NFFO representatives meet new Minister

NFFO Chief Executive Mike Cohen; Executive Committee members Juliette Hatchman, Chloe North, Steve Parker and Martyn Youll; and several NFFO members met with newly appointed Minister of State Daniel Zeichner yesterday. The Minister was visiting Brixham, to hear about concerns and priorities in one of England’s busiest fishing ports.

While it was clear that Mr Zeichner was mainly there to listen and to learn, he also spoke about some of the government’s early thinking that would affect the fishing industry.

Food security was seen as a high priority for the new government and the fishing was acknowledged as an important contributor to that, which the government was keen to support. He emphasised the need for stability, following an extended period of parliamentary and national turmoil, suggesting that we should not expect to see any radical changes in fisheries policy any time soon. Like the Prime Minster last week, he focused on economic growth and was happy to acknowledge that, properly supported by government, our sector has a part to play in this.

There were no major announcements on Thursday but what the Minister said and did was, in a considered and understated way, far from insignificant. Less than 72 hours after his appointment he had already been aboard an under 10m netter and an over 10 m beam trawler, talking fishermen and learning about their businesses. There is a clear message of respect and support here, in both the timing and the action, for our industry as a whole and for the fleet diversity that makes it successful.

The priorities of his government – food security, economic growth – are things that our industry can contribute to and benefit from. If they are true to their word, then a government looking to promote economic growth will see fishing not as a problem, but as part of a national solution.

Tellingly, this was not a Minister offering us grand gestured and quick fixes. We’ve had tub-thumping politicians making easy promises before and they were quickly shown to be cynical and hollow.

Maybe the steady and serious approach is worth a try.

We have now passed the halfway point of this general election campaign. Last week saw the publication of the last of the major party manifestos. Fishing is an important industry, but one about which most people have little knowledge, so we can hardly be surprised if the concerns of our industry are not the priorities of the nation. Some manifestos have featured fishing and maritime matters explicitly, if mostly briefly. Others have been more notable for what they have left unsaid.

Manifestos are advertising. They are inducements to the general public to vote for the politicians who write them. There are values associated with fishing – hard work; self-reliance; physical bravery – that some of those politicians want to emulate. It takes more than having your photograph taken clutching a lobster to acquire those traits, but there will always be some on the campaign trail who think it worth the attempt, so the staged photo opportunities around fishing boats and harbours are bound to continue.

Bold and brash promises are freely made in manifestos, but frequently forgotten once power has been won. We can all remember what was said ahead of the Brexit referendum and we all know how little those promises were worth in its aftermath. The time for real work comes when the campaigning is over, a new parliament is in session and the difficult, painstaking and unglamorous job of studying, managing and developing our fisheries resumes.

If the opinion polls are to be believed, we are likely soon to have a different government. This is a point of change, then: a moment to take stock and consider what could be done better. There are many detailed suggestions that could be made for improving fisheries management and the NFFO will engage with the new government on all of them at the appropriate time. For now, though, I’d like to propose 5 important general ideas for politicians to bear in mind when they are developing specific policies.

Food

Above all else, policy makers need to remember that fishing is about food. It is not a conservation problem. It is not a heritage activity, or a hobby. It is a modern industry that produces food.

People are finally waking up to the fragility of a food supply system that is over-reliant on time-sensitive imports and the rapid, affordable international transport links that make them possible. The British fishing industry provides healthy, affordable, free-range food, with a carbon footprint that compares favourably to any other source of dietary protein.

Furthermore, it is increasingly acknowledged that stability of food supply is fundamental to our national security. This applies as much to the food we export as to the food we eat: everywhere is safer when no-one is hungry.

Fisheries policy needs to remember what should be its ultimate goal: sustainably maximising production of food from the sea, in the national interest.

Collaboration

One of the few tangible benefits of Brexit was the advent of a new fisheries management system for the UK, free from the overbearing and unsuccessful bureaucracy of the Common Fisheries Policy. This election has been called in the middle of the period in which the UK’s Fisheries Management Plans were being developed. As a result, consultations have been put on hold and meetings have been postponed. The FMP rollout has paused and we all wait to see if, when, and in what form they may resume.

A new government may feel the need to separate itself from its predecessor in the policy directions that it pursues, but on this point, caution would be sensible. The FMP approach must not be seen as the product of a particular government. It involves collaboration between industry, fisheries managers and scientists, in order to develop evidence-based management measures. Many of us have been calling for exactly this for years. This fundamental principle is a good one and the system built upon it should not be discarded wholesale just because a particular party happened to be in office when it was finally implemented.

Space

For centuries, fishing and transportation were the only industries active in the sea. Now many newcomers have entered the scene. Unlike fishing and shipping, many of these industries (wind power, aggregate extraction, conservation) want exclusive access. Fishermen cannot own the waters they fish and so are steadily being squeezed out of their traditional grounds.

This is all despite the fact that, unlike many of the new uses that people have found for the sea, fishing brings direct benefits to coastal communities. Wind turbines speckle the UK’s east coast and Grimsby is trumpeted as one of the biggest offshore wind operations hubs in the world, yet that town remains one of the poorest in Britain.

Fishing doesn’t just provide jobs on boats. It generates work ashore in harbours, fish markets, maintenance facilities and chandleries. It provides a living, working seascape that visitors flock to, supporting tourism-sector businesses. It gives a sense of continuity and proud tradition that binds communities together.

Policies that allow fishing to be squeezed out will devastate communities that are already on the edge in every sense. Conversely, policies to promote sustainable growth in the fishing industry will help those places to thrive.

People

We hear a lot – rightly – about sustainability when fisheries policy is discussed. What is often ignored is the need for the lives of fishers to be sustainable too.

Fishing is undeniably a dangerous trade, but significant advances have been made in improving safety. At the same time, however, some government initiatives have had the opposite effect. The application of the small work-boat code to fishing vessels was poorly thought through and badly implemented leading to requirements for vessel modifications that experts condemned as unsafe.

The introduction of medical certification requirements against the advice of the NFFO and others, precipitated a mental wellbeing crisis as fishers found their livelihoods under threat, without improving anyone’s safety. The under-10m fleet was exempted from these disastrous regulations only after an extensive campaign from the NFFO and not before many people wasted money on unnecessary fitness tests, while others were forced out of the industry altogether. The blinkered decision-making process that allowed that debacle to happen in the first place needs fundamental reform.

The costs of doing business as a fisher and the rewards to be obtained from it also need consideration in government policy. A fair price for the products of their labour and energy costs that are not ruinous are essentials for any productive industry and the health, safety and mental wellbeing of those who work in them.

Strategy

Fishing is managed in a multiplicity of different ways by a wide range of different people, for a host of – often mutually contradictory – reasons. Fishing effort is managed internationally by treaty and annual negotiation; it is managed nationally by Defra; and locally by IFCAs. There is stock-based management through FMPs, and spatial management through regional Marine Plans. Fishing grounds are taken for other uses under the national energy strategy, and also by the national conservation strategy, while the Crown Estate leases areas out to any industry but ours for profit.

Fishing is continually disadvantaged by the lack of a holistic plan to guide its development as an industry. We need a national strategy that will tie together the management of existing fisheries and the sustainable development of new ones. A strategy that will open up fishing’s scope to create jobs and support communities in coastal areas. If Britain does this, then we will finally embrace fully the potential for fishing to contribute to the nation’s food security and economic growth.

Perhaps we may even restore some of the pride we should feel in having such committed, resourceful, and necessary people as fishermen around our coast.

This is a welcome outcome, to be sure, and desperately needed. It is a total reversal in the government’s position on the under 10m fleet and will benefit thousands of fishermen. They will no longer have to live with the constant prosect of losing their livelihoods because of medical conditions that are demonstrably having no impact on their safety.

It is, admittedly, rather strange that the government has chosen to announce this as ‘reducing the burden’ on fishermen, since it insisted on creating that burden in the first place, despite our warnings about the consequences of doing so. Nevertheless, it is the right thing to do and will help many people who would otherwise have faced a bleak outlook.

Many, but not all, however.

This may be a deeply necessary move, but it is not sufficient. Deciding who should benefit from this exemption based on the length of their boat does not make sense. Inshore boats over 10m may work in the same places in in the same ways as under 10s. These fishermen are just as likely to be self-employed and their businesses are just as vulnerable to new legislative burdens. Indeed, they already have the additional challenges of e-log and VMS systems to contend with.

Surely, an exemption based on time at sea and distance from port would be more sensible and proportionate than one based on vessel length. This would help where help is needed and balance the risks in a more equitable way.

Even within the under 10m fleet, the story is not over. What happens now for all those who left the industry because they went through the medical certification process and received an outcome that made continued working impossible or impractical for them? How many lives have been upended, in entirely predictable ways, for no good reason and what will the government do for them now?

In short: we have won a battle, but the fight goes on.

After a highly successful first event in Newlyn, we will be running a session next week in Grimsby. Participants will receive a £40 thank you payment for up to an hour of their time.

Please email charles@nffo.org.uk to register your interest and to book a time slot.

Last December, fisheries managers at the annual UK/Norway/EU trilateral negotiations set the total allowable catches (TACs) for 2024.  When they did, they made the deliberate decision to diverge from the 2024 ICES Northern cod advice.  Against the background of widespread increasing stock biomass, the ICES MSY-based assessment through a novel precautionary procedure would have cut the TAC by 17%.  Instead, managers decided on an increase of 15%, and the North Sea fishing industry breathed a collective sigh of relief that it would not be facing the creation of another set of impossible working conditions.

Managers appreciated that had the advice been adopted, one of the practical consequences would have been large scale discarding, or if applied under a full system of discard controls, economically ruinous tie ups, together with significant lost yield due to under fishing a variety of intrinsically linked stocks.  ICES’s own supplementary analysis of the implications of the single stock advice on catches of other stocks in the mixed demersal fishery predicted that 35 out of 43 of the North Sea fleets would have been choked.  Managers wisely avoided that unpalatable scenario.

Narrow Rigid Design

The advice for Northern cod reflected a particularly acute case of dislocation between scientific advice and management decisions, but it is not a one off.  Protocols designed to attain maximum sustainable yield, whilst applying precaution under single stock assessments imply management incoherence over discards in several important fisheries.  Insufficient attention paid to the implied consequences, not to mention balancing socio-economics and business stability, results in perverse outcomes.  Yet this approach is by design a central feature of the current policy-science framework.  It is especially stark when 0 TAC advice results.  I would argue that to achieve better practical outcomes in the realities of mixed fisheries trade-offs, the format of that advice could and should change.

The extent to which discards are factored into ICES single stock assessment advice, and therefore the annual negotiations, is deliberately constrained.  Norway, the UK and the EU approach those negotiations in slightly different ways but the concept of MSY ranges, enshrined in the EU multi annual plans (MAPs) are influential in the advisory process.  MSY ranges explicitly aim to provide a degree of flexibility over MSY but only a narrow one.  They are constrained to allow for no more than a 5% reduction of yield when compared to MSY, whilst also ensuring there is less than a 5% probability of biomass falling below limit refence points.  Such limits are essentially arbitrary but prioritise single stock MSY.  This is quite different to purposefully evaluating the trade-offs between MSY and precaution, along with implied discards or lost yield as a result of chokes across a complex of stocks.

An attempt to bridge this divide and evaluate the management trade-offs is provided by ICES in a separate supplementary mixed fisheries analysis that examines the implications of the single stock MSY advice for mixed fisheries by applying a range of scenarios that allow the identification of choke risks among complexes of stocks.

However, this supplementary advice has yet to command the profile of the single stock advice and attention to it varies across the contracting governments.  Its production requires the completion of the single stock advice first so that it generally lands midway through the annual negotiations.  Whereas the single stock advice gives a single headline TAC recommendation, the mixed fisheries analysis presents the results of the applied scenarios without giving a single recommendation.  Managers may then interpret the results accordingly.  On the other hand, a single headline advice number encourages the nailing of colours to masts.

Public Discourse Confusion

The mixed signals generated by the advisory process and the often-unrealistic single stock headline advice, which demands that managers diverge from it to correct for the “bigger picture”, results in an unnecessarily unhealthy public discourse on the state of our fisheries that harms the reputation of the industry.

ENGOs routinely use any divergence from single stock advice to accuse decision makers of pandering to industry short-termism to paint an environmental disaster narrative, persuade consumers to avoid particular stocks, and sow confusion over the state of our fisheries to leverage ever more rigid controls.  Blue Marine Foundation and Client Earth are presently respectively taking the UK government and EU Ministers to court over the matter, arguing that sustainability goals are not being met.

Fixing the System

So, what needs to change?  The policy and the ICES science communities need to chart a way out of the present incoherence, but from EEFPO’s perspective, I would suggest the following:

• ICES should be given a strengthened mandate to provide advice with respect to managing discards. Current MoUs between the contracting countries and ICES lack this specificity.
• Chokes identified by the mixed fisheries analysis need to be related to suitable reference points in single stock advice to illuminate short-term trade-offs between discards, MSY and precaution, to guide management decisions clearly and justifiably on the basis of the available science.
• Single stock MSY should not be the sole yardstick of health applied across every As any fisheries scientist will tell you, you can’t achieve single stock MSY across all stocks at the same time, yet we presently lack transparent systems for recognizing this or prioritizing certain stocks over others.

When selectivity measures can only go so far, and choke risk implies underfishing more commercially important stocks, there is a good case for minor commercial or bycatch stocks not to have the same level of priority.  This is not to undermine the need to prevent a stock from becoming biologically impaired and collapsing, but in the face of the operational needs to best manage discards MSY needs a more holistic interpretation than presently applies.

A more balanced approach would try to maximise yield across a complex of mixed fishery stocks, recognising that, for some, greater flexibility over meeting single stock MSY is justified.  This could be implemented through long-term management plans such as EU MAPs, UK FMPs or the multi-annual strategies process under the Trade and Cooperation Agreement (TCA).

Adaptive or Crisis Management?

The format in which ICES advice is currently presented is not well designed to support fisheries managers to arrive at well-balanced decisions.  Precaution, MSY and discards minimisation are important parameters for TAC decisions, but the advisory process is presently too narrowly aimed at the interpretation of single stock MSY and precaution at the expense of discards management.  This amounts to an overly rigid straitjacket.  It should be orientated more towards the careful evaluation of the trade-offs among conflicting management goals to facilitate adaptive fisheries management.  This would afford fisheries science, a more useful and constructive way to support management decisions.

This question becomes more relevant each year as the consequences of following the EU /UK landing obligation materialise.  A sub-optimal science/policy framework makes TAC decisions much harder work than it ought to be.

The sandeel ban will not directly affect UK fishing businesses, as they do not target this species. Given the government’s failure to take control of access to our waters, however, we have to be concerned about the effect of displacing the EU boats that do target it. Until the government makes good on its promises and starts acting as though Britain really is an independent coastal state, we will continue to get window-dressing measures like this, rather than properly integrated marine resource management.

The exclusion of mobile gear from rocky reef areas is another piece of invented drama that we could do without. Although there is relatively little fishing activity in the areas in question and so the immediate impact on livelihoods will not be substantial, it is part of the ongoing trend for fishing to be displaced from traditional grounds in favour of other interests.

Whether it is extracting aggregates from it, building wind farms on it, or asking for donations for campaigns to ‘protect’ it, many industries are now making good money from the seabed. There may be a place for what they do, but none of it puts food on tables or provides jobs in coastal communities and it all squeezes out fishing businesses, which do. If we continue to allow the piecemeal degradation of the nation’s fishing capacity, we will lose something of fundamental importance that cannot easily be recovered.

When consulting last year on the measures that have been introduced today, the MMO described the evidence that fishing was causing damage to these seabed features as ‘limited’. Hardly surprising, since the impact of most mobile fishing gear on the seabed is vastly less than the exaggerations peddled by those with little expertise and a vested interest in attacking fishermen. The MMO also stated that social and economic factors would not form any part of its decision-making on this matter. And so we end up with today’s announcement: prioritising the protection of underwater rocks from the mere potential for damage by activities that they have survived for centuries.

There is a serious job to be done in managing our marine resources in a changing world, but political theatre likes today’s announcement does not contribute to it. Let us hope that it is not a sign of more such posturing to come.

Draconian Cuts following Benchmarks

This draconian cut to the pollack quota has followed a radical change in perception of the stock by ICES scientists, following one of their periodic benchmark meetings; but there are sound reasons to question whether this opinion will be sustained when the assessment is revisited in the future. ICES benchmark exercises are important as they allow the science to evolve. By questioning the models used, and the data employed, weaknesses can be weeded out.

But when benchmark exercises result in extreme volatility in stock perception, followed by radical changes in recommended TACs, a mechanism is needed to moderate these swings. Scientists don’t make the right call 100% of the time. There are already several examples of scientific opinions reverting to the original view further down the road, but by then the damage is done. So long as the biomass is projected to increase in the following year, a management mechanism is required to reduce the volatility and filter out radical swings – either way, up or down. It makes no sense to inflict serious socio-economic damage on the fleets – only to follow a revised opinion later.

Most ICES assessments are uncontroversial but a pattern is emerging where benchmarks are followed by extreme swings in advice. That is what has happened with pollack.

TAC Constraints

TAC constraints – minimising the extent of TAC swings to, say 15%, have been employed effectively in the past but seem to have dropped out of fashion. Applying a TAC constraint would have moderated the TAC reduction for pollack in 2023, but would have still seen the biomass increase by the end of 2024. As it is, the year-end quota negotiations have left us with an unmanageable fishery for the coming year. This is a chaotic way to manage fisheries and we need to move beyond it as a matter of urgency. A mid-year review of the TAC decision is required to retrospectively apply some kind of TAC constraint. The UK should initiate discussions with the EU immediately to rescue this situation.

Longer Term

In the longer term, ICES should examine whether the form in which it provides advice is as useful to fisheries managers as it might be. In recent years there has been some attempt to supplement zero TAC advice with options to deal with unavoidable bycatch – but this doesn’t help where, like pollack, a substantial part of the catch is targeted. Limiting extreme swings in the advice, especially when there might be doubts about the safety of those opinions, would help to avoid catastrophic mistakes with serious real-world consequences.

In the meantime, however, an urgent intervention is required by fisheries managers (and in this context this means the UK and the EU) to call off the dogs.

Knock-on Effects

Our immediate concern has to be for the fleets targeting pollack – many of them small inshore vessels – with few if any alternative opportunities to sustain them during 2023. There are, however, already signs of diversion of effort with potentially destabilising consequences in adjacent fisheries. We fear that the progress in rebuilding the biomass of the bass stock will be impeded if faced with increased effort. Likewise, redirection into non-quota fisheries like crab, lobster and crawfish could do untold harm to stocks and conservation strategies. In a word, the TAC decision on pollack could set us back years in a range of other fisheries.

Pragmatism

What is required at this juncture is a healthy dose of pragmatism. Client Earth’s attempt to use the European Court to tie the EU to rigid formulaic rules in setting TACs is now likely to be defeated, following the ECJ’s recently released provisional judgement. We are reasonably confident that Blue Marine’s legal manoeuvring will meet the same fate, not least because the UK’s Fisheries Act provides explicit flexibilities to meet complex situations of this kind.

What is required is a pragmatic and urgent intervention by the management authorities to avert the immediate crisis, followed by a longer-term evaluation of how to avoid getting into this situation again. This would allow time also to develop a suite of measures to rebuild and sustain the pollack stock through more intelligent management measures, applied with the support and involvement of the fishing industry. Better data, more targeted measures, real-time information from the fishery (including from the significant recreational fishery) could all be in the mix.

The priority for now, however, is to revisit the TAC decision immediately.

Let’s be clear: there are many different rates of tax on fuel and they vary according to the type of fuel and its user. That is not the same thing as a subsidy.

Charities don’t pay tax on most of their profits and get a huge discount on their business rates. Is that a subsidy? How about the £4.55 billion that the UK’s Universities were given from the public purse last year?

It’s not as though fishermen don’t already pay plenty: they pay for their licences; they pay for vessel inspections; they pay for medical certificates and mandatory training courses – and much more besides. These ivory tower commentators would like fishermen to pay even more tax. By the same logic, perhaps they would like farmers to be taxed more for fuel as well. Then when no one in Britain can afford to produce our food any more, we can just import it all. I wonder what that will do for the nation’s carbon footprint?

Or maybe we should give up on food altogether and just eat grant applications?

Today, the Maritime and Coastguard Agency has announced that it is consulting on a change to its regulations on medical certificates for fishers. The consultation asks whether existing fishers working on boats under 10m registered length should be exempted from the requirement to hold a medical fitness certificate.

You can find a link to the consultation here: Medical Exemption – Existing Fishers on Vessels of 10 Metres and Under – GOV.UK (www.gov.uk)

For months, the NFFO has campaigned for the medical certification regulations to be changed. Until now, the Department for Transport has insisted that this would not happen. Our persistence has paid off, though and they are now considering a change to the one of the most damaging aspects of those rules.

There is still a lot to be clarified, however. The NFFO highlighted the harm that these regulations were causing and called for exactly this exemption, months before the rules came into force on 30^th November. If the DfT changes its mind now and brings in this sensible exemption for the under 10m fleet, will they reimburse all those who paid out to get a certificate that they no longer need just a few weeks later? Many under 10m fishers are still waiting to have their medical assessment appointments. Are they really expected to go ahead with them while this consultation is ongoing? What about the other issues with the regulations and inconsistency with other industries (it’s still harder to get a medical certificate to work on a fishing boat than to drive a bus)?

Anyone who admits that they have got something wrong and tries to put it right should be applauded and this consultation and the change that it could bring about are very welcome news. Surely, though, the issues that it highlights demonstrate that it is time to pause the operation of the regulations altogether and order a full and independent expert review.

The outcome of that review can only be rules that are better formulated to ensure that fishers are safe at sea and that fishing businesses can keep providing jobs and food. Why would anyone object to that?

BBC television’s One Show has reported on the problems being caused for fishers by the new medical certification rules. You can watch it here, the first item on the programme

The NFFO has been campaigning on this issue for months. We have succeeded in raising its profile and have won support from across the political spectrum. On last night’s programme, NFFO Chief Executive Mike Cohen explained the situation and the serious impact it is having on the welfare of fishers across our inshore fleet. He called on the government to take action to solve this completely unnecessary crisis of their own making.

This film was recorded more than a month ago and the situation has only worsened since then. The deadline for obtaining medical certificates is now only a day away. The Department for Transport is responsible for implementing these regulations and their silence on the issue has been deafening. It is time for the government to decide exactly how it regards Britain’s fishing industry and what message it wants to send.

Once this principle is established, however, things become complicated and there is an important and legitimate distinction to understand between scientific advice and subsequent management decisions. Scientific advice on next year’s quotas is based on recommendations produced to meet a particular agreed format, whilst fisheries managers have a wider set of responsibilities. It is important that this is understood.

Scientific Advice

Fisheries scientists working within the ICES* framework make recommendations on total allowable catches (TACs) according to a format laid down by the people commissioning the advice. (UK, EU, Norway etc)

In recent years, a key question for scientists to answer has been – what quantitative catch limit for any given stock would be consistent with achieving maximum sustainable yield in the year ahead? There are other possible options to focus the scientific recommendations, for example: what level of catch would be consistent with a precautionary approach? or what quota level will deliver the biggest increase in biomass left in the sea? All of these options are valid and they give fisheries managers (those countries or groups member states with a stake in each fishery) the possibility of choices when making those final decisions in the year end fisheries negotiations.

In most cases maximum sustainable yield has become the favoured option from this range of choices in most because it provides a handy rule of thumb for achieving long term sustainable exploitation. This is particularly straightforward in single species fisheries.

Things become more complex when managers have to make TAC decisions in mixed fisheries – where multiple species are caught together. Importantly, the scientific advice is provided by ICES on a single stock basis, although in recent years attempts have been made to quantify the impact of a TAC choice for one stock on the other stock in a mixed fishery. The degree of association of different species is a further complication to be mindful of.

Then there is the legal angle. EU legislation requires TACs to be set at single stock MSY level, with little scope for managers to take wider factors into account. The UK Fisheries Act provides explicit scope for managers to depart from single stock MSY in particular circumstances. Norway on the other hand generally adopts a pragmatic approach towards MSY depending on the factors in play in any given year.

Domestic legislation is one thing but as there are generally more than one country involved in TAC decisions that are usually made in a series of multilateral, trilateral and bilateral negotiations each autumn. The domestic legal constraints of each individual country cannot be binding on all parties – that way a perpetual logjam results. TACs are set through negotiation, using the best available science as the essential reference point – but not necessarily the single stock MSY number – other options might be more relevant depending on the circumstances.

Management Responsibilities/Trade offs between Different Objectives

Anyone with a sincere desire to manage our fisheries rationally, fairly and sustainably, will soon come to the realisation that TAC decisions are a series of trade-offs between different objectives. So, making progress towards MSY, or holding a stock in the region of MSY will be important. But minimising discards or reducing the scope for chokes will also be a valid aim in the negotiations (Chokes are where in the context of a requirement to land all quota species, the exhaustion of the quota for one species will trigger the closure of the fishery for multiple other stocks – up to 25 in some cases).

Managers might also consider that a multi-year strategy makes sense to build up a stock has slipped below safe limits, without causing undesirable consequences for fishing businesses and fishing communities.

A Norwegian scientist one said that fisheries management is not rocket science. It’s much more complicated than that. Some of the factors include:

• The quality of the assessment – periodically reviewed through a benchmarking process to establish whether the data, model and assumptions stand up to scrutiny
• The alignment of political boundaries with biological stock boundaries
• The option of supplementing TAC decisions with technical measures
• An ‘of which’ quotas (which subdivides a TAC area)
• What to do when the scientists conclude that a stock cannot be recovered to single stock MSY in a single year and therefore according to the advice format ICES is obliged to advise a zero TAC. ICES in recent years has also provide technical advice on levels of unavoidable bycatch, which is an important and helpful development for managers making difficult decisions.
• Securing optimum outcomes in mixed fishery configurations

Trends

It is important to appreciate that we have come a long way since the 1990s when many of our fisheries could justifiably be called basket cases. Right sizing the fleets during the late 1990s and several other important fisheries management measures have made a huge difference. The general situation now is that with a few outliers, stock trends broadly continue, year by year, to move in the right direction as they have for more than two decades now.

This is not the time for complacency but neither is it time to pay heed to the siren voices who routinely peddle a catastrophe narrative that suits their fund-raising purposes.

Legal Actions

Some environmental NGOs have threatened or initiated legal action in an attempt to force fisheries managers (the European Commission and Council and UK government) to set TACs at the single stock MSY level indicated in ICES advice. This is generally accompanied by an apocalyptic narrative predicting widespread and imminent collapse of fish stocks in European and UK waters. Apart from being at variance with the broad fishing pressure and biomass trends identified by ICES, if successful these legal maneuovers would remove all scope for nuance and scope for pragmatic fisheries management. The necessary trade-offs between rebuilding depleted stocks where this is necessary, minimising discards and chokes in mixed fisheries, adopting a multi-year staged rebuilding programme would become impossible, with serious socio-economic consequences. These aggressive but naive manoeuvres are unlikely to be successful because of explicit scope for departure from single stock MSY in both the CFP and UK Fisheries Act but this will not prevent the accompanying media hysteria, which can rattle ministers.

Dialogue and Real World Consequences

For many stocks, setting TACs each year will be a straightforward process of applying ICES single stock MSY advice. But many of our demersal stocks are caught within mixed fishery configurations and this is when trade-offs between different objectives are unavoidable.

Fisheries managers will be concerned above all with real world consequences of their decisions and these cannot be read off a spreadsheet but require a detailed understanding of the dynamic patterns in each fishery. Negotiators will therefore want to maintain a close dialogue with the fishing industry before and during the negotiations to test various options.

A consultative process has evolved in which industry representatives are involved throughout the year, in the quality of the scientific assessments and advice and how the emerging recommendations should be applied to secure the best outcomes.

Conclusion

Hopefully, this short article will have provided some insight into the complex process of setting TACs during each autumn’s negotiations. Much is at stake each year and scientists, fisheries managers, and industry representatives have important but distinct roles to play.

*International Council for Exploration of the Seas – the Copenhagen based multi-national coordinating body uses for scientific advice in the North East and North West Atlantic.

With the much anticipated Northern cod advice now out showing increasing biomass on the northern fishing grounds including West of Scotland and a recovery trajectory in the southern North Sea, it should be a time for jubilation.  Regrettably, with an overall implied 17% reduction in TAC it is anything but.

Despite an improvement in the evidence base that underpins a move this year to a multi-stock assessment model with three sub-stocks, a novel decision-making process applied by ICES has paradoxically led to a ratcheting up of precautionary procedure that has resulted in the cut.  This would see the fishery considerably constrained on the main northern grounds, well below the MSY estimates for the individual sub stocks, in order to supposedly protect the southern sub-stock, the weakest of the three, not a prime consideration in previous assessments that assumed a single North Sea stock.

The decision appears to rest on a lack of knowledge on the degree to which the sub-stocks mix, meaning that the main fishery on the northern grounds may theoretically exploit a component of the southern stock should it migrate onto the grounds.  But this is theoretical and does not consider to what extent it may or may not be a factor, nor the degree to which it may knock the southern sub-stock off its current recovery trajectory.  Not accounting for it in previous assessments, and a resulting increasing of biomass is evidence in itself that it probably won’t.  Instead, the advice, if adopted, will most likely translate to increases in unaccounted mortality and wasted yield from the cod stock.

It comes at a time when in the North Sea we are witnessing strong increases in biomass across the whitefish stocks more broadly; haddock and whiting especially, but also saithe.  The evidence and views from industry also indicate a growing ling stock despite another seemingly perverse cut in the ICES advice of 12%.  If, despite growing biomass, cod becomes the limiting stock because of a disproportionately precautionary TAC constraint, under a system of discard management with full control it can only translate to wasted yield from the other stocks, as well as cod.

This points to what is perhaps an even more significant problem than the headline TAC advice this year – the longer term implications of repeating such decision-making processes or applying it to other stocks based on multi-stock assessment methods that are surely to be more widely used in the future.  In a single stock advisory process that rigidly and single mindedly champions single stock MSY and precaution over all other considerations, and especially discards, it threatens to deepen dysfunction in a management system that is also aimed at minimising discards.

The current Defra consultation on discard reform and REM makes no reference to TAC setting processes in shedding light on a new direction for discard policy.  Unless policy makers and scientists are going to take discards seriously and embed their consideration in TAC setting decision-making, by properly recognising and evaluating the conflicting management trade-offs, we are heading closer and closer to a system of chaos.

ENDS

28/09/23

Notes:

Contact:  Dale Rodmell, Chief Executive, Eastern England Fish Producers Organisation, Unit 4a, Village Farm Business Centre, East Street, Holme-On-The-Wolds, Beverley, East Yorkshire, HU17 7GA, Tel. 07500 945843, Dale@eefpo.org.uk

Eastern England Fish Producers Organisation (EEFPO) was established in Grimsby in 1981, formerly as the Grimsby FPO.  EEFPO membership comprises of 25 vessels include larger vessels up to 35m in length operating pair seines and single trawls, targeting haddock, cod, saithe and whiting as part of the mixed demersal fishery, as well as nephrops and predominantly fishing in the northern North Sea from Peterhead and other Scottish ports.  Our smaller day boats, ranging from 8-18m, operate along the east coast of England fishing for crab and lobster with pots and brown shrimp with trawls in the Wash.

As fisheries policy changes in response to the Fisheries Act (2020), it becomes more important than ever for us to ensure that all of our members can help shape our responses moving forward. The role of the Regional Committees is to represent those NFFO members who do not belong to a PO and are often most in need of representation and support with regional issues and concerns.

Regional Committees were always a key way for non-sector members to influence NFFO policy, but their activity had waned post-Covid. We are now in the process of kickstarting a new round of committee meetings to ensure that all voices are heard, and regional members feel they are getting represented with regards to any issues of concern they face.

September saw the North East committee meet in Whitby with good representation from Bridlington to Blythe attending. The North East committee was chaired for a long time by Ned Clarke, who championed the region’s members on all aspects of fisheries concerns. On Ned’s retirement from the post, Richard Brewer of Whitby was formally voted in to succeed him at the meeting in September. The NFFO and new North East chair would like to thank Ned for his strong support over the years and wish him luck in his retirement.

Richard Brewer has extensive experience in all aspects of fishing and has sat on the NFFO Executive Board in the past. He is very keen on giving something back to the industry that has supported him over the years and ensuring the members in the region are supported with the extensive issues the sector is currently facing.

The region covered by the North East committee is vast, with varied fisheries and different concerns across the membership. To better support the diverse concerns across this area, regional members and the NFFO Executive have decided to divide the area in two. Going forward, a new Yorkshire and Humber Committee will sit alongside our North East Committee and we will be seeking a chair for it soon.

September also saw the West Coast Regional committee sitting in Whitehaven and discussing a range of issues. The issues discussed at both committees included the NFFO Training Trust, medicals, fisheries consultations and fisheries management plans, IFCA’s, offshore development and the future of how the committees can work.

The South East, South West and East Anglia committees will meet in the coming months as soon as fishing permits and at the direction of the regional Chairs.

The NFFO would like to encourage non-sector members to join their local regional committees. It gives the NFFO team an opportunity to hear directly from the fishermen we work for about the concerns specific to their region. It also allows us to pass on information about proposals that may affect local fisheries and to discuss what we can do about them. Information flowing both ways ensures that we can represent our members effectively.

With a general election on the horizon and many changes to fisheries management already being proposed, we hope to hear about the parties’ different visions for the future of our seas and our industry.

The AGM is open to all NFFO members and will be held at Watermen’s Hall, in London, on 18^th October, starting at 1000. There will also be an option for those who cannot be present in person to join online.

Members who wish to attend should register by emailing Joanna Lenehan Joanna@nffo.org.uk or telephoning 01904 635430 and stating whether they will attend in person or virtually, so that we can inform the venue, or send out the joining link, as appropriate.

Of course, the implementation of a system may be very different from its design. Already we have seen a lot of variability in how the first FMPs have been developed. The scallop FMP, for example, was developed largely by industry, while we have heard complaints that at least one other Plan failed to engage adequately with fishermen.

So much for the system. The management measures themselves are still very much open for debate. We have now seen the first proposals and it will take time to read all of the detail and understand them properly. The NFFO will be canvassing its members, to ensure that our responses to all of these consultations incorporate as broad a spectrum of their views as possible. We encourage everyone to submit their individual views as well.

Of course, we won’t know the real value of the new system until we see the results that come out of these consultations. It is a very good thing to be asked for our suggestions, but the exercise is only meaningful if we are listened to.

It is easy to be cynical, because we have all seen too many initiatives that have failed to secure the economic, social and environmental sustainability of our industry. Clearly, too, the FMP process so far has had its flaws. Nevertheless, there is an opportunity here to engage and, as long as we keep advocating forcefully for management measures that will keep our industry healthy and prosperous into the future, I think there is real cause for optimism.

We must remember also that FMPs are intended to be iterative. These first proposals are the start of a process, not its end point. What comes out of this first round won’t be perfect, but if voices from our industry are listened to as we have been promised, it will be the beginning of something far better than we had before.

[A version of this article appears in Fishing News ]

The new partnership sees The Seafarers’ Charity and NFFO utilising their specialist skills and resources for the broader benefit of the commercial fishing sector. The Seafarers’ Charity is a leading maritime funder of safety initiatives and welfare services for people working at sea. The Charity brings its funding resources, collaborative approach and convening powers to the partnership; which will be informed by the NFFO’s representation and specialist knowledge of the fishing industry in England and Wales.

The formalisation of a partnership builds on The Seafarers’ Charity co-funding with the NFFO of their Risk, Safety & Training Lead post held by Charles Blyth. The post has already been co-funded by the two partners since May 2022 and the Charity recently agreed a further two year funding commitment into 2025. In addition to funding this key role, the two organisations have committed to collaborating on various initiatives and projects that will contribute to raising awareness and understanding of safety management practices.

The promotion of safe working practices is a key part of the work of NFFO. The Federation has representation on many maritime safety groups within the United Kingdom and Europe and engages on the world stage at the IMO and ILO. Mike Cohen, NFFO Chief Executive explained their strategy, ‘The NFFO is helping members, skippers and crews to manage risk at sea on their vessels, to ensure their vessels are operated in the safest way possible and that crews are properly trained and receiving the best welfare provision. Joint initiatives, developed with support from The Seafarers’ Charity, provides us with additional resources to take forward new and innovative projects which will make a significant contribution to improving fishing safety for many more than just our members.’

CEO of The Seafarers’ Charity, Deborah Layde said: ‘I am delighted that we are able to do even more to support improvements in safety and welfare for people working in UK fishing and that these are industry led initiatives. The MOU signed with the NFFO formalises a long-term working relationship and collaboration which is already providing much needed help and guidance to many fishing vessel owners across the whole of the UK and there will be more to come as the partnership continues over the next two years.’

Barrie retired in April after 38 years at the NFFO: 26 of those years as CEO.

NFFO President Andrew Pascoe said: “Barrie has done a huge amount for the fishing industry during his career and its great to see this acknowledgement of all that he has achieved. He guided the NFFO through many changes and has left it in a very strong position.”

New NFFO Chief Executive Mike Cohen commented: “Although the whole NFFO team was very sorry to see Barrie leave, his retirement was at least a chance to celebrate his remarkable career. This honour caps off that celebration in the best possible way and we were all delighted to hear about it.”

Although, as event’s title suggests, the focus was terrestrial – and so too were the major policy announcements that the Prime Minster made on the day – nevertheless, there was ample opportunity to ensure that the fishing industry’s key concerns were on the agenda. Discussions covered labour shortages, access to fishing grounds and the need to balance nature conservation objectives with food security.

The government has now made it clear that food production – both for Britain’s own security and as one of our most successful exports – will be given high priority. They have also made it clear that fishing is an important part of this.

If this is a real commitment and not just an attempt to pacify an industry placed under increased pressure by the government’s own policies, we should expect to see it reflected in actions. We should expect to see our access to fishing grounds protected; unnecessary and restrictive regulations rethought; fishing prioritised in international negotiations.

Time will tell.

Dear Minister,

The NFFO has noted with alarm the failure of the MCA to engage with fishermen’s concerns about the impending deadline for small boat fishermen to obtain medical fitness certificates in order to continue in their jobs.

We made plain our concern about medical certification for fishermen when the adoption of ILO C188 was first proposed. It is clear that our objections fell on deaf ears. Since then, we have made repeated efforts to work with officials to avoid the looming disaster that these rules seem certain to cause, to no better effect.

When the UK government transposed ILO C188 into UK law via the The Merchant Shipping (Work in Fishing Convention) (Medical Certification) Regulations (2018) it gave itself the option of creating an exemption from the medical certification requirement for the small vessel fleet. That successive Secretaries of State have opted not to do this is as baffling as it is disappointing.

Making matters worse, it was decided to compound the problem by gold-plating the regulations:  applying to inshore fishermen the same standards as are applied to mariners in the deep-sea merchant fleet. Fishermen working close to shore, on vessels under 10 m in length, are being held to more exacting standards than those mandated for HGV driving or working at height. This cannot be right.

An expensive, onerous and hugely anxiety-provoking solution has been created for a problem that does not exist. I do not believe that a single instance will be found in the reports of the MAIB of an accident being caused by a fisherman being overweight. By contrast, the terrible consequences of the toll that these rules are taking on fishermen’s mental health can all too easily be imagined. The MCA’s single-track approach to fishermen is having unintended results that contribute nothing to their safety.

This is not merely a further extension of the proliferation of red tape that has swamped small fishing businesses in recent years, it is an existential threat to hundreds of livelihoods.

We would highlight:

• The unavailability of GPs willing to undertaking ML5 examinations.
• An appeal process that is slow and lacking in clarity.
• Reluctance to apply workable grandfather rights for single-handed vessels.
• Unwarranted discrimination against existing medical conditions.
• Unnecessary additional pressure being placed on an already exhausted NHS primary care system.

We cannot believe that this government is intent on depriving hard-working people of their livelihoods. The implementation of these regulations in the small boat fleet must be halted while government reconsiders its position.

We would like to meet with you to discuss the resolution of this issue as a matter of urgency.

Current NFFO, Paul Gilson, who is expected to move up to become President, at the AGM, said:

“Although Chris has sat round the Executive Committee table for a relatively short time, he is an example of a wise head on young shoulders and has earned a great deal of respect over a that period. I have no doubt that I am handing over the chair to a very safe pair of hands.”

NFFO Chief Executive, Barrie Deas added, “Beyond his formal qualifications, Chris has built up a huge body of knowledge about the industry through working directly with fishermen and fishing vessel operators, firstly an fisheries animateur, helping the industry to navigate routes to access support and grant funding, and secondly liaising with policy makers and decision-making processes to shape grant schemes in the first place. He is used to operating within the many different aspects of the industry. All that is perfect for his new role and in addition, he is a superb communicator.”

As Chairman of the NFFO, Chris will not have an easy ride. The fishing industry faces an array of formidable challenges, not least the spatial squeeze from offshore wind and the expanding network of marine protected areas. The development and application of the first generation of post-CFP fisheries management plans will also come to fruition on his watch, as will the end of the TCA adjustment period in 2026.

Chris’s experience in recruitment and training, infrastructure needs, marketing initiatives and producer organisation strategy will all come in handy.

The inaugural meeting was held on the 30th November 2022, facilitating a more direct dialogue between the fishing industry and fisheries scientists from Cefas. The first meeting was held online, with the hope of future meetings being either face-to-face or hybrid.

NFFO Chief Executive, Barrie Deas, said: “We have long recognised the importance of a strong dialogue between fisheries scientists and the industry, but in recent years we have tended to hold those discussions within a policy context. It’s important that this continues but we think that a forum like this would allow for a more direct conversation between fisheries scientists and the industry to take place. You can’t expect to have good fisheries management based on inadequate information, so understanding each other is of paramount importance.”

Cefas CEO Neil Hornby commented: “This Forum provides a great opportunity for the fishing industry and Cefas’ scientists to come together to discuss the pivotal issues facing the marine environment. There are many topics where we share a mutual interest and it was interesting to hear the concerns, comments, and suggestions of the industry. I hope that this Forum will continue to promote a closer working relationship and enhance outcomes for the ocean.’

Topics

The first meeting covered a wide range of topics:

• stock identification
• inshore trends
• the young fish survey
• science underpinning discard policy
• Fishery Management Plans (FMPs)
• cuttlefish stock assessments
• distributional changes in species
• impacts of sea temperature change
• incorporating industry knowledge
• data-limited stocks

Geofish

Cefas presented their new analytical tool, Geofish, which has the potential to revolutionise our understanding of the spatial dimensions of fisheries. The tool, whilst still in development, combines satellite tracking, and logbook, data that can be probed to provide detailed information about fishing activity and its impacts. Geofish is emerging as an important advisory tool for some of the trade-offs ahead. Data security, levels of access, and adequate safeguards will be crucial and were part of the discussion.

Spatial Prioritisation

The second area into which the Forum took a deep dive was spatial prioritisation, against the background of the ABPmer report produced for NFFO/SFF, which signposts the scale of potential displacement of fishing activities from historic fishing grounds.

Future

Topics for discussion at future meetings of the Forum were discussed and will likely include:

• shellfish management
• scientific contribution to FMPs
• improving use of industry data in assessments
• discards/selectivity
• mixed fisheries
• data-limited species
• gear design and bycatch mitigation
• future climate change impacts on fisheries
• marine spatial prioritisation
• long-term trends/challenges in specific fisheries; e.g. North Sea demersal, Celtic Sea and Channel
• new emerging fisheries

Conclusion

This was an important first step to establish a regular dialogue between fisheries scientists and the fishing industry. Although the first meeting included scientists and the NFFO Executive, the Forum could evolve over time to incorporate other parties. The Forum will meet three or four time a year, with the next meeting in April 2023. This will not preclude stand-alone meetings on specific topics in the meantime.

An important feature of the original Cod Symposium, organised by the regional advisory councils in Edinburgh in 2007, was the recognition that in the context of mixed fisheries a more intelligent approach was required, centred on realistic TACs and cod avoidance. The symposium, which brought together fishermen, fisheries scientists and fisheries managers was an attempt to understand what worked and what didn’t. It also brought to the fore the need to understand cod within its ecosystem context.

Blue Marine seem entirely ignorant of these important developments.

The work of the original symposium was recently refreshed and updated by the ICES coordinated meeting, also held in Edinburgh at the request of the international fishing industry group, the Northern Demersal Alliance. All this seems to pass Blue Marine by, as it parrots biomass statistics that ignore ecosystem changes, including the gadoid outburst in the 1970s and the important drivers identified by the ICES working group WKIrish, in its rush to put the blame on fishing. It is tempting to think that Blue Marine are entirely ignorant of the facts. The NGO also seems to think that the EU Cod recovery plan only covered the North Sea, when it embraced the West of Scotland and Irish Sea too, rendering their comments on this worthless.

But this is about more than ignorance. Our original article on Blue Marine’s recent misinformation campaign on cod made clear our view that the NGO’s underlying motivations are more to do with attracting funding in a competitive marketplace than tackling the real challenges of fisheries management within the context of mixed fisheries and environmental change.

For more than 30 years, the NFFO has been centrally involved in building partnership approaches with fisheries scientists, pioneering innovative and intelligent approaches to cod avoidance and selectivity, and balancing the difficult trade-offs required in achieving sustainable harvesting within the context of mixed fisheries and a changing ecosystem.

Meanwhile Blue Marine’s solutions are:

1. To slash quotas to levels that would make quota management impossible and close multiple fisheries for which cod is an unavoidable bycatch
2. Ban mobile gear fishing for prawns which if taken seriously would rapidly empty fishing communities leaving plenty of properties for the second home market in quaint fishing villages devoid of their populations except in summer.
3. Jump on any anti-fishing bandwagon that happens to be passing

Quite how cod is to be “nursed back to profusion” against a background of changing distribution patterns, environmental regime shift and a northward shift in cod populations (probably related to changing water temperatures) is, typically, not addressed. The reason that the real challenges facing cod within mixed fisheries are not tackled by Blue Marine is straightforward. Blue Marine is not a serious voice in fisheries management. It is a self-promoting enterprise, whose business model is centred on repeating variants on a catastrophe narrative that in turn can be monetised.

Misinformation and Dishonesty

A tabloid newspaper could be proud of the selective, blinkered, bigoted, self-serving and entirely unhelpful narrative promoted by Blue Marine. To deliberately ignore the big picture trends in fishing mortality and biomass, documented clearly by ICES, which witness the vast improvements in sustainable harvesting of the stocks in our waters, is shockingly dishonest.

There are unsustainable fisheries to be found in the world. The fisheries in the Northeast Atlantic are not amongst them and haven’t been for decades.

Accepting that there will always be statistical outliers and annual natural fluctuations, the biomass trends for all of the major species groups in the Northeast Atlantic have been upwards for 23 years. This followed a range of management interventions, the most significant of which was fleet decommissioning. These trends since the turn of the century are just ignored by Blue Marine because they don’t fit with its fatuous catastrophe narrative.

It is not difficult to understand why Blue Marine takes the positions that it does – it’s the money. But it is vitally important that they are not taken to be serious, or disinterested, actors.

Opportunity

Nevertheless, escaping the dead clutches of the overcentralized and cumbersome Common Fisheries Policy was regarded by many as a major positive. The legislation that gave UK fisheries ministers powers to manage our own fisheries, the Fisheries Act of 2020, was carefully constructed to avoid the pitfalls of the CFP. Lessons had been learnt and these were carried through into the Joint Fisheries Statement which provides a balanced policy framework for managing our fisheries within the context of devolved and reserved powers. Although a huge amount of work remains to be done to realize the benefit of this new framework, especially through the development and implementation of fisheries management plans, it is a huge opportunity.

Disappointing

Against this background it is disappointing, therefore, that the promised agility of the new framework to deliver effective and timely outcomes has been thwarted by the UK’s own legislative systems.

Bass and Spurdog

It is just downright embarrassing that, for the second year, increases in catch limits for bass agreed with the EU within the context of the annual fisheries negotiations, will be implemented by the EU from 1^st of January – but those same increases will not be available to UK fishermen until much later in the year. This is because of the UK’s own domestic legislative hurdles that have to be cleared.

A similar situation applies in relation to spurdog. Following revised scientific advice, spurdog is to be removed from the prohibited species list and a substantial TAC for 2023 and 2024 has been set jointly by the UK and EU. Yet, legislative obstacles mean that access to these quotas for UK fishermen will not be available until May at the earliest. Legal and constitutional processes again undermine the ability to implement a responsive and agile fisheries policy in the UK.

From Statutory Instrument to Licence Condition

There is a solution. Much of the unwarranted delay arises from the fact that the legal route to deliver these management systems is through a statutory instrument. These parliamentary hoops require an inappropriate level of parliamentary involvement when the decisions, after all, have already been taken within the context of bilateral fisheries negotiations. In any event, these are mainly technical adjustments that don’t need a high level of parliamentary scrutiny.

Streamlining the UK’s own route to implement decisions made within the context of bilateral (or trilateral) fisheries negotiations should now become a political priority, but ironically, the main delay in shifting the approval process from statutory instrument to licence condition is in finding sufficient parliamentary time. The Government’s ambition to “sunset” all existing EU law by the end of 2023 is likely to constrain available parliamentary time even further.

Implementation of policy and management decisions through licence conditions can be done within 24 hours where necessary, rather than the 5 months which the statutory instrument route takes. This is a no-brainer and should be a priority for the Government, which cannot enjoy the tag of overseeing a process even slower than the cumbersome CFP that it replaced.