicly and in parliament that 40-100ft trawlers cannot pursue pelagic species as they happily manage in Norway and Ireland?

3) The discard ban addresses the discard symptom rather than the quota cause. It is acknowledged as an existential threat to the viability

'Choke species', when vessels have to tie up on exhausting their lowest quota to avoid discarding, will cripple all bar a few of the biggest quota holders.

Why did the SFF, after talks in Downing Street, roll over so easily to a transition where the EU will be free to enforce the 2019 discard ban, bankrupt all bar the biggest quota holders, and then claim the resources we would no longer have the fleet to catch using UNCLOS Article 62.2?

4) Given no credible solution has been found in 8 years to discards or choke species being the result of quotas, why do the SFF and NFFO resolutely want to maintain quotas and the unsolvable discarding that will ruin the majority and leave only a few big players?

5) Why do the SFF and NFFO continually seek to defile the unique, world leading hybrid quota/effort control system FFL have developed to achieve discard free, soak time at sea fisheries. One generating accurate science from all catches being landed, preserving and adopting FQAs and their investment, whilst providing all a limit of time at sea to survive.

If it is doomed to fail why not support a credible trial on 20 vessels to prove it is wrong or, if it works, have a credible alternative for everyone to survive....what's to lose?

6) Why does the SFF continually make representations to government to keep quotas, & worse to keep the FQA share system that drives consolidation to few big corporates? Why are continual governmental assurance also sought for allocating all repatriated resources through the disastrous FQA system too?

7) Is the resistance to not continuing with the same failed system by moving to new better management less to do with environmental and operational concerns and more to do with preserving a quota trough for some prominent members who have their trotters firmly in it?

8 ) How can the NFFO say it speaks for British fishermen, and does the NFFO not have a severe conflict of interests, given that the government FQA register and Companies house show that the majority, around 75%!, of the NFFO membership of POs and their FQAs (and therefore the financial clout) is controlled by EU owned but UK registered 'Flagships'?

9) How can the SFF purport to speak for Scotland's fishermen when many fishermen and associations from Orkney to the Western Isles to Lothian and Fife are not in the SFF; the founding Clyde Fishermen's Association quit due to problems addressed in the questions above; and many are hugely disgruntled at the corporate racket but persist only to obtain the necessity of guard work jobs?

10) Why will the SFF and NFFO not condemn quota renting and 'slipper skippers', who SeaFish statistics show are bleeding 50-60% of the profit for reinvestment from the industry as active vessels have to pay to fish? Do they agree with FFLs position that, slipper skippers should be banned; that entitlement to fish should only be on active vessels; and that the price of swapping entitlement should be capped at 4% of the gross realised for the fish caught by that entitlement?

Quotas have trashed the environment with mass discards and trapped the industry in perpetual data deficiency on actual catches.

Quotas and the now economically prohibitive and illiterate cost of rent and purchase of FQA entitlement units has crippled community and family fishing the federations say you represent and wish to protect.

It has culled recruitment of a next generation to realise a sea of opportunity by barring a career from deck to wheelhouse. All this and yet you both lobby to keep the same failed system reviled by so many fishermen you claim to represent ...why?

We suggest it is for the same reason - preserving the status quo on quota - that stopped the NFFO and SFF backing Brexit.

Until the above Ten questions are honestly answered there is a long gap between actual fishermen and the two federations who purport to represent them.

So the choice is; come together by decrying the failed systems of the past. Say repatriated fish will be distributed to all fairly. That slipper skippers and flagships will be banned and curtailed and that we trial a potentially world leading hybrid refined effort control system that would work and give a future for ALL

...OR will the SFF and NFFO continue trying to preserve a corporate racket of quotas, FQAs discards & slipper skippers for the benefit of a few?

One thing is certain, coastal constituencies will decide on MPs choice of what is listened to... MPs and government can listen to a bright future for all or keeping trotters in the trough for a few...?