cfpo

Spurdogs

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: SPUR-DOG

 

We have had to accept that the current ICE’s advice is that Spur-dog 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 in 2010 were neither appropriate nor fit for purpose if the objective was to reduce fishing mortality on Spur-dogs to give stocks an opportunity to recover.

 

We share with the Commission and Council the aim of reducing fishing pressure on Spur-dog 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. However we are frustrated that the concrete measures put in place will do nothing to rebuild Spur-dog populations and will in practice retard the development of a meaningful conservation policy for Spur-dog.

 

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

 

  • Spur-dog are found in shoals but these are uneven and generally unpredictable in their distribution for the most of the year

 

  • As a result, although not targeting Spur-dogs, on occasion gill-netters targeting species such as Hake and Pollock can on occasion catch substantial amounts of dogfish

 

  • A similar pattern can be seen when trawlers hit unpredictable shoals of Spur-dog

 

  • 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 zero TAC, albeit with a 10% by-catch tonnage per member state, is an inadequate management response to the problems confronting Spur-dog.

 

The result of an in effect zero TAC provision can be described quite precisely:

 

  • A significant discard problem where previously there was none

 

  • No reduction in fishing morality on Spur-dog

 

  • 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 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 Spur-dog fisheries

 

  • Replacement of the zero TAC limit by a monitoring programme to minimise by-catch of dogfish where possible and maximise 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 Spur-dogs (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 Spur-dog avoidance strategies

 

  • Encourage fishing industry collaboration or partnership to trial and test technical, spatial and temporal means of reducing  dogfish 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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