Consultation on the Introduction of Catch Recording for licenced fishing vessels in boats under 10 metres in length.
Response by the National Federation of Fishermen’s Organisations
New Requirements
Defra, Welsh Government and the Marine Management Organisation are consulting on a new requirement for mandatory catch reporting for the under-10 metre commercial sea fishing fleet in England and Wales.
If enacted, the new requirement would oblige all under-10m vessels to provide catch information on species subject to quotas, catch limits or effort restrictions, via a mobile device (a smart phone or tablet), prior to the fish leaving the vessel. Vessels which only catch non-quota species would be required to record their catches via a smart phone or lap-top within 24 hours.
In addition, for all catches, (quota and non-quota), a declaration would be required within 48 hours providing accurate weights of all species landed.
Purpose and Intention
We agree that the under-10m sector continues to be disadvantaged by patchy and incomplete collection of catch data. Stocks such as skates and rays, which are important for many small-scale vessels, when categorised as data-limited or data-poor, have been subject to a fundamentalist interpretation of the precautionary approach, triggering 20% annual reductions in TACs over successive years. The consequence has been a severe reduction in fishing opportunities and loss of earnings for the fleets concerned. The EU landings obligation has increased the risks associated with data gaps exponentially. The skates and ray fishery illustrates the type of circumstances where improved catch data could be used to channel policy and management decisions into a more constructive direction for the small scale fleets.
Accurate catch data is likely to become more important in the future. In addition to choke risks, the design of light touch management measures for genuine low impact vessels is likely to require better catch data from the small-scale fleets than has been the case to date. Understanding the individual vessel and aggregate fleet exploitation rates are central to the design and application of management measures appropriate to the stocks and fleets concerned.
We also agree that modern technology (smart phones, tablets and lap-tops) can play an important role in collecting and transmitting data in ways that are more efficient than paper log-books. There are advantages associated with technology that can minimise reporting requirements by eliminating duplication. Systems can be updated quite simply through software updates.
Caveats and Concerns
Having made these points, we consider that the consultation reflects a regulatory approach that:
Is insufficiently grounded in an understanding of the practicalities involved, or the specificities of the fisheries concerned
Has made little attempt to establish a meaningful dialogue about the practical implementations issues with those who will be affected
Pays insufficient attention to the range of fishing operations, type of vessel, and patterns of landing in the under-10m sector
Suggests a blanket bulldozer approach, when a more discriminating application would deliver better results
Potentially threatens to criminalise small-vessel operators for non-compliance, when the ability to comply is outwith their hands.
Potentially risks not catering for those who are not literate in the use of computers or electronic smart-phone technology
A good idea can be spoiled by poor implementation and this consultation carries the hallmarks of a recipe for, if not wholesale failure, then sub-optimal outcomes.
Our advice is to avoid the arbitrary timetable proposed and move away from a blanket approach. Instead, begin a national conversation with the different small scale fisheries in the ports and creeks about the pros and cons of improved data and the means available to secure it. This will certainly involve effort and delay but our considered view is that in the long run it will deliver better outcomes.
The list below provides a sample of the concerns raised by our members in response to the consultation. At the very least, they give a flavour of the gulf between the consultative proposals and the real world concerns which have arisen in response from very diverse fisheries.
Members’ Specific Concerns
- A requirement to submit a catch report before the boat land is impractical and in some circumstances is unsafe from a navigation and safety at sea perspective. Submission within 24 hours would make more sense
- There are practicality issues associated with the use of mobile phones in an open boat. There should be some recognition of this.
- In some instances, individual fishermen will be landing a significant number of different species – e.g. up to 30. The amount of time that the fishermen will then be required to spend entering data on a mobile app before disembarking and landing fish could be considerably above the estimates provided by Defra.
- In addition, the risk of mistakes was underlined given the requirement to complete declarations before disembarking when fishermen were often tired after long hours at sea.
- As presented, there is no mention in the Consultation document of recording discards for non-quota species (and MCRS may vary around the country) – how are such requirements to be enforced?
- There is also the question of presentation and how weights are to be recorded – e.g., for gutted fish the conversion factors to be used (not all fishermen in small vessels will automatically have the conversion factors in their heads).
- Reservations were expressed about Data Protection and what information was to be transmitted, and to whom, post-Brexit.
- Questions were also raised as to how the iPads, etc. would feed into the International Catch Certificate requirements and the EU fish transport documents.
- Considerable scepticism was expressed about the amount of duplication, or worse, involved in the weighing process – weights on landing, weights on arrival at auction where sorted and graded and then weights again on sale (bureaucracy gone crazy?).
- At a practical level, concern was also expressed about possible losses of connection and how they were to be dealt with, as well as the usual reservations about service when there are communications problems or technical glitches.
- Is it intended to, at least for an interim period, continue with a back-up paper system – and if so, does it also have to be expanded to cover the additional fisheries?
- Particular concern was expressed by the shellfish sector where there are already considerable reporting requirements in place: MSAR monthly returns for crab and lobster; IFCA returns for cockles and mussels; whelk returns; Shellfish Registration Documents for cockles, mussels and whelks. The question arises as to how all these returns (and other similar returns) are to be integrated into the new system. At the present time, considerable additional data is recorded (e.g. cock and hen crabs) in much finer detail – is this to be lost? Or are further burdens to be placed upon fishermen?