4 June 2015
The NFFO has prepared the following position paper on a sea bass conservation strategy. A variation on the paper has been sent to the North Sea and North West Waters advisory councils for consideration.
Science and Management Policy
ICES advice suggests that against the background of below
average recruitment and high fishing mortality the stocks of bass in our waters
is in decline. it would therefore be prudent to take proportionate steps to significantly
reduce fishing mortality.
The EU’s policy of achieving MSY by 2015, or where this is
not possible by 2020, has created a further impetus towards additional
management measures for bass.
Bass Exploitation
The bass stock is subject to exploitation by a wide range of
fishing métiers and both recreational and commercial fishing, including:
Pelagic trawl
Otter trawl
Pair trawl
Fly shooter
Drift net
Trammel net
Gill net
Rod and line
The diversity and complexity of this exploitation pattern imposes particular challenges for the design of effective management measures.
Fishing Mortality
On the basis of recent ICES advice fishing mortality on bass can be broken down into three main groups:
Targeted pelagic vessels (30%)
Bass caught as a bycatch in mixed fisheries (40%)
Recreational fisheries (30%)
Total Allowable Catch
We consider that a TAC approach to managing bass would not be appropriate and would not be effective because of:
• The relatively high proportion of the catch taken by recreational anglers, who would not be subject to TAC constraints
• The regulatory discards that would result from a TAC allocated on a relative stability basis at a time when the EU is focused on discard reduction if not elimination of discards.
• Allocation on the basis of catches over a recent historical reference period would unfairly disadvantage those member states which have already unilateral steps to constrain their fleets’ activities on bass.
Alternative Management Measures
- In January 2015, the European Commission used its emergency powers to apply a seasonal closure to the pelagic fishery for bass mainly prosecuted in the mid-Channel
- Subsequently, the Commission proposed a 3 fish bag limit on recreational anglers which was adopted as part of an amendment to the TACs and Quotas Regulation
- A proposal for a further amendment to the TACs and Quotas Regulation has recently been published by the Commission. If adopted by the Council of Ministers it would:
• Apply monthly catch limits scaled to different métiers.
• Generalise the ban on fishing for bass, currently applied by the Republic of Ireland to its own fishermen, to all EU fishermen operating within a zone around Ireland, excluding waters within 12 miles of the UK coast.
- Further measures under consideration by the Commission include an increase in the Minimum Conservation Reference Size for bass to 42cm and corresponding mesh size increase for static nets, as part of the revision of the Technical Conservation Regulation.
NFFO Position
The NFFO represents fishermen in England, Wales and Northern Ireland. Amongst its members are many of the 800 fishing vessels which catch bass either as a target species or bycatch. For some of our members, bass is an economically vital component in their annual income. For others it is an economically significant but subordinate part of their catch; and yet others catch bass only sporadically and irregularly.
Although there are uncertainties about the accuracy and completeness of the ICES bass assessments, the NFFO accepts that a high level of fishing mortality and lower than average recruitment calls for remedial measures to rebuild the biomass. We do not accept that impetuous measures driven by an artificial MSY timetable is the correct or effective way to rebuild the bass stocks. All our experience suggests that, rushed, poorly thought through, knee-jerk over-reactions, is a recipe to make things considerably worse.
Principles
Measures should be effective, otherwise there is there is no point
- The measures should be capable of delivering recovery within a reasonable timeframe
- Cosmetic measures, or measures which fall disproportionately on one métier should be avoided
- The objective is to reduce fishing mortality, facilitating the rebuilding of the biomass
- The effect of the measures should be understood as far as possible in advance
- Measures should be proportionate in terms of sharing the burden and rebuilding the stock
- Measures should strike a balance between rebuilding the stock whilst maintaining and protecting the livelihoods of those dependent on the fishery
- Potential collateral consequences and displacement effects of measures should be understood and taken into account as far as possible in the design of the measures
Taking the proposed measures in sequence:
Emergency pelagic closure
There is no doubt that the directed fishery for bass by pelagic pair trawlers in the Channel is a major source of mortality when the bass aggregate to spawn. Some form of seasonal closure could therefore play a valid part within a conservation strategy for bass. However, significant as this component is, the catch amounts only to 30% of the overall fishing mortality on bass. Constraints on this fishery are only justifiable within the context of a broader strategy which addresses the other sources of mortality.
Fisheries managers also have to take into account the displacement effect of such a closure. The vessels concerned will have to earn a living and so in terms of fisheries management the knock on effects should be understood and taken into account. If the overall effects of the closure, brought in as an overreaction to scientific advice and political pressure, are negative, it wouldn’t be the first occasion that a seasonal closure was brought in in such circumstances, only for the post-hoc scientific evaluation to conclude that little was achieved for the primary stock but the negative displacement effects were significant.
We know for example that displaced vessels from the bass fishery have moved into the hake fishery, depressing prices for that species. At present, the hake stock is very healthy but this was achieved by strenuous efforts to reduce fishing mortality. It would be a tragedy if this success story was turned to dust as a knock-on effect of the bass seasonal closure.
Recreational Fishery Bag Limits
Given that the recreational fishery for bass is estimated to account for around 30% of the fishing mortality on that stock it is entirely appropriate and fair that anglers should bear a proportionate weight of the burden of rebuilding the stock. We are however, inevitably, skeptical about the level of compliance with this measure – and therefore the real contribution that it makes. Given the amount of bass that finds its way into hotel kitchens and restaurants, this is part of a much wider issue about fish being sold for profit without a fishing licence. Action on this front is overdue and we have called on the MMO to instigate a risk analysis as a prelude to high profile prosecutions.
Monthly Catch Limits
We can follow the logic of catch limits insofar as they are a direct curb on catches and are designed to share the burden proportionately. However, simply increasing discards of bass caught in mixed fisheries, after the catch limits are reached, does not seem to us to be an intelligent solution. This could be ameliorated if the catch limits contained a degree of flexibility to aggregate limits over say, three months. This would address to some extent, the problem of catch spikes, that are characteristic of the bass fishery.
We are particularly concerned about the impact of monthly catch limits on seasonal inshore fisheries which are particularly susceptible to the effect of weather on their operations. Without the flexibility to aggregate catch limits over a reasonable period, these vessels will be denied any fishing activity during poor weather and then be constrained to uneconomic catch levels when they are allowed to go to sea. The socio-economic consequences on this category of fishing business could be very serious.
Irish Closed Zone
The closure of the zone around the Republic of Ireland to bass fishing, as far as we can see, will only oblige vessels to discard small bycatches of bass. This is not an area in which bass aggregate to any extent or in which there is much of a targeted fishery, and so it is hard to see why it has been proposed except for cosmetic reasons. As a measure, in our estimation it will achieve little or nothing, other than to marginally increase discards of bass.
Technical Measures
Looking slightly further ahead to the revised Technical Measures Framework Regulation, we are still uncertain how the new approach envisaged will operate in practice. We agree in principle that it makes sense to move away from prescriptive micro-management towards a results focused approach. If MCRSs are retained within the context of the landing obligation, it is not clear whether mesh size rules corresponding to the MCRS will be set. To do so would be to revert to prescriptive micro-management, when what is required is a shift in flexibility to allow vessel operators to choose the right gear to catch the right size and species.
MCRS
We support the increase in MCRS for bass to 42cms, with the proviso that this should be increased from 36cm in annual increments. This will avoid sharp losses in income and help to build support for the package of measures. The support of the industry is generally a prerequisite for its effectiveness.
An incremental approach will also allow scope to measure and assess the effect of the measures and to adjust the approach in light of lessons learned.
Nursery Areas
With recruitment, we are very much at the mercy of processes in the wider environment. We would, however, be prepared to consider further recommendations for geographical and temporal closures of nursery areas, as we do believe that these could contribute to the protection of incoming year classes. Our precondition would be that these should be designed and located on the basis of sound scientific evidence, and introduced only after a full consultation which allows us to weigh the advantages with the socio-economic costs.
Bass Conservation
Developing an effective conservation strategy for bass is not easy. As well as being a relatively late maturing fish, the complexity of the exploitation patterns, the diversity of the métiers involved in the fishery, the breath of the stakeholder community, all suggest that there is unlikely to be a silver bullet.
In complex situations such as these, we are firmly of the view that the best solutions materialise when three groups are in the room: fisheries scientists, fisheries managers and fisheries stakeholders. To date, although there are some channels of communication, these groups have worked in relative isolation. We advocate a symposium on bass after which the best ideas and shared understandings can be harvested. At present, the dialogue has been intermittent and bears all the hallmarks of panicked over-reaction. The experience of North Sea Cod demonstrates that a number of false starts were made before the right approach was found to rebuild the biomass. This should give us hope but also pause for thought, before rushing into law measures that may make things worse.
This is not an argument for inertia but it is a plea for intense dialogue, the collation of the best information, and the careful application of remedial measures.