='"loading" + data:blog.mobileClass'>

Wednesday 19 December 2018

Oceana seminar - the address from Marai Damanki looking forward to 2019 and beyond.


Seminar with Oceana

Ladies and gentlemen,

As you know we are approaching the end of my term as European Commissioner; a new Commission is being formed as we speak; the fisheries reform has been in force for several months. So this is probably a good time to see how far we've got and give you some personal reflections on where to go from here.
I think we've come quite a long way. To put it upfront: we have managed to modernize our fishing and set aside short-term economic interests in favour of science and sustainability. 
By 2019 we will no longer be throwing away by-catch but using it as food, feed or raw material. Countries have started fine-tuning management rules to the specific conditions of each fishery.  
We have some new Advisory Councils and their composition has changed in favour of small fishermen and civil society. 
We have gone from 5 stocks being fished sustainably in 2010 to 27 today – and counting. 
We also put an end to the gruesome practice of shark finning.
Internationally, we have been pushing for sustainability with all our partners; when we fish outside the EU, we make sure it is with no detriment to fish stocks or local communities. We have helped the recovery of the Eastern Atlantic Bluefin tuna stock. We have overcome dragging disputes with the Faroe Islands, Island and Norway about mackerel and other pelagic stocks. Our strict course of action against illegal fishing has led to banning imports from some countries. I think we can fairly say that on the sustainability front the European Union has been leading by example, and has set itself an agenda to maintain that role.
All this doesn’t mean of course that the battle is over. I am underlining the positive results to convey the message that it can be done. But my successor - and you of course - will have a lot to do for the implementation of all this. I have tried to make it irreversible, but we all know that the devil is in the details. Let me now share some of my experience with you.
The fisheries reform was all about change – relinquishing old models and going for new and long-lasting solutions, in fisheries as in ocean affairs in general.  And change is never easy. There was considerable inertia to overcome, both in the Council of Ministers and in the European Parliament. We had also against us vested interests in fisheries industries and in the markets. 
So we turned to consumers and informed citizens. We turned to other important players, especially non-governmental organizations, and got their support on sustainability and long-term plans. On discards public indignation was mounting, with celebrity chefs helping our case, and we managed to ride that wave too.
On paper Europe was already committed to sustainability, but in practice Member States kept staving off the deadlines for it. Getting by, procrastinating, protecting the status quo had become the norm.  Here is the importance of setting a deadline – ambitious, realistic, binding. I have been pushing towards sustainability since the beginning, and this has allowed us to prove with concrete examples that once it is achieved, fisheries give higher yields.  This definitely has helped to bring many reluctant Member States on board.  
The landing obligation has been one of the most contentious issues – and is one of the most important structural changes. Public support for my proposal put pressure on the opponents. But reform-oriented groups in the Parliament and in the Member States also played their part. Like for instance the Danish minister who took the Presidency in a crucial phase of negotiations in the Council. 
On other points, such as regionalization or the international dimension, we drew our force from experience and from criticism against us.  It was clear for instance that the Brussels micromanagement model could no longer hold. So here we offered elements of power to the national governments and the MEPs in exchange for sustainability. 
We improved the relationship between the Council and the Parliament. There had been tension between the two since the introduction of co-decision in 2009; the stalemate on multiannual plans was that tension's most overt expression. Tactically, we had to break through this pattern to make progress. We managed to agree that the stalemate and the reform were entirely separate issues. A dedicated Task Force would take care of the multiannual plans right after the finalization of the reform negotiations. Then during the reform we made sure that elements like fleet management or national quota allocation remain in the hands of the Member States. This gave the administrations confidence that they would keep control over policy implementation. And we pointed out that regionalization gives them even more freedom to cater to specific problems and situations as they deem fit. 
At the same time, to satisfy the ambitions of Parliament, we made fleet management and quota allocation entirely transparent – with an obligation for Member States with overcapacity to come up with solutions.  
Not only was this trade-off found acceptable, but it also helped to improve relations between the three institutions. So it created a basis for a speedy agreement on the multiannual plans - which both complies with the Treaty and is mutually satisfactory. So on top of everything else, the reform helped us overcome an institutional problem that had blocked us for five years.
In sum, ladies and gentlemen, 
I'm quite happy with the results. The Commission's main ambitions were materialized.
But of course the worst thing we can do now is rest on our laurels. The reform is not an end in itself. Sustainability is. And it carries a whole lot of work and a whole set of new challenges.  
Sustainability is now in the law but is yet to be achieved throughout the Union, and should also be the ambition internationally. There is a clear mandate and so we'll have to adjust the quotas accordingly, in the coming years. For this we imperatively need to keep improving our biological knowledge and advice.
For landing obligation we need to find and apply effective, sensible measures which do not prevent the fleets from functioning normally. The policy allows for flexibility. But this should never undermine the goal itself .We should not let the strict ambitions out of sight. 
We need to go back to our long-term management approach by developing a whole series of multiannual plans. This is good for the resource and for the stability of the industry.
We can now move away from micro-management and regionalization is already underway.  But from a regulatory viewpoint the process also requires a hefty clean-up: for instance over the last three decades the technical measures have layered up into an almost inscrutable maze of rules and detailed requirements. We have to find our way back to a lenient set of rules that are sensible, flexible and serve their purpose. This has to go hand in hand with inclusive stakeholder consultation, paying particular attention to the interests of small-scale fisheries.
Internationally we have made giant steps, but we need to keep the pace to improve the operation of RFMOs by reforming them and supporting them as a leading player in the process. The eradication of pirate fishing and overcapacity are expected to continue to be high on the list of international priorities.  And we need to remodel all our bilateral agreements according to our new standards. Here I have some good ideas still to be implemented and I hope we can continue the cooperation with you and other partners for this. 
These and other challenges stem from the reform. It will take time to materialize, for recovering stocks to grow, for a career in fishing to become attractive again or for responsible management to become the norm worldwide.
Most of all, we will still need the input - and the pressure - from civil society. It will be up to them to make sure that we stay the course.
But with a clear idea of the tasks and clear deadlines we are in a position to continue to build on the strong foundations set during these five years. I am confident that Europe will recover and prosper with more fish, more wealth and more coastal and maritime jobs. 

San Sebastian, 9 September 2014
Speech by Maria Damanaki





EU AgriCouncil agree new quotas for 2019 - South West winners and losers.


Snapshot of next year's quotas hot off the press from Brussels. The usual mix of good and bad for south west fishermen - then it's down to the MMO and Defra as to how the grand totals are allocated - especially crucial for the Under 10m sector.

Here's the document in full:


Winding down for Christmas, it's the penultimate fish market of 2018 in Newlyn.


The netters Ajax...



and Silver Dawn...



landed their final hake trips...


while the beam trawlers like the Fildelfia do their bit to keep the local crabber fleet supplied with bait...


and the merchants well supplied for Christmas with quality fish like these brill...


cuckoo ray...


red gurnard and red mullet...


John Dory...


haddock...


and even a few bass for the Aaltje Adriaantje...


along with a good run of plaice...


while the Lisa Jacqueline weighed in with some cracking lemons...


and monk...


and added to the Dover sole landings along with the Filadelfia...


together with a few boxes of cuttles...


take the money or lift the box...



the buyers are looking at the penultimate auction of the year...


which has seen more of these gree-eyed...


spur-finned dogfish than for many years landed to the market...


once conger eels were landed by the tn when there was a longline fleet working in the port - Bill Tonkin and the Bonny Mary once caught 660st (4000kg) from a single night's fishing...


longliners also targeted ray and skate back in the 60s & 70s...


as the netter fleet ties up for the big spring tide over Christmas...




it's good to see skipper Dwan make an effort to inject some festive spirit aboard the boat...


along with some of the workshops down the quays...


over in Penzance Dry Dock the Scillonian III is still undergoing her annual refit...



while the Coop makes a delivery for the Scillys supply ship, Gry Maritha...


as Tom maintains his ever-watchful eye over the Western Approaches.

Tuesday 18 December 2018

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."

Bulk carrier, Kuzma Minin has run aground off Falmouth's Gyllyngvase beach.





VesselTracker's AIS app shows how southerly winds up to 60 mph have forced the 183m long Russian bulk carrier Kuzma Manin to drag her anchor off Gyllyngvase Beach at Falmouth in the early hours of this morning...



the huge carrier is lying beam on this hugely popular summer beach... 




with the Falmouth lifeboat Richard Cox Scott and the Falmouth harbour tug, St Piran are in attendance.  With no big rescue tug stationed in this part of the UK the local Falmouth tugs will be faced with a huge challenge to re-float the ship at high water, around 13:10 this afternoon.


The Kuzma Manin had recently sailed from the Dutch port heading west.

In September earlier this year 20 Russian crew members were stranded since May 15, 2018, on the Kuzma Minin in the Dutch bulk port of Terneuzen because the shipping company could not meet its payment obligations. The crew could not disembark, because they would then have to renounce their wages and other schemes. The Ferns Centre Foundation has decided to organize a fundraising campaign, because the crew has been left to its fate and has not had fresh fruit for months, almost no money and also needed all kinds of products. They have to pay their contract or they will no longer receive any wages. The shipping company already has several ships under detention due to major financial problems. A collection for the crew started on Sep 24. There were already two bags with groceries ready to be brought on board.



The Sevenstones Lightship off Lands End has seen the southerly winds steadily increase to nearly 50 knots in the last few hours - the worst possible wind direction for a casualty on the south facing coast of Cornwall.
 


And it's not looking too cracky here off Newlyn on the webcam this morning either!


Successfully re-floated in the afternoon - a satisfactory outcome and a credit to all those involved in challenging conditions.


Monday 17 December 2018

NFFO - THE EU LANDING OBLIGATION: CONTINGENCY PLANNING FOR CHOKES MUST BEGIN NOW

The December Council meetings are livestreamed.
Click on the image to open the livestream.



December Council. Despite a four-year phase-in, it seems highly unlikely that the Council of Ministers, which begins today, 17th December, will resolve all the outstanding problems associated with the implementation of the landing obligation.

Legislative Design Faults

We can expect that some progress will be made over the next three days but a widespread recognition has built over the phase-in that the landing obligation, adopted as part of the 2013 reform of the CFP, is a deeply flawed piece of legislation. It is also clear that there are there are no easy solutions at hand:

  • The problem of chokes in mixed fisheries (where the exhaustion of one quota will preclude a vessel from catching all its other quotas) is by far the problem with the most serious far-reaching consequences
  • There remain conflicts with other CFP regulations which either contradict, or are at least not consistent with, the requirements of the landing obligation. These include:


  1. The EU technical conservation regulation, currently under revision but so far stuck in limbo between the EU Parliament, the Commission and the member states
  2. The EU control regulation is also undergoing revision which will take around two years
  3. The absence of a multi-annual plan for Western Waters which could help mitigate chokes by allowing quotas to be set within a range of fishing mortalities consistent with maximum sustainable yield
  4. Relative Stability, the EU formula for distributing quota between member states, means that what quota there is, is frequently in the wrong place to deal with chokes. It is not known whether the system for quota swaps and transfers will be adequate to the task, given that fishing groups and member states are likely to want to hold onto quota to deal with their own domestic chokes
  5. The 2020 deadline for all stocks to be managed at MSY is both biologically unachievable (because of natural variability) and a self-imposed constraint that will intensify the choke problem in some fisheries
  6. The means to effectively monitor and enforce the landing obligation are simply not there because the new policy was adopted with inadequate preparation
  7. Minimal attempt has been made to prepare the fishing industry for the major change ahead through comprehensive guidance, not least because the rules are still being constructed, a fortnight before they are due to come into force


Against, this background of legislative confusion, it is no surprise that many in the fishing industry have adopted a wait and see attitude.

No Magic Wand

Despite its design flaws, because the landing obligation is welded into the basic CFP Regulation, there is little prospect that it could be revisited before the next CFP reform in 2023.

The realisation that the full implementation of the landing obligation “presents serious challenges” is now widely shared amongst fisheries administrators, enforcement authorities, and throughout the fishing industry and throughout the supply chain. All those concerned with the practical implementation of the policy confront the difficult reality that there is no magic wand and that we are about to enter a period of painful and complex adjustment which carries serious risks to fishing businesses, crews and established fishing patterns. Also under threat, are the scientific models which inform stock assessments. These require accurate data and depend on looking backwards to predict forward. This knowledge provides the basis for the sustainable management of our fish stock and anything that undermines its reliability, undermines our ability to manage our fisheries effectively.

In recent weeks, senior figures in fisheries management have described the choke problem as “intractable”, the landing obligation as “unenforceable”, and full compliance with the landing obligation as indivisible from choke risks. The risks are now clearly recognised but solutions are only partially in place.

Commitment to a Workable Discard Ban

Thankfully, despite the cluster of unresolved issues, we detect a maturity and level-headedness within the fishing industry and amongst decision-makers about http://nffo.org.uk/news/landings-obligation-statement-of-intent.html finding a way forward.

Constructive discussions have been held involving government, fishing organisations, processors and retailers. These talks have provided a common understanding of the issues. There is a commitment and sense of joint responsibility to work towards a workable version of the landing obligation. The NFFO and others have recently given evidence to a House of Lords enquiry into the issues associated with the implementation of the landing obligation. The Committee’s report is likely to bring the issues into stark relief, and hopefully will point to ways in which discards policies have been successfully implemented in other countries.

Period of Adjustment

The magnitude of change represented by the landing obligation would require a period of adjustment, even if the legislators had delivered a coherent and consistent set of rules and prepared the ground properly. The fact that they didn’t, particularly in the failure to provide adequate tools to deal with chokes in mixed fisheries, ensures that the period of adjustment will be more turbulent than would otherwise have been the case.

A great deal is at stake. Unless we move carefully, livelihoods and the progress that we have made in putting our fisheries on a sustainable footing over the last two decades are now jeopardised.

Against this background, the NFFO has called on ministers to begin contingency planning. Chokes will be difficult to predict with accuracy but tying vessels or fleets to the wall when they have significant quotas left is not a politically, ethically, or socially acceptable option. What will happen then?

It will also be important to guard against unintended consequences, such as disruptive displacement effects, as individual vessels, or fleets, seek to avoid the consequences of chokes.

All this requires contingency planning, with a strong dialogue between the fishing industry, fisheries administrators, control authorities and key players in the supply chain.

Brexit

The full implementation of the landing obligation takes place against the background of the UK’s departure from the EU. If a way is found through the current political turmoil to a withdrawal agreement, the EU landing obligation would be part of the CFP rules that would continue to apply during any transition period. In those circumstances, the UK’s ideas for mitigating choke risks (outlined in the Fisheries White Paper and legislated for in the Fisheries Bill) would have to wait on the sideline. In the case of a no-deal scenario, the UK would become an independent coastal state from 29th March and immediately have more flexibility to vary its approach, although within the context of a legal obligation to cooperate in the management of shared stocks, and against the background of an abrupt rupture with the EU, which would carry its own consequences.

Contingency Planning

Having recognised and acknowledged the profound problems generated by the landing obligation, the immediate priority has to be to prepare to intervene to address the consequences of this flawed legislation as they arise.

Sunday 16 December 2018

FISHERIES COUNCIL 11TH DECEMBER 2018 IN DOMESTIC FISHERIES POLICY, FISHERIES SCIENCE





The December Council of Ministers will not only be the last in which the UK participates but one of the most complex. A perfect storm of conflicting regulations means that ministers face a number of unpalatable choices and trade-offs. These conflicts include:

⦁ Full implementation of the EU landing obligation (discard ban) from 1st January

⦁ Setting total allowable catches consistent with achieving the MSY objective by 2020 for all harvested stocks

⦁ Avoiding serious choke risks

⦁ Meeting the EU objective of managing fisheries in a way that is consistent with long term sustainability and generating social and economic and employment benefits

⦁ Basing TAC decisions on the most recent scientific advice, including advice for zero catch in specific fisheries

It is clear that not all these objectives can be achieved simultaneously, and so ministers must find a way through to the most reasonable trade-offs.

Chokes could emerge with almost any stock, depending on changing scientific advice, whether TACs have been set at the right level or the rate of quota uptake. The stocks in which these conflicts are at their most acute, however, are:

⦁ North Sea cod

⦁ Celtic Sea haddock

⦁ Irish Sea whiting

North Sea Cod

After more than a decade in which low fishing mortality (pressure) has led to steady increases in the spawning stock biomass, lower than average recruitment and a change in the scientific perception of the stock has led to ICES advice for a 47% cut in the TAC. If fully implemented this reduction would make cod an acute choke risk for haddock, saithe and whiting and other economically important species. As a jointly managed stock, the EU and Norway will probably set the TAC with a lower level of reduction, possibly -33%. This will still present fisheries managers and the fishing industry with a choke risk during 2019.

The TACs for North Sea joint stocks, were agreed at the EU/Norway negotiations held in Bergen and London which concluded on 7th December. The agreed TACs are as follows:

TACs

⦁ Whiting: -22% reduction (MSY Approach).

⦁ Cod: -33% (FMSY).

⦁ Haddock: -31% (MSY approach).

⦁ Saithe: +18% (MSY approach).

⦁ Plaice: +11% (MSY approach).

⦁ Herring: -35.9% (Fpa). The block between Denmark and Norway’s positions on cuts to the industrial bycatch fleet was eventually resolved with a smaller reduction being accepted and a working group established to discuss this further next year. The stock will be stepped back to MSY in 2020 instead of taking the full cut advised by ICES (-51%).

There is an outstanding issue on whiting, relating to the scale of deduction relating to a de minimis exemption for part of the fleet. The magnitude of the Commission’s calculations are being challenged.

Celtic Sea Haddock/Cod

Haddock in the Celtic sea is caught along with cod and whiting and a range of other species. Zero catch advice for cod means, if acted upon in management decisions, vessels would be immediately choked and have to cease fishing in the Celtic Sea. One solution that has been proposed is the introduction of a “Union quota” for cod in which bycatch quota is pooled for use of those who need it to avoid chokes. To date, however, there has been no consensus on how such a system should operate. Discussions continue on how to resolve this dilemma.

The choke risk for haddock lies with the UK’s low quota share and a reduced TAC. The UK share of Celtic Sea haddock quota is 10%. The French share is 66% (although the bulk of the catch is made in UK waters). Industry has been working with scientists on enhanced selectivity but this multi-faceted problem will not be solved without a TAC set at a realistic level.

Irish Sea Whiting

Historically there have been very high discards of whiting caught in the nephrop fishery because small whiting has a very low market value. There has been significant progress in introducing more selective fishing gear but whiting remains as a stubborn choke risk. This is a fishery in which the TAC serves no purpose and does not constrain fishing mortality. Against this background, the only solution appears to be the removal of TAC status or listing whiting as a prohibited species. Whichever of these options is taken, whiting will be returned to the sea in 2019.

Scientific Advice and Management Decisions

It is important to understand the distinction between scientific advice, and management decisions, not least because there are individuals and organisations in the NGO community, who routinely suggest that any difference results from irresponsible ministers and industry pressures.

In fact, ICES scientific advice is the basis for all TAC decisions but catch advice generally includes a range of options for managers to consider. Managers (in this case fisheries ministers) have a responsibility to balance this advice with a range of other responsibilities, including:

⦁ Discard reduction and implementation of the landing obligation, including mitigation of choke risks

⦁ The management of mixed fisheries, where a number of species are caught together and a TAC decision on one species has implications for others

⦁ Socio-economic impacts (a staged approach to TAC reductions, where these are necessary, is a frequently used approach)

⦁ Building stocks to deliver high average yields (usually understood in terms of maximum sustainable yield)

It is important that these management responsibilities and the trade-offs that they necessarily entail and properly understood.

The general stocks picture, across all species groups in the North East Atlantic, is best captured in the following statement:

"Over the last ten to fifteen years, we have seen a general decline in fishing mortality in the Northeast Atlantic* and the Baltic Sea. The stocks have reacted positively to the reduced exploitation and we're observing growing trends in stock sizes for most of the commercially important stocks. For the majority of stocks, it has been observed that fishing mortality has decreased to a level consistent with Maximum Sustainable Yield (MSY) – meaning levels that are not only sustainable but will also deliver high long term yields.” (Our emphasis)

Eskild Kirkegaard,

Chair of the Advisory Committee,

International Council for Exploration of the Seas

*Includes the North Sea

Landing Obligation

In the last two weeks, Fisheries Minister George Eustice has described the problem of choke risks as “intractable”. During the same period, a senior CEFAS scientist told a parliamentary committee that the consequence of fully enforced landing obligation would be chokes. Finally, a senior fisheries regulator recently described the landing obligation as “unenforceable”. These comments provide an idea of the scale of the challenge presented by the implementation of the landing obligation. Against this background the NFFO has entered into urgent discussions with the Marine Management Organisation and Defra to prepare for the full implementation of the new regime in the New Year.

Statement of Intent by the the National Federation of Fishermen’s Organisations

Background

The EU landings obligation comes fully into force on 1st January 2019 and will then apply to all quota species, unless a specific de minimis or high survival exemption applies.

The full implementation of the landing obligation presents a number of challenges for the fishing industry, fisheries managers, and enforcement authorities, on a scale of magnitude not seen before. The problem of chokes in mixed fisheries, and the challenge of monitoring and controlling fishing activities in diverse fleets across a vast marine environment are at the top of the list of those challenges.

The regulatory regime underpinning the landings obligation is still in a period of adjustment, with important decisions still to be made at the December Council and beyond which will have a direct bearing on choke risks in specific fisheries.

There is a recognition that the year ahead could carry a number of serious risks to the economic wellbeing of the fleets and the integrity of the management regime.

Against this background, the Marine Management Organisation, Defra and the NFFO met in London on 4th December to discuss how to deal with this complex of issues in the coming year.

Draft Statement

Dealing with Chokes in 2019

1. We are entering a difficult period of adjustment in which a pathway to compliance is not yet clear

2. 2019 will be challenging in terms of:

⦁ Choke risks

⦁ Potentially low levels of compliance with the landing obligation in some fisheries

3. The fishing industry and fisheries regulators should have a common objective in achieving a workable landing obligation and a high level of compliance

4. There is a need to prepare to deal with contingencies that may arise during 2019

5. Within a collaborative approach, a forum is required to bring together the insight and experience of vessel operators, producer organisations, the MMO and Defra, to deal with implementation issues as they arise. As well as responding to specific current issues, the forum could also provide a space in which new methods of monitoring and control, such as reference fleets and remote electronic monitoring, could be discussed.

6. The overarching principle guiding the group should be that achieving a workable landing obligation and high levels of compliance, is a joint endeavour, with shared responsibility on vessel operators, producer organisations, fisheries managers, enforcement, control authorities and Defra policy officials. All affected parts of the fleet would be invited to participate in the work of the group.

7. It will be important to send a public statement that the group has been formed and is focussed on developing solutions to outstanding problems

NFFO December 2018