The newsletter of July and August 2017 includes:
Follow this link to download News From The Deck – July and August 2017
Warsaw, 14 September 2017
Marcin Ruciński
The management of the European Eel, a fascinating, elusive fish with a very complex and not completely understood life cycle has long posed a difficult challenge for all involved. Labelled a critically endangered species by the IUCN, listed in Appendix II of the CITES Convention, and subject to an EU-wide recovery plan since 2007 both in sea and inland waters, it is nevertheless a severely troubled stock.
In its October 2016 advice, ICES advised that all anthropogenic impact on eels – including recreational and commercial fishing at all stages, hydropower, pumping stations, and pollution should be kept as close to zero as possible. At the end of August of this year, LIFE Members from the Baltic Sea area, along with many other fishers, have seen and considered the annual European Commission proposals for 2018 Baltic Sea Fishing Opportunities, which includes a total ban on any eel fisheries in the maritime waters of the Region .
The Commission’s zeal to protect European Eel is understandable. However, one cannot forget an important number of small-scale fishers, that fish for eels in the waters of the Baltic Sea. For some of them, eel is an important source of income. Many contribute to financing of restocking activities and have embarked on the elaboration and implementation of national Eel Management Plans. Their catch reports provide an important basis for scientific assessment of the stock status, which has suffered from data deficiencies for years.
Is it really necessary and indispensable to impose a total ban on them? Do we have to sacrifice them? And most importantly: will it help European Eel?
At LIFE, we think there are better ways to protect this stock than simply instituting a total ban on exclusively small-scale marine fishing in just one EU region, which also happens to be particularly productive for silver eel, while leaving things as they are in other EU regions, some of which matter much more to the European eel’s future, such as glass eel-producing ones. Given the level of management complexity and time constraints, we focus on highlighting specific issues that should, in our opinion, be urgently addressed by fisheries managers and other stakeholders at European, regional and national levels, if the stock situation is to improve.
Data deficiency has been plaguing scientific assessments of European eel for long enough. Even if the data from national level are available, they come in sets and formats making it impossible to form a meaningful overall picture. The latest ICES advice is yet another example of this unfortunate phenomenon. Furthermore, despite some real efforts, illegal fishing remains a big issue for the European eel – one that will not be solved by simplistically banning the legal fisheries in the Baltic. We therefore propose that those responsible for European eel management and control are tasked– as a matter of urgency – with elaborating a single document and system to record all eel catches in a uniform way across Europe, in marine and inland waters alike, for all eel life stages. This will achieve two important aims: it will give scientists a solid basis to determine real stock status and trends, and at the same time equip the control authorities with an important instrument to combat illegal fishing. There are of course serious challenges along the way, legal ones and others, such as the very extent of the Common Fisheries Policy for example. But at LIFE, we believe in the good will of European Institutions, including their Legal Services, to help solve the problem.
With the pan-European span of fisheries and trade, combating illegal fishing and marketing of eel must be intensified and coordinated at European level. The existing knowledge, experience and national-level achievements in combating eel-related IUU should be presented and analyzed to identify and then implement best practices. We are lucky to have the European Fisheries Control Agency at our disposal, and an existing multiannual plan to implement. A coordinated approach, supported by a genuine and proactive approach from individual member states has the capacity to make a significant contribution to the protection and survival of the European eel and those that rely upon it for a living.
It is high time for a serious effort by all stakeholders – including those outside the fisheries sector – to help in downstream river migration of the silver eel. It is particularly important to make the key migration routes accessible and safe to silver eel during the migration period. This could, for example take the form of coordinating the timing of hydropower dams’ maintenance works (so that they remain idle, not lethal to silver eels) with the migration period. The small-scale, low impact fishers should, of course, play their part as well, by restricting fishing effort during silver eel migration time, in order to “close the cycle”.
A properly conducted restocking with glass eels can bring about positive effects to the stock. It is particularly true for glass eels entering uninhabitable inland waters. Effects of certain national Eel Management Plans from the Baltic Sea region, as illustrated by the latest ICES advice, are a good example of this. The more glass eels we can reserve for restocking, the more silver eels will migrate back to the Sargasso Sea.
It is clearly in the interests of Baltic small-scale, low impact fishers to contribute to improving the European Eel stock situation. We will spare no effort to do so, including support for further fishing restrictions where justified. But this cannot be yet another nail in the coffin of our already threatened profession. The Commission proposal forces us all to commit to serious measures to protect the stock for the longer term. Let us not squander this chance.
Tuesday, September 5th
Jeremy Percy
A meeting in Nieuwpoort, Belgium on September 1st, organized by Belgian inshore fisherman Jan De Jonghe and attended by a variety of commercial fishermen from the UK, Belgium and Holland as well as staff from the Low Impact Fishers of Europe Platform [LIFE] and researchers from the Marine Institute, highlighted the increasing concerns over the negative impacts of the massive and uncontrolled rise in electric pulse beamers in the southern North Sea. A delegation from the meeting later met with a senior official from the Dutch government, Ms Bea Deetman, responsible for European fishing authorizations and regulations. Electric pulse trawlers do what it says on the tin, they fire electric pulses into the seabed and this effectively replaces the job that tickler chains normally do to push the fish up and into the path of the net. The gear used is much lighter than traditional beam trawls, uses less fuel to tow, appears to catch more Sole than Plaice and has much lower rates of bycatch.
So far so good, but despite the protestations of the pulse fishermen that the outputs in terms of both pulse shape and power can be and are strictly controlled, observations by other fishermen and scientists contradict the view expressed that it does no harm to either the target or other species on and in the seabed.
The use of electricity [as well as poisons and explosives] is specifically banned under the Common Fisheries Policy so all those currently using this gear [Dutch national and subsequently UK flag ships] are operating under a dispensation from the European Commission. They benefitted from an original derogation for 5% of the member state beam trawl fleet, together in some cases with very significant financial support from Europe and this number then increased dramatically through the imaginative use of Article 14 of the new CFP that states that “Member States may conduct pilot projects, based on the best available scientific advice and taking into account the opinions of the relevant Advisory Councils, with the aim of fully exploring all practicable methods for the avoidance, minimisation and elimination of unwanted catches in a fishery”.
What is abundantly clear is that there has been insufficient research and effective trials before the Commission, the Dutch government and beam trawl fishermen jumped in with both feet on the basis of the apparent benefits of the method [especially to profit margins]. Current numbers of pulse beamers are well over a hundred and probably increasing with much of the focus of effort on the southern North Sea. The pictures below illustrate the migration of what were beam trawlers converted to pulse fishing to the previously unfished areas off the Thames.
The meeting heard testimonies from a range of fishermen, all of whom highlighted that there had been a drastic decline in sole, cod and seabass since the introduction of large scale pulse fishing 3 years ago, some reported seeing and hauling up large quantities of dead fish. Some referred to the Southern North Sea as a dead zone. Others mentioned that the only fish they had seen were (spotted) dogfish and rays.
The concerns expressed were really summed up by a note written by Tom Brown of the Ramsgate Fishermen’s Association, a précis of which is reproduced below:
“In the Thames estuary, we have an area between the Knock and Falls that is just outside our 12 mile limit. [see pictures above. Ed] In the past the traditional beam trawlers could not work there because of the soft ground, we only had the occasional French trawlers. However, for the past four years we have been inundated with Pulse trawlers. This area is well known to us as being a Dover sole feeder area for the Thames estuary. In the wintertime when the sea turns cold the sole heads for deep water and buries itself in the mud. With the advent of the Pulse trawlers they have become vulnerable. When the Pulse Beamers first fished this area they couldn’t believe how lucrative it could be, so much so that they were rushing back to port changing crews and coming back out again. To top it all they were bragging about it on the radio.
Four years later the Thames estuary has become almost devoid of fish to the point that a number of fishermen have gone out of business and the boats fishing in the Estuary declined. Possibly this is partially due to the excessive dredging that is being carried out in the Thames but I’m sure also Pulse trawling plays its part.
Our local boats have noticed that where the Pulse trawlers have been working there is any amount of dead shellfish, starfish and small mixed fish. It appears that when working deep water, they can turn the current up and in shallow water reduce it so as not to damage other fish. We are led to understand that in order to maximise the catching ability, the power is turned up all the time. We are not in the way of progress but it must not be at the expense of the environment and other fishermen.
We are being informed that Pulse fishing is up to 3 times more efficient as normal fishing. If that is the case, are those countries that operate pulse fishing going to reduce their fishing effort pro rata? If pulse trawling was rolled out across the EU in order to prevent technical creep I presume everybody will have to reduce their fishing effort accordingly to stay within the present parameters and not destroy the stocks again”.
Specific comments from local fishermen include:
It’s not just inshore fishermen from around the southern North Sea who are concerned. The ICES Working Group on Electrical Trawling met three times (22–24/10/2014; 10–12/11/2015, and 17–19/01/2017) to discuss the ongoing research projects in Belgium, the Netherlands, and Germany and provide an overview of the state of the art knowledge of the ecological effects. Their final report states that; ‘The sole pulse applies a higher frequency that invokes a cramp response that immobilise the fish species facilitating the catching process. The use of electricity in fishing has raised considerable concern among stakeholders which is mainly focused on the unknown effects on marine organisms and the functioning of the benthic ecosystem but also altered fishing efforts & catch efficiencies’. It goes on to say that ‘……… Exposure to the sole pulse stimuli invoked vertebral fractures and associated haemorrhages in roundfish species (cod), but not in flatfish species (sole, plaice, dab) or seabass. The results suggest that fractures are restricted to the larger size classes of cod that are retained in the net…..’
The report concludes that “Although the irreversible effects of electrical stimulation seem to be restricted to the vertebral fractures in cod and whiting, further research on the effects of electrical stimulation on marine organisms and ecosystem functioning is needed to assess the effects on the scale of the North Sea”
These comments underline the concerns expressed at the meeting. The Genie is out of the bottle and despite clear evidence, both scientific and anecdotal, that there are significant adverse impacts from electric pulse fishing, there appears to be no reduction in the headlong rush by managers and beam trawl fishermen for this sort of gear.
Just what the public will make of the fish on their plate having been electrocuted and their backs broken in the name of increased profits and reduced physical impacts remains to be seen although some of the larger buyers are avoiding purchasing electrofished products at present.
As Tom Brown’s note makes clear, the increased use of electric pulse fishing by increasing numbers of large vessels is undoubtedly having an adverse impact on stocks, especially those previously unfished. Whilst there is an argument that fishing effort, by whatever means, is ultimately controlled by quota, the ability of electric gears to focus effort on a relatively small area is of concern, as is the unknown and possibly long term effects on the wider marine ecosystem.
No one really expects the Commission to withdraw its current derogation but they should certainly act now contain effort, spatially, numerically and in terms of effective management of impacts until such time as there has been significantly more research into the potentially damaging aspects of this form of fishing.
If we should have learnt anything from the abject failures of fisheries management over two centuries it is that no amount of short term profit for the few should be used as a reason or excuse for ignoring longer term impacts and the rights of the many.
Access the official testimonies from the meeting here
The newsletter of June 2017 includes:
Warsaw, 10 July 2017
Marcin Ruciński
As every year, the prospects for LIFE’s members, and the fate of the resources they depend on, hang on the discussions, negotiations, and decisions on setting catch levels and accompanying measures for Baltic fisheries in 2018. Our position, based on numerous discussions with our Members, is outlined below, a position that is also briefly reflected in the relevant BSAC Recommendation[1]. For the sake of sustaining both small scale fishing livelihoods in the Baltic and the resources they depend on, we very much hope to be heard and heeded by decision-makers.
Precaution is of paramount importance for any fisheries management. Too much optimism on Western cod, notable in decisions taken until 2015, has led us to the brink of stock collapse last year. This year, we were lucky with a very strong year class of 2016, which allows us to look at the future of this stock, so immensely important to many small-scale fishing communities, with a glimmer of hope.
A glimmer of hope, however, must not be answered by recklessness. So, no tampering please with the management measures that have enabled the recovery we are now starting to observe. This goes particularly for the extended spawning protection, which LIFE advocated as top priority last year. The closed season enacted last year must not change. Any relaxation here, let alone its abolishment, would be premature and risky for the fragile stock recovery, based as it is on just one year class. It may well be that prolonging the spawning closure in question, enacted back in 2015, allowed for the successful 2016 spawning.
The newly recruited cod need additional protection from being prematurely caught and discarded in trawl fisheries. As the results of EFCA campaigns[2] show, this risk is terribly real with trawls currently in use and industry practices at sea. Therefore, LIFE lends its careful and conditional support for the repeated BSAC calls to promote the use of innovative mobile gears. The condition of our support is simple: there must be strong “checks and balances” by the authorities, at both national and EU level, ensuring that: a) new gears have been proven more selective than the currently used ones in a transparent scientific peer-review process, and b) intensive at-sea inspection campaigns are undertaken to weed out and deter from any practices nullifying selectivity.
On the TAC level, at LIFE we trust in the wisdom of decision-makers, as last year. We hope they will be mindful of the heavy TAC cut last year, swallowed with big difficulty by small-scale, low impact fleets. Many of us were forced to switch to fishing flatfishes for part of the season, with rather poor economic results. We note that ICES advice allows for a moderate TAC increase (around +9%), in full compliance with the multiannual plan. The real levels of discards in trawls observed by EFCA make case for the use of Article 17 of CFP Basic Regulation even stronger. We therefore very much hope that any increase will predominantly benefit those who behave responsibly and whose activities have the lowest possible impact on the resources.
At first glance, ICES advice for the stock does not differ very substantially from that of last year. The difference in advised level of catches is about 3%. There are two particularly worrying signs though: the decline in stock size indicator and the level of discards, which ICES considers to be much higher than officially reported. This is confirmed by what our Members observe, and the situation seems to be even worse than last year in certain areas. It is therefore of paramount importance that the illegal cod discarding problem in the Eastern Baltic is urgently addressed – both by introducing innovative, more selective towed gears peer-reviewed by scientists og stepped-up at-sea inspections to weed out and deter any practices from nullifying selectivity.
It is equally important to analyze and fully respect the ICES advice, which points to the important role played by large-scale pelagic fisheries in current cod condition, characterized by food deprivation. ICES confirm the view already expressed by LIFE last year[3] that there is excessive effort on forage fish, which makes their long-standing call for a spatial management plan for large pelagic fisheries in subdivisions 25-26 stronger than ever.
Managers must no longer ignore this call. The arguments presented by large pelagic fleet representatives simply won’t wash: modern pelagic trawlers of 25 meters length and (much) more are perfectly able to steam north of Subdivisions 25-26 to reap the benefits of strong pelagic species’ concentrations. ICES confirm that it would also be beneficial for the pelagic stocks there if they did.
As to the TAC level, we hope the managers will take on board that 3 years of consecutive TAC reductions have not relieved the woes of Eastern cod. Please don’t make the small-scale, low impact fishers of the Baltic Sea pay the heavy price for a difficult stock situation that is not of their making.
[1] http://www.bsac.dk/BSAC-Resources/BSAC-Statements-and-recommendations/BSAC-recommendations-for-the-fishery-2018
[2] See slides 8-9 of presentation by EFCA Executive Director, Pascal Savouret, available here http://www.bsac.dk/getattachment/Meetings/BSAC-meetings/BALTFISH-BSAC-EFCA-Workshop-on-implementation-of-t/FromEFCA-BSAC-EFCA-BALTFISH-presentation-9-March-2017.pdf.aspx?lang=en-GB
[3]See LIFE comments on 2017 Fishing Opportunities https://lifeplatform.eu/baltic-stocks-comments-highlights/
In line with ICCAT, Europe is celebrating the successful application of Bluefin tuna recovery measures in its waters and the rebuilding of stocks by increasing quotas allocated to the industrial and sports fishing sectors. Once again Europe’s small-scale fishers have been over looked and their interests discriminated against.
To draw attention to this omission, and to open up a dialogue with the authorities, the Union of Small-scale fishers from Occitanie (former SPMLR) took the initiative to mount a legal challenge to the French Ministerial decree through which tuna quota is allocated. In this endeavour, they are joined by 4 other associations, representing small scale fishing interests from the French Mediterranean and Atlantic coasts, and at European level. Between them, these associations represent over 1,500 French small-scale fishers, and around 7,000 fishers from 12 European Member States. These organisations include:
The diversity and strength in numbers represented by these bodies highlights both the frustrations and the high hopes of the professional fishers concerned, on both the Atlantic and Mediterranean seaboards of France. The engagement of LIFE in the campaign underscores the importance of the European dimension, where despite a significant overhaul of the regulations in the 2014 Common Fisheries Policy (CFP) reform, Member States are still able to go about their business as usual, ignoring the interests of the small-scale fleet segment.
In a general sense, the grievances that have led to the action are the same as those voiced by small scale fishers for years. They demand that the way fishing quotas are shared out must change to ensure a fairer allocation and a wider spread of benefits amongst small scale fishers who have been excluded up to now. In particular that the provisions of Article 17 of the CFP be fully applied, and not merely using catch history as the main method for quota allocation.
Article 17 obliges Member States to use transparent and objective criteria including those of an environmental, social and economic nature when allocating fishing opportunities, and encourages them to provide incentives to fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact.
This demand is not restricted to France, nor to Bluefin tuna. Across Europe, traditionally polyvalent, seasonally diverse small-scale fishery activities are increasingly being forced to adopt more homogeneous fishing methods, and to fall back on non-quota species, being deprived as they are of access to quota species.
The legal challenge addresses the following shortcomings of the tuna quota allocation system in France:
This action does not signify a split amongst the professionals, with “small” pitted against the “large”. The problem of sharing out the quotas is a recurring one with a long history. The purpose of this action is rather to break the deadlock; it should not interfere with negotiations between professionals in the sector. That is not the intention of those bringing the action. On the contrary, questioning the law should provide a lever, to make those in the profession take heed, and to make the authorities aware of the disproportionality and inequality of the current situation.
Last November, Commissioner Vella informed LIFE that “it is for the Member States to decide on how BFT fishing opportunities are allocated” within the limits set. He assured LIFE that the Commission would continue to address this allocation issue regularly with Member States to ensure that the provisions are correctly applied (https://lifeplatform.eu/correspondence-vella-tuna-quota/). LIFE welcomes the Commissioner’s response, and hopes that this new action will highlight where Member States are falling short in putting their commitments into practice, and open the way for the Commission to oversee the correct application of the CFP provisions.
Finally, both ICCAT and the scientific community agree unanimously on the improving health status of Bluefin tuna stocks, which are well on the road to a full recovery. This is confirmed by the regular sightings made by small scale fishers, who watch tuna swimming past without being allowed to catch them. Rarity is no longer an acceptable excuse for denying access to small scale fishers.
Discriminating against the interests of the small-scale fleet segment, whose potential catch rates are relatively low, and whose hook and line techniques are highly selective and discard free through such a differentiated treatment is not acceptable.
It is in the interests of all professional fishers and the sustainability of their professions that a fair re-balancing of quota allocation is made.
Access article by the french magazine Le Marin by clicking here (in French)
Brussels, 22 June 2017
Brian O’Riordan
A highly charged debate on electric pulse fishing, organized by the Intergroup for Biodiversity & Ecosystems Services, took place in the European Parliament yesterday, Wednesday 21 June. Under discussion was the issue electric pulse trawling as a more sustainable alternative to beam trawling. A pulse trawl uses electric current to shock fish off the seabed, and is more than 10 times lighter than a conventional beam trawl (240 kgs vs 3,000 kgs). It has huge benefits for fuel economy, carbon footprint, and mechanical seabed impact.
However, the lighter weight of the gear means that it can be used in areas inaccessible to beam trawls, and the lethal, sub lethal, and wider ecosystem impacts of electric pulses are as yet not sufficiently researched. LIFE therefore urges precaution prior to deregulating the gear. For details see https://lifeplatform.eu/shocking-the-fish/
Small scale inshore fishers using fixed gears are concerned that, thanks to pulse technology, beam trawl effort is now shifting into more sensitive and environmentally fragile areas, where the impact of overfishing and electric pulses on marine fauna and associated habitats threatens their activities. Allowing the encroachment of electric pulse trawling into these inshore areas in the absence of any effective regulatory and control framework flies in the face of any precautionary or ecosystems based approach to fisheries management.
Representing DG Mare, Elisa Roller hailed pulse trawling as “the most innovative, most researched and most fuel-efficient gear”, which she sees as a crucial tool for dealing with the challenges of the landing obligation. As Head of Unit for CFP and Structural Support, Policy Development and Coordination, she is sufficiently satisfied with the evidence from research to allow the mainstreaming of the pulse technique throughout the EU. She highlighted a few outstanding issues that need to be taken care of, which essentially boil down to a misunderstanding on pulse issues, she said.
Pim Visser for the Dutch industry called for an increase in the number of licenses for brown shrimp vessels, highlighting the 60 to 70% reduction in by-catch obtainable.
Ricardo Serrao Santos drew attention to the ethical issue of fish welfare, and pointed out that innovation could be both Dr Jekyll and Mr Hyde. Innovation was a two-edged sword that was both the cause of and potential solution to climate change, pollution, ocean acidification, and plastic waste.
Hans Polet from ILVO – the Flemish Agriculture and Fisheries Research Institute – highlighted that despite much research, there are still significant knowledge gaps as regards the wider ecosystem and longer-term impacts.
Bjorn Stockhausen for Seas at Risk urged that regulatory conditions governing licence restrictions for pulse trawling are strengthened not weakened, and that existing licenced operations are evaluated. Small mistakes can make big impacts he said. He pointed out that the repetitive and cumulative effects of electricity over time were unknown.
Frédéric le Manach for Bloom drew attention to the ethical issues, stating that it is not acceptable to electrocute Nature; that electric pulses are not selective, all fish are electrocuted.
Brussels, 20 June 2017
Brian O’Riordan
Tomorrow, Wednesday 21 June 2017, a hearing will take place in the European Parliament on electric pulse fishing http://ebcd.org/wp-content/uploads/2017/06/Draft-Agenda-Intergroup-event-on-Pulse-Fisheries.pdf.
The use of poison, explosives and electricity for fishing is banned in Europe (EU Regulation 850/98), and beam trawling, though an ancient technique, is, and has been the cause of much controversy in times past as today. Beam trawling is one of the least selective and most highly impacting gears on the sea bed and related habitats that are crucial to different life stages of many commercially important fish species.
Electric pulse trawling uses a relatively light weight towed fishing gear that transmits electrical pulses to catch species targeted by beam trawls. Thanks to a special derogation under EU law (Council Regulation (EC) No 43/2009) this fishing method is being developed as an alternative to conventional beam trawling. On the basis of reduced fuel consumption, higher selectivity for sole and reduced bottom impact, its protagonists promote it as a more sustainable alternative to the traditional beam trawl.
In contrast to the conventional beam trawl which uses tickler chains to mechanically stimulate target species from the seabed, the pulse trawl consists of a beam (or wing) fixed with rubber-coated cables containing electrodes. These electrodes produce short electrical pulses to electrically shock target species from the seabed.
LIFE is not against the development of alternative fishing methods to beam trawling. However, as yet very little, if any, meaningful research has been carried out on the impact of electric pulses on the fish and other marine life that are subjected to them. Worryingly, neither is there any way as yet to control the amount of electricity, pulse frequency, and other potentially harmful characteristics of the gear.
Despite these glaring omissions, Dutch national and EU authorities are already promoting pulse trawling as a sustainable alternative. Already there are over 100 beam trawlers rigged to fish with electricity, mainly from Holland but also from the UK, Germany and Belgium, with some conversions funded by the EU.
Both ICES and the MSC have advised against allowing the wide usage of the gear before effective control and regulatory mechanisms are put in place, and before we understand the impact of the gear on the marine ecosystem and related marine life.
In February 2016 ICES advised that “the existing regulatory framework (for pulse fishing) is insufficient to prevent the introduction of systems that potentially could have such (harmful) impacts.” The advice also cautioned not to generalize the research results to allow the expansion of pulse trawl to other areas or to use new technology without an appropriate impact assessment. For details see: http://www.ices.dk/news-and-events/news-archive/news/Pages/Advice-released-on-effects-of-pulse-trawling.aspx.
Such an appropriate impact assessment has yet to be carried out, and crucial aspects of research on the key pulse characteristics and thresholds below which there is no evidence of significant long-term negative impact on marine organisms and benthic communities have not been carried out, and there are also outstanding questions on the delayed mortality of species, as well as on how the electricity might affect them in other ways such as reproductively.
In November 2016, the MSC refused to certify pulse trawls because of the “impact of electricity from the gear on a range of environmental elements including ETP [endangered, threatened and protected] species (including elasmobranchs) and benthic organisms which may also have implications for the wider ecology of the area fished” . For details, see: https://www.msc.org/newsroom/news/assessment-clarifies-sustainability-challenges-for-pulse-trawl-fisheries.
Prior to issuing any further pulse licenses, or promoting pulse trawling as a sustainable alternative, the Low Impact Fishers of Europe insist that proper steps must be taken to ensure that a) it is impossible to interfere with the transmission of electric pulses whilst fishing, b) an enforceable regulatory framework and control system are in place, and c) last but not least adequate research and development are undertaken to ensure that electric pulse fishing has minimal negative impact on the seabed fauna and flora, and on the lethal and sub lethal effects on fish species that come into its range.
Brussels, 20 June 2017
Brian O’Riordan
There is self-evidently a place and a need for both small and larger scale fishing fleets, but this requires first of all establishing a level playing field that ensures fair access to resources, to markets, to sector support, and to decision taking processes for all fleet segments.
When Commissioner Vella asked LIFE whether or not all small-scale fishing activities in the Mediterranean and Black Sea were really low impact, he had already answered his own question. Earlier in his speech to the fishery stakeholders in Malta on 29 March 2017, European Commissioner for Maritime Affairs and Fisheries had pointed out that 80% of the Mediterranean “fleet belongs to small-scale fishermen (with vessels under 10m long), who fish a quarter of the total catches”. This means that, according to Commissioner Vella, just 20% of the fleet, the larger-scale segment, take 75% of the catch, thus having by far a greater impact on fish stocks and the marine environment than 80% of the fleet with 25% of the catch[1].
Of course, not all small-scale activities are low in impact, and not all larger scale fishing is destructive. Stocks may be more vulnerable during certain seasons when they aggregate to spawn, feed, and develop. Both small and large-scale activities that target these aggregations may have significant impacts on them. High concentrations of small scale gears in inshore waters, for example, despite being worked from very small [<6m] vessels may have a big impact on these aggregations. So too, relatively small vessels kitted out with modern fish finding and navigation technology, gear haulers, and powerful engines, that fish intensively may also have a considerable impact. Small, like large, also requires effective management and regulation, but the same regulatory and management measures are not necessarily appropriate for these two fleet segments.
Small size can be an indicator of sustainability, in as much as small in fishery terms implies using gears low of environmental impact, vessels with a relatively low carbon foot print, with activities rooted in coastal communities, undertaken by small family based enterprises that provide jobs and income in areas with few economic or employment alternatives, and where women play a key role, albeit often unseen and unrewarded economically. It is certainly the case that it is far easier for a vessel pulling a trawl net the size of a football pitch, with an engine power measured in the 1000’s of kilowatts, or a seiner using heavy metal wire rather than the traditional ropes to do far more damage, far more quickly than the average small scale vessel.
In this sense, the Members of the European Platform “Low Impact Fishers of Europe (LIFE)” aspire to having the least possible impact on both the fish stocks and on the fishing grounds through adopting a best practice approach – using the right gear, at the right time, in the right place. Our answer to Mr Vella’s question, is therefore: “No, of course not. Not all small-scale fishing activities are low in impact, but they could be if given a fair chance and adequate support.”
LIFE has always held that both large-scale (lsf) and small-scale (ssf) fishing activities, at all stages of the supply chain from catch to consumption, are needed, and play complimentary roles in providing income, employment, and food supplies, creating wealth, and contributing to the culture and social wellbeing of coastal communities. Stocks further off shore may be more effectively caught by larger vessels able to deal safely with offshore conditions, and with the capacity to store larger catches. Bulk landings from larger scale fleets may be more suitable for large processing facilities supplying mass retail markets. At the same time, there are advantages to reserving inshore areas, for smaller scale fixed gear operators, who have traditionally supplied high quality fresh fish to local and more niche markets. These coastal fishermen and fisheries also underpin numerous vulnerable coastal communities, often with few alternative employment opportunities, not just in terms of food production but also for the added value they bring to the tourist experience, the significant number of shore based jobs they support and the maintenance of maritime related knowledge and skills.
Indeed, it is in everyone’s interest that the intrinsic complementarity between large scale and small-scale, artisanal and industrial fleets, and between traditional and modern activities should be recognized, and synergies identified and capitalized on. This can only be done if a level playing field is established where competition and conflicts do not put one or other sector at a disadvantage, where each fleet segment is provided with a fair and transparent share of access rights, where good practice is rewarded and innovation encouraged.
This also requires a governance system that puts those who fish and are active in the supply chain centre stage, enabling them to engage meaningfully in the decision-making processes that affect both them and the resources they depend on. Such governance systems do exist, and require that authorities and fishers sit together on co-management committees to solve problems and agree courses of action together, with these committees fully empowered by the administration through formal power devolution procedures. It is to be welcomed that the Government of Catalonia is now making such co-management law through a new decree http://international-view.cat/2017/05/23/its-the-governance-stupid/.
By contrast, for over 30 years, fisheries in Europe have been governed by the Common Fisheries Policy (CFP), a policy that has turned a blind eye to small scale fisheries, treating it as a national issue, and making exceptions for smaller vessels to many EU rules. This has proved to be a poisoned chalice for the small-scale sector, which has effectively been often operating under the regulatory radar. It has meant that catches from the sector have not been properly recorded and documented, and this has put smaller vessels at a disadvantage when it comes to quota allocation. It has also meant that small scale fishing organizations have been disempowered from engaging in decision taking processes at EU level, as no support has been provided to establishing structures like small scale producer organizations.
This aspect was recently highlighted by a special report from the European Court of Auditors on EU fisheries controls http://www.eca.europa.eu/en/Pages/DocItem.aspx?did=41459. This highlighted that, as a result of the application of the rules of the Control Regulation, 89% of the EU fleet, 95% of which comprises vessels under 12 metres long, is not monitored by a vessel monitoring system (VMS). This significantly hinders effective fisheries management in some fisheries and for some species. The report also highlighted that a lack of transparency in the way that some producer organizations manage quotas increases the risk that specific interests of certain economic operators are favoured at the expense of others, creating unequal competition between fleet segments.
In many EU member states, small scale activities, traditionally polyvalent using a variety of gears around the year, targeting a seasonally diverse array of species – right gear, right place, right time – are now only permitted to catch a limited range of non-quota species. Thus, for example in the UK the small scale under 10 metre sector, representing 77% of the fleet by number, has access to only 1.5% of the UK quota by tonnage, and must rely mainly on non-quota species like whelk, brown crab and lobster. This increases pressure on these species, and tends to flood markets, often depressing prices.
In Ireland, small-scale fishers from island communities are not allowed to catch the fish in their coastal waters. Meanwhile, supertrawlers that fish around the world are allowed to, catching the species traditionally caught by them and hauling away their gear with impunity. Irish islanders, represented by the Irish Islands Marine Resource Organisation (IIMRO), are proposing that Ireland adopts a system of “heritage licences”, allocated to smaller scale fixed gear vessels, owned and operated by fishers from island communities. These vessels would operate in waters adjacent to the islands, and would be managed under a locally led co-management regime.
Financial support is another area where larger scale fishing activities have gained huge advantages at the expense of small-scale activities. Whilst it is often said that subsidies to industrial fishing is subsidizing overfishing, at least in Europe, it could be said that in the case of the small-scale sector, subsidies have been subsidizing underfishing.
In Europe, over the period 2000 to 2006, the large majority of subsidies for vessel construction and modernization went to vessels over 24 metres, whilst vessels under 12 metres received twice as much funding for scrapping as they did for modernisation and construction[2].
A recent study by the University of British Colombia reports that at global level, 84% of subsidies to the fishing sector, valued at 35 billion US$, go to vessels over 24 metres in length. It highlights how fuel subsidies promote fuel-inefficient technology and help large-scale fishers stay in business, even when operating costs exceed total revenue gained from fishing. Subsidies for port development and boat construction, renewal and modernization also give the large-scale fisheries sector significant advantages over their small-scale counterparts, who receive only a small percentage of those subsidies https://www.eurekalert.org/pub_releases/2017-06/uobc-spo053117.php.
So, how can a more level playing field and a more transparent and fairer system for allocating fishing rights and financial support be established?
First and foremost, the small-scale sector must be brought into the regulatory fold. This could be done by establishing a differentiated approach to managing small and large-scale fishing activities, based on spatial management, with exclusive fishing areas designated for small scale, low impact fixed gears, and confining the activities of more heavily impacting mobile gears further out to sea.
The benefits of such an approach are highlighted in a recent report by the Scottish Creel Fishermen’s Federation (SCFF) http://www.scottishcreelfishermensfederation.co.uk/report.htm. The SCFF point out that the combination of Marine Scotland’s “hands off” approach, and de facto creel limits imposed by the trawl sector has resulted in trawlers managing to secure 87.7% of the Scottish Nephrops prawn catch; a level of access to stocks, according to SCFF, not warranted by the trawl sector’s economic or environmental performance, or indeed any coherent performance indicator. Fishing with creels not only delivers more jobs per tonne caught, it is economically more efficient (i.e. profitable) to catch a tonne of Nephrops using creels rather than trawling the sea bed. By reallocating access to Nephrops in favour of creeling, and by establishing creel only areas, Marine Scotland has the opportunity to increase total employment, total household incomes, total profits /economic efficiency and the number of individual fishing businesses in coastal areas. Many of these areas are remote and suffer from a narrow range of economic opportunity.
Secondly, a differentiated approach would involve establishing different access regimes for polyvalent low impact small scale fixed gear operators on the one hand, and larger scale mobile gear operators on the other. The former would involve regulating access using input controls, such as days at sea, spatial and temporary fishery closures, and putting restrictions on the quantity of gear that any vessel could deploy within a given time frame. The latter regime for larger scale operators could involve a mixture of both input (restricting effort, for example, through days at sea) and output (restricting catches, for example, through quotas) controls.
Den quid pro quo of this would be that ssf operators would need to engage more proactively with scientists and fishery managers in providing data on fish catches generated by them using new technologies available thanks to the development of mobile applications for smart phones and tablets.
New, simple and powerful, electronic technologies are available that make the whole process of data logging at sea relatively easy to do http://abalobi.info/, using smart phones and tablets. Already such mobile technologies are being used by fishers to improve their marketing arrangements and to engage more effectively as data providers in fisheries management. Such data gathering tools could also be developed as electronic log books.
The current focus on the blue economy, sustainable development goals, and climate change provides a useful opportunity to reflect on the state of play in European fisheries, to highlight some hard facts, and put forward solutions.
LIFE exists to provide a dedicated and specific voice for the previously silent majority of fishers in European waters. LIFE also believes that there is a need for much increased transparency, a fairer and more equitable approach to access to the resource, a differentiation in some form between mobile and passive gears and vitally, much improved co-management systems for fisheries in coastal near-shore waters.
Exploiting the synergies and complementarities between small and large-scale fleets should provide the possibility for putting European fisheries on a fairer and more sustainable footing for the future. It is an opportunity there for the taking and one that all concerned ignore at their peril.
[1] https://ec.europa.eu/commission/commissioners/2014-2019/vella/announcements/press-statement-meidterranean-fisheries-conference-malta_en
[2] http://www.smh.com.au//breaking-news-world/eu-subsidies-have-encouraged-overfishing-study-20100331-re68.html
The newsletter of May 2017 includes:
