23 November 2015
The Federation writes to the Minister on the need for a proportionate response to bass management.
Dear Minister
We would make four points as we move towards the December
Council and critically important decisions on bass.
1. The emerging scientific advice on bass indicates that
successive below-average year classes and an overall fishing mortality that is
too high, requires remedial action.
2. Landings statistics make plain that a very large number
of fishermen, using a range of gears, depend on bass for a significant part of
their annual income.
3. The history of the CFP is littered with examples where
clumsy measures have made things worse rather than better
4. The Commission’s Proposal, which amounts in effect to a
moratorium on bass, is driven by the legally binding but wholly arbitrary
requirement to reach MSY by 2016 or 2020 at the latest.
Against this background we consider that it is important
that the UK takes a measured and proportionate position at the December
Council.
A moratorium would have devastating social and economic
consequences. The science on bass gives cause for concern; but it does not
justify overreaction. Catch limits, an increased minimum conservation reference
size and bag limits have been in place for under a year; it takes time for the
effect of measures to work through.
Against this difficult background, we urge you to position
the UK to:
1. Reject the Commission’s proposal
2. Support proportionate
step-wise measures – but only after the efficacy of those measures that have
already been put in place have been properly evaluated
4. Recognise the multi-faceted dimension of the bass fishery
and therefore the need for measures tailored to the specifics of each fishery
5. Take account of the potential for unintended
consequences, not least the scope to generate a significant discard problem
where none existed
On this latter point, it is important to learn the lessons
of the recent past, where ministers have not infrequently agreed eye-catching
blanket measures that deliver much less than hoped for. The obvious example is North
Sea cod, ministers’ actions resulted in a dramatic increase in discards, which
can only have impeded recovery. A more intelligent and effective approach only
emerged later. We think that this is an important lesson that has significance
for bass.
The most important step to be taken in the present
circumstances is to establish an effective dialogue between fishermen who rely
on bass for their livelihoods, fisheries scientists and fisheries
administrators as to what measures would work and which not work in their fleet
sector. Because of the complexity of the bass fishery it is metier specific
measures that are required and the old discredited blanket knee-jerk carries a
risk of making things worse.
Tony Delahunty
NFFO Chairman