CFPO Letter to Fisheries Minister - Spurdogs Discards

Huw Irranca-Davies

Minister for the Natural and Marine Environment, Wildlife and Rural Affairs

DEFRA

Nobel House

17 Smith Square

London

SW1P 3JR

Dear Minister

SPURDOG DISCARD REDUCTION PLAN

We have had to accept that the current ICES’ advice is that Spurdog stocks are currently depleted and that management measures to rebuild populations to safe biological levels are a legitimate priority for fisheries managers and ministers.

However, given the representations that we and others made to you in the run up to the December Council , it will not surprise you that we  think that the measures that have been adopted are neither appropriate nor fit for purpose, if the objective is to reduce fishing mortality on Spurdog to give stocks an opportunity to recover.

Therefore, whilst we share with you the aim of reducing fishing pressure on Spurdog, and can even understand the short term pressures which led the Council of ministers to adopt an essentially cosmetic measure in the form of a zero TAC, we are frustrated that the concrete measures put in place will do nothing to rebuild dogfish populations and will in practice retard the development of a meaningful conservation policy for Spurdog.

 The basis for these comments lies in our practical experience and knowledge of the fishery. The salient points are:

• Spurdog are found in shoals but these are uneven and generally unpredictable in their distribution for most of the year
• As a result, although not targeting Spurdog, on occasion netters targeting species such as Hake and Pollack can on occasion catch substantial amounts of dogfish
• A similar pattern can be seen when trawlers hit unpredictable shoals of Spurdog
• This pattern of catches is reflected in the CFPO landings statistics (attached for information) where generally very low levels of unavoidable by-catch are interrupted occasionally by substantial catches

All this demonstrates that a zero TAC, albeit with a 10% by-catch tonnage per member state, is an inadequate management response to the problems confronting Spurdog.

The result of a zero TAC along with a (ludicrous) two fish per trip by-catch provision can be described quite precisely:

• A significant discard problem where previously there was none
• No reduction in fishing mortality on Spurdog
• An alienated and frustrated fishing industry obliged to discard a not completely insignificant part of their earnings for no comprehensible reason

Alternative

Clearly, this is an unacceptable position for all concerned. Stocks of a vulnerable species remain under pressure; fisheries managers see their measures fail to deliver a reduction in mortality that will be a prerequisite for improvement in the stock, ministers remain under pressure from environmental organizations to “do something”; fishermen can only shake their heads in despair at yet another irrationality in the management system.

Away from the immediate pressure of the Council and the year end negotiations, we believe that it is possible to design an approach that at least has the potential to deliver recovery Spurdog populations by effecting a reduction in fishing mortality

Proposal

We propose the following: 

• No targeted Spurdog fisheries
• Replacement of the 2 fish per trip limit by a monitoring programme to minimize by-catch of dogfish where possible and maximize return of live incidental by-catch
• Retention of the 100cm maximum landing size, if felt necessary
• Release and recording of data on numbers, size and position of live Spurdog (verified by observer coverage if necessary)
• Continual monitoring of by-catch rates and if increasing significantly immediate remedial action to be taken

Benefits:

• Reduce discarding of dead fish
• Maximize return of live fish
• Improve scientific data or understanding of these species as basis for the design of effective Spurdog avoidance strategies
• Encourage fishing industry collaboration or partnership to trial and test technical, spatial and temporal means of reducing dogfish by-catch
• Build in step wise fashion an effective rather than cosmetic approach

This is an issue which requires immediate resolution to avoid any further unnecessary discarding and alienation of the fishing industry. Therefore I would suggest an urgent meeting of DEFRA policy officials and scientific advisors to develop a practicable management regime that could, in the first instance, be piloted by CFPO vessels as soon as possible.

I trust that you will appreciate the genuine nature of these proposals and assist us in addressing this issue as a matter of urgency.

If you require any further information please do not hesitate to contact me.

 Yours sincerely

Paul Trebilcock

Chief Executive

 Cc: Barrie Deas        NFFO