Dear Hugh………… Fight for Fish Campaign

Hugh Fearnley-Whittingstall

KEO films

101 St John Street

London

EC1M 4AS

Dear Hugh

Fight for Fish Campaign

As you know the NFFO was pleased to support the Fight for Fish campaign and we are equally pleased to see that it has already had some positive effect. Demand for some of the low value species, like pouting, has increased as a direct result of the Channel 4 focus on fish, fishing and discards.

As we have said on our website, the programmes brilliantly illuminated the discards problem. Even if the campaign was a little thin on describing what is already being done to reduce discards, and what in practical terms can be done to move further, it provided the level of public attention that can translate itself into political and commercial action.

The main test of the Campaign’s strength, and whether discard reduction really has become a priority for the Common Fisheries Policy, will come later this year with the review of the EU Cod Management Plan. When the current plan was adopted in 2008, the Commission took the deliberate decision to set the North Sea cod quota at a level in which massive discards were inevitable. If we are to avoid a repeat of this economic, environmental and ethical catastrophe, the Commission will have to be persuaded that the avoidance of discards should be at the heart of their approach.

It is important for you to understand that there has already been real progress in reducing discards. Moving beyond posturing will require all parties to build on what has been done already. There is no single solution to discards because different kinds of discards have different causes; but there are solutions – tailored, customised initiatives that have already made a difference. None of these represent a panacea: there are none. Supported (rather than undermined) by the management system, we believe that discards could be progressively pushed to the margins rather than residing as at present centre stage. We draw your attention to some of these initiatives:

Catch Quotas: participating vessels provide fully documented catches and commit to no discards of cod

Trevose Seasonal Closure: provides protection for aggregations of spawning cod where and when they would be vulnerable and discards more likely

Square Mesh Panels: have dramatically reduced unwanted catch of either juveniles or by-catch of haddock and whiting

Catching for the Market: aims to align landing with what can be sold profitably

Cod Avoidance Plans (formal and informal): where skippers use their own knowledge and experience to avoid cod whilst fishing for other species and while stocks rebuild

Benthic Release Panels: provide beam trawlers with a means to reduce discards and maintain the quality of their catch

Irish Sea Double Panel Project: trials to reduce discards of demersal species in the nephrops fishery using a double square mesh configuration

Shrimp veils: permit the escape of small plaice and other species in this necessarily small mesh fishery

Real Time Closures: have successfully diverted fishing on vulnerable aggregations of cod and encouraged cod avoidance

50% Project: through involvement of skippers and social marketing reduced discards in the beam trawl fishery by more than 50%

Eliminator trawl and (variations on the same approach) allows cod to escape from a demersal net

Against and so far limiting all of these initiatives are three main drivers of discards – regulations that generate discards; unselective fishing gear; and low value species. The Fight for Fish campaign, if sustained, we believe could provide the dynamism and commitment to secure a major breakthrough in reducing discards of all three types. So far, this has been missing at the highest levels (although public hand-wringing has not).

Regulatory Discards

The most dramatic intervention that the Fight for Fish could make would be to ensure that the replacement to the current cod management plan (from Jan 2012 onwards) will avoid the obscene levels of discards witnessed during the current plan.

Secondly, the Technical Conservation Regulation (EC 780/98) is based around the notion of catch composition and is well overdue for replacement. Vessels are required to have on board the “correct” catch composition for the mesh size that they are using. This inevitably generates discards as “fish don’t necessarily swim in the correct percentages”. This is another sphere where the focused attention of the campaign could be useful.

And finally, each December the Council of Ministers on a proposal by the Commission make quota decisions for the coming year that increase discards. This is where the cosmetic approach to fisheries management is at its worst. At present this is the approach that is resulting in the discards of many tonnes of dogfish, skates and porbeagle shark.

Gear Selectivity

We are certain that huge steps can be taken in reducing discards by refining gear configurations. Indeed huge steps have already been taken. What prevents a further rapid movement in this direction is a complex mix of economics, mindset and inertia. It is not possible to disregard economics especially in fisheries like sole where small adjustments carry major consequences. However, the 50% Project gives a taste of what can be achieved when skippers are involved and enthused. More of this type of approach will deliver real reductions. The secret seems to be the right level of involvement, incentive and support, leaving the skippers to find their own technical solutions.

Low Value Species

The public and supply chain seems to have reacted quickly to the Channel 4 programmes promoting the use of less well known species. The challenge is how to keep this momentum. Having seen what can be done it would be very disappointing if this was now lost.

Blind Alleys

Again quoting from our website, if we are to make genuine progress in reducing discards it is important to knock a few blind alleys on the head.

• Some commentators have reverted to saloon bar logic: “just ban” discards. It is important however to understand that where a theoretical discard ban is in place, such as in Norway, it is the cherry on top of an entirely different approach to fisheries management – one that is adapted to the specifics of their fisheries. In Norway’s case the primary emphasis is on protection of juveniles, principally through a massive programme real time closures. This certainly works well to reduce discards, although even here there should be no illusion that discards have been entirely eliminated. But is difficult to see how a ban and the underpinning programme of large-scale RTCs could be workable in the much more complex and diverse mixed fisheries of the EU. Giving in to demands for a theoretical ban on discards would amount to posturing and would achieve roughly zero. We have already tasted this kind of knee-jerk non-solution with the 2008 ban on high-grading, as meaningless a piece of poorly thought-through reactive legislation as you are likely to find.
• Quotas are here to stay. The reason for this is that in fisheries where stocks are shared it is necessary to distribute the fisheries resource to the different member states, to Third Countries that have access arrangements with the EU, and to different groups of fishermen and vessel operators. Despite the rigidities of the present system and of operating a quota system in mixed fisheries, no one has yet been able to suggest a more effective allocation mechanism that would deal with the realities of shared stocks. The plain fact is that we have little option but to work to make the quota system function better than it does at present as opposed to ditching it. And there is much that can be done on this front. Catch quotas are one example. More efficient quota swaps and transfer arrangements are another.
• Replacing quotas with effort (days-at-sea) allocations, despite its superficial attractions to some, is a non-starter. Experience as well as academic economic theory confirms that effort limitation creates a perverse incentive which intensifies fishing activity during the period that the vessel is permitted to go to sea. One form of this is seen in technological innovation – what the Americans call capital stuffing. It is therefore an approach entirely counter-productive in conservation terms. Besides it lacks the precision of the quota system as an allocation mechanism.

All of this suggests both that there are practical, doable, ways of reducing discards but there are also pitfalls to avoid and that there is much to be done. We look forward working with you collaboratively to achieve a progressive reduction of discards in the ways outlined above.

Kind Regards

NFFO