Who’s to Blame for Landing the Blame?


In an open letter to the New Economics Foundation, the NFFO has challenged its misguided campaign, “Landing the Blame”, for failing to account for the range of scientific advice that must inform ministers’ decisions on TACs at the December Council.

Since 2014 the New
Economics Foundation
has published a series of publications claiming that
European ministers consistently set fishing opportunities at levels higher than
scientific advice. The research is based
on comparing final Total Allowable Catch (TAC) decisions with the single stock
advice provided by ICES.

This analysis is misleading as it fails to account
for critical contextual considerations associated with using the ICES single
stock advice and falsely implies that it represents the entirety of the scientific
advice upon which Ministers’ should make TAC decisions.

The following aspects of the scientific assessment
advisory process applied in recent years have been ignored:

1. ICES first introduced Maximum Sustainable Yield
(MSY) advice for TACs in 2011 based on transitioning to MSY by 2015. As fisheries were not being managed to MSY reference
points before this date it is unsurprising that many were not being fished at
MSY at the time and that there would be the need for a period of
adjustment. Since 2014 ICES’s MSY advice
has been based on transitioning to MSY in the year that the advice
applies. The Commission acknowledges
that in cases where applying MSY would seriously jeopardise the social and
economic sustainability of the fleet, it is appropriate to reduce fishing
opportunities to align with MSY at a more gradual pace.

2. Advice is produced on a single stock basis but
most fisheries catch a mixture of species.
According to ICES“this
does not remove the need to modify stock-specific advice to take account of
technical interactions (e.g. bycatch in mixed-species fisheries) or of
biological interactions (e.g. predator–prey relationship)…
For stocks exploited by mixed-species
fisheries, it may not be possible to achieve the single-stock MSY catch advice
for all the stocks simultaneously. Either the advised catches for some stocks
will be exceeded in trying to catch the TACs of other stocks, or the TACs for
some stocks will not be caught in order to prevent overshooting the TACs of
other stocks.” (1)

In the
case of the North Sea and Celtic Sea demersal stocks, ICES now present the
results of a mixed-species model, which according to ICES“provides information on catch composition
of different fisheries strategies to illustrate the trade-offs between the
strategies” (1)
. This is expected to be
applied by fisheries managers alongside the single species advice.

3. The single stock advice will usually describe
discards in the context of its advice, but other than assuming that fisheries
coming under the landing obligation will land the component of the catch that would
have previously have been accounted as discards, the advice takes no account of
the ability of the fleets concerned to be able to effectively reconcile the
implied TAC with the abundance of a stock on the fishing grounds. This can be at significant variance in cases
of sporadic recruitment spikes, for example, or in cases where the implied
single species TACs in mixed fisheries will generate heavy discarding of one or more species. The mixed fishery advice helps to scientifically inform this issue. Given that the landing obligation is now an integral part of the Common Fisheries Policy (CFP), addressing this matter is critical to the coherence of the whole CFP.

If fisheries were heading in the wrong direction and steadily depleting the resource, the aims of your analysis may have value, but on the whole in the north east Atlantic steady progress is being made towards high yield fisheries. UK fisheries are witnessing what is probably an unprecedented rate of recovery of stocks. 47% of our stocks were at full reproductive capacity in 2007 (2). By 2014, 91% of North Sea and 72% of western waters stocks had reached that mark (3).

In this context, a narrow fixation on only the divergence between ministers’ decisions and the outputs of single stock assessments at best only diverts attention from the complex issues associated with delivering the CFP, such as balancing the most radical change in fisheries management ever under the CFP, the landing obligation, with ensuring high yield fisheries and maintaining a viable fleet. These are not mutually exclusive issues, as your analysis assumes, they are interconnected. Your prescription, therefore, of a wholesale blind adherence to the outputs of these assessments would be no triumph of science over political short-termism. It would in reality be a triumph of dogma that in time would lead to a systemic failure of the CFP to deliver its objectives.

Your report, Landing the blame: Overfishing in EU waters 2001-2015, published in September calls for better transparency to improve the reputation of the CFP and the fishing industry. If organisations such as your own reported the correct understanding of the scientific-management process that must inform Ministers’ decisions beyond ICES initial single stock advice, and did not draw sweeping conclusions about one element of that advice and the final TAC decisions, then you could help to dispel some of the negative reputational myths that surround fisheries management, rather than add to them.

As an organisation that presents itself as a think tank that forms policy positions based on high quality ground-breaking research, we would suggest that you examine your own motives and reputation for undertaking a campaign on the basis of such a narrow analysis of the evidence.

Yours sincerely,

Dale Rodmell

Assistant Chief Executive

(1) Advice basis, ICES advice, 2015. http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2015/2015/General_context_of_ICES_advice_2015.pdf

(2) https://consult.defra.gov.uk/marine/msfd-programme-of-measures/supporting_documents/20141015%20POM%20complete%20consultation%20document%20FINAL.pdf (p108)

(3) http://webarchive.nationalarchives.gov.uk/20141203181034/http://chartingprogress.defra.gov.uk/feeder/HBDSEG-FeederReport-sec3_4.pdf (p159)