The NWWAC has responded to the UK Government’s consultation on the reforming of the management of discards in England
The North Western Waters Advisory Council has offered its response to the UK Department for Environment, Food and Rural Affairs (Defra) consultation regarding the reforming of the management of discards in England.
The consultation had been opern in the period from 17 July 2023 to 09 October 2023 in conjunction with other consultations, namely on expanding the use of Remote Electronic Monitoring and on various Fisheries Management Plans.
Given its role as legitimate EU fisheries stakeholder body and the geographical remit of its work, the North Western Waters Advisory Council (NWWAC) has prepared the following position paper in response to the abovementioned consultation:
Before addressing the main points of this consultation, the NWWAC wishes to make a few general remarks.
- The NWWAC highlights the need for a certain degree of harmony in managing fisheries between the European and UK waters. Vessels active in the North Wester Waters often fish in both areas. Having two diverging systems to comply with when crossing the border between EU and UK waters represents a great concern and would create unbearable difficulties for fishers. The NWWAC urges both parties to address this aspect as a matter of priority and strive for cohesive and harmonised management systems.
- As mentioned above, several consultations have been launched by DEFRA since July 17 with a duration between 11 and 12 weeks. These consultations were launched in the middle of the summer period, where most of the people were on leave, and will close early after the beginning of the school year, which leaves a very short time to read all the related documentation. This is especially more difficult for stakeholder organisations such as Advisory Council, where certain consultation procedures need to be followed in order to meaningfully engage members and reach consensus on a position. Overall, the NWWAC acknowledges that the duration of the consultations is reasonable, but feels that setting up these consultations at this time of the year is not cooperative with stakeholders.
- The NWWAC emphasizes the great need to link this proposal for a discard reform to the proposal on the use of REM.
The NWWAC agrees with the principles mentioned by the questionnaire to be adopted in managing the new approach to discards.
Accordingly, the NWWAC would like to be kept informed of any proposed measures which may be introduced as part of this reform and to be included in any consultation where this is possible under the rules of the TCA. The NWWAC aims at ensuring stakeholder involvement in the EU decisionmaking process regarding fisheries management in the EU North Western Waters. While the NWWAC is not an official entity in the UK, it is still an important partner in this consultation and in supporting a collaborative working approach on the matter, given its role as a legitimate EU fisheries stakeholder body and its geographical remit.
The AC has frequently stipulated in its recommendations that avoidance and minimisation of unwanted catches are baseline tools to achieve the selectivity objective. At the same time, when using the landing obligation, avoiding choking a fishery remains one of the biggest challenges in the mixed and dynamic NWW fisheries. Clearly, there is a high risk of choke issues especially for those stocks which have been characterised by zero-catch scientific advice. Focusing efforts on these higher risk stocks first seems a reasonable approach. Overall, priority should be given to avoidance measures that aim at unwanted fish not entering the gear in the first place. Subsequently, measures to mitigate chokes which do not only minimise the amount of unwanted catches (and thus the choke risk), but also help the relevant stocks recover in the long-term, are to be considered. Allowing stocks to recover to healthy levels so that they no longer pose a choke risk is a meaningful way of preventing future chokes.
Finally, the NWWAC agrees that discarding is a complex problem, with practical challenges varying across gears and stocks. Close collaboration with the fishing sector and other stakeholders remains vital to develop and implement effective solutions for each individual fishery.
The NWWAC agrees with the list of stocks identified as priority fisheries.
Beside selectivity measures or spatio-temporal actions that could be taken to manage these delicate stocks, it is important to focus on and examine the trends characterizing them, also taking into account fishers’ observations at sea. In this regard, the NWWAC wishes to mention cod in the Celtic Sea and how climate change is challenging its preservation. The influence climate change may have on this should be further examined and properly quantified.
The NWWAC wishes to raise attention on issues relating to stock identification. Uncertainty around the degree at which two or more stocks of the same species are mixed may frustrate the stock assessment process. Mixing can also lead to problems with the setting of limit reference points and issues around management decisions due to mismatch between stock and TAC management areas. This is especially the case for haddock in the Irish Sea and in the Celtic Sea.
Catch accounting options
The NWWAC is aware that an a priori deduction before the allocation of quotas does not encourage greater selectivity, as the volumes deducted are a definitive loss. Discards should therefore be deducted after landing. Alternatively, a mechanism must be found to return quotas when discards are lower than estimated. In any case, a more detailed and dedicated discussion is needed on this matter.
Measures to avoid or reduce unwanted catch
The NWWAC acknowledges that the consultation includes a proposal for setting up steering groups for the fisheries where discarding poses higher risks. These would have representatives from industry and other stakeholders as well as fisheries managers and scientists. These groups would be tasked with identifying fishing gear modifications, area closures and other measures that could help to reduce discarding in that fishery. The NWWAC would appreciate being kept informed of the work of such steering groups and given the opportunity to be consulted where possible under the rules of the TCA.
In relation to gear modifications and the intention make them mandatory for all vessels, including international vessels, the NWWAC stresses again the need for harmonisation across the border. Having different measures to comply with when crossing the border between EU and UK waters represents a great concern and difficulty for fishers. Collaboration and dialogue between the two parties are essential. Similarly, international stakeholders should be involved in discussions around area closures.
In general terms, the NWWAC advises to retain existing exemptions to avoid the implementation of the landing obligation becoming impracticable.
The AC wishes to highlight that having two different regimes between the EU and the UK in relation to exemptions will create serious control and compliance issues. Once again, we reiterate the need to seek harmonisation via the Specialised Committee on Fisheries to ensure a level playing field in the respective fisheries management areas.