cfpo

Porbeagles

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 PORBEAGLE SHARK

 

We have had to accept that the current ICES advice is that Porbeagle Shark 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 we think that the measures that were adopted for 2010 were neither appropriate nor fit for purpose, if the objective was to reduce fishing mortality on Porbeagle Shark to give stocks an opportunity to recover.

 

We share with the Commission and Council the aim of reducing fishing pressure on Porbeagle Shark 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 prohibition on landing these sharks. However, we are frustrated that the concrete measures put in place will do nothing to rebuild or protect Porbeagle Shark populations and will in practice retard the development of a meaningful conservation policy for Porbeagle Shark.

 

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

 

  • Porbeagle are uneven and generally unpredictable in their distribution for the most of the year

 

  • As a result, although not targeting Porbeagle, on occasion gill-netters targeting species such as Hake and Pollock can on occasion catch individual shark or a small group of sharks (often thought to be chasing feed fish such as mackerel)

 

  • This pattern of catches is reflected in landings statistics (Cornish Fish Producers Organisation from the UK figures by fleet sector attached for information) where generally very low levels of unavoidable by-catch are interrupted occasionally by substantial catches.

 

All this demonstrates that a prohibition on landings is an inadequate management response to the problems confronting Spur-dog.

 

The result of a prohibition on landings can be described quite precisely:

 

  • A discard problem where previously there was none

 

  • No reduction in fishing morality on Porbeagle

 

  • An alienated and frustrated fishing industry obliged to discard a not completely insignificant part of their earnings for no comprehensible reason

 

  • Loss of catch data that could provide the basis for practical solutions

 

Alternative

 

This is an unacceptable position for all concerned scientists, fishermen and fisheries managers. 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 organisations to “do something”; fishermen can only shake their heads in despair at yet another irrationality in the management system.

 

Proposal

 

We propose the following:

 

  • No targeted Porbeagle fisheries

 

  • Replacement of the landing prohibition by a monitoring programme to minimise by-catch of Porbeagle where possible and maximise return of live incidental by-catch

 

  • Retention of the 200cm maximum landing size, if felt necessary

 

  • Release and recording of data on numbers, size and position of live Porbeagle (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

 

  • Maximise return of live fish

 

  • Improve scientific data or understanding of these species as basis for the design of effective Porbeagle avoidance strategies

 

  • Encourage fishing industry collaboration or partnership to trial and test technical, spatial and temporal means of reducing  Porbeagle by-catch

 

  • Build a solution in step wise fashion an effective as opposed to a cosmetic approach

 

This is an issue which requires immediate resolution to avoid any further unnecessary discarding and alienation of the fishing industry.

 

I trust that you will appreciate the genuine nature of these proposals and assist us in securing fit for purpose management measures for this stock as a matter of urgency.

 

Yours sincerely

 

 

 

Paul Trebilcock

Chief Executive

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