cfpo

2011 TAC CFPO Document

16 November 2010

 Our Ref: PDT/111610/dc

 

Richard Benyon MP

Minister for Fisheries

DEFRA

Nobel House

17 Smith Square

London

SW1P 3JR

Dear Minister

COMMISSION PROPOSALS FOR 2010 TAC AND QUOTA REGULATION

Background

Following the release of ICES advice for 2011 and the Commission’s Policy Statement we, through the NFFO, have met with you and your officials to discuss the UK’s position in relation to the year end negotiations, and the 2011 TAC and Quota regulation. Building on this constructive start, I have now outlined below the principle areas of concern for the CFPO for these negotiations

 

We have gone through all of the TAC stocks of interest to the CFPO membership which will give you an idea of the breadth and diversity of our fleet and which are reflected in relatively wide ranging priorities.

 

You will fully understand that the Cornish fleet is unique in its diversity and because of this we understand that the ultra-mixed fisheries in the South-West present a real challenge in these negotiations. Because of this fleet structure and the high degree of fisheries dependence in the South West that outcomes of this December negotiations should be viewed as an overall package rather than isolated issues. In recent years some important stocks have been subjected to a ‘salami slicing’ of the TAC. In many cases this has not been justified by the science and has rather reflected the Commission’s slash and burn approach to dealing with MSY or deficiencies in the data. This has led to an unnecessary increase in discarding as well as adding economic pressure to a fragile fleet.    

 

It is important to remember that other Member States have shared objectives with the UK on many of the stocks that are important to the CFPO and we have attempted to flag these up for your information ahead of the negotiations.

 

The Commission appear to be taking a far harder line on TACs this year for political reasons rather than based on good science; this could have far reaching economic and social implications without delivering the core objectives of optimal sustainable exploitation of many stocks. The Commission as always will put an emphasis on the scientific assessments from ICES in their proposals. However the data used to develop the advice for many of the stocks in area VII remains relatively inadequate and in many cases is the same as last year; this is a situation that must be remedied as a priority. Work to improve the data and reduce knowledge gaps must be made a priority for DEFRA, the Fishing Industry, the RACs, ICES and the Commission during 2011.

 

From a UK perspective further development and use of the vitally important Fisheries Science partnership (FSP) data is essential.

 

One of the most disappointing aspects of the 2011 proposals is our failure to persuade the Commission that efforts to base TACs for 2011 on recent catch levels for many stocks is seriously misguided. The Commission must be deflected from this approach as it will simply lead to mismanagement and discarding in some Member States.  It will also encourage Member States to put pressure on stocks to retain future TAC levels. This appears to be part of the Commission’s negotiating strategy by creating pressure points across a broad front. The 15% reduction in TAC seems to be a default position when stocks are stable and no other reason for reduction can be found.UK efforts should be made to address this as soon as possible (specific stocks are detailed below).

 

Discards will be significant in the Commission’s thinking and any proposed regulation that could potentially increase discards should be challenged and efforts made to work in partnership with the fleets involved addressing the core issues in a practical and effective manner.

 

Summary

 

In terms of summarising the detailed analyses in the following CFPO position paper and offering a suggested negotiation line we would suggest four lines of strategy as follows:

 

  • UK Key Priorities: Cod VIIb-k secure TAC increase and resist extension of effort control, Sole VIIe TAC and effort levels, separate Plaice quotas for VIIe and VIId and workable management measures for Porbeagle, Spurdog and Skates and Rays

 

  • ‘Use it or Lose it’ Stocks (with other Member State support seek to resolve these early): Pollock VII, Saithe VII, Sole VIIhjk and Plaice VIIhjk

 

  • Other UK Priorities: Haddock VIIb-k TAC level

 

  • Other Member State priorities to Support: Sole VIIfg, Plaice VIIfg, Northern Hake, Monk VII, Megrim VII

 

All of the above are of importance to the CFPO as well as the UK fleet and the objective must be to secure all. The outcome will be judged as a package and cosmetic cuts that will only increase discards will be challenged. We are committed to sensible evidence based management and we hope that you are with us on this core principle.

 

POSITION BY STOCK:

 

Cod VII b-k

Commission Proposal: Cut TAC by 15% and introduction of effort regime to Celtic Sea

This stock appears to fit into EU Commission Policy Statement Category 7 “State of the stock not known precisely and STECF advises to reduce fishing effort.” The TAC should be reduced by up to 15% and STECF should be asked to advise on the appropriate level of effort.

 

There is considerable doubt about this assessment and no new advice has been offered. STECF agrees with the ICES assessment that the state of the stock is unknown. Fishermen in all fleets working in the area are reporting a high abundance cod in the size range 30-40cms. CEFAS and BIM have indicated the there are signals of good recruitment from their official surveys which seem to corroborate the observations of fishermen.

 

The fishing industry initiated the Trevose Closure (although not to date scientifically assessed) is believed to be having a positive effect on fishing mortality and contributing to the stock improvement. It can be said with certainty that there has been a significant reduction in effort as a direct result of the closure.

 

We are currently working with French, Irish and Belgium colleagues through the NWW RAC to develop a long term management plan. The NWW RAC response on the Commissions proposed effort regime is attached for your information. This industry developed plan will meet the objectives of fit for purpose stock management. We will keep you informed of this plan. However a reduction in TAC and the Commission’s toxic meddling in this stock for political reasons could create significant problems in this process.

 

With the scientific assessment so uncertain and the experience of all member state fishing fleets so clear, it is important that there is a substantial increase in this TAC to avoid unnecessary wholesale discarding.

 

One of the issues identified by ICES was the perceived truncated age structure of this stock. The implementation of the Trevose Closure has had the effect of delaying the time of capture and it is believed that this will positively contribute to the improvement of the age structure of this stock.

 

There is a strong scientific argument that this stock should fit into the Commission’s Policy Statement Category 8: “State of the Stock not known precisely and STECF advises the stock is increasing.” The TAC should be increased by up to 15%. No increase in effort. Given the uncertainty in the assessment coupled with the strong indicators of improved recruitment (both scientific and fisheries based) it is credible and coherent to increase this TAC to avoid unnecessary discarding.

 

The industry buy-in and participation in this area has we believe contributed significantly to the improvement in the stock and will contribute to improving the assessment. It is important that this is not lost through a heavy handed approach from the Commission.

 

Potential support: France, Ireland, Belgium

 

Haddock VIIb-k

Commission Proposal: Rollover TAC

This Stock fits into EU Commission Policy Statement Category 8 “State of the Stock not known precisely and STECF advises the stock is increasing.” The TAC should be increased by up to 15%. No increase in effort 

 

While a roll-over TAC is an improvement on last year’s advice it is not acceptable that in 2008 ICES flagged up the paucity of science on this stock and nothing has been done to remedy this situation. We find this extremely disappointing given the importance of this stock to the South-West fleet.

 

The Area VIIb-k haddock fishery has historically followed cycle of approximately one or two good year classes every 7 years. However about 3-4 yrs ago this changed to a multiple year-class fishery thus becoming a very important, year round fishery for trawlers operating in Area VIIb-k.

 

Skippers can clearly identify four large year classes of haddock in their catches which we feel demonstrates in part at least that this stock is now well established in the Area VIIb-k. This is a question of time-lag as the formal assessments catch up with the changes in the stock which are already seen by the industry.

 

It should be noted that ICES are currently reviewing their use of data hungry assessment models to ensure that they are improved and are both more accessible for fishing industry data and of more use in stock assessments. Therefore, we would strongly recommend that FSP work to be carried out with immediate effect to address this key priority. We have vessels ready and willing to assist in this work and we must progress it immediately.

 

Potential support: Unknown as it is not likely to be a priority for other Member States

 

Pollack and Saithe

Commission Proposal: Cut TAC by 15%

These stocks fit into the EU Commission Policy Statement Category 11 “There is no STECF advice”. TACs should be adjusted towards recent catch levels but should not be changed by more than 15% per year or Member States should develop an implementation plan to provide advice within a short time.

 

There is no ICES advice for these stocks. Therefore the Commission’s proposal is to cut the TACs to average recent catch levels. This approach is not justified for the following reasons:

 

  • Unintended effects on relative stability.
  • Potential increase in discards within individual member states.
  • Prejudice fishery dependent scientific data due to the above.

 

These stocks are of vital importance for the CFPO netting fleet, particularly Pollack.

 

Potential support: Most other Member States on principle of ‘use it or lose it’, although other member states unlikely to consider them as priority stocks.

 

Ling

Commission Proposal: Rollover TAC

This Stock fits into EU Commission Policy Statement Category 6 “State of the stock not known precisely and STECF advises on an appropriate catch level.” Aim to set the TAC according to STECF advice but do not change the TAC by more than 15%.

 

The ICES advice for this stock is that although there is limited scientific data and the stock does not appear to be in decline, there should be no increase in effort.

 

This stock is of vital importance for the CFPO netting fleet particularly in the spring of the year and rollover TAC should be secured.

 

 

Northern Hake

Commission Proposal: Rollover TAC

This stock fits into EU Commission Policy Statement Category 4 “Stock is subject to long-term plan and scientists’ advice on the catch that corresponds to the plan.” The TAC must be set by following the relevant plan.

 

Scientifically this is a stock in good shape and the transition from recovery plan to long term management plan is well underway, although yet to be formally agreed. It is important that the good state of this stock is maintained whilst having regard for the implications of the technical aspects and implications of any agreed long term management plan to the UK fleet.

 

Potential Support/Lead: Spain

 

Monk VII

Commission Proposal: Cut TAC by 15%

This Stock should under ICES assessment fits into EU Commission Policy Statement Category 8 “State of the stock not known precisely and STECF advises the stock is increasing” The TAC should be increased by up to 15%.

 

Instead the Commission have opted to classify this stock as Category 6 and proposed a cut in the TAC. This does not appear to be justified.

 

The important FSP work carried out by Cornish beam trawlers should be used to evidence the wrong category classification by the Commission. Although the state of the stock is not known precisely, the trends demonstrated by the FSP time series show an improving stock.

 

Area VII Monk is an example of using scientific and fishing industry data in partnership to develop sensible advice.

 

Potential support: Spain, France, Ireland

 

Megrim

Commission Proposal: Cut TAC by 15%

This stock fits into the EU Commission Policy Statement Category 11 “There is no STECF advice”. TAC’s should be adjusted towards recent catch levels but should not be changed by more than 15% per year or Member States should develop an implementation plan to provide advice within a short time.

 

The Megrim advice falls into the category of under-usage and scientific uncertainty. The basis for advice is no increase in effort and therefore we disagree with the proposed cut of the TAC. The advice clearly points to a rollover TAC.

 

Potential support/lead: Spain

 

Sole VIfg

Commission Proposal: Increase TAC by 25%

This stock fits into EU Commission Policy Statement Category 1 “Stock exploited at the maximum sustainable yield rate”. Aim to set the TAC to the forecast catch corresponding to the fishing mortality that will deliver the highest yield in the long term, but do not change the TAC by more than 25%.

 

Scientifically this stock is in good shape and well within safe biological reference points. This stock is of vital importance to Cornish beam trawlers. Looking at the ICES advice it is scientifically justified to consider this significant increase.

 

Potential support/lead: Belgium

 

Plaice VIIfg

Commission Proposal: Cut TAC by 9%

This Stock fits into EU Commission Policy Statement Category 3 “Stock outside safe biological limits.”

 

The scientific assessment of this stock is not good. However the indirect affects of the Trevose closure and uncertainty in recruitment/discard information point to serious data reliability issues. Although a small cut is proposed this doesn’t reflect catch rates being experienced. This stock is taken by beam trawlers as a relatively low by-catch but is of greater importance to trawlers operating in further east in area VIIfg.

 

Anecdotally, catch rates have been improving over recent years and again this is a candidate stock for an FSP project. The difference in assessment and experience of fishermen on the ground needs to be addressed urgently.

 

We feel that the objective based on the poor science should be reversing this proposed cut and seeking to maximise an increase in the TAC. A small increase will only lead to a marginal improvement in discarding or high-grading.

 

Potential support/lead: Belgium

 

Sole VIIhjk 

Commission Proposal: Cut TAC by 15%

This stock fits into the EU Commission Policy Statement Category 11 “There is no STECF advice”. TACs should be adjusted towards recent catch levels but should not be changed by more than 15% per year or Member States should develop an implementation plan to provide advice within a short time.

 

This proposal is particularly disappointing, every year this stock is a proposed 15% cut on the ‘use it or lose it’ principle. This is totally unacceptable as the UK will take near to 100% of its quota so will be disadvantaged by this proposed cut and there is no scientific justification for a cut.

 

As we have said before this approach is not justified for the following reasons:

 

  • Inadvertently undermines relative stability.
  • Potential increase in discards within individual member states.
  • Potential increase in high grading within individual member states.
  • Prejudice fishery dependent scientific data due to the above.

 

These stocks are of vital importance for the CFPO beam trawl fleet. The objective should be at least a rollover of the TAC.

 

Potential support: Most other Member States on principle of ‘use it or lose it’, although other member states unlikely to consider them as priority stocks.

 

Plaice VIIhjk

Commission Proposal: Cut TAC by 15%

This Stock fit into EU Commission Policy Statement Category 6 “State of the stock not known precisely and STECF advises on an appropriate catch level.” Aim to set the TAC according to STECF advice but do not change the TAC by more than 15%.

 

The ICES advice for this stock is that there is limited scientific data. The Commission’s proposal is to cut the TAC to average recent catch levels. This approach is purely cosmetic and will result in increasing discards. The UK has swapped in over 30t of this stock from other Member States in 2009 to avoid discarding but this will not be possible with a further 15% cut. 

 

This approach is not justified for the following reasons:

 

  • Inadvertently undermines relative stability.
  • Potential increase in discards within individual member states.
  • Potential increase in high grading within individual member states.
  • Prejudice fishery dependent scientific data due to the above.

 

These stocks are of vital importance for the CFPO beam trawl fleet. The objective should be at least a 15% increase in the TAC. The UK only has an allocation of 14 tonnes and we have landed far in excess of that figure thanks to international quota swaps. These cannot be relied on indefinitely and it is essential that there is an increase in this TAC to avoid significant discarding.

 

Potential support: Most other Member States on principle of ‘use it or lose it’, although other member states unlikely to consider them as priority stocks.

 

Sole VIIe

Commission Proposal: Increase TAC by 15%

This stock fits into EU Commission Policy Statement Category 4 “Stock is subject to long-term plan and scientists advise on the catch that corresponds to the plan.” The TAC must be set following the relevant plan.

 

We have worked with the South Western Fish Producers Organisation on assessing the implications of the advice on this stock and we fully support the detailed arguments they have submitted.

 

Potential Support: France

 

Plaice VIIde

Commission Proposal: The introduction of separate TACs for VIIe and VIId

 

Again we have worked with the South Western Fish Producers Organisation on assessing the implications of such a move and they have submitted a detailed case on this aspect which we fully support.

Porbeagle, Spurdog and Skates & Rays

 

We will write separately on Porbeagle, Spurdog and Skates and Rays. Needless to say these are important stocks and need sensible management measure to offer protection, improve the scientific assessments but do not increase discards.

 

Recent measures on these stocks have been driven by aesthetic politics rather than sensible management and we hope to change that.

 

 

As always I will be available in the run up to and through-out the Council negotiations should you or your officials require any further information or clarification. I trust you will consider the issue above carefully and act accordingly.

 

Yours sincerely

 

 

 

Paul Trebilcock

Chief Executive

 

Cc:      Barrie Deas               NFFO

            Andrew George         MP St Ives

            Sheryll Murray            MP South East Cornwall

            George Eustice         MP Camborne and Redruth

            Richard Pullen           DEFRA

            David Dawson           DEFRA

            Simon Waterfield      DEFRA

 

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