Accelerated Offshore Wind increases the Spatial Squeeze of Fishing

This scale of ambition, along with hints that this will be achieved by relaxing planning consents, cannot but generate fear and concern that this policy shift will mark a huge erosion of the area available to fish in. Already facing a potentially huge displacement problem, the outlook has just become a lot worse.

Cumulative Effect

38% of English waters are already designated as marine protected areas as one kind or another. Depending on the management measures employed, extensive displacement of fishing activity from these areas is a serious threat, not only to fishing businesses and communities directly affected but knock-on unintended consequences elsewhere.

Put plainly, despite the UK’s enormous exclusive economic zone, there is simply not enough marine space to accommodate the current ambitions to expand nature conservation objectives and offshore wind, and still leave room for fishing. The political imperatives driving the growth of offshore wind are clear. Less clear is how key areas of the marine space will be safeguarded for food production, including wild fish capture. Unlike farmers, the fishing industry does not have property rights over the areas essential for production. Unless there is a recognition that access to fishing grounds must be protected, the contribution made by the fishing industry to the nation’s food security will be seriously impaired.

Hope

The fishing industry’s one hope was that lessons learnt from earlier phases in the expansion of offshore wind would serve to inform a more thoughtful, rational, and balanced approach to the location and design of windfarms. An early example of what to avoid was the Westernmost Rough windfarm, where the new development was located on top of the most prolific lobster grounds in Europe. Early engagement with the Crown Estate and individual developers and those fishing interests potentially affected by projected floating windfarms in the Celtic Sea is already under way but there has to be a fear now that an accelerated process will undermine marine spatial planning.

Food Security

The Government has now published its intentions on energy security, but the Ukraine crisis has also brought with it a re-evaluation of food security and fishing is part of those policy shifts. Fish is a low-carbon, nutrient rich food source, available on our doorsteps. It should be a key aspect of plans to tackle climate change, while simultaneously ensuring stable food supplies for the British people. It will be important that this wider policy review will recognise the potentially existential threat to fishing as an important strand in the nation’s food security. Protecting the most important fishing grounds when making planning decisions on the location and design of offshore wind infrastructure and cable routes should be a central objective alongside biodiversity and energy security.

Report

The NFFO and the SFF, with support from the Fishmongers Company, have commissioned an analysis of the cumulative impacts of the spatial squeeze. The report will be published shortly and will inform our representations to government on why food production areas for fishing must now be integrated into all future policy decisions.

Consultation on the draft Joint Fisheries Statement

Response by the National Federation of Fishermen’s Organisations

Introduction and Background

The UK’s formal departure from the EU (and consequently from the Common Fisheries Policy) can be regarded as a necessary initial first step towards independent coastal state status. The UK now holds legal authority (under UNCLOS) to sustainably manage the fisheries resources within the UK EEZ, independent and separate from the CFP.  Several additional steps are, however, required to bring the full realisation of meaningful coastal state status.

International Fisheries Agreements

Cooperation with those countries with whom the UK shares specific fish stocks is a broad overarching principle and requirement within UNCLOS. The UK now enters fisheries negotiations as an independent sovereign party. As such, the UK has entered into fisheries framework agreements with Norway and the Faeroes Islands which provide the broad guiding principles for future annual fisheries agreements.

Trade and Cooperation Agreement

The UK has also signed the more detailed and complex UK/EU Trade and Cooperation agreement, the chapters on fisheries of which provide for annual fisheries agreements, and a Specialised Committee on Fisheries to deal with other aspects of the UK/EU fisheries relationship.  The provisions of the UK/EU trade and cooperation agreement (TCA) tie the UK into an adjustment period governing access arrangements. The adjustment period lasts until 2026. The TCA acknowledges that the two parties have regulatory autonomy over fishing activity within their respective EEZs but cedes access to EU fleets to fish within the UK EEZ (and under specified conditions to the UK 6-12nm limits) during the adjustment period.

EU Retained Fisheries Law and the Fisheries Act 2020

A large body of EU fisheries regulation was transferred directly onto the UK statute books from the CFP, adopted as EU retained law, pending retention, revision, or repeal, using the powers to UK ministers granted under the Fisheries Act 2020. That Act sets eight fisheries objectives which ministers must take into account when formulating and implementing secondary legislation.

Joint Fisheries Statement

The Joint Fisheries Statement, on which the four UK fisheries administrations are now consulting, represents a shared high-level vision of how those objectives will be met during the first phase of the UK’s operation as an independent coastal state.

The central thrust and structure of the Joint Fisheries Statement (JFS) is an implicit and explicit acknowledgement that fisheries are largely a devolved area of responsibility. Significantly, international negotiations, including fisheries agreements, remain a reserved power

These four elements provide the legislative and policy architecture which will both manage the transition from the CFP to a more customised UK fisheries policy and provide the framework for the future development of the content of that policy.

Lessons Learnt

In broad terms, the NFFO welcomes the JFS and regards it (and the Fisheries Act 2020 which preceded it) as serious and well thought-through attempts to deal with an undoubtedly complex policy arena. The policy direction in both the Act and the JFS suggests that important lessons arising from our experience under the CFP have been absorbed and have informed important new and innovative approaches. European Commission green papers in advance of the CFP reviews in 2003 and 2013 identified the central fisheries management challenges on the European continental shelf. A centralised, top-down, command-and-control approach applied to multiple, diverse, multi-species, multi-gear and multi-jurisdiction fisheries tends to produce:

• Frequent policy delivery failures
• Unintended consequences
• Alienation and disaffection amongst those whose activities are being regulated
• Vast complexity, as multiple derogations and exemptions are needed to accommodate fisheries which fail to fit the rigid one-size-fits-all template being applied

Moves to decentralise the CFP decision-making process were in fact under way in the establishment of regional advisory councils (2003), and the regionalisation of policy formulation (2013) to address this recognised weakness. Simultaneously, however, the Lisbon Treaty (2009) and in particular the extension of co-decision making (European Commission, Council of Ministers and European Parliament) to fisheries, reasserted and reinforced blunt, top-down, legislative approaches. The results are most clearly seen in the incoherence of the EU landings obligation (2013).

A recognition of the inherent limits of top-down command and control approaches to managing complex and diverse fisheries lies at the heart of the Fisheries Act and the JFS. This is important and welcome. Whilst a fisheries management framework is necessary to fulfil the UK’s international obligations, set broad policy directions and define responsibilities, the management of fisheries at the appropriate scale and with the close involvement of those whose activities being managed lies at the heart of the new approach. This is an important corrective to some of the blind alleys visited over the last four decades.

The chosen vehicle for delivering the broad objectives in the Fisheries Act is the fisheries management plan, one for each fishery, dovetailed into an interlocking system of overall fisheries management system. This is that strategy and plan for an evolution away from the rigidity of the CFP decision-making process and towards a more agile, adaptive, collaborative set of arrangements. It is a mammoth undertaking, not without its own challenges. It will require fisheries managers, fisheries scientists and the fishing industry itself, to change and adapt. It is also an approach that the NFFO has worked and argued for, and strongly supports.

The new approaches envisaged do not take place in a vacuum and the NFFO’s initial comments on the JFS consultation identifies some of the significant external factors that will come into play. We ignore these at our peril. https://www.nffo.org.uk/joint-fisheries-statements-nffo-first-reactions/ Put plainly, despite the centrality of the Fisheries Act and the JFS, there are many external factors, from the TCA to the politics of devolution, to international geopolitics that have the potential to shape the way we manage our fisheries beyond the intentions and provisions laid out in the legislation.

The word adaptive above is important. Given the inherent complexity of managing the numerous, diverse, often overlapping, fisheries within and beyond the UK EEZ, it is unlikely that we will get things right straightaway. A degree of humility and realism is required when designing and implementing management measures for complex dynamic fisheries. Unintended consequences are a frequent feature of fisheries management. Both the Fisheries Act and the JFS acknowledge that it is important to be able to take first steps and then adjust as we learn.

Frameworks and Content

If the Fisheries Act 2020 is the legislative framework for the future development of UK fisheries policy, the Joint Fisheries Statement provides the policy framework. The aim is to add substance and content over time, mainly through the development and application of fisheries specific fisheries management plans. This makes complete sense and can be regarded as laying the foundations and installing the essential support infrastructures for future fisheries policy. This does, however, leave many what might be regarded at first sight as omissions, gaps, silences, and underdeveloped themes. This is mainly deliberate and consistent with the broad approach being taken. On the other hand, there may be issues and policy areas that have been omitted through oversight or have been treated inadequately.

In our response therefore, where we highlight some of those gaps, our remarks are often not so much criticisms as pointers towards the direction we consider policy should now head.

NFFO Response

The National Federation of Fishermen’s Organisations is the representative body for fishermen and fishing vessel operators, in England and Wales.^. As such, the NFFO represents many different fleets and sizes of vessel, employing many different fishing gears and targeting many different species. Although we would not purport to represent the whole inshore fleet, many parts of which lack any representative cover, it is safe to say that the NFFO represents more under-10m fishermen as members than any other body in England. The Federation also represents the interests of eight producer organisations on the national and international stage and over-10m vessels operating outside producer organisations.

As has been made clear above, we welcome the Fisheries Act and the JFS as important steps towards a rational and effective framework for the future management of our fisheries. This is not, however, to say that we do not have our fears, concerns and doubts about aspects of the JFS, which bears the hallmarks of a document drafted to meet different demands from different quarters. This response has benefited from a series of detailed meetings with the Defra team responsible for drafting the document and the efforts of an internal NFFO working group.

Our concerns fall into five main categories:

• Participation in policy formulation
• Balance and proportionality
• The interface between domestic policy and international negotiations
• External impacts
• Underdeveloped Areas

Participation in Policy Formulation

Fisheries management plans are an integral part of the approach described in the JFS.

Accepting that the process of formulating the first tranche of FMPs is only just getting under way, we nevertheless think that it is important to express concern over the lack of clarity in the JFS as to how those whose activities will be directly affected by the content of specific plans will be able to participate in their design and implementation.

In particular, we have concerns over how we will be consulted on the development of FMPs where responsibility lies with another fisheries administration, but the fishery lies within English waters. The Farne Deeps nephrops fishery is an obvious example. This is currently the most vulnerable functional unit and where management measures are most immediately required. Cosmetic consultation after the event will not be sufficient. A clear idea about how those who are affected by FMPs will be involved in their design in the vital early stages of policy formulation will be essential.

Reference to co-management is made within the JFS but there is little depth as to advance our understanding as what it will mean in practice in different circumstances. The Shellfish Industry Advisory Group and its subgroups provide one model of a platform for co-management within the shellfish sector, and an equivalent for non-quota finfish species has recently been established. We believe that the SAIG provides a useful template for involving the three main groups that should be involved in the development of FMPs: fisheries managers, fisheries scientists, and the relevant parts of the fishing industry.

Ideally the JFS would have had much more to say on how co-management will (or could function) in different fisheries. The mechanisms for industry/science/management collaboration are absent or underdeveloped in the JFS. The JFS would also benefit from a reference to the involvement of the industry in the delivery of fisheries science.

Finally, if co-management is to be meaningful, it will require both human and material resources. Yet the JFS is relatively silent on this, apart from an enigmatic and to some, troubling, reference to “making a greater contribution to costs.”

There is we believe, a huge appetite in the fishing industry to work collaboratively with fisheries managers and fisheries scientists. The priority must be to find the institutional arrangements that allow this dialogue to take place. Once established, an iterative process of engagement, in a continuous feedback loop is likely to deliver the best outcomes.

The idea of nested FMPs goes a considerable way to dealing with the questions of FMP boundaries and overlapping fisheries. The example of how dialogue could be structured in the shellfish sector is relevant:

• Sea-basin management and international negotiations
• Non-Quota Species: Multi-year strategies with both domestic and international dimensions
• Shellfish Industry Advisory Group
• Crab/lobster/whelk/scallop subgroups
• Regional or local input

Balance and Proportionality

Recent events in Ukraine since the JFS was drafted, have triggered important policy re-evaluations particularly in the spheres of defence, energy security and food security. It will be important for the JFS to reflect and allow for some of these fundamental reorientations. The catching, landing and sale of fish by primary producers, is the foundation for the whole supply chain. In light of this ongoing policy re-evaluation the JFS should:

• Prioritise our most important food production areas from pressures from other marine users
• Re-evaluate the UK’s negotiating priorities in international fisheries agreements,
• Promote the balance between food security and environmental protection.

The text would benefit from a more explicit assurance that an equilibrium is required between maintaining food supplies and securing long term environmental objectives and that trade-offs are an integral part of fisheries management

Environmental objectives are necessary and important, but in our view the JFS as currently drafted fails to achieve an adequate balance between the importance of food supply and environmental protection. The way in which a balance can be achieved is through a risk-based approach through which risks are analysed and weighed against the benefits of food production. In particular, no clear link has been made between a risk-based approach and the precautionary approach – a discussion of proportionality is missing.

The contribution to the national benefit objective made by catching, landing, selling and consuming fish is understated. This should be strengthened.

The most challenging management challenges often lie with mixed fisheries. Although it is possible to see mixed fisheries considerations just under the surface of the draft JFS, the document would benefit from a clear discussion of the necessary trade-offs required to manage fisheries where a mix of species are caught together, and fisheries managers (and fisheries management plans) must balance competing management objectives.

This is especially true of the way the concept of maximum sustainable yield is defined and used. MSY is a useful benchmark but becomes problematic employed dogmatically, without a degree of pragmatism and flexibility. Ultimately we have no control over biomass, which can be affected by climate change, food competition and predation. The use of Bmsy to mark trigger points for management intervention is not without its challenges but a clear focus on fishing mortality provides more rational and biologically literate tool to use. We are surprised that this is not made more explicit in the JFS. Similarly, the reference to “time-bound targets” can be rendered meaningless and unachievable if due consideration to natural biological processes is not given.

International Negotiations

The notion that fisheries management plans could be used to inform the UK’s negotiating positions is aspirational but there are a number of practical and political obstacles:

• How is the interface between domestic management plans and international fisheries negotiations to be managed?
• How to balance transparency with stakeholders with effective negotiating strategies?
• The politics of devolution have the capacity to derail the translation of FMPs into international fisheries agreements. How is that relationship to be managed?
• How will relevant parts of the fishing industry be involved in fisheries negotiations?
• Where a fisheries administration takes the lead on the development of a FMP, there is potential for discriminatory outcomes, in effect or through intention. Although all FMPs require sign-off by all interested fisheries administrations, this is not an adequate safeguard if the relevant stakeholders (from a different jurisdiction) have been excluded from the development process. The example of the directed and bycatch fisheries for saithe is a case in point. Similarly, measures detrimental to pelagic freezer trawlers could be applied in an ostensibly disinterested but actually discriminatory way
• The principle should be a much clearer requirement that all fisheries administrations should involve all affected stakeholders from the outset – not only as part of a formal consultative exercise after plans have been developed; this would minimise the scope for political horse-trading
• The scope for internal UK relationships to shape external fisheries relationships requires further discussion – the issue is not restricted to the UK/EU fisheries relationship – and should cover the main elements of fisheries agreements:
• TAC setting
• Access arrangements
• Quota Exchanges
• Common technical measures (where appropriate)
• Data exchange
• Control enforcement and monitoring

External Impacts

As above and https://www.nffo.org.uk/joint-fisheries-statements-nffo-first-reactions/

Underdeveloped Areas

We hesitate to overload this section because we recognise that the JFS is a high-level document and that it is exactly an over-prescriptive top-down approach that we wish to leave behind in favour of an adaptive approach based on evidence, participation and balance. Nevertheless, it may be useful to lay some markers about concerns or suggestions for future work.

Displacement and Marine Spatial Planning

The acknowledgment that displacement of fishing activity will be an inevitable consequence of the spatial squeeze is welcome – but the JFS provides no indication of how displacement is to be mitigated of how it might impact on FMPs. This question has an added urgency as a result of the Government’s intention to accelerate the already rapid expansion of offshore wind. There is no reference in the JFS as to how marine spatial planning could be done better.

Incentives

There is no discussion about how to create positive incentives and avoid creating incentives that run contrary to management objectives.

Complexity

There is potential to create great complexity: simplicity of fisheries regulation should be an important goal in itself

Fishing Capacity

The reference to fishing capacity is welcome but sparse. Given that the balance between fishing capacity and available resources underpins sustainable (and profitable) fisheries management, this dimension/section requires further development

Partnership

Co-management requires meaningful financial support and to date it is unclear where this would come from. An explicit understanding of the costs involved would be a good place to start. An understanding of the terms of engagement between fisheries administrators, fisheries scientists and the relevant fisheries stakeholders would also be required. Terms of Reference for FMPs will be necessary, but these would probably best be developed at the operational level and should avoid unnecessary rigidity.

Fleet Diversity

The advantages of a diverse UK fleet could usefully be emphasised in the JFS

Carbon Footprint

The JFS makes the assumption that seabed disturbance releases significant amounts of carbon although the underpinning science is contested and uncertain. This is probably related to the fact that the JFS was drafted during a period when an alarmist article published in Nature ( subsequently withdrawn because of a flawed peer review process) received undue publicity. A more nuanced reference should be considered

Value Chain

Fishing is a commercial activity and should be recognised as such. The whole value chain should be oriented towards customer needs and fisheries policy should explicitly make recognition of this important dimension.

Links between Objectives and Policy Areas

The colour coded links between the JFS, Fisheries Act objectives and relevant policy areas are confusing and contain some omissions, including bycatch/fisheries management and fishing opportunities and equal access

Displacement and Evidence

The consequences of displacement are mentioned but not dealt with in any depth in the JFS. It would be important that MPAs are reviewed periodically, as part of an evidence-based approach, to demonstrate that they are delivering the anticipated benefits.

Jurisdictional Opportunism

All parties should be alert to the possibility of opportunist expansion of management jurisdictions as FMPs are developed. Empire-building by various management authorities can be expected and it is important that management structures are not unduly swayed by self-interested interventions

Funding for the Evidence Base

It is not sufficient to merely say that policy should be informed by evidence. Funding for adequate scientific/evidence/data underpinning for FMPs should be budgeted for adequately in future spending rounds.

Summary

We support the broad thrust of the draft JFS and recognise that it outlines policy directions rather than policy detail. Nevertheless, the draft text raises important questions that we have tried to address and suggest constructive ways forward.

The question of balance is an important one and we would question whether the role of food security is given sufficient attention. The JFS should explicitly address how the management of our fisheries is resilient to current and future shocks

Kent & Essex IFCA are continuing their review of current management and development of future management related to the cockle fisheries within the Kent and Essex IFCA District.

Consultation 1, which has taken the comments and views of our stakeholders from the Listening Phase asks you to agree initial framework model outlines.

As with the Listening Phase, they will be also be listening to the views of all interested stakeholders by inviting them to come talk to the IFCA on 20 and 21 April at the Inn on the Lake, Gravesend, Kent. For information on how to book a slot to talk to Members of the IFCA on 20 or 21 April go to http://cocklereview.kentandessex-ifca.gov.uk/ and click on consultation 1 on the timeline.

For more information on the proposed process and timeline go to http://cocklereview.kentandessex-ifca.gov.uk/

Completed questionnaires must be returned to info@kentandessex-ifca.gov.uk by 9 May 2022

If you require a paper copy of the questionnaire then this can be posted out to you or collected from one of the IFCA offices. Please ring 01843 585310 and that can be arranged with you.

Dear Minister

Fuel Price Crisis 

I know that your officials have been monitoring the price of fuel in the wake of Russia’s invasion of Ukraine and are aware that for some classes of fishing vessel we are approaching the threshold at which it becomes uneconomic to go to sea. For some vessels this point may already have been passed.

It will not have escaped your notice also, that other countries, and fisheries administrations within the UK, are putting in place measures to sustain their fishing sectors.

There are, of course, immediate business, personal, and community consequences when vessels are forced to tie-up in this way. Over and above these however it is important to recognise that without landings of fish, the whole supply chain cannot function. The invasion of Ukraine has brought into sharp focus issues surrounding energy and food dependency. The contribution made by the UK fishing industry to national and global food security should be central to the Governments revaluation of its policy priorities moving forward in these new, radically altered conditions.

Against this background, and the continuing volatility in the price of fuel, we consider that it is vital to begin work on support arrangements that would allow threatened fishing vessels to continue functioning. We are not oblivious to the fact that people across the whole country are suffering from the increased cost of energy and foodstuffs. A starting point might be the repurposing of the funds currently allocated under FASS. Put bluntly, investing in infrastructure for the future is important but only if we maintain the fleets through this (hopefully) short-term crisis. It is imperative that the government finds a way to support the sector through the second crisis in as many years.

We would value the opportunity to speak to you directly about the challenges facing our industry in these troubled times.

What is this about?

D&S IFCA is inviting you to respond to the formal consultation on proposed amendments to existing Category One (commercial) Diving Permit Conditions.  The proposed changes constitute a package of management measures that relate to the removal of scallops from D&S IFCA’s District during the months of July, August and September and the monitoring of the fishing activity.  Category Two (Recreational) Diving Permit Conditions will not change.  The formal consultation provides draft wording and formatting of the Permit Conditions (subject to refinement following legal advice and consultation responses), which are set out one by one, along with D&S IFCA’s rationale for the potential change.  The formal consultation includes links to further information and ends on 18th April 2022.
We are directly contacting everyone on our (email) mailing list and are giving you options on how to respond.  Your view is important, and we also encourage you to forward this information or notify others that may have an interest in the consultation.  All stakeholders can respond even if they do not conduct commercial diving for scallop within the D&S IFCA’s District.  Information is available on the D&S IFCA’s website to support this direct email notification.

How can changes be made to the Permit Conditions?
The Permit Conditions are flexible and can be amended providing a process, as set out in the Diving Permit Byelaw, is followed. D&S IFCA’s Byelaw and Permitting Sub-Committee (B&PSC) has considered information and evidence, including the findings of previous engagement work.  On 24th February 2022, the B&PSC agreed that formal consultation be undertaken on specific changes to the Category One Diving Permit Conditions.  The findings of this formal consultation will be documented and discussed by D&S IFCA’s Byelaw and Permitting Sub-Committee before any changes are made to the Category One Diving Permit Conditions.  If changes are agreed, they will come into force before 1st July 2022.

List of the Proposed Changes to Category One Diving Permits

A) An increase in the Minimum Conservation Reference Size (MCRS) for scallop to 110mm that will apply to divers with a Category One Permit in July, August, and September.
B) The introduction of a catch limit of 2400 scallop per vessel, per calendar day, that will apply to divers with a Category One Permit during July, August, and September.
C) A Remotely Accessed Electronic Monitoring Device (IVMS), that transmits the required information, must be fitted to every vessel operating under a Category One Diving Permit.
D) In July, August and September commercial diving for scallop will be restricted to those Marine Protected Areas where the use of scallop dredges is prohibited
E) In July, August and September a Category One permit holder is not authorised to remove scallop from a fishery unless all scallop removed from a fishery, on that fishing trip, is from within the District.

Rationale for the proposed changes

The Permit Conditions enable tailored management measures to balance the needs of different fishers. The proposed changes reflect a package of management measures that supports the further development of a low impact commercial dive fishery for scallops; whilst maintaining the conservation status of the Marine Protected Areas. The proposed amendments reflect different drivers for change including D&S IFCA’s own vision:

We believe in shared responsibility for the health and benefits of the marine environment and uphold our duties, now and in the future. We will be proactive in our management to restore and recover marine ecosystems, habitats and species. We envisage that the waters, under our authority, will support sustainable fishing practices serving local, national and international communities. We will innovate, and champion the use of technology, the delivery of low impact fisheries and the UK Government’s ‘Net Zero’ by 2050 carbon target. We embrace co-management and will drive change in inshore recreational and commercial fisheries, recognising their social and economic benefits, and securing a future for sustainable fishing in the coastal belt.

Other factors have been considered in the development of the proposals which include:

Under the joint Fishermen’s Mission/Seafarers’ Hospital Society the GetSeaFit Programme, managed by Carol Elliott, seeks to provide a measure of mental health advice and support for fishermen and their families as follows:

• Quayside Healthy Lifestyle Adviser covering Fraserburgh, Peterhead and Aberdeen. The adviser can refer clients to counselling and other mental health services. Email: healthylifestyleadvisor@aberdeenshire.gov.uk Tel: 07436 020165
• Health trainer(s) around the Bridlington, Scarbourgh, area who can signpost to appropriate services. Email: HNF-TR.healthtrainers@nhs.net  Tel:0800 9177752
• MH counsellor joint funded by SeaFit/Fishwell providing MH counselling services to fishermen in Norfolk/Suffolk. Email: info@fishwell.org.uk Tel: 07930 273807
• Quayside MH counsellor in Newlyn who can provide support to other areas of Cornwall.  fairwinds781@outlook.com  Tel 07934 720429

Outside of SeaFit, the Fish Mish, has a contract with ‘Inspire Workplaces’ to provide telephone MH counselling.

Seafarers Hospital Society also offer an online MH service through their ‘Together All’ programme. https://seahospital.org.uk/help-for-you/mental-health-and-wellbeing/

For more information click on the link below:

SeaFit Programme | Fishermen’s Mission (fishermensmission.org.uk)

* (For more detail on the Objectives, please see CFPO briefing on the Fisheries Act 2020).

In this, it defines how the four policy authorities understand and define the objectives and how that applies to fisheries policies. The JFS also notes wherever any one policy may meet multiple objectives.

A key element of the JFS is further detail on Fisheries Management Plans (FMPs). The JFS defines their purpose and lists the specific plans that authorities intend to publish. It does not contain the content of the FMPs.

The JFS will be reviewed a minimum of every six years. Policy authorities will publish a progress report every three years, explaining the extent to which the JFS has been implemented, and how much this has contributed towards meeting the Fisheries Act objectives. The report will also include information on FMPs’ progress and related stock status information.

Fisheries management, fishing opportunities & capacity  

The Secretary of State will determine the total fishing opportunities (through catch quota and effort quota) for the British fishing fleet annually. For most stocks, this will follow international negotiations. Sometimes, fishing opportunities will be determined on a ‘provisional basis’, if negotiations overrun. The SoS determines the share of the opportunities to go to each fishing authority, and each authority then determines the way in which those opportunities are distributed to industry. How fishing opportunities are divided between authorities will be set out in publicly available UK Quota Management Rules (QMR). Fisheries authorities will also publish their own QMR, publicly and transparently. Factors that may influence how quota is distributed (as foreseen in the Fisheries Act) include:

• Historic catch levels, contribution of fishing to the local economy, compliance with regulation, impact of fishing on the environment.

Authorities may also use quota distribution to incentivise:

• The use of more selective fishing gear and the use of fishing techniques that have a reduced impact on the environment.

The JFS notes an ambition to restore or restore all stocks to ‘biomass levels that produce yields that are sustainable for the long-term’ but does not reference MSY in this context. It provides more flexibility than CFP MSY-based targets by noting that the journey towards achieving long-term target biomass levels ‘may need to speed up or slow down’ based on changeable environmental, social and economic factors. MSY is noted as one of the core principles of how the UK will engage on international fishery negotiations, where the text refers to ‘increasing the overall number of [shared] stocks fishing at MSY or suitable MSY proxy’.

As detailed in the Trade and Cooperation Agreement (see CFPO briefing here), the JFS notes that the UK and the EU are in a 5.5 year ‘adjustment period’, allowing fleets from both sides to adjust to new access arrangements. At the end of the adjustment period, access as well as fishing opportunities will be subject to annual negotiations.

 For stocks that exist only in UK waters, the government will use the precautionary approach, using the ‘best available scientific evidence’.

Developing sustainable management for non-quota stocks (NQS) is listed as a priority in the JFS, both domestically and internationally – through the Specialised Committee on Fisheries (established by the TCA).

Fishing capacity will continue to be set at a level which balances economic needs against the need to maintain stock health, and highlights that public funds will not be given to new fishing vessels where this would increase fishing capacity beyond this level.

On fisheries monitoring, a UK ‘work plan’ is set out as part of our commitments to the Data Collective Framework. Exploring options for Remote Electronic Monitoring (REM) is referenced, but no commitment to roll-out is included.

Displacement

The JFS notes that fisheries conservation measures may result of displacement of fishing activity, and that this can have negative social, economic and environmental impacts. The statement says that government will ‘work with sea users’ to identify and address thought issues – noting pressures from offshore wind in particular.

Climate change

The JFS highlights ways in which the seafood sector can respond to climate change, both by supporting efforts to reduce its impacts and by identifying ways to adapt to it.

Central to the JFS is the government’s commitment to supporting the sector through this, and in particular, improving understanding of the impact of climate change across the industry supply chain as a whole. The effects of climate change on marine species, their habitats and fisheries will be monitored through a range of methods including the Marine Climate Change Impacts Programme, and the JFS notes a focus on understanding the importance of blue carbon habitats and their interactions with the fishing sector. 

The JFS states that these findings will be used to develop, in partnership with the industry, fisheries management approaches that will allow for long-term sustainable fishing success for stocks affected by climate change. Innovations to either reduce the impacts of climate change or respond to it will be identified, including technical engine upgrades, gear choices, and alternative fuels, along with behavioural and management changes.

 Reducing bycatch

The JFS notes that the government is committed to partnership working with industry on reducing all forms of bycatch through developing management measures. Each authority can develop their own discard exemptions for commercial catches, and the JFS points to the impending ‘Bycatch Mitigation Initiative’, which will include broad principles for reducing bycatch of sensitive species (such as whales, dolphins, seabirds, seals and turtles). The BMI is not yet published, but will set out actions to improve monitoring of sensitive species bycatch, and develop and adopt effective mitigation measures. Additional bycatch policies, under the BMI, may be developed in partnership with industry – including fishery-specific policies within FMPs.

Production, marketing & consumption of seafood

The JFS highlights the need to support coastal communities and all those working in the industry, ensuring its long-term prosperity. It highlights the government’s intention to work with the sector to strengthen the workforce and encourage new workers to the industry, including an increase in the domestic workforce. Specifically, improved training, work conditions and standards (including a focus on safety at sea), and fairer pay conditions are noted. Opportunities to diversify will be identified in collaboration with industry and pursued to help all those working in the industry adapt to the changing environment and respond to consumer needs.

Of particular interest to the PO from a Seafood Cornwall perspective, the commitment to strengthen both the domestic and international markets is highlighted through references to the promotion of healthy, sustainable and distinctive products using recognised labelling to support accreditation and demonstrate quality, sustainability and the responsible practices of the UK industry, along with the use of the best available (new and existing) markets.

Fisheries Management Plans (FMPs)

​​Fisheries Management Plans (FMPs) are being established to set out socio-economic and environmental measures relating to sustainability, the ecosystem, climate change and bycatch objectives.

FMPs will be one of the policy instruments with the most direct impact on the fishing industry’s day to day existence, shaping management and data requirements on a fishery basis. Some key details:

• They will be prepared either by one national fisheries authority, or jointly, and will set out a range of policies aimed at restoring or maintaining stocks at sustainable levels, along with targets for achieving those goals.
• Not all stocks will be covered by an FMP – data, including commercial interest, economic value, socio-economic important and ecosystem significance, will determine whether a stock should have an FMP.
• FMPs will, where possible, include specific approaches to data collection, modelling and monitoring of stocks and ecosystem health.
• Regional FMPs may also be developed, recognising geographic differences, and cover local variations in fishing activity and stocks that are not the focus of a UK-wide FMP.

The JFS also highlights the role of FMPs in informing the UK’s international negotiating position on achieving sustainable stocks, particularly for stocks where the UK shares management responsibility with other coastal States and therefore requires support from other states to deliver against the objectives of an FMP.

Existing conservation/management measures operated by each authority will be retained, and EU Multiannual Plans retained under UK law will continue to apply, although government will consider which elements may be retained or be included in FMPs with a view to phasing out EU MAPs in due course.

Before being published, all FMPs will be subject to public consultation.

FMPs will be monitored, their effectiveness regularly assessed and reported on at least every 3 years, and reviewed fully every six years (as a maximum). Reports will note progress on the implementation of policies in an FMP and the subsequent effects on sea fish stock levels in the UK.

To listen to the latest digest of Joint Fisheries Statement on Fathom, click here.  

The Executive Committee of the National Federation of Fishermen’s Organisations, at a recent meeting, declined to become involved in a judicial review aimed at overturning the Marine Management Organisation’s catch app for recording under-10m vessels catch, but has urged the MMO to open discussions to address the outstanding issues.

The NFFO Executive was unanimous that an adversarial, legal challenge would drive the parties into their respective corners, without finding solutions to the issues that some vessel operators face. Given the challenges ahead (including management measures in marine protected areas, the expansion of offshore wind and the development of fisheries management plans to replace the CFP) there is an urgent need for all parts of the fleet to be in a position to document where they fish and what they catch. Modern information technology like iVMS and the catch app definitely have a role to play. That is not to say that this version of the catch app is the definitive version or that improvements can’t be made. There are serious concerns regarding the implications of the accuracy of catch estimates prior to landing and, in some places, there are remaining technical issues. There is also a case to be made for exemptions for very small vessels and for a generation who have had limited experience of smart phones. All of these are valid points for mature discussion rather than being lost in courtroom manoeuvring where the outcome is always a gamble.

The fact that 80%-90% of the under-10m fleet are now using the catch-app doesn’t mean that we should stop addressing the outstanding issues.

Against this background, the NFFO will now call on the MMO to open fresh discussions on a new-generation catch app and the rules surrounding its use.

Areas for further work

NFFO member from Shoreham, Charlie Brock, has neatly outlined many of the outstanding issues along with positive ideas for improvement in an email recently sent to the MMO.

The email reads:

In advance of the Catch App event that is being held in Shoreham tomorrow, please see below some of our experiences (both good and bad) of using the system over the last 2 years.

 Positives:

•  The App remembers certain details like vessel PLN (as the user chooses the vessel) and most frequently used gear types and species as these can be set to a favourites list
• The system can be easily amended if the skipper has made a mistake
• Users have reported that the device shows a green status indicating that the record has been submitted successfully – a good step in the process However, on occasion this submission entry (even though green) is not seen on the PC desktop site until the user of the app submits it again for a second time.   This invariably is a few days after the day/trip until the user has the knowledge that that particular day/trip is not showing on the desktop site as submitted. This is quite commonplace, and I am unsure whether this is a device phone reception issue or a MMO server issue, as the status bar is telling the user that they have submitted successfully when they haven’t. Perhaps a secondary confirmation from the App by text message would assist here?  I am happy to talk to the software developers and explain and/or develop this further if required.
• The user interface from a PC (office based) is easy and quick to view once logged in.
• It is compatible with multiple portable device makes and models
• It is free (to those who already have the internet or a tablet or smart phone) – so only costs the fisher time.
• There are older generations of fishers that do not have the internet, email, or a smart phone.  These typically phone in their record manually which I am told by the few works well but is a slow process.
• Leach Fishing’s skippers (of under-10’s) have embraced the change and are trying very hard to be accurate and fastidious in its use (since November 2019). 

 Issues to Address:

• When adding new species, particularly in a mixed fishery where up to 25+ different species are caught, there are a few issues to address:
• If you try to add a new species to the list but have already inputted weights for other species, then the weights already inputted jump down the list as the new specie is added. This makes all the previous work of inputting now invalid, as the weights for each specific specie are now wrong.  It seems like a simple formatting software upgrade would solve this. This is not such an issue in single species fisheries like Whelks or crab/lobster
• Pots are not defined for whelk or crab lobster, so the MMO don’t know which type of pot is being used.  Crab/Lobster pots are very different to a whelk pot.
• When netting, under 10s use a multitude of mesh sizes to optimise catch returns for the day.  There are issues when choosing or deciphering what catch came out of what size fleet.  With the abolition of the catch composition rules now due to the Landing Obligation, is it not more sensible to simply ask the skipper to determine the size rangeof the type of nets he is using (e.g. trammels, gill nets etc – 90-120mm ) and then input the catch once (i.e. not each species multiplied by each net type and size) – this will create mistakes to ask a skipper to enter weights down to that minute detail.
• The ICES rectangle is split down further into 9 smaller sub areas.  This is not the case on paper logsheets or E-logs, so why is this different for the catch App users? This causes difficulty and inaccuracy when gear is spread across multiple rectangles. Which does the fisher choose?
• Inability to access the app (either on potable device) or on a desktop PC – see screen shot attached taken today at 05:27 – stating that the MMO server is down so users cannot access the site.  This has happened more than once.

 The regulation behind the catch app and further suggestions:

• In practical terms in a mixed fishery where quota species are caught as part of the catch, the skipper must complete his catch record before landing.
• Whereas those fishing purely non-quota stocks, have 24 hours to complete their catch record.  This creates disparity – different rules for different fishers and I would think makes MMO enforcement more difficult.
• 10% tolerance for accuracy is too tight on an “estimated” weight of catch. If the fisher is out with the 10% he is exposed to possible prosecution. Paper log and E-log have the 50kg rule to help manage this for the fisher, thereby creating disparity across fleet sectors.
• However, there is no such 50kg rule for the catch app. A person is more likely to get the estimate of smaller weights wrong and therefore fall outside the 10% tolerance. Again this exposes the vessel to possible prosecution. This is because the fisher is now required to input everything he catches, down to fish in single numbers. It is near impossible for fisheries managers to estimate within the tight 10% tolerance, let alone a fisherman rolling around at sea.
• Scales on the quayside do not offer a solution either, as the weights on a resulting sales note will often be different (e.g. the fisher has sold 25kg for cash as per his allowance, drainage loss, gut factor conversion differences etc etc)
• More accuracy would be obtained if the under-10 sector had to complete a landing declaration as the over-10s do.
• Duplication – in the Sussex IFCA area the IFCA require those catching shellfish to complete shellfish returns in line with their Shellfish Permit byelaw.  It seems nonsensical that the fisher is providing this information to MMO on the catch record daily, and then again to the IFCA on a shellfish return once a quarter – why can’t the IFCA simply have access to the Catch record data or request it quarterly from MMO? Especially now with iVMS imminent.

Way Forward

My suggestion would be to reform the catch app into a more streamline version of itself, keeping the good bits, outing the bad, and incorporating new elements to put it in line with other fleet segments and lessen the probability of mistake and following prosecution.

This will take more than contained in this email, but I’m happy to discuss in further detail if there is the political will in Defra/MMO to talk about its reform.

The main concern was that the catch app would create disparity and differing standards across fleet sectors.  This could lead to confusion in understanding which ultimately will lead to more prosecutions.  The message was to “keep it simple”.

To some extent this has been achieved from MMO’s point of view, however there is still some way to go from an industry point of view to avoid any unnecessary prosecutions due to an overly complex process creating a lack of understanding.

All the very best  

Charlie Brock

The Ukrainian conflict will also come to be seen by history as a major political and economic turning point. The fishing industry will not be exempt from those changes. “Inflection point”, “game changer”, and “paradigm shift”, are some of the terms already in use in government circles to describe the momentous period of change that we are facing.

Changes

A driving and urgent need to reduce dependency on hostile and potentially hostile countries for our energy and food supplies has rocketed to the top of political agendas in the UK, Europe and across the world. A complete re-evaluation of where our interests lie is under way and that is likely to have profound implications for the fishing industry.

Fuel Costs

The most immediate issue is undoubtedly the cost of fuel, which remains volatile but last week came perilously close to the break-even point when it becomes no longer economically viable for some classes of vessel to go to sea to catch fish. As energy markets adjust to the new geopolitical realities, the supply chain cannot function without raw material and primary producers, the focus is on how to provide the support that the fleets need to maintain continuity of supply. Repurposing some of the existing funds allocated to fishing to support continuity of food supply whilst the energy markets adjust seems like the most likely route to immediate relief. This could be done much faster than making an entirely new case for support to the Treasury. Talks with government are already under way.

Energy Security

The expansion of offshore wind, already moving at breakneck speed because of the climate emergency, is almost certainly to be accelerated by removing planning obstacles and providing incentives of one kind or another. This has profound potential consequences for where we will be able to fish in the future. The NFFO and its constituent organisations is already in discussion with the government, Crown Estate and individual offshore developers on prioritisation, the siting and design of next generation windfarms and their export cable routes. The importance of safeguarding priority fishing grounds is under urgent discussion.

Food Security

The NFU has already indicated that making up the shortfall of reduced supplies of wheat, sunflower oil, and other agricultural products from Ukraine will require a re-evaluation of agricultural and land use policies. It will be important that the role of fish and shellfish in contributing to national and global food security is recognised as these policy adjustments take place.

It is not expected that domestic supply can completely fill the gap left if imports of whitefish from Russia are closed down, but it will be important to do what can be done. There are opportunities, for example, to focus attention on the many under-utilised species that make good eating but are not marketed to optimum effect.

Ukraine has been an important market for some pelagic species and repercussions of war and population displacement will have both economic and political consequences.

All this underlines that the importance of fish and fisheries products to food security is given due weight as policies are re-evaluated and policy adjustments made.

Policy Arena

The new priority given to unity in the face of aggression will remove earlier policy fault-lines and potentially create new ones. We need to be alert to the rapidly changing policy landscape.

Summary

 Within a few weeks, the world has been forced into a radical rethink of the assumptions that have underpinned defence, energy and food supply policies for decades. These changes will impact on the fishing industry, and it is important that we fight our corner to ensure that the contribution of fishers as primary producers – on which the whole edifice of food production depends – is recognised and understood. Even within, or even because of the fog of war, a coordinated and coherent approach to the new imperatives of energy and food security is required. It is essential that the voice of the fishing industry is heard within this period of fundamental policy reorientation.

Research shows that women’s roles in fisheries are vital, from net to plate (Gustavsson, 2020), and UK Women in Fisheries is here to recognise the work that we do, and support it.

Through networking, events and resources, members will get to know each other, support each other and build a presence. Women’s role in fisheries will be recognised and their voices heard, so that the whole sector can be improved.

https://www.women-fisheries.com/#:~:text=UK%20Women%20in%20Fisheries%20is,else%20in%20the%20fishing%20industry. 

These events will allow local stakeholders to learn more about the SEP and DEP projects, provide an opportunity to ask the project team questions, and for the project team to understand local concerns. The details of the events can be found below.

• Monday 07 March – 2pm to 7pm – Aylsham Town Hall, Market Pl, Aylsham, Norfolk NR11 6EL
• Tuesday 08 March – 1pm to 6pm – Hall for All, Weston Longville, Norfolk NR9 5JP
• Wednesday 09 March – 1pm to 6pm – Swardeston Village Hall, High Common, Swardeston, Norfolk NR14 8DL
• Thursday 10 March – 11am to 4pm – Sheringham Museum, Lifeboat Plain, Sheringham, Norfolk NR26 8BG

In October 2021, Equinor announced their decision to extend the pre-application period for the SEP and DEP projects to allow time to carry out additional analysis and further develop proposals. It was originally planned to submit the Development Consent Order (DCO) by the end of 2021, but the intention now is to make the submission to the Planning Inspectorate by early summer 2022.

Email: info@sepanddep.co.uk

Freephone: 0808 1963 673

Freepost: FREEPOST DUDGEON AND SHERINGHAM EXT

As part of this three-year project, Cefas have constructed a questionnaire to gather feedback which will help target sampling in the future. This questionnaire is targeted at skippers and vessel owners, and aims to provide an insight into edible crab stocks around the country. The knowledge and experience of CMG members would therefore be greatly valued, and in the interest of reaching as much of the fleet as possible, it would also be appreciated if members were able to share this survey with others within the crabbing fleet.

This questionnaire (linked below) takes 5-10 minutes to complete, and is entirely voluntary. Cefas have asked that if you do choose to respond, could you please complete the questionnaire by 31st March 2022. (NB. The questionnaire is not related to the Defra-led investigation into crustacean mortalities in the North-East).

Link to questionnaire:

https://forms.office.com/Pages/ResponsePage.aspx?id=mTHq7qCv60G78vbkLD2nz5-qfDkVfQVJt0AaGRMDFrlURFFBVkNRMU1SRlEwVEI3RUlCNk1GWjgwNi4u

The circulation of this questionnaire has been coordinated by Rosslyn McIntyre (Shellfish Scientist, Cefas), and she is happy for anyone to get in touch via email with further questions or comments (rosslyn.mcintyre@cefas.co.uk).

The shellfish industry is, understandably, desperate to get to the bottom of the issue before the main fishing seasons begin later in the year. There is also the question of consumer confidence to consider as the media coverage spirals out of control.

Despite the range of viewpoints on the causal factor behind the deaths, all parties have an interest in getting closer to a definitive answer. The official report by Cefas for Defra does not offer that irrefutable explanation but suggests that the weight of evidence tends to support the algal bloom theory. Algal blooms are naturally occurring events that can temporarily reduce the oxygen levels in the water column – potentially causing deaths in crustacea on the seabed.

Some parts of the industry are convinced that the evidence – in particular, the location and spread of the deaths and tidal patterns – points firmly towards dredged spoil from the Tees as the causal factor. So far, the testing that has been undertaken has not identified a smoking gun – a toxic chemical in sufficient quantities to cause the harm witnessed.

The Cefas/Defra report must not be the end of the matter. It is imperative that all the authorities – Defra, Cefas, Environment Agency, IFCA – cooperate to collate, pool, and analyse the necessary evidence to arrive at a definitive conclusion.

If this is a natural event, then there is a job of work to be done in providing assurance that crab and lobster are now safe to eat. Even natural events like algal blooms can have their origins in human activities. If this was an algal bloom, then there is a job of work to be done to provide the definitive proof of it and to understand what has caused it in this place and at this time. If the evidence points to pyridine or some other contaminant, there is a strong case for the application of the precautionary approach – to prohibit further dumping and any further die-offs.

It is legitimate and important that independent voices and research be considered too. This is no time for creating artificial boundaries to knowledge – but the work must adhere to the most rigorous scientific standards. Cherry-picking facts to support one explanation or another is not science.

The central point is that this must be an evidence-led process. Going down the wrong path has the potential to cause as much harm to fishing interests on the coast as the original event.

The MMO’s decision to suspend its prosecution of Greenpeace, is a desperate betrayal of the fishing industry. It represents a massive breach of trust and confidence that will take a lot to repair.

The MMO had been given clearance by the courts that it was fully within its authority to prosecute Greenpeace for dumping boulders within an MPA without a licence as part of its ongoing anti-fishing campaign. Despite having obtained sufficient evidence that an offence had been committed, the MMO has chosen to abandon the case because of some quite irrelevant side remarks made by the judge. An option to appeal against the judge’s misapplication of the law has not been taken.

This decision will have consequences that will undermine the MMO’s authority across the piece. It will confirm the fishing industry’s view that the rule of law is applied unevenly. It very much fits the current theme in high politics that there are rules for some which don’t have to be followed if you have friends in high places. It will undoubtedly mean that the roll-out of the catch-app and iVMS will be made many times more difficult. Instead of sending a signal that we are all equal under the law, it will send a green light for further vigilante actions as already seen on the Dogger Bank and Channel.

The Marine Management Organisation has made the wrong call. The MMO should have done the right thing and now its credibility will be called into question.

In the wake of the TCA, and the cooperation needed to build effective well-designed fisheries management plans under the new Fisheries Act, rebuilding trust between the regulator and those whose activities it seeks to regulate should have been an absolute priority. Together with the revelation that the increased catch limits for bass agreed with the EU are available now to the European industry but not UK fishers until mid-year because of a legal technicality, this decision will create nothing but barriers.

For those of us who have worked for a collaborative relationship between fisheries regulators, fisheries scientists and fishers , this is a massive reverse and there is no other way to express it.

As for the judge in the case:

“Responsibilities which are conferred by law on ministers politically answerable to Parliament should not be shifted to judges politically answerable to no one. The function of the courts is not to review the social or economic merits of government policy. It is to determine whether it had the power in law to act as it did… and whether the decision-making process was defective.

…Judges are not voted in and cannot be voted out. They should be careful therefore not to exceed their proper role.”

Jonathan Sumption LRB 10/2/2022

The MMO’s decision to abandon this prosecution is an abrogation of its own duties as a regulator and branch of government. There are already questions about the MMO’s arms-length-status to government in the context of devolution and political accountability because only the English fishing industry has no dedicated voice at ministerial level within internal UK negotiations. This case will not diminish those concerns.

Dear Minister

Seabass Catch Limits

It is with some incredulity that we have learnt that the increased catch limits for bass agreed with the EU before Christmas will not be available to UK fishermen until mid-year. Meanwhile, EU vessels, some operating up to six miles of the UK coastline, will be able to utilise those higher limits with immediate effect.

The explanation that a new statutory instrument is required, and that this form of legislation takes time, is a poor excuse and does not sit well with the Government’s assertion that independent coastal state status will allow the UK to deliver a more agile and effective fisheries policy than the CFP.

To be clear, for the period British fishermen are denied access to the higher catch limits, they will be forced to discard valuable seabass caught as an unavoidable bycatch. The changes to the bycatch limits, by providing vessels with more flexibility, were expressly made to address this unacceptable by-product of the bass regulations.

We would be grateful if you could take every step available to you to fast forward the legal process. It does not bode well for the future if every adjustment to the UK rules is stalled, whilst European vessels operating on our doorstep enjoy a significant advantage.

Note

Bass limits for 2022 agreed with the EU in December and reflected in the agreed record:

• Hooks and line from 5.7 tonnes per year per vessel, up to 5.95tonnes
• Fixed gill nets from 1.4 tonnes per vessel per year up to 1.5 tonnes
• Trawl/ beam trawl– 760kgs per two months, up from 360kilos per month, within 5% per trip limit

The consultation can be viewed here

The policy statement will provide a UK framework for delivery of the eight settled objectives in the Act (see objectives below). This is therefore a document of historic importance, which will shape the way we manage our fisheries in the decades ahead. Each Joint Fisheries Statement (JFS) will be reviewed at least every six years.

Like the Fisheries Act, the draft Fisheries Statement is a carefully crafted document which balances ambitions to deliver fisheries operating at their maximum sustainable yield, with the realities of managing complex fisheries, sustaining economically viable fishing businesses, and underpinning thriving fishing communities.

Especially welcome is the emphasis on delivering resilient supply chains and acknowledgement of the role the fishing industry plays in providing food security for the nation and beyond. The JFS stresses the importance of generating well remunerated high -quality jobs throughout the fishing sector.

Significantly, the policy document will also inform the UK’s approach to international negotiations.

Fisheries Management Plans

In the consultative documents, heavy emphasis is placed on the fisheries management plans which will provide the future basis for delivering sustainable and profitable fisheries. These will initially focus on some of the most commercially important fisheries. As each of the plans has selected a lead administration, there is likely to be some controversy on boundary issues and choice of lead administration. The development and implementation of fisheries management plans implies a mountain of work ahead.

The NFFO will now study the JFS in detail before submitting a detailed consultation response before the April deadline.

Context

The JFS is a statement of intent, but it will not be played out on a blank canvas. The political context within which those intentions are taken forward can profoundly shape outcomes.

Ill-considered amendments to the Fisheries Act were largely fought off as the legislation passed through Parliament. The Act managed to retain its coherence and focus. Industry representative bodies, including the NFFO, briefed extensively through the whole process to ensure that parliamentarians across the political spectrum understood what was at stake. It will be important that the JFS is similarly protected as it passes through the consultative process and parliamentary scrutiny. There may be scope for some improvements, but the bigger risk comes from the one-dimensional “further, faster” school of naivety.

It will be important to fight these off vigorously.

The more significant risk comes from outside the legislation or formal policy statements.

Fisheries policy evolves within and is shaped by its context. That context includes the Trade and Cooperation Agreement with the EU which holds the UK fishing industry far from the access and quota share arrangements normally associated with an independent coastal state. There is little sign, either, that the EU, or its member states intend to passively accept the implications of the regulatory autonomy that is written into the TCA. This is likely to remain a source of tension, not least around how non-quota species are to be managed in future. The UK/EU Specialised Committee on Fisheries, along with annual fisheries negotiations, will be the principal arena in which these frictions are worked out.

Displacement of fishing activities is briefly acknowledged in the JFS but the scale of potential unintended consequences implicit in the UK’s plans for offshore wind and marine protected areas is seriously understated. Displacement has the potential to knock fisheries policy and the fishing sector sideways.

The scope for high level political interventions based on not much more than whim and good intentions, also has the potential to undermine the fishing industry and long-term sustainable fisheries management, whatever the Act and JFS say about evidence-based fisheries policy. Constant litigation is not a financially viable or attractive option for holding government to the binding obligations of the Act, JFS, or management plans, at least not for most industry organisations. Who is in government and their priorities will therefore remain a profoundly significant factor, whatever is in the JFS.

The politics of devolution are never far from the surface and have the potential to disrupt or delay.

The Policy Statement may therefore lay out destination and ambition but there are some very big pitfalls to swerve and battles to be fought on the road to its delivery.

Institutional Memory

Perhaps the most disturbing aspect of the JFS is its relative silence on the role of the fishing industry in shaping its own destiny. Co-management is given a notional mention but the lack of detail or serious attention speaks volumes. The people whose livelihoods are shaped by the policy statement are treated as just one more stakeholder – equivalent to those many groups who merely hold various opinions on fisheries.

An unwelcome gap between the rulers and the ruled is opening, seen most vividly in relation to policy on highly protected marine areas, but showing also in the UK’s approach to international negotiations, where the industry is largely a bystander.

A command-and-control approach to fisheries management has been the hallmark of the CFP. Even progressive parts of the European Commission, expressed in their periodic green papers on reform recognised that remote top-down decision-making was the root cause of repeated implementation failures.

There are signs that as the years pass important lessons are being forgotten. There are, in fact, no technocratic solutions in fisheries management. Effective fisheries policy requires the involvement and at the very least, the acquiescence of those whose activities are being managed. The outright failure, unintended consequences, or stuttering implementation, of a succession of cod recovery measures, closed areas, the landing obligation, technical measures and a myriad of other initiatives, all provide testimony to this essential truth. On the other hand, examples of intelligent recovery plans developed in close collaboration between fisheries administrators, fisheries scientists, and the fishing industry testify to the effectiveness of the co-management ideal in its various forms when it is adopted.

The failure to learn these lessons is a loss of institutional memory and there are danger signs that that is exactly where we are as we move to adopt the first joint fisheries statement and fisheries plan under the new regime.

Conclusion

The Fisheries Act, the Joint Fisheries Statement, and fisheries management plans, are important steps forward towards a more agile and effective fisheries policy than we have been used to than under the CFP. The NFFO will now scrutinise the JFS and comment appropriately. But hard lessons over the years suggest that words in a legislative or policy text often tell us little about how the measure will be implemented and the real-world consequences. It will be important to stay engaged, stay united and prepare for what contingencies arise, whether from the political sphere or from the complex nature of fishing itself.

Notes

The objectives in the Fisheries Act are:

(a)the sustainability objective,

(b)the precautionary objective,

(c)the ecosystem objective,

(d)the scientific evidence objective,

(e)the bycatch objective,

(f)the equal access objective,

(g)the national benefit objective, and

(h)the climate change objective.

The FISP Network, comprised of three fishing charities, was set up to support a collaborative approach to fisheries research whereby fishers and scientists jointly develop a scientific proposal, based on a set of research needs set by government with stakeholder input. All developed proposals are supported through the process of applying for further stages of government grant funding.

The FISP Network launched in November 2021 to coincide with the inaugural opening of the government’s £10 million grant scheme, Fisheries Industry Science Partnership (FISP). The FISP grant scheme is currently closed, however, the FISP Network are still asking people or groups within the industry to come forward with their ideas, so that proposals can be developed and written in time for the second round of the FISP grant, scheduled for spring 2022.

Why is industry input important?

The value of involving industry and using the intimate knowledge and experience of fishermen has historically been side-lined in scientific research and fisheries management, despite industry being most directly affected by management decisions in terms of their economic livelihoods and well-being. The failure to bring industry into the fold has ultimately impacted the sustainability of fisheries and has contributed to data deficit fisheries, poor research capacity and a siloed approach to conducting and developing fisheries science and management.

It is now widely accepted that industry, academia, and government all have unique contributions to make to fisheries research, and no single group can provide the information required to meet the increasing challenges of fisheries sustainability alone. Research that is collaborative (i.e., involving industry, academia, and government) will help to solve persistent and emerging problems in fisheries; effectively utilise the skillset of stakeholders; and help to build new capacity in fisheries science. Collaborative research also allows stakeholders to disseminate so that the science is effectively understood and accepted by a wider audience outside the scientific community.

The FISP grant scheme and supporting FISP Network provides a platform that enables industry-led priorities that are pertinent to sustainable fisheries management to be given a fair and equal opportunity to be developed and funded.

What is the FISP grant scheme?

The Fisheries Industry Science Partnership (FISP) scheme is a £10 million government fund which seeks to:

– improve data collection, particularly for data limited species,

– enhance knowledge of technical measures including fishing gear selectivity, and/or

– build a better understanding of the ecosystem benefits and environmental impacts of aquaculture.

Projects can apply for funding to develop a research study (i.e., Part A of the FISP scheme) or fully developed scientific proposals can apply under Part B of the FISP scheme. Grants of up to £20,000 are available to develop research proposals. Contracts of up to £300,000 are available to carry out a full research project.

The FISP grant is a competitive process managed by DEFRA. The FISP Network does not have any influence over the grants awarded.

More information about the FISP scheme can be found on the government website: https://www.gov.uk/guidance/uk-seafood-fund-fisheries-industry-science-partnerships-scheme

What does the Network do?

The Fishing Animateurs identify and collate industry-driven ideas, connect industry with academic institutes, and help to write grant application bids.

Fishing into the Future can help to develop the ideas further by supporting stakeholder relationships and facilitating knowledge sharing between industry, science and government.

The Fishmongers’ Company’s Fisheries Charitable Trust offer match-funding for bids nurtured through the FISP network and approved under the FISP scheme. Funds are capped at £2,000 for Part A and £30,000 for Part B of the FISP scheme.

Who are the FISP Network?

The Fishing Animateurs

The Fishing Animateurs help members of the fishing industry understand the requirements of government grant programmes and support the application process. Their service is free of charge and is aimed primarily to support the small-scale coastal fleet.

Lead Contact: Imogen Smith-Devey. Imogen started working on the Fishing Animateur project two years ago, after studying for a Zoology Degree with an emphasis on marine ecosystems. During her time working in the Fishing Animateur team, Imogen has supported hundreds of fishermen to access government grant funding to improve their businesses. She believes in industry-led action and can help to access funding to enliven projects.

Fishmongers’ Company’ Fisheries’ Charitable Trust (FCFCT)

The Company’s Fisheries Charitable Trust supports a wide range of projects, grants and convening to build and safeguard a prosperous and sustainable fishing and aquaculture industry. The Company’s Fish & Fisheries team work in collaboration with industry, government, academia, non-governmental and third sector organisations and engage across the breadth of the UK fisheries sector.

Lead Contact: Alison Freeman. Programme Manager

Alison Freeman manages the Company’s inshore fisheries programmes. She helped to set up the Company’s COVID-19 ‘Rapid Response Grant Programme’ and the Master Fishmonger Standard. She advocates community-led, regional fisheries management through a number of developing initiatives.

Fishing into the Future

Fishing into the Future is a UK charity that was built and is guided by fishermen. They support people in the fishing industry to engage with fisheries science, management and sustainable business practices and bring fishermen, scientists, and fisheries managers together to share knowledge, strengthen relationships and build confidence in order to achieve effective dialogue, collaboration and mutual understanding.

Lead Contact: Emma Plotnek, Executive Director

Emma Plotnek returned to the UK to work at Fishing into the Future in September 2020 after spending time working in the Chilean fishing sector. Since joining FITF, Emma has been guided by the industry to improve knowledge sharing between industry government, and the scientific community.

Who should I contact?

For further information or to tell us about your idea and/or study, please contact the Fishing Animateurs on:

Call: 01736 362782 to leave a message about your project idea. Text: 07534580450 with your name, project theme and size of vessel. Email: fishing@cornwallrcc.org.uk More information: https://www.fishinganimateur.co.uk

The NFFO’s take on these crucially important negotiations and a round-up of the main issues confronting our industry in the year ahead are included in our newsheet which can be read here.

On the table for discussion is the Fisheries Industry Science Partnership (FISP) scheme, which forms one arm of the three-stranded £100m UK Seafood Fund. The FISP scheme aims to improve and share knowledge of fisheries and aquaculture by funding data collection and research to support sustainable fisheries management. This will be done through collaboration between the fishing and seafood industry and research organisations.

Defra’s policy official described how the scheme has been set up to build a better understanding of stocks, with the intention of producing results that are valuable for the fishing industry. He explained projects will only be funded if they involve a partnership between industry and scientific representatives and that there are two branches to the scheme.  Part A provides funding for the development of research ideas, so fishermen don’t lose out on any expenses for travel to meetings etc., while the more substantial Part B provides funding for the research project itself.

“One of the key characteristics of FISP, is that in order for a project to be funded, it must have a partnership between a research organisation and a part of the industry. Therefore, it must have buy-in from the industry.” Defra Official

Barrie raised the main concern for many fishermen about the scheme – while established institutions and academics are well-versed in applying for funds, working fishermen typically have less time and resources to tackle the application process. This makes it challenging for the industry to fully engage, and even when included alongside scientific institutions, could just fulfil a ‘token’ function.

Defra addressed this concern, and highlighted the FISP Network, which comprises Fishing into the Future, the Fishing Animateurs, and the Fishmongers’ Company’s Charitable Trust. These three organisations aim to help fishermen overcome barriers to accessing the scheme, such as through connecting fishermen with ideas for research projects with relevant academics. The official recommended getting in touch with the Fishing Animateurs to receive guidance for going through this process.

“The Fishing Animateurs are a really good first port of call…I understand they have already put several potential applicants who are looking to apply for future rounds of FISP in touch with research organisations where those links didn’t exist before.” Defra Official

Defra also emphasised that the FISP scheme aimed to be receptive to feedback and could adapt as it progresses. Submissions for the first round are currently being assessed, and subsequent rounds will incorporate any lessons learnt, making sure that industry and science actors are working closely together and both fully included in making decisions.

“In all of these funding programmes the proof of the pudding is always in the eating. The key indicators that we’ll be looking at is whether the different parts of the industry welcome this as something that’s useful and relevant to their businesses, their fisheries, their lives, or whether it’s something that channels the funding in a different direction that doesn’t benefit the industry…for us that’s the key and that’s where the scrutiny must lie.” Barrie Deas

Barrie mentioned Fisheries Management Plans as a potential area for FISP to focus on, given that virtually all fishermen have a stake in plans relevant to their activities. Defra are receptive to this idea, and though the scheme is quite broad at present, it retains capacity to narrow its focus for future rounds.

With regards to when funding becomes available, it was noted that most of the funding will be paid in arrears – once the work has been completed. For Part B, this will be in quarterly installments to match milestones throughout the course of the project. Part A, however, does include the potential for a 25% upfront payment. This is in recognition of the fact that many industry representatives, especially small-scale fishermen, do not have the capital required to pay for project costs and recoup later.

 Listen now

The full Fathom episode can be accessed here, for a full exploration of the points covered above. There will be three more episodes in partnership with the NFFO, released in the New Year – stay tuned for updates. Follow Fathom on Twitter, add your mobile number on the CFPO’s website for free text alerts

Additional licences have been issued, but the UK has stuck to its position that licences to fish in the UK inshore zone will only be granted when there is sufficient evidence that each vessel meets the eligibility criteria of having fished within the UK 6-12 zone during a defined historic reference period. Technical discussions between the UK and the EU have resulted in some additional licences being granted – but others have not met the eligibility criteria and will not be licenced. This is entirely within the terms and spirit of the TCA. Technical level meetings have focused on separating difficult borderline cases from opportunists. There are those amongst the applicants who see the value of a licence endorsement to fish in UK waters but never used that right in the past. The technical level is where the matter should have stayed but wider political issues escalated the issue to the diplomatic level and in the media. The allocation of licences has also been complicated by the right of crown dependencies to apply their own management rules autonomously. 

Belligerent Language and Wider Politics

The extraordinarily belligerent language used by the French government over the issue sparked a diplomatic incident earlier in the year. This rhetoric, however, owes more to domestic politics in France, and especially manoeuvring ahead of the impending presidential election, than anything connected to the intrinsic issues at stake. The generally poor relationship between the UK and France on a range of other issues including submarine contracts and Northern Ireland hasn’t helped.

Parts of the French fishing industry are likely to maintain their rhetoric on the issue and we can expect a certain amount of gesture politics from time to time. In part this is because the French industry was told, and appears to believe, that the TCA represents the CFP status quo when it does not. Licences to fish in UK inshore waters are conditional. More widely, regulatory autonomy (the ability for the parties to apply their own fisheries management rules to all vessels operating within their respective EEZ) are explicitly recognised by the TCA and will become more evident over time. In part the vitriol from France has also been an attempt to limit the UK’s evolution away from the CFP. It is inevitable, however, that UK’s fisheries regime will over time continue to diverge from the CFP, as fisheries management plans are developed and implemented. Threatening language can be expected each time the UK takes another step away from the body of retained EU fisheries law. 

Replacement Vessels 

It is important also that replacement vessels are limited to like-for-like if we are to avoid the emergence of a new class of oversized EU fishing vessel entering the UK 6-12mile limit to exploit the UK’s coastal fisheries. Both in terms of the TCA but also future sustainability it is important that this loophole is closed quickly. Our understanding is that a formula which constrains replacement vessel capacity is part of the deal reached with the EU. 

Red Line

This time last year the UK fishing industry was bitterly disappointed by the terms of the TCA and the abandonment of an important red line that promised an exclusive 12-mile limit to protect our coastal fisheries – a normal right exercised by all other coastal states. It is worth remembering that the geo-political adjustments associated with the UK’s departure from the EU (including those related to fisheries) have only just begun. They will work themselves out over the next years and even decades. The UK’s legal status as an independent coastal state under international law will be a central reference point but much will also depend on the political alignments of the day.

Remember the claim published in Nature that trawling disturbance releases more carbon than the whole airline industry?  The estimate upon which it is based is at least an order of magnitude too high according to a response led by Jan Hiddink of the University of Bangor.

This and flaws found related research is reported on by Max Mossler of Sustainable Fisheries UW.

Another high profile paper that the Nature paper depends on that claimed closing an additional 5% of the ocean to fishing would increase catches by 20% was found to have seriously flawed assumptions about the connectivity of global fish populations which meant for example that MPAs in the Atlantic could benefit fish in the Pacific.  A further assumption on fish birth rates (density dependence) assumed dependence on the whole world population when in fact they can be only dependent on the specific population of a particular species; North Sea Cod has no relation to the breed success of Gulf of Maine Cod.  Serious data errors were also identified one of which overegging the food benefits of MPAs.  The paper was retracted after it emerged that the person responsible for assigning peer reviewers had collaborated with the authors and was a lead author of the Nature paper.

This follows a trend in publishing  predictions using limited sets of assumptions in high profile journals, courting high profile media that is then used for advocacy for ocean protection to limit fisheries.

Read Max Mossler’s full article

The campaign is providing the fishing industry with advice on how to reduce the risk of capsizing, and is asking skippers and fishing vessel owners to do their stability and freeboard checks this winter. 

Capsizing due to insufficient stability is a major cause of fatalities for fishing vessels under 24m in length, especially those under 15m. The main causes of capsizing are:

• Vessel modifications
• Free surface effect
• Hauling
• Overloading

The Home and Dry website offers helpful resources on vessel stability, including;

• Videos on how to do a roll test and measure a vessel’s freeboard, 
• Easy-to-understand animations detailing the main factors that can impact stability on a vessel, 
• The new requirements of the Code of Practice for the Safety of Small Fishing Vessels and 
• Stability awareness training courses. 

Know your limits. Check the stability of your vessel. #HomeAndDry #KnowYourLimits

Website: www.homeanddry.uk/vessel-stability

Roll test video: https://vimeo.com/651987307 

Offset load test video: https://vimeo.com/651988514