29 June 2011
We welcome the Commission’s clarification over the definition of the term “overfishing”.
1. “Overfishing”
We welcome the Commission’s clarification over the definition of the term “overfishing”. In the public mind the term is associated with extinction or collapse and the Commission has not been careful in the past to make clear that its use has been changed to indicate failure to exploit to full potential. This is an important clarification.
2. Improving Fish Stocks
We also welcome the Commission’s acknowledgement that fish stocks in European waters are improving. Important progress has been made in the Atlantic zone and, although we agree with the Commission that this is good news and that it shows that “determined action makes a difference”, we probably do not share with the Commission the same view as to which measures have made a difference.
3. Maximum Sustainable Yield
The RACs have submitted advice to the Commission explaining that the current Commission approach to achieving maximum sustainable yield by 2015 is flawed, principally because it fails to take account of the implications of exploitation in multi-species fisheries. We await the Commission’s response to the points made by the RACS and the alternatives proposed.
4. North Sea Saithe
The Communication suggests (Section 2) that all stocks in the North Sea except plaice, haddock and herring are overfished; however it previously indicates (Section 1) that saithe was one of the North Sea stocks that are known not to be overfished. This apparent contradiction requires clarification.
5. Council Decisions
In various places within the Communication the Commission indicates that the TACs adopted in previous years exceed scientific advice by a range of percentages, in what appears to be an implicit criticism of the Council of Ministers, the RACs and the fishing industry. We would make the following points in response:
ICES advice to date has been exclusively biological, taking no account of socio-economic consequences; it therefore, by default, falls to the Council, as responsible fisheries managers, to factor-in the socio-economic dimension, in an appropriate and balanced manner, including the time-frame over which to phase necessary TAC reductions
To date ICES has provided advice in a single stock format: As responsible fisheries managers, the Council when agreeing TACs, is obliged to make judgements based on mixed fisheries considerations, not least on the extent to which discards will be increased or decreased by TAC changes
6. Data Poor Stocks
We are well aware of the data deficiencies that prevent in the region of 60% of ICES stock assessments from achieving analytical status. The Commission advances four actions to resolve this unacceptable situation. The first is a 25% reduction in the TAC and fishing effort for data poor stocks, “unless scientific advice indicates that a bigger reduction is necessary because of short term risks to the stocks”. We would make the following points:
A 25% reduction in the TAC (“and effort”) for data deficient stocks would be misconceived, punitive, disproportionate, and counterproductive,
It would generate additional widespread discards in mixed fisheries
It would also be grossly inequitable, as the consequences of a TAC reduction would fall on all member state fleets, whereas the data problems may only arise from a single member state
It would also be inequitable in that the consequences of shortcomings of member state authorities would be made to fall on the stakeholders in the fishing industry; this cannot be just.
The NSRAC and NWWRAC have held highly productive discussions with ICES during the course of this year on how to resolve the problems of data deficiencies in stock assessments, through a collaborative, stock-by-stock approach, identifying specific problems, responsibilities and remedial actions. A crude, clumsy, belated and coercive approach that beats stakeholders for the misdeeds of others is not a helpful or logical approach.
We agree with the Commission’s other three suggestions:
Member states should devote sufficient resources and urgently deliver the necessary information
Scientific agencies should be tasked in resolving the data problems
Indicators from commercial fisheries and from scientific surveys should be used to develop some robust rules to guide fisheries towards sustainable exploitation of resources in data poor situations
We would add that we fully support ICES’s work in developing new and simpler assessment models that are less data hungry, capable of using industry generated data, and therefore of greater utility.
7. Fishing Effort
The use of fishing effort to underpin TACs rests on an important assumption: that there is a significant and causal correlation between a reduction in fishing effort and a reduction in fishing mortality. We have yet to see any evidence that this is the case. In fact the experience of effort control, within the cod recovery and cod management plans, suggests that at very best there is a very weak causal link; the complexity of administrating effort limits in multi-jurisdictional, multi-species, multi-gear fisheries amplifies our view that this is not an instrument that is fit for purpose. To follow the provisions of the Cod Management Plan in 2012 (which specifies a further round of effort reductions) would be to ignore this body of evidence; and would apply extreme economic pressure to the handful of vessels in a minority of member states that are seriously constrained. There is no reason to believe that this will contribute to rebuilding cod stocks.
8. Long Term Management Plans
We support the development of long term management plans as a means of moving away from a continual cycle of crisis management. It is our frustration however, that the time necessary for developing well-founded, stakeholder-led, LTMPs is eroded by the more immediate pressures of dealing with extreme proposals such as the present one on data-deficient stocks. We will continue to work with ICES scientists in this area.
9. North Sea Herring
Although the Commission’s paper states that an ‘MSY TAC has been set for North Sea herring’ this is misleading as the 2011 TAC for this stock was set at 200,000t whereas an MSY TAC calculation (using fmsy) would have given a TAC of around 370,000t. This very large difference has been caused by a 15% limit having been placed on the annual TAC increase by the EU/Norway management plan (which will be reviewed in 2011) and a large upward revision of the SSB by ICES in the light of new scientific data.
ICES advice suggests an MSY TAC for 2012 in the region 478,000t. However, if the current management plan is rolled forward the proposed TAC will be 230,000t (+15%).
The situation clearly highlights the importance of building in the possibility of adjusting management plans in the light of new scientific data.
10. Working Method for Proposing TACs
- Long Term Management Plans: Where LTMPs have been developed with stakeholder involvement and are well founded, they have our support
- We have submitted our views on the “MSY Framework approach” and await the Commission’s response
- We strenuously reject the Commission’s approach to setting TACs for data-poor stocks