Home > 13/09/2014 – Fishing Opportunities Consultation for 2015 under CFP

INTERVENTION TO IRELAND OP(s) re: ENHANCED OVERSIGHT OF FISHING OPPORTUNITIES AND PROPOSAL FOR IRISH SEAL SANCTUARY NOMINEE TO NEW OPMC,  from Sea Fisheries Advisory Group (SFAG),Irish Seal Sanctuary (ISS)

The Irish Seal Sanctuary (ISS) is an active stakeholder in fisheries and has a Sea Fisheries Advisory Group (SFAG) drawn from and working with fishing communities. The ISS has served on both Exec and WG (4 especially) of NWWRAC/now AC from the beginning, indeed the only Irish ENGO there till the current transformation. The ISS serves this last 3 years also on the OPMC. The ISS sets out here in summary broad and general principles developed for all fisheries and recommendation more locally for the Irish Sea to be designated as FDF, restored as mixed fishery with LTMPs and pilot/template for roll-out of FDFs across EU.

Fishing Opportunities from the outset must be based on Ecosystem Approach and Precautionary Principle. To overfish, fish depleted or data deficient stocks, fish in nursery areas, continue discarding unselectively or incur unsustainable bye-catch…..is not opportunity under CFP Reform but a reverse to historic, destructive practises of poorly allocated and regulated “opportunities” of former CFPs.

Fishing opportunities must be wholly compliant with CFP reforms and all it’s parameters for sustainable stock and economic growth, growth in employment and food security. Landing Obligations, Discard reduction measures and good environmental status must be clearly defined under grounding principles.

TCMs, “de minimis” regulations, use of choke species, temporal and spatial closures can only succeed if broadly understood and agreed. LTMPs for single species and mixed fisheries are attainable objectives. Resources must be provided (from  M.S.s and EMFF) to improve science and Data Deficiencies. Opportunities must be cross compliant with MSFD, climate mitigation, BioD recovery measures and MPA roll-outs.

While CFP reforms and sustainability principles are generally agreed they are poorly applied and subject still to horse- trading, nationalistic interests. Their application must be pragmatic and inclusive and face the realities of reducing fleet capacity and matching effort to stock sustainability in short term.
Inevitably to achieve reforms and equity in fishing opportunities there must be transparency and trust and FDFs present the only way forward. FDFs must be accompanied by effective enforcement and oversight and here is role for the OPMCs in the disbursement of EMFF. In Ireland to date the OPMC has been a largely rubber-stamping exercise. With oversight responsibility as intended, in allocation of fishing opportunities and funds it is possible to close the loop from catch effort and control to monitoring and enforcement to oversight and fund access and retrieval. With FDFs and effective oversight in public interest sustainable fishing opportunities and access to EMFF would be harmonised.

Ireland has produced FH2020 targets setting growth in fisheries before scientific advise.
Many stocks remain data deficient and ISS believes auto reductions in absence of scientific returns should apply. Operators facilitating and contributing to science should be incentivised appropriately.

ISS recommends the Irish Sea as pilot FDF and template for sustainability. Ireland has a long history of failed measures….notably cod and salmon and likely the highest rate of discarding in EU. The Irish Sea  is almost a single species fishery now with collapse of BioD. Small and contained, it presents a unique and challenging opportunity to fisheries, for implementation of L.O. and discard reduction and with appropriate inclusion measures for those out of work or underemployed, would have the co-operation of remaining fisheries operators and citizen science.

Ireland and range M.S.s with all fishing opportunities must invest further in addressing data deficits and EMFF makes provision for fund transfers for such purpose across Axis.
Delays to 2015 MSY must be validated and accompanied by LTMPs, or opportunities reduced.
The role of the OPMC in monitoring must be central to fishing opportunities….this not the case in Ireland.

Stocks with zero TAC or data deficient may require a special, regulated, scientific category of opportunity in interests of recovery till above spawning stock biomass capable of sustaining MSY.

MPAs and protection of nursery areas are key to stock recovery and sustainability and where fishing opportunities are available, best suited to artisanal opportunities. In Dublin Bay, the Bull Island UNESCO Biosphere has a no fish zone and there are proposals now to extend the Biosphere from Rockabill to the entire Bay…..this presents an opportunity to match fishing effort to best practise and create new opportunities….further endorsement of Irish Sea as template for recovery measures.

There is a growing divide between scientific advise, fisheries opportunities and TACs and worryingly between catch and non-catch stakeholders,  principles and practise. FDFs, full transparency on fishing opportunities and EMFF disbursements and OPMC oversight throughout EU are path to equitable and sustainable opportunity.

Removal of higher and lower trophic levels in  ecosystem is impediment to recovery , whether at nursery level, discarding or “slipping”, high grading or bye-catch etc. and so opportunity needs be matched to best selective fishing practice and highest rates of selectivity. This will be reflected in LO and and discards in FDFs.
Indicator species such as seabirds, marine mammals, reptiles, shark and ray are affected by over-fishing and discarding as well as victim to bye-catch and opportunities require matching to such incidental and non-targeted attrition.

The potential for increased landings and employment  is well illustrated in “Jobs lost at Sea” in medium to long term recovery and known to most honest, experienced fisheries operators, often entangled in the race for grants over opportunity, driven by fisheries managers and poorly regulated markets. They know this for a race to the bottom and ecological collapse.
2015 MSY deadlines must be held and scientific opportunities rigorously regulated
EMFF funds must be matched to opportunities and rigorously enforced and monitored.
Decommissioning and adjustment of fleet capacity will be inevitable and should be accompanied by diversification and inclusion measures (Human discards have matched fish discarding with little attention over successive CFPs). A cap on technical creep, displacing people also will be offset and employ more by Opportunity and EMFF transfers to more selective and sustainable practices.

By Enhanced OPMC Oversight of matching Opportunities to funds and reform criteria Sustainable Fisheries can be achieved.

Brendan Price EuroProBiol   on behalf SFAG/ISS
Patsy Peril  Chair SFAG/ISS
Johnny Woodlock Sec. SFAG/ISS
John Daly Retired Skipper and Irish Sea Advisor, SFAG/ISS

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