Draft NEF Working Paper Restoring EU Bass Stocks

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Draft NEF working paper Restoring EU bass stocks

Written by: Chris Williams & Griffin Carpenter

New Economics Foundation www.neweconomics.org [email protected] +44 (0)20 7820 6300 @NEF

Contents

Contents ...... 2

Summary ...... 3

Fisheries Context ...... 5

State of bass stocks ...... 5

Political Context ...... 7

EU Emergency measures ...... 8

What further action is needed? ...... 8

Seven key steps to bass stock recovery ...... 10

1. Follow scientific advice ...... 10

2. Increase the Minimum Landing Size to 42cm ...... 11

3. Regulating netting for bass ...... 12

4. Limit landings ...... 13

5. Expanding the level and extent of protection of nursery areas ...... 15

6. Permanent prohibition of pair trawling during spawning season ...... 16

7. Adequate resourcing ...... 16 Discussion: From Emergency Measures to long-term sustainable and equitable management ...... 19

Using TACs and Quota (Article 17) as a solution ...... 21

‘Best value’ ...... 23

Commercial fishing ...... 23

Recreational fishing ...... 24

Distribution of access to the resource ...... 24

Notes ...... 26

Appendix ...... 28

Glossary (MMO, 2013) ...... 34

Endnotes ...... 38

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Summary

The European Commission has agreed emergency measures, a ban on pelagic trawling for bass, to halt the severe decline of bass stocks (EC press release – 26/01/2015). Following this announcement, we are providing an outline of the necessary change1 to ensure the future of the species in UK and European waters. The EU measures ban pelagic trawling for bass in the Channel, Celtic Sea, Irish Sea and southern North Sea. Our suggestions make the case for a range of measures which can inform a UK management plan for bass (a legal obligation under CFP Art 2(2) with Member States and the Commission both responsible). We also call for investment in fish stock restoration and ensuring best value for society by adequately resourcing our regulators and fisheries managers. Only these measures will enable us to rebuild and ensure resilient, sustainable bass stocks for future generations. As the Natural Capital Committees 3rd report states: ‘… the long-term gains [of restoring commercial fish stocks] are potentially large, securing jobs in the industry for generations to come. Investing in measures to restore certain stocks of shellfish could deliver benefit cost ratios in excess of 6:1’ 2 The EU emergency measure explains clearly that ‘…Seabass is a late maturing and slow growing species whose fishing mortality [is four times] the maximum sustainable yield (MSY) levels. It is therefore appropriate to establish fishing opportunities for this stock in the form of fishing effort and catch limits, which should target the main sources of fishing mortality, i.e. pelagic trawling and recreational fishing.’3*

While our recommendations are based on the needs of the UK, many are equally applicable to other EU member states involved in bass fishing (FR, IRL, UK, BEL, and NL). We recommend seven key steps to bass stocks recovery which the UK can adopt and present to the EU as the most effective and equitable and proportionate** way forward: 1. Follow scientific advice – natural limits cannot be negotiated. 2. Increase the Minimum Landing Size to 42cm for commercial and recreational fishers. 3. Regulate netting for bass by increasing the mesh size of nets and decreasing the length of nets used. 4. Limit the commercial weekly landings per vessel to 1.5 tonnes – a necessary reduction from the current 5 tonnes and introduce a recreational bag limit (with mandatory fin clipping).*** 5. Better protect nursery areas for bass around the UK coastline. 6. Make the pelagic trawl ban permanent, not a one-off measure, and extend the duration of the ban from December 1st – April 30th. 7. Adequately resource regulatory bodies tasked with fisheries management so they can extend effective regulation to other fisheries which have a significant impact on bass.

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* The pelagic trawl fishery is almost entirely (96%) French, while the recreational mortality comprises four member states (France, Ireland, the UK and Holland). When looked at on a member state basis, the commercial fisheries are responsible for higher mortality than recreational fisheries.

**’Proportionate’ in terms of favouring those fisheries/fleets/stakeholders that create ‘best value’ to society. Numerous fleets may have the same overall impact on the stock/F, but the level of discarding (waste) and wider value created or destroyed (e.g. fossil fuel use) should be considered when allocating access to the resource.’ Emergency measures to be taken are not directed “against” a specific fleet segment. The justification for emergency measures is to protect the spawning stock of sea bass and its capacity to reproduce against an imminent serious threat.’ 4

*** CEFAS’s examination of the profile of the UK commercial bass fishery 2010 as described by Walmsley & Armstrong, shows that of the 1,344 vessels (combined under and over 10 metres fleet) that landed bass in England:

Number of vessels (percentage Quantity of bass landed (2010) of overall total)

788 (59%) landed less than 100 kilos for the year

195 (15%) landed less than 100 kilos for the year

129 (9%) landed less than 100 kilos for the year

89 (6%) landed 500 – 1000 kilos for the year

61 (4.5%) landed 1 – 2 tonnes for the year

77 (6%) landed 2 – 10 tonnes for the year

6 (0.5%) landed over 10 tonnes for the year

The 1.5 tonne limit would by itself have a negligible impact on bass mortality. This measure is being proposed alongside other measures for their cumulative impacts on stocks and considering the socio- economic impacts they would entail.

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Fisheries Context

State of bass stocks The bass mortality as a result of fishing (F) on Figure 1 below indicates harvesting pressure on the bass stock. Mortality has been rising since the new millennium and even more steeply since 2011. ‘The most common target in fisheries management is achieving FMSY, i.e. the rate of fishing mortality that ensures the maximum sustainable yield (MSY - see below). A fishing mortality rate above this threshold is indicative of overfishing’5. For the entire 28 year record available from ICES (the International Council for the Exploration of Sea), we have been fishing bass above levels that would lead to a stock size with the maximum sustainable catch levels (Fmsy on the graph below). ICES advise a reduction of (F) to 0.13, a level we have not seen since before 19856. There are multiple reasons for this alarming trend, ranging from biological to socio-economic and political. Bass numbers have, until a recent spell of cold winters been increasing,7 growing rapidly from the mid-1990s and reaching a high point in 2010.8 This has driven increased exploitation as the availability of the resource has increased. ‘However, the stock is being fished harder than is appropriate for such a slow growing, late maturing fish. To make matters worse, the number of young bass surviving from spawning in the years 2008 to 2012 appears to be well below average, probably due to unfavourable environmental conditions’9. Additionally, there has been increased pressure as small-scale (inshore) fisheries have shifted to bass and other non-quota species because of a lack of access to other quota, all as demand grew and prices remained high10. Figure 1: EU Bass Fishing Mortality. Source: ICES, 2014

EU Bass Fishing Mortality

0.45 0.4

0.35

0.3 0.25 Mean Total F 0.2 (Ages 5-11) 0.15 Fishing Fishing Mortality Fmsy 0.1 0.05 0

‘Commercial fishermen are still trying to supply the increased market demand created when the bass stock was at its peak. But with fewer young fish surviving, there’s a danger of depleting stocks of adult fish beyond recoverable levels.’11 The end result of this trend is clear. Mortality rises, stock biomass decreases, fishery closes, possibly irreversibly. So, despite the delays throughout December 2014 and January 2015, the European Commission has taken the first step towards averting the tragedy of the commons – now the key question remains: how do we focus on achieving better long-term management and fair distribution to restore bass stocks?

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The failure to manage the stock to date, has been the failure to ensure that fishing mortality (F) was limited when bass recruitment slowed over a series of poor winters. As a result of this failure, the structure of the stock relies heavily on recruitment from single year classes. This means the fishery still balances on a knife edge. Another bad winter with similar negative impacts on recruitment, combined with further high (F) (removing the spawning stock biomass in December and January) means we may be left without an insurance policy. Hence the continued risk of a crash in bass stocks if measures are not meaningfully enforced (which will require Government investment). According to the Scientific, Technical and Economic Committee for Fisheries (STECF), bass catches ‘…can be broadly split into three categories: (i) recreational; (ii) commercial fisheries targeting sea bass, and; (iii) fisheries where sea bass are taken as a commercial by-catch in mixed demersal fisheries. Based on 2010-2013 data, recreational fisheries account for 26% of the overall catch (commercial and recreational); commercial targeted fisheries account for 33% (mid-water pair trawls and lines) and other commercial fisheries where sea bass are taken as by-catch account for 41% of the overall catch’12. STECF also deemed current national bass conservation measures as ineffective.

There have been substantial criticism of this assessment regarding what comprises a ‘’mixed demersal’’ fishery and what comprises a ‘’targeted’’ bass fishery13 which are described in the endnotes. It is also apparent that from a UK point of view most bass fishing should be considered as ‘‘targeted / directed’’ bass fishery.14 We propose that all of the directed fisheries should be considered as such and come under regulation. This must include the substantial ‘entangling’ net fishery and recreational catches. These remain as outstanding issues for the UK to address urgently, given the now banned pelagic trawling effort (mainly French vessels15) during seasonal spawning aggregations in ICES divisions IVb, c and VIIa, d-h and areas VIIj, k are included to prevent displacement).

Figure 2: ICES areas

As Figure 3 shows below, EU level landings are highest in the Western and Eastern Channel, but the stock is exploited throughout its range, from spawning sites in the Channel through to the inshore areas and Atlantic coastlines of the UK and France.16 Closure of fishing on spawning aggregations will produce immediate benefits if properly enforced, as removing specific and targeted effort, will allow a significant number of multi-season-spawners to reproduce uninterrupted. There is evidence that any disturbance of the spawning aggregation during fishing operations may have a further adverse effect on recruitment success so this measure is a vital first step.17

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The EU measures are a necessary starting point, but the UK has to act decisively and gain the support of other EU Member States to ensure that we can make the transition to maintaining balanced bass stocks, with a range of year classes that can be sustained into the long term. This will require compromise. This can longer be a binary issue of apportioning blame; rather it is about a collective acknowledgement of a crisis and the right approach to restore bass stocks. Figure 3: Map of EU bass catch using MMO data (2012).18 The rectangles on this ‘heat map’ (see Annex 4) correspond to ICES rectangles.19

Political Context As a result of the EC failing to reach a decision on how to deal with the alarming decline in bass stocks at December council,20 public campaigns called on EU Commissioner Karmenu Vella and Bernhard Friess (Directorate C – DG MARE) to announce tough EU emergency measures. NEF and others called on UK Fisheries Minister George Eustice to act unilaterally to ensure that in our 0-12nM (or even 0-200nM21/22) zone, bass management is appropriate and can deliver the long-term benefits that a healthy bass stock structure would lead to. On December 19th 2014, Defra requested ‘emergency measures’ under Article 12 of the reformed Common Fisheries Policy (CFP) (1380/2013), ‘in case of a serious threat to marine biological resources’23 with regards to bass stocks. But this applies only to the Western Channel (VIIe): ‘Given the urgency of the situation, we are hereby making a reasoned request…for the Commission to adopt emergency measures to alleviate the serious threat to the sea bass stock. To reduce fishing pressure by protecting the spawning aggregations the UK proposes the adoption of measures to close area VIIe to pelagic trawlers targeting bass during January to April 2015.’24

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On January 19th 2015, The European Commission announced a package of measures ‘to ban pelagic trawling of sea bass during spawning season which runs until the end of April’. It stated that complementary measures affecting the other commercial and recreational fisheries impacting bass stocks were also needed (See Annex 3).

EU Emergency measures The Emergency Measures, described in an EC press release on January 26th 2015:  ‘Immediately effective emergency measures will place a ban on targeting the fish stock by trawling while [sea bass are] reproducing, during the spawning season, which runs until the end of April. This will be complemented by further measures to ensure that all those who fish sea bass make a balanced and fair contribution to saving the stock.’25  ‘The measure will therefore come into force immediately and last until 30 April 2015. It will apply to the Channel, Celtic Sea, Irish Sea and southern North Sea.’ It appears that the delay over the future of this iconic fish species had been paralysed by finger- pointing and has focused on two issues: the first being the total catch of bass – which needs to be reduced for the main bass-fishing nations (France, UK and Holland).The second being what measures should be brought in to regulate sea angling for bass, nationally and EU-wide. Bass are a highly mobile species, often migrating over hundreds of kilometres, between both territorial and international waters. International cooperation is essential to effective conservation of the species and fishery, although some reports point to little mixing suggesting that only 10% of UK stocks would be available to the offshore pelagic fishery.26 Our proposals are for UK specific measures, which could be used to help other Member States take necessary action. They are discussed in detail in our proposed ‘seven key steps to bass stock recovery’ below.

There are two legal drivers under the reformed CFP which should help the UK Government take urgent, effective action:

The first relates to Maximum Sustainable Yield (MSY - the maximum harvest that can be maintained in the long run without depleting the stock) based fishing levels to be in place ‘by 2020 at the latest’ for ‘all harvested species’.27 This includes bass even though it is not a Total Allowable Catch (TAC) managed species. But this only leaves five years for a huge turnaround in our exploitation of this species.28

The second legal driver is Article 17 of the reformed CFP, regarding criteria for the allocation of fishing opportunities by Member States: ‘When allocating the fishing opportunities available to them, as referred to in Article 16, Member States shall use transparent and objective criteria including those of an environmental, social and economic nature.’29

Both of these drivers are elaborated on later in the discussion section.

What further action is needed? Aside from UK specific management proposals, there are wide-reaching impacts from mixed trawl fisheries which the UK (and EU) must address urgently in a coordinated manner30: Bycatch provisions31, whether “targeted” or ‘accidental’ must be made. Addressing the mortality caused by other trawl / all metiers other than pelagic trawl & line fisheries which contributes 41% (STECF, 2014) to bass mortality must be an urgent priority for the countries involved. The UK can take the lead on this issue by restricting other trawling efforts during spawning season and by

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applying spatial restrictions following the bass migration inshore. Around 40% of bass stock removals EU wide come from mixed demersal fisheries32, but the EC measures have not included these mixed fisheries. Reducing this source of mortality is likely to have the lowest socioeconomic impacts while contributing to stock recovery by reducing F. Clearly, there are gear selectivity issues, but as this is predominantly a seasonal issue, spatial or temporal measures could be the most appropriate means of addressing this. For example, lessons learned from the South West Mackerel box –hand lining mackerel or spatially managed gillnetting and hand-lining33 – could be used for bass. We need to look at a combination of locally appropriate measures, according to up-to-date science and fisheries management knowledge.

The presence of some of the largest EU fishing (engine power >10k Hp) vessels in the English Channel, where bass following migratory routes (where they are particularly vulnerable to capture) should be reviewed without delay. These vessels may be responsible for a substantial bycatch of bass. An effective inspection of landings could provide evidence of their impact. Reports from fishers indicate that there is extensive mortality of small bass in some mobile gear fisheries. The selectivity work supporting the landings obligation should be considered with regard to bass as well as current quota species.34

The wording of the current emergency measure 35 does not address the issue of demersal stern trawlers which catch bass. These vessels which are known to catch significant amounts of bass36 are not included in the regulation. Effectively, this technique is used inshore to target black bream37 and bass in a mid-water fishery38. But due to the shallow depth inshore, these demersal trawlers are effectively fishing the entire water column and should thereby be considered in the regulation as ‘pelagic’ trawls. The UK must address this issue urgently and influence EC regulations to do so too.

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Seven key steps to bass stock recovery

1. Follow scientific advice Scientific advice from the International Council for the Exploration of the Sea (ICES)39, on how to address declining EU bass stocks, has been systematically ignored for years. As our landing the blame series demonstrates, scientific advice is not adhered to for a wide variety of species and stocks. Bass is sadly no exception. The EU emergency measures are only the starting point: ‘ICES advises that a management plan [for bass] is urgently needed to develop and implement measures to substantially reduce fishing mortality throughout the range of the stock.’40 The UK must develop a management plan that tackles overfishing of bass in all forms. ‘The combined commercial and recreational fishery F is well above the FMSY proxy.’41 All sectors are having an impact on bass. Both commercial and recreational fishermen will need to compromise and accept that cumulatively their activity has impacts at stock level.

The EU Scientific, Technical and Economic Committee for Fisheries (STECF) say a reduction of 60% in the current levels of fishing mortality (F) for bass is needed to allow stock to recover to its Maximum Sustainable Yield (MSY) over a 3-5 year period. ‘STECF notes that to reach FMSY as advised by ICES (ICES 2014), would require a reduction in F of around 60%. It is unlikely that any one single measure of those identified above will be sufficient to bring F to FMSY.’42 Therefore reducing weekly bass landings from 5 tonnes (the current only direct control measure – a license condition43) to 1.5 tonnes per vessel (contributing towards the ICES target44) must follow the pelagic ban and be put in place urgently. It is noted that this measure along will have a negligible impact on mortality, but is proposed as part of a substantial package of measures which balance biological and socio-economic considerations.

Even in 2013 the final recorded commercial landings sent to ICES were over 4,000 tonnes as Figure 4 shows below. Capping fishing for all commercial fleets (and recreational fishermen) fishing for bass is necessary and urgent. Recreational catch contributes approximately 25% to sea bass landings45.

‘In 2010, 4,752 UK vessels recorded one or more fishery landings …Of these, 1,480 or 31.1 % landed some bass. Of the 1,841 active under-10m English vessels, 1,107, or about two-thirds, landed bass at least once. Similarly, half of the English 10m-and-over vessels, and over one-third of Welsh under-10m vessels landed bass. The proportion of Scottish and Northern Irish vessels that landed bass was generally low’.46 Bass are caught in a large number of UK fisheries and corresponding management for all fleets that impact bass is needed. The pelagic trawl ban only accounts for a quarter of the impact at stock level.47 Figure 4 does not include the substantial recreational take of bass (STECF estimates 1,500 tonnes48 per annum) EU wide. Recreational angling therefore contributes significantly to overall F and it is estimated that a total of 380-690 tonnes of bass in England and around 940 tonnes for France are caught.49 Scientific advice is clear – all sources of mortality need to be managed and this includes recreational angling.

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Figure 4: EU Commercial bass landings 1985 - 2013

European Sea Bass Landings 6000

5000

4000

3000 Tonnes

2000

1000

1992 2007 1985 1986 1987 1988 1989 1990 1991 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2008 2009 2010 2011 2012 2013

Belgium Denmark Germany France UK Netherlands Channel Islands

Source: ICES data (note French data for 1999 was not submitted: estimated).

2. Increase the Minimum Landing Size to 42cm Increasing the Minimum Landing Size (MLS) for bass to 42cm immediately as the EU suggests50 is an urgent priority. It must apply to all sectors, commercial and recreational, and should be brought into effect in a phased way throughout the EU. This increase will have socio-economic impacts for various fleets fishing for bass, but will contribute significantly to stock recovery and the long-term ability of those fleets to fish for bass. Longer term, there is a clear case for management to take the MLS to 48cm or even higher. CEFAS have stated that the highest yield per recruit would be obtained with a MLS of 48 – 50 cm51. Why does the MLS need to be increased? Because ‘..large animals contribute much more to the next generation. They produce disproportionately more offspring than small fishes….For example, an 80cm European sea bass produces 14 times more young than when it was 40cm (see figure 5 below).’ As the end notes show, the MLS debate is the longest standing issue with regards to bass and a governmental review of the MLS started in 2012. This is the most fundamental fisheries management and stock conservation point, and must be increased to 42cm immediately.

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Figure 5: Bass size and production of offspring (Image credit: PISCO, 2011)52

3. Regulating netting for bass Both inshore and offshore netting (drift and static ‘entangling’ nets) takes place for bass, and all forms of netting have an impact at stock level. This is why a number of measures (for all vessels in our 0- 12nM zone) are needed, which can balance a desperate biological need to reduce F with socio- economic concerns around coastal livelihoods in net fisheries. These measures should enable fishermen to continue making a living, while also aiding bass stock recovery.

For all forms of netting, static, drift, inshore, and offshore, these regulations should include:

 Increasing the mesh size to 120mm in all ‘entangling’ net fisheries between 0-12nM. This mesh size would allow fish up to 45cm to pass through, continuing to replenish and diversify the age classes of the bass stock.53 Appropriate licensing and limitation of netting, would accommodate the proposed increase in Minimum Landing Size (MLS). This measure will be more effective than only an increase in the MLS, as increasing the mesh size prevents capture in the first place. The fisheries management principle for bass relates to the assumption that at 42cm, 50% of the bass stock would have been able to spawn once or twice, hence replenishing the stock and providing a balanced age and class structure. Mesh sizes for nets need to increase to allow smaller bass to slip through and help stock recruitment and year class diversity.

 Netting is currently unregulated to a large degree. The length and number of nets (fleets - which run for many miles at a time and are shot simultaneously) needs to be brought under management and restricted. This could be done through local byelaws or nationally. Licensing of netting activity would have an immediate impact on decreasing mortality.

 Offshore. A reduction in the very large, 170mm mesh size used by the mid channel netters should be restricted down to ~140mm (dependant on CEFAS/scientific advice on the relationship between mesh size and fish age) in order prevent the capture of these very large

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fish.

 Inshore. ‘Inshore gill net fisheries intercept bass reaching the minimum legal size after leaving estuaries (recruitment fisheries) and adult bass, which have returned from winter spawning migrations and have dispersed throughout the coastal waters of England and Wales’.54 For those fisheries reliant on the capture of a smaller run of inshore fish, consideration should be given to a reduction in the length of the nets which are permitted.

 Selectivity is affected by two issues beyond mesh size; hanging ratio and twine thickness. Both of these issues must also be covered by regulation.

o Hanging ratios: ‘When a mono net is purchased it arrives similar to a sausage with all meshes horizontally stretched closed and generally measures 100 metres. This is then attached to a headline and footline measuring less than the fully stretched netting to allow the meshes to hang open vertically. Traditionally, 100 metres of stretched netting would be hung on 66 metres of headline/footline – set by 66%. More recently, setting ratios appear to be nearer 50% with a lot more slack in the netting and far less selectivity.’55. For all netting, the ratio should be set via regulation at 66% as previously practised.

o Twine thickness:‘…thinner twines [are] less stiff and more supple or soft so that combined with a slackly hung net, fish are more likely to become entangled and captured by being retained by their various body protuberances, teeth or jaws, rather than conventionally gilled."56. Local IFCA byelaws should aim to increase twine thickness where needed.

 Numerous net fisheries are Marine Stewardship Council (MSC) certified, e.g. the Thames herring drift net fishery, as well as netting for mackerel and herring in Hastings. The Dover Sole gillnet fishery in Hastings is also MSC certified. Regulating netting for bass could also be sustainable at a stock level in the long-term, providing high value and quality fish. But in the short to medium term, restrictions are needed.

 Gear modification funding to adapt to the new regulations could be covered in part by the European Maritime and Fisheries Fund (EMFF). This will require bids written by regulators and fishermen in partnership with research bodies such as the Centre for Environment, Fisheries and Aquacultural Science (Cefas).

4. Limit landings Overall landings for bass need to be limited, as the stock level impact from targeted and mixed fisheries (including those which may be termed ‘mixed’ but are effectively ‘targeted’ bass fisheries) are unsustainable.57 The UK Government and regional regulatory bodies (IFCAs) must ensure that weekly catch limits are set using the precautionary principle and in-line with scientific advice. We need to assure a 60% reduction in mortality (F), and as suggested above, the 1.5 tonnes per week per commercial vessel, should contribute to that total. However, for vessel limits to be considered to effectively reduce (F) for bass, the spatial distinctions of the bass stocks and corresponding sub- populations need to be considered. In the first instance an overall reduction in vessel catch limits is necessary, which can be refined on a regional or local basis and would likely have to be reduced further to achieve a reduction in F as a standalone measure.58 Limiting landings per vessel to 1.5 tonnes per week is an urgent first step which would allow fishermen to remain active and to make a living, while significantly reducing their impact on the stock. Maximum monthly landings should be limited to 5 tonnes per vessel as a license condition which is reviewed in-line with scientific advice.

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The following data comes from Cefas (‘The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012) and shows how a wide variety of fleets catch bass, in all the southern regions of the UK– from the Celtic sea in the West, to the North Sea in the East. Taking this broad view on where and how bass are caught is important in terms of adequately managing all sources of (F) for bass in the short, medium and long-term to rebuild the stock.

‘The majority of English10m-and-over vessels that caught bass operated in the North Sea and Western Channel, with otter trawl being the most common gear. English under-10m vessels catching bass in the North Sea tended to mainly use gillnets or otter trawls, but gill nets or hooks & hand-lines were more common in the Western Channel. As may be expected, Welsh vessels caught bass mainly in the Bristol Channel, the Celtic Sea and in the Irish Sea, mainly using gillnets or hooks & lines, apart from five otter trawlers working in the Bristol Channel.’59

Species composition of landings of 10m-and-over vessels that each landed >500kg of bass in 2010.

o North Sea: for drift nets ~60% of catch is bass, for gillnets bass comprise around ~15%, and others (e.g. otter trawl, pair trawl, scot seine) bass represents ~5% of the catch. o Channel & E-Channel: Hooks and drift net catches are around ~80% bass, for pair and otter trawls, bass catches comprise under 10% of total. o W-Channel: pair, otter and twin trawl all catch bass, comprising 10% or under of the total. o Bristol Channel: otter trawl catches comprise around 50% bass.

Species composition of landings of under-10m vessels that each landed >500kg of bass in 2010.

o North Sea: those fisheries where bass represents above 50% of catches include; drift, gillnets and hooks, trammel and otter trawl. Other fisheries which include otter, gillnet, drift and gillnet, gill and trammel, long-lines catch 20–40% bass (some polyvalent gears have a major cumulative impact - see footnote 36). o Channel and E-Channel: bass catches as high as 80% for hooks and gillnets, 90% for vessels using hooks and around 50% for otter trawls and gillnets. All other gears report catches of bass representing 20% or less of the total. o W-Channel: Catches of around 50% of bass for gillnets; gillnet and hooks, gillnet and otter trawls ~30% of catch is made up of bass; for vessels using hooks bass comprise 10% of catches. o Bristol Channel and Celtic Sea: 80% of catch is bass for vessels using hooks; 60% of catch using hooks and gillnets; and bass make up around 50% of catches using gillnets [120/220/110], and around 60%for gillnets [230] catches. o Irish Sea: bass catches by gillnet are around 40%; for hooks and gillnets bass catches are around 20% of total, and for gillnets and beam trawl bass catches are around 35% of total.

 As the details from Cefas (2012) above makes clear, the impact on bass comes from a wide variety of vessels and fleets, in terms of regions they operate in, the gear type(s) they use, and the varying percentage of bass that makes up their catch. However, it is clear that the cumulative impact on stock levels from such a wide range of fishing efforts and by both targeted and bycatch fisheries that the next step in terms of management, must be to bring catches of bass under control from all of the above fisheries in all regions.

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 This is also true with regards to landings (retained fish) from recreational fisheries. Recreational fishing mortality must be substantially reduced and the EC recommendation of a 3 fish per angler, per day bag limit60 should also be adopted in the UK – this must include spearfishing for bass. To ensure retained bass are not then sold on an illegal commercial basis under the guise of recreational fishing, we suggest the UK should go beyond the proposal to amend Regulation (EU) 2015/104 and legislate or use local Inshore Fisheries and Conservation Authorities (IFCA) byelaws. This is so that all retained bass caught in recreational fisheries are fin clipped1 to identify that they have been caught recreationally and to make onward sale traceable and thereby impossible.

As we discuss in detail below in the section on TACs/quota – the consistently most effective means of reducing (F) is through limiting catch via quotas. When quotas are in-line with scientific advice, these have been shown to be the most effective means of reducing fish mortality and increasing stock biomass. Any TAC for bass should also include recreational fishing as they cumulatively have a significant impact at stock level. As ICES states ‘the fishing mortality needs to be reduced. The stock is likely to decline further in the short term due to recent low recruitment. In the longer term, management of sea bass fisheries could take into account the objectives and the economic and social value of the commercial and recreational fisheries that share the resource, adopting a common methodological approach to estimate the value of each fishery.’’61

5. Expanding the level and extent of protection of nursery areas Currently, ‘...the nursery areas comprise river estuaries, harbours and power station outfalls where juvenile bass usually predominate and are more easily caught, particularly during the summer months. In certain nursery areas, fishing may also be subject to other restrictions implemented by the local sea fisheries committee or the Environment Agency. Such restrictions may include prohibitions on the setting of fixed nets or restrictions on the use of mobile gear. The prohibition on bass fishing in nursery areas does not apply to fishing from the shore. However it is expected that shore anglers and their associations will respect the need for this prohibition and return to the sea any bass caught within nursery areas’62.

Expanding the level and extent of protection of nursery areas, including incentivising recreational anglers to avoid these areas altogether for bass around the UK coast, and pushing for these measures to be adopted by all EU Member States, is a crucial part of ensuring diverse classes of bass. Cefas have written extensively about the need to protect nursery areas, and our recommendation is to increase the level and extent of that protection and ensure any fishing for bass in nursery areas is seasonally restricted and on a catch-and-release only basis.63 Appropriate IFCA regulations for nursery areas should be determined on a local basis.

As the UK’s 3rd Natural Capital Committee (NCC) report states: ‘Intertidal habitat creation to meet objectives set out in Shoreline Management Plans. These areas provide a wide range of benefits including coastal flood protection (and can reduce costs of maintaining concrete defences), carbon storage, areas for wildlife and the provision of nursery grounds for important commercial fish stocks’.64 We recommend the UK follows the NCC advice to restore saltmarsh habitats as a priority (where applicable, e.g. Chichester harbour) due to its contribution to the expansion of suitable nursery area habitat for bass.

1 Carcass tagging could also be introduced. For further discussion see Annex 6. 15

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6. Permanent prohibition of pair trawling during spawning season Prohibiting pair trawling during spawning season in all ICES areas where bass are known to spawn until stocks have recovered – not just during 2015 – is a logical and urgent step. This ban should not be a one-off, but the first step towards a responsible, long-term vision for improving and maintaining bass stocks at levels capable of producing MSY (Maximum Sustainable Yield). Seasonal closures need to continue and cover all areas so as not to displace all efforts onto Eastern English Channel, the Bay of Biscay, and the Portuguese coast. It should also include all EU fishing fleets.

 We propose an extension of the trawl ban from December to April permanently. The emergency measures make it clear that further fishing of bass during spawning season, and in the spawning aggregations in the Western and Eastern Channel, is no longer acceptable due to its impact on the spawning stock. Bass actually start spawning in December, so the ban should be brought forward to protect bass throughout their spawning season and range. The emergency measures65 should be carried forward in the form of a permanent ban on pelagic trawling for bass, which must also address demersal trawls which are effectively fishing the entire water column (i.e. pelagic) as noted above with regards to Sussex. These measures should form a long-term management plan and enable spawning stocks to reproduce, unaffected by fishing pressure. The UK must address the categorisation issues of pelagic and demersal trawls and push for more comprehensive wording in the EC proposals for measures and management going forwards.

 As the EC working document states, ‘[I]n order to alleviate effects for the pelagic trawlers, which would be mainly concerned by the emergency measures, aid for temporary cessation of fishing activities is available, both under the EFF and under the EMFF. Both the EFF and the EMFF envisage temporary cessation aid precisely in order to bridge temporary emergency measures; this is one of the purposes of this financing instrument. The initiative to use such aid would need to come from the Member States concerned’66.

7. Adequate resourcing According to the Natural Capital Committee, with regard to fisheries, ‘Persistent overfishing drives down underlying stocks and diminishes the returns that can be generated from the stock which remains. Paradoxically, the unfavourable current situation means that there are likely to be substantial benefits from better management of that stock. But there are risks too. If current stocks become too low, the chance of irreversible collapse is all the higher. This would remove perhaps permanently, the option to enjoy these increased benefits in the future.’67 This is certainly true of bass. Restoring bass stocks will require investment2. We need to aim for a stock which is rebuilt and can deliver long-term benefits to all stakeholders. To make this possible we need a number of commitments from the UK Government which will demonstrate they are serious about restoring the bass fishery. Commitments must include adequate resourcing to Defra, the MMO and IFCAs so they regulate the fishery and take a proactive role in regulating sea angling for bass. To make it easier for Defra to regulate the bass fishery, help recover the stock and help IFCAs set up regionally appropriate management we need to double the financial support from central Government made available to them68. As the Impact Assessment prior to creation of the IFCAs showed, they actually require twice the resources they now have at their disposal69. The challenge they face and the responsibility they have is however increasing.

UK specific measures should explicitly support the role of the Marine Management Organisation (MMO) and IFCAs to protect bass. It should also fund Cefas to conduct much needed research,

2 Alternative funding options, such as ‘user pays’ are described in Annex 7. 16

17 New Economics Foundation (NEF) Working paper on bass

focussed on addressing stock level issues. Measures should not only focus on the distribution of access to a declining stock as that will not solve the main problem: mortality as a result of all forms of fishing/mortality for bass.

The budget for IFCAs and other relevant bodies needs to be increased to enable them to carry out this urgent work on bass.

Aside from the regulatory and enforcement functions of IFCAs, three specific areas of further work also need adequate resourcing: Illegal, Unreported and Unregulated (IUU) Fishing Clearly, the issue of IUU (illegal, unreported and unregulated) fishing is a serious problem for bass (as it is a non-quota, high value species with a substantial targeted recreational fishery) for both data reliability and illegality. ‘STECF observes that the landings statistics from the commercial fishery are uncertain due to the likelihood of underreporting. Unreported removals are associated with the allowances under article 65(2) of the EU Control regulation 1224/2009, which permits disposal of up to 30kg of fish for personal consumption without supplying sales slips and article 14, which exempts the mandatory recording in logbooks of catches of all species less than 50kg . For small-scale, low- volume fisheries catching sea bass, this legal missing catch could be significant.70 The uncertainty in the landings statistics due to underreporting should be taken into account when making decisions regarding management. Data-reporting requirements should be extended into the bass fishery, alongside resources to collect and analyse data in a meaningful way.

The clearly significant illegal fishing effort by individuals and groups ‘fishing at commercial levels under the guise of RSA [recreational sea angling] and selling the fish to a variety of outlets, [shows] there is an immediate need for much improved enforcement throughout the supply chain’.71

This issue could be tackled by legislating mandatory fin clipping for any retained bass (up to a maximum of 3 per day). As Cefas have pointed out, the UK’s Salmon Act 1986 relating to the possession of fish could be reviewed and similar legislation applied to bass as well.

Adequate resourcing to investigate IUU fishing that enables managing authorities (IFCAs) to draft byelaws and mount legal cases when commercial activity is being conducted in an unlicensed manner is crucial. Resources to run public awareness campaigns on ‘’clipping’’ for anglers (see section on recreational angling below) is also necessary to combat IUU fishing of bass. Data collection and knowledge gaps In addition to the necessary data to fill the knowledge gaps concerning IUU and the legally unreported small quantities of bass (see Annex 6), there are other data issues which need to be tackled.

Lacking data on the full impact of recreational fishing and the survival rates of fish that have been released, is a key priority to ensure that recreational angling for bass can be a high income, low impact part of the fishery. This will only be possible when the wider impact of recreational fishing practises can be quantified and regulated accordingly.

There is a lack of dedicated funding in the European Maritime and Fisheries Fund (EMFF) for data collection on bass. Defra should include funding for bass research in its Operational Plan for the EMFF. This should include resourcing for Cefas, IFCAs and other bodies to conduct in-depth research into bass mortality as a result of recreational angling among other currently under funded research areas.72

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Funding the Solent survey Since 1981, Cefas has carried out trawl surveys each year in the major estuaries along the Southern coast of England. These surveys cover the Solent, Southampton Water, Langstone and Chichester Harbours; these areas include the most important bass nursery areas on the south coast of England.73

Funding was cut last year for the Cefas Solent Bass Survey,74 the only survey capable of showing the structure of the pending year classes. This is critical information for long-term fisheries management as it can present data on survival, recruitment and the impacts of environmental conditions on the bass stock. Without this survey a major part of the evidence base for making long-term management decisions will be absent. For example, the average sea temperatures in 2014 were higher than the previous years and therefore it appears that environmental conditions are improving for bass. This could have contributed towards the number of very young bass recorded in the Solent trawl survey conducted by Cefas in September 2014.75 This could mean more bass for the subsequent year classes, which is good news, but we still need to reduce mortality and fishing pressure on bass stocks.

Providing funding for the Solent survey on an annual basis and ensuring that other major estuaries can be surveyed and incorporated into survey plans for all relevant IFCAs and Cefas is an essential component of being able to understand and manage the resource.76 Researching and regulating the impact of displacement Displacement of fishing effort as a result of bans in certain areas and seasonal and spatial restrictions is a serious concern for fisheries management. Defra, the MMO and IFCAs must be adequately resourced in terms on financial support, staffing and expertise in order to plan for possible displacement scenarios, and to employ adaptive management to reduce negative socio-economic or environmental impacts.

To help consider possible displacement scenarios, we have modelled possible displacement impacts using the dynamic heat map tool described in Annex 4. This tool has been specifically tailored to commercial bass landings and is available on request.

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Discussion From Emergency Measures to long-term sustainable and equitable management

Before the management plan called for by ICES is written and implemented, the emergency measures need to be enforced to halt the significant reduction of spawning stock biomass. Emergency measures should provide the UK and the EU with the necessary space to reach agreement on a long-term management plan to move towards re-building bass stocks.

The development of a management plan will require compromise with different sectors and could set an example to other Member States to follow. As the reformed CFP gives responsibility to both Member States and the European Commission, a serious risk of inaction presents itself as there is no clear line as to who takes responsibility for the decision. If the entire decision-making process is left to EU level discussions, it will take years to formulate and agree. The UK needs to take responsibility and live up to the stated ambitions of our politicians (see endnotes) – this includes setting out clear roles, responsibilities and committing funding and human resources to address this problem.

From a UK perspective, the economic costs associated with a ban on pelagic trawling are minimal (see economic analysis section in Annex 5). The request for emergency measures (Annex 2) may result in the loss of political capital vis-à-vis France, and could have a detrimental, long-term impact on cross channel collaboration. While, clear that the pelagic trawl ban will have a positive effect in terms of the protecting the spawning aggregations throughout the range, it will not necessarily have an impact on other fleets which catch bass as a major bycatch, or on those that target bass throughout the year, or with other gear (most significantly drift and fixed netters).

A major issue from a UK perspective is how to regulate netting effectively and introduce regulations that will reduce the amount of bass bycatch in other (mainly trawl) fisheries. Ensuring that the management plan is coherent through IFCA districts, and applies from both 0-6nM and 6-12nM regardless of which regulator (MMO or IFCA) is given responsibility (and adequate resourcing to undertake the work) will be challenging.

‘’For the great majority of English vessels that recorded catches of bass in 2010, bass was a relatively small part of the annual landings. For 805 out of 1107 under-10m GBE vessels and 233 out of 237 10m-and-over vessels, bass contributed less than 10% to their total annual landings. However, for 130 under-10 m English vessels, bass comprised more than 50% of their total annual fishery landing. The Welsh fleet had a greater dependency on bass, with 61 out of 96 under-10 m vessels having catches in which 75% of the total annual landed weight was bass.’’77

The costs associated with new regulations for netting may be badly received by some of the fishermen affected. But the reality is that if effective regulation and management do not begin imminently, there won’t be a bass stock big enough to sustain the expected level of production to derive any future benefits from. After years of environmental and human pressures on the stock, we can’t afford to take a short term view –we need to look at stock level solutions.

It is worth remembering again that netting is important to the UK inshore under 10m vessels fleet. The value of netting is significant and although the current fishing effort is unsustainable at a stock level

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(51% of landings – see economic analysis section below), following recovery, this high inshore value could be captured sustainably.

‘Of the 1107 under-10m English vessels that landed bass in 2010, 635 vessels each landed less than 100kg of bass. The total first sale value was £124,000 (2.4% of the total first sale value of bass for the under-10m fleet), and each vessel earned an average of only £196 for its bass. In contrast, 61 English under-10m vessels each landed between 2 – 10tonnes of bass in 2010, earning a total of over £1 million, with each vessel averaging £25 000 per year for its bass. Almost 50% of the first sale value of bass in 2010 was from the 114 English and 11 Welsh under-10m vessels that each caught between 1 and 10tonnes of bass.’78

Netting can be a highly selective and sustainable type of fishing with a low environmental impact and high social value. But the regulation of mesh sizes, the length of nets, and number of fleets is essential for the cumulative impact to be sustainable at a stock level. Netting can also be a fuel- efficient means of fishing.

Article 17 of the reformed CFP - Criteria for the allocation of fishing opportunities by Member States ‘[w]hen allocating the fishing opportunities available to them, as referred to in Article 16, Member States shall use transparent and objective criteria including those of an environmental, social and economic nature.’79

Following the logic of CFP Article 17, we should be allocating commercial fishing opportunities exactly to those fleets. Only, if those fleets are fishing towards MSY level exploitation, can we begin to think about allocating opportunities to those who provide high socio-economic value. If current cumulative trends continue there won’t be a bass fishery left in the channel for which to determine fishing opportunities.

We have to use the space created by the emergency measures to come up with the long-term, workable and equitable solution in line with the reformed CFP. This means distributing opportunities to those who create best value to society (Art 17 – see below) and ensuring that the stock level is recovering towards MSY (Art 2).

As ICES and indeed the Advisory Councils (ACs) have suggested, a comparison of the socio- economic benefits of recreational fishing versus wild capture, using the same criteria, should be considered by the Commission.

21 New Economics Foundation (NEF) Working paper on bass

Using TACs and Quota (Article 17) as a solution

Bass is not a quota species at present. But looking at how some species have fared as a result of total allowable catches (TACs), maybe bass should be put forward as a quota species after-all? Looking at Figure 6, we can see that EU quota and fisheries management measures have had a positive impact on fish stock biomass overall: fishing pressure has been reduced and the average stock biomass has increased.

This has not happened for bass due to a lack of management as new regulation, enforcement and adequate resourcing of regulators has been lacking. This is also a result of fishing pressure combined with the environmental factors described in the ‘fisheries context’ section.

Just a brief glance at the average stock biomass graph for 85 major fish stocks (Figure 6), compared to the downward trajectory for bass surely makes the case to start discussing the impact a quota system (following Article 17 and ensuring that fishing opportunities or quota go to those who demonstrate best value to society and the environment) could have on bass stocks.

ICES (2014) advice stated, ‘the total allowable catch (TACs) should therefore be established, in line with Regulation (EU) No 1380/2013, on the basis of available scientific advice, taking into account biological and socio-economic aspects whilst ensuring fair treatment between fishing sectors, as well as in the light of the opinions expressed during the consultation of stakeholders, in particular at the meetings of the Advisory Councils.’80

Figure 6: Comparison of bass trends with other major North East Atlantic fish stocks.81,82,83

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Why the UK reluctance towards a quota system?

There are two main obstacles regarding a quota for bass84:

1. As George Eustice put it in Parliament: ‘Initially, the European Commission suggested a total allowable catch for bass, but we firmly believe that that is not appropriate because a new TAC is established on track records of catches, so there is a real danger that that would simply lock in a continuation of the current exploitation pattern, which now needs to change radically. A further disadvantage of setting a TAC for bass is that it would take no account of the efforts a number of member states have already unilaterally taken to limit commercial catches, which would be unfair to those countries.’

However, because of the reformed CFP quota now may be allocated along transparent social and environmental criteria (Article 17), rather than track record (‘relative stability’).85

Bass should be the first TAC not based on relative stability. When it comes to stock decline as severe as that suffered by bass in recent years, we need new solutions. This should be Article 17 in practise. We need to think about pragmatic, workable solutions. Article 17 now provides Member States with a great opportunity to allocate quota or fishing opportunities in a way that is aligned with the public interest.

2. Converting bass to a quota-managed species, would pull it under the landings obligation (or ‘the discard ban’), presumably since the start of 2015 since it is caught in pelagic fisheries as discussed above. Given the current concerns from government86, industry87, scientists and NGOs88 about the pelagic discard ban which came into effect on January 1st, the addition of another species to the list of those caught in mixed fisheries is an unpopular option.

Under Article 17, Member States “shall endeavour”89 to provide incentives to vessels to use more selective gear or gear with a generally lower environmental impact. Recreational angling, commercial hook and line fishing, as well as gill and drift netting would qualify as ‘low impact’ compared to pair, pelagic, otter or demersal trawling – but how can the reformed CFP be used to incentivise this? Impacts on unwanted bycatch species are reduced in the static gear and hook and line fisheries, and there are limited or reduced impacts on the seabed compared to mobile gear. Any more selective gear, with a lower environmental impact, should be favoured according to the reformed CFP as part of addressing environmental criteria (discards, impacts on seabed, bycatch, fossil fuel use etc).90 In terms of the importance of bass to the inshore fleet the number of jobs and active fishermen who rely to some extent on catches of bass means it ranks as a high value species when considering its contribution to employment in fishing. This socio-economic value needs to be safeguarded through rebuilding the stocks.

23 New Economics Foundation (NEF) Working paper on bass

‘Best value’ According to the Natural Capital Committee’s 3rd state of Natural Capital report: ‘Wild fisheries are an important resource that are not all being managed with a view to long-term sustainability. The gains from improving commercial fish populations could be as much as £1.4bn to the economy per annum. Achieving this across all fisheries in the UK could increase resource rents by approximately £570m per annum, ten times more than their current value’.91 It is clear that a restored and sustainably fished bass stock makes economic sense, but how do we ensure that we get the most out of the bass resource once it has recovered?

NEF’s “best value criteria” approach was advocated during the reform of the CFP in ‘Value Slipping through the Net’ – a study comparing trawling and gill-netting for cod in the North Sea using social and environmental criteria. This showed that fishing using gillnets had a lower environmental impact and employed more people per tonne of cod landed, but were disadvantaged both in terms of cod quota and direct subsidies. Following Article 17 of the reformed CFP the EU should use transparent criteria to allocate resources in the public interest. In the case of bass this could be to the highest value fleets and sectors with the lowest environmental costs. Once bass stocks recover, this approach to managing fisheries in the public interest should apply to commercial hook and line fisheries, inshore net fisheries and recreational fisheries.

We have discussed the need for good data, good management, proper funding for enforcement, the need for EU-wide measures that will impact the whole stock. What is certainly needed in order to advance the ‘best value criteria’ approach is better data. Without reliable data on the survivability of bass caught by recreational anglers or in drift or fixed nets, a rigorous assessment of the impact on the stock by these forms of fishing will not be possible.

Commercial fishing

Cefas (2012) produced a detailed report outlining the value of the bass fishery to the UK fleet. The total landed weight of bass by UK vessels comprised 719 tonnes. ‘The total first sale value for…bass [was] just over £5 million. The largest economic return of bass was for the under-10m fleet…Bass were caught at least once in 2010 by 60% of under-10m vessels and 50% of 10m-andover vessels in the UK fishing fleet. However the bulk of the catch was taken by a much smaller number of vessels, predominantly in the under-10m fleet. This reflects the more inshore distribution of bass during most of the year’’92 It is clear from Cefas work and from reports produced by IFCAs 93 around the UK that the highest socio-economic value for bass accrues inshore.

In France, for example, ‘Sea bass fished by small-scale fishermen who use lines/hooks is a high value product ("bar à la ligne"). Bass caught in that way has a much higher sales value (16.67 euro/kg in France 2013), appr. twice the value than bass caught by trawlers. Pelagic trawls on spawning aggregations yield the lowest prices (7.37 euro/kg in France 2013; see annex). Pelagic trawling may also be responsible for pressure on overall prices: during the first quarter of the year, when pelagic trawlers target sea bass on spawning grounds, average prices are half as low as during the rest of the year.’94 Commercially caught bass by hook and line represent the highest value from the resource, as the EC working document95, MRAG study96 and SW Handlining97 for mackerel have shown.

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Recreational fishing

Sea Angling 2012 ‘…estimated that in 2012, recreational angling in England supported 10,400 fulltime equivalent jobs and, taking into account indirect and induced effects, sea angling supported over 23,600 jobs.’98 Bass is also one of the most prized species for recreational sea angling in the UK, with specific associations such as B.A.S.S., dedicated solely to bass fishing. A recent MRAG report makes some interesting economic assertions about the value of recreational fishing, particularly for bass. The MRAG case study99 shows the value of recreational bass fisheries in Sussex are three times higher than commercial fisheries for reduced environmental and stock impacts, while also employing more people suggesting ‘fish should only be caught with hooks’100(more economic return for lower impact on stock and marine environment). Sussex landed 247.58 tonnes101 of bass in 2012, a considerable percentage (above 20%) of the total of UK commercial bass landings and was chosen as a case study region.102 ‘The conclusion drawn by BLUE, which funded the study, is that it would be better both economically and environmentally if the commercial fleet converted to charter angling and rod and line fishing, making bass a recreational species as it is in Ireland.’ 103

This helps further demonstrate that the highest value for bass is accrued inshore and that recreational fishing for bass is a high value activity.

There is a substantive problem with control and compliance in terms of IUU (Illegal Unreported and Unregulated) and “black market” sales, which includes both unlicensed illegal commercial activity and legal, unrecorded sales (see Annex 6) – specifically highlighted in both the ICES June 2014 advice on sea bass and the STECF plenary report, July 2014. The EC proposal of 3 bass per angler, per day is actually more generous than the 2 bass per angler, per day proposed by the UK and EAA. Ensuring that any retained bass are clipped to avoid IUU fishing for bass is a key step towards ensuring that value is only captured by licensed fishermen. Discussions around a catch and release only fishery for bass during the spawning season should also be seriously considered to minimise the impact on bass through recreational fishing. Fines could be imposed for any retained bass to ensure compliance.

Distribution of access to the resource

As ICES clearly states: ‘The fishing mortality needs to be reduced. The stock is likely to decline further in the short term due to recent low recruitment. In the longer term, management of sea bass fisheries could take into account the objectives and the economic and social value of the commercial and recreational fisheries that share the resource, adopting a common methodological approach to estimate the value of each fishery.’’104

Both commercial and recreational interests have an impact at stock level – and both need to be incorporated into a management regime. If there was a quota for bass, that would be the correct time to assess the social and environmental impact of recreational angling, commercial hook and line fishing, as well as netting and trawling for bass.

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What do scientists say about commercial-recreational interests?

ICES advise that ‘[t]he implied total landings should be no more than 1155 t. ICES has no basis for advising on the allocation of the advised landings to commercial and recreational fisheries. The commercial landings corresponding to the advice will depend on the recreational landings and vice versa.’105 For this reason the proposed bag limit of 3 fish per angler, per day should be introduced in the UK 0-12nM zone in order to contribute to the remaining reduction in bass mortality called for by ICES. It has been shown conclusively that recreational angling contributes to bass mortality and therefore reducing the impact of angling must be part of the solution. ‘Including the recent recreational landings estimate in the stock assessment implies that recreational (F) could be almost 30% of the total fishery (F), although this proportion is uncertain and will vary over time according to the relative trends in commercial and recreational fishing effort on sea bass. A large percentage of sea bass are released by recreational fishers, but the mortality of the releases is poorly understood.’’ 106 As Annex 8 shows,

ICES also state the need for better data from all sectors and scales: data requirements must include recreational fishing. There is no time-series data to evaluate how variable the recreational fishing mortality of bass is over time. ‘There is a need to ensure adequate and representative sampling coverage of fleets catching sea bass, including developing regional time-series of recreational fishery catch, effort, and catch composition. Further studies using tagging, genetics, and other stock and individual markers are needed to more accurately define stock boundaries suitable for assessment and management purposes. Studies are needed to estimate the survival of recreationally caught and released sea bass’’107.

Starting a reporting requirement for recreational angling (such as exists for migratory species such as Salmon and Sea trout in the UK, may be a first step which anglers can take towards better data. It’s also something that the UK could legislate and push for within the EU as part of its proposals and negotiations.

It’s time for the UK to take the lead

The UK must follow scientific advice, which includes:

 Increasing the MLS108 across the board as it will bring immediate benefits. This must apply to commercial and recreational fisheries alike.  Regulating netting for bass in all UK waters.  Reducing commercial weekly landings to 1.5 tonnes and monthly landings to 5 tonnes per vessel.  Introducing a three bass bag limit and mandatory clipping of retained bass in recreational fishing.  Protecting and managing nursery areas.  Pushing for a permanent seasonal pelagic trawling for spawning bass from December to April at EU level.

The Government needs to adequately resource the regulators and scientific advisers in order to capture the long-term benefits and value from commercial and recreational bass fishing. This will

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include funding to ensure their ability to regulate, to enforce regulations and to carry out much needed research and effort into reducing IUU fishing of bass.

Ireland took the decision to ban commercial bass fishing in1990 now the MLS will be increased to 50cm and will include a bag limit. Holland is considering a 45cm MLS and bag limit, banning pair trawling and netting for bass, so the UK would not be alone in taking unilateral action. But learning from past mistakes, missed opportunities and thinking beyond perceived short-term losses are the only way this magnificent fish and the associated fishery and fishermen can protect their future.

European bass (Dicentrarchus labrax). Credit: Toni Llobet

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Notes What do or fisheries ministers and MPs think about this issue?

George Hollingbery (MP):

‘The current minimum landing size is an absolutely ludicrous 36 cm. That was set back in 1989, when even the Department’s own estimate said that the maximum sustainable yield for sea bass would be reached if the minimum landing size was 50 cm, yet still we sit here with the level at 36 cm…We have to drastically reduce the amount of fish taken. We have to allow fish to reach sexual maturity. We have to stop most, if not all, fishing in the spawning season. We have to do a better job of protecting and enhancing nursery areas.’109

Ben Bradshaw (former Fisheries Minister):

‘…when I was the Minister I took the decision to increase the minimum landing size, to 40 cm as a first step, then to 45 cm after a period of review. Tragically, however, that decision was reversed by my successor who, as is often is the case, came under pressure from the very powerful self- appointed commercial fisheries spokespeople.’110

Richard Benyon (former Fisheries Minister):

‘When you are a Minister, people tell you that someone cannot be prevented from doing something without enough evidence and judicial review, and that there are threats of infraction, and all the other things. However, I freely admit that if I had my time over again I would steamroller this through and take the consequences, because the consequence now is a crashing stock. The stock will disappear, along with the economic value.’111

Bernard Jenkin (MP):

'We have seen European law, human rights law and fear of judicial review take over the whole of government in some Departments—DEFRA may be one of the worst instances—but we expect our Ministers to govern.'112

Angela Smith (current shadow Fisheries Minister):

‘We need a better set of proposals from the EU than the one currently on the table. Although it is possible for member states to develop measures unilaterally, the impact of such measures is weakened by the grandfather rights on access to home waters that are enjoyed by some member states. That is why we need agreement at EU level. The ideal outcome would be a set of measures that all member states have to abide by, including short-term measures to halt the alarming decline in stocks while further research is undertaken and a long-term management plan is developed.’113

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Further reading

CFP basic regulation http://cfp-reformwatch.eu/wp-content/uploads/2013/06/2013-06- 14_Basic_regulation_on_the_CFP_final_compromise_text.pdf

IIEP and RSPB report on Art 17 http://www.rspb.org.uk/Images/IEEP_2014_Practical_implementation_of_CFP_Art_17_tcm9- 385886.pdf

CEFAS C-Bass project https://marinescience.blog.gov.uk/2014/06/16/conservation-seabass/

Defra have responded with a desire to fill as many of these outstanding knowledge gaps as possible and have funded “C-Bass“, a four-year bass research programme: ‘Population studies in support of the Conservation of the European sea bass’. Cefas are leading this project, working with stakeholders from the commercial and recreational fishery sectors. The C-Bass project is coordinating scientific research and data collection in several different areas. ‘By going back and analysing growth and distribution patterns in previous years, and applying sophisticated computer models to predict the dispersal of eggs and larvae from spawning grounds, C-Bass scientists hope to better understand how bass respond to a range of environmental factors. As a result, we can better predict how bass stocks will behave in the future, for example, in relation to rising sea temperatures.’ 114

Appendix

Annex 1: The EU management measures proposed on December 16th in council115

European Commissions proposed measures for 2015 Additional management measures at the EU level (i.e. for all Member States targeting bass commercially and recreationally) have been proposed by the European Commission for 2015 (EC, 2014). They are:

- Monthly catch limits (tonnes) and effort limits (days-at sea) between 1st January – 30th April for pelagic trawls with a track history of catching bass with a cod end mesh size greater than 80 mm in ICES division VIIe (Western Channel).

This would apply to all EU vessels with a track history of catching above a certain tonnage (still to be defined) in the area for the period from 1st January to 30th April 2014.

- Restrictions on access to ICES division VIIe for any pelagic trawl between 1st January – 30th April if the vessel has no previous track history of fishing in VIIe between 2009 and 2011.

Access may be granted to a vessel in the period if the Member States ensures that the equivalent capacity, measured in kilowatts, is prevented from fishing in the area. Conditionality’s for the transfers of days at sea between vessels for this purpose are detailed in the proposed regulation.

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- Bag limits for recreational fishermen. A bag limit of only one bass, per person, per day (Article 12). The limit will foreseeably apply to anglers and other recreational fishers e.g. nets and pots and to spearfishing.116

Annex 2: Defra request for EC Emergency Measures

Accessed on December 22nd from Le Marin: http://www.lemarin.fr/secteurs-activites/environnement/20497-bar-le-royaume-uni-demande-des- mesures-durgence http://www.lemarin.fr/sites/default/files/2014/12/22/draft_sea_bass_art_12_email_19_12_14.doc

Sea Bass: UK Request for measures under Article 12 of the CFP Regulation

At this week´s meeting of the Council we were not able to agree measures to protect the seriously threatened stock of sea bass. However, there was included in the final compromise an important statement which underlined the commitment of the Commission and the Member States involved in this fishery to do the utmost possible, as of the start of the fishing season in January 2015, to reduce fishing pressure, protect spawning aggregations and so prevent a collapse.

The Commission has noted there is a particular imperative to protect spawning aggregations, which occur during the January to April season, with especially strong concentrations in the Western Channel (area VIIe). Consistent with the statement included in the final compromise, this requires urgent action to address the threat to these fishery spawning aggregations posed by pelagic trawling for bass from the start of January. According to the ICES advice, in 2013 this fishery accounted for 37% of all commercial catches.

In line with the commitment made at Council, the UK stands ready to work with the Commission and the other Member States involved in this fishery to take measures to protect this stock from the start of January 2015. Given the urgency of the situation, we are hereby making a reasoned request, under the terms of Article 12 of the CFP Regulation (1380/2013), for the Commission to adopt emergency measures to alleviate the serious threat to the sea bass stock. To reduce fishing pressure by protecting the spawning aggregations the UK proposes the adoption of measures to close area VIIe to pelagic trawlers targeting bass during January to April 2015. This is consistent with the focus of the Commission´s original proposal in the TACs and Quotas regulation.

Should it be possible to identify an alternative and equally viable approach to protect the spawning aggregations from the start of the fishing season in January 2015, the UK would be willing to assist in developing such an alternative and, on implementation, withdraw this request.

Further action will be required to address additional sources of mortality on the sea bass stock from other commercial fisheries and the recreational sector ahead of those fisheries taking place later in the year. We are already looking at ways to reduce the pressure exercised by these sectors on bass stocks in domestic waters, as part of our approach to promoting a more sustainable fishery. However, the need to take urgent action from January 2015 to protect the spawning aggregations justifies the use of emergency measures under Article 12.

In support of our request we would refer the Commission to the ICES advice on European sea bass and the 46th Plenary Meeting Report of the Scientific, Technical and Economic Committee for Fisheries (Plen-14-02) from July 2014 (and the accompanying technical paper below). For ease of reference, the main ICES and STECF reports can be found on the following links: http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14- 02_Final+Report_JRC91540.pdf

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I am copying this request to other Member States with a fishing interest in VIIe (France, Netherlands, Belgium and Ireland). I am also copying this to the Chair of the North West Waters Advisory Council. In line with the procedure outlined in Article 12 of 1380/2013, they have seven working days to submit any written comments on this proposal, that is by 2 January 2015. A Commission decision on whether to adopt these measures with immediate effect is then expected by 14 January 2015.

Should the Commission or other Member States wish to discuss this further, please contact Roy Smith ([email protected], +44 207 238 1245) or Andrew Randall ([email protected], +44 7715 989411) in the first instance.

John Robbs, UK Fisheries and Marine Director, London, 19 December 2014

Annex 3: EC announcement of Emergency Measures

Commission to adopt measures to protect sea bass stock

(19/01/2015) The European Commission has announced a package of measures aimed at averting the collapse of the declining sea bass stock. In the first instance emergency measures will be implemented to ban pelagic trawling of sea bass during spawning season which runs until the end of April.

(26/01/2015) The European Commission has announced measures to avert the collapse of the declining sea bass stock. Immediately effective emergency measures will place a ban on targeting the fish stock by trawling while it is reproducing, during the spawning season, which runs until the end of April. This will be complemented by further measures to ensure that all those who fish sea bass make a balanced and fair contribution to saving the stock.

The pelagic trawling ban is a critical first step in this package of measures. This ban will protect the stock from being targeted when at its most vulnerable – when the fish is coming together in shoals during the spawning season to reproduce.

The spawning season is already underway and will last until end of April. Pelagic trawling on is a major source of mortality and reduces the spawning stock as it makes up 25% of the impact on the stock. With a reduced spawning stock further actions and any rebuilding of the stock would be endangered. The measure will therefore come into force immediately and last until 30 April 2015. It will apply to the Channel, Celtic Sea, Irish Sea and southern North Sea.

Commercial and recreational fishing In order to help the stock of sea bass recover, more action is needed to address the impact of all other commercial and recreational fishing activities.

Therefore the Commission is currently making a renewed and urgent effort in order to help Council and Member States put in place a package of measures to manage commercial and recreational fisheries on sea bass more effectively.

For recreational fishing which accounts for 25% of sea bass catches, this would include a limit of three fish per day per angler. Member States would also need to set a minimum size of 42 cm so that fish are not caught, or are released, before they have reproduced.

For other commercial fisheries than pelagic trawling, this would also include limiting catches. The Commission is working with the Member States involved to prepare a proposal to the Council of Ministers as soon as possible.

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Annex 4: Dynamic heat map tool

In order to help provide evidence to the UK Government (MMO/Defra), DG MARE and IFCAs (fisheries managers/regulators) we have produced an excel tool which can produce ‘heat maps’. These graphics show bass landings in UK ports or bass caught by UK vessels (by either volume or value) for ICES statistical rectangles around the UK, relative to each other. The darker red the rectangle, the higher the relative bass landings. A number of these ICES statistical rectangles comprise one ICES fishing area.

The MMO publishes the landings data with the following description: ‘Data on fishing activity is taken from the IFISH data system. There are three key sources of data – the logbook of activity while at sea, the landing declaration recording the accurate weight of fish when landed, and sales notes created when the fish are first sold after landing. The finest available level of spatial resolution for activity data within IFISH is an ICES rectangle. Each rectangle represents an area of the sea that measures 0.5 degrees of latitude by 1 degree of longitude.117

The tool has a number of parameters which can be selected. One scenario in the tool could include up to five parameters at once:

Third of Variable Year Gear Gear Category Length Landed Weight Demersal (tonnes) 1st Active trawl/seine Over10m

The tool can show relative landings by: landed weight, live weight or value; by four month periods throughout the year (third of year/trimester); active or passive gear; gear categories (demersal trawl/seine, dredge, drift and fixed nets, pots and traps, hooks, beam trawl, other passive gears, pelagic seine; and over or under 10m length category.

Figure A below shows the total UK bass landings118 taken between January and April 2012 by over 10 metre demersal trawlers. It is clear from this example that the main UK trawling effort/landings are outside of ICES Area VIIe (and are focussed on the Eastern Channel VIId).

This serves as an example of how the excel tool can be used to examine the possible displacement effect if a particular area (although 4 potential stock areas exist119) is closed longer term/annually. The resulting heat map shows bass landings around the UK and can be divided between mobile/static, under/over 10m, volume/value and different gear types as is shown in the drop-down menu below. Figure A: UK bass landings (2012) from January-April by over 10m demersal trawlers.

Variable Third of Year Gear Gear Category Length Live Weight (tonnes) 1st Active Demersal trawl/seine Over10m

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For comparison, Figure B shows total UK bass landings for the same time period taken by drift and fixed nets under 10m in size. Figure B: UK bass landings (2012) from January-April by under 10m drift and fixed nets.

Variable Third of Year Gear Gear Category Length

Live Weight (tonnes) 1st Passive Drift and fixed nets 10m&Under

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Annex 5: Economic analysis - Using port landings data from the MMO (2013)120 Costs/impacts affecting the UK as a result of a ban on trawlers

Bass Landings by British Vessels Over Three Trimesters Vessel Tonnes of Percent of annual Time period Nationality landings landings

1st UK 149.39 19%

2nd UK 253.30 31%

3rd UK 402.81 50%

Total UK 805.50 100%

Conclusion: Of all the trimesters, the first is the one with the least impact on commercial landings FROM British vessels.

Costs at UK port level

Bass Landings in British Ports Over Three Trimesters Tonnes of Percent of annual Time period Port Nationality landings landings

1st UK 138.40 17%

2nd UK 255.06 32%

3rd UK 402.29 51%

Total UK 795.75 100%

Conclusion: Of all the trimesters, the first is the one with the least impact on commercial landings TO British ports.

Overall costs at UK level: UK vessels to UK ports.

Bass Landings in British Ports Over Three Trimesters Time Vessel Port Tonnes of Percent of annual period Nationality Nationality landings landings

1st UK UK 123.11 16%

2nd UK UK 252.33 33%

3rd UK UK 398.54 51%

Total UK UK 773.98 100%

Conclusion: Of all the trimesters, the first is the one with the least impact on commercial landings FROM British vessels TO British ports.

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Overall statistics on UK vessels bass landings

Bass Landings by British Vessels of Different Gear Types Gear Type Vessel Nationality Tonnes of landings Percent of total landings

Drift and fixed nets UK 408.09 51%

Demersal trawl/seine UK 197.19 24%

Gears using hooks UK 190.71 24%

Beam trawl UK 4.21 1%

Pots and traps UK 4.30 1%

Other passive gears UK 0.78 0%

Dredge UK 0.21 0%

Pelagic seine UK 0.01 0%

Other mobile gears UK 0.00 0%

Total UK 805.50 100%

Conclusion: Less than a quarter of the commercial landings by British vessels is by trawlers.

Annex 6:

An alternative/additional idea is for carcass tagging to be introduced for commercial landings. There are salmon fisheries in the UK and striped bass fisheries in USA where mandatory carcass tagging exists and no doubt much could be learnt from these experiences. The Handline Association http://www.linecaught.org.uk/ are already voluntarily fitting carcass tags so the practicalities of fishermen fitting them are not an issue.

The problem of bass being sold both illegally and legally where the landings data is not collected is serious and complex.

a) Bass sold from an unlicensed motorised vessel however captured [rod & line, nets, long line] are sold illegally.

b) Bass sold from a vessel without an engine [sail boat, row boat, kayak] may be sold legally providing they are not purchased by a Registered Buyer.

c) Bass captured from the shore [stake nets, spilter lines, seined, rod & line] may be sold legally to anyone including a Registered Buyer.

d) Bass captured and sold from a licensed vessel directly to consumers for personal consumption [i.e. not for re-sale as in restaurant or fish trader] is legal providing each transaction does not exceed 30 kilos. [no limit on number of transactions daily]

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e) Bass captured and sold from a licensed vessel to restaurants, pubs, fish traders, that are not Registered Buyers are sold illegally.

The cumulative weight of bass landings from above scenarios across the UK is likely very significant but apart from c) the landings data is being missed. Since the paper work for Register Buyers is designed to record data for vessels, it is highly likely that landings from scenario c) are also not being collected.

Summary courtesy of Malcolm Gilbert, January 2015. Annex 7:

Over the last four decades, numerous commentators have raised the issue of ‘user pays’. The Prime Minister’s Strategy Unit report ‘Net Benefits’ (2004) drew particular attention to fisheries management costing the tax payers approximately £13,000 per fisherman. The introduction of bass licenses for recreational and commercial exploitation (similar to salmon fishing licenses) would generate an income stream for investment and may well be an idea to take forward. The potential returns are very substantial and an example is the striped bass fishery where between 1986 and 1996 when stocks increased sevenfold due to highly restrictive management, the recreational fishery also grew sevenfold in both participation levels and economic/employment impacts. Summary courtesy of Malcolm Gilbert, January 2015. Annex 8:

The history of recreational angling mortality is that as a % of all mortality has been declining since 1985 [see figure from CEFAS below] against the correspondingly increasing proportion of fishing mortality from commercial fishing. According to ICES, data on commercial catches is likely to be a sever underestimate and analysis using more accurate data may reveal a lower estimated % of F attributable to recreational angling for bass: http://www.ices.dk/sites/pub/Publication%20Reports/Expert%20Group%20Report/acom/2014/IBP%20 Bass%202014/ibpBass_report_2014.pdf

‘The official reported landings of sea bass in the UK are known to underestimate the true total landings, particularly for small-scale inshore fisheries where there has been no requirement to submit EC logbooks. Prior to the introduction of Buyers and Sellers regulations in 2006 requiring sales documentation, local fishery inspectors estimated landings of the under-10 m fleet using whatever information they had available from auctions, and frequently entered aggregated estimates for multiple vessels into the fishery landings database. Unfortunately the Buyers and Sellers regulations do not cover all landings. Where a single landing has less than 25 kg of fish, it is not mandatory to have a record of the landing from sales slips or other documents. This is ostensibly to reduce the administrative burden for a skipper disposing of small quantities for personal use. However, for small-scale fisheries where there are very large numbers of small vessels often catching small quantities, the cumulative catch of unrecorded small landings can be relatively high. This is likely to be an issue over the full time-series. Due to the known inaccuracies in reported landings of such vessels, Cefas (UK) implemented an independent logbook scheme and port survey in England and Wales in 1985 to estimate mean cpue (annual landings per vessel, based on a logbook kept by selected skippers) and total number of vessels catching sea bass (from an annual port survey covering different stretches of coastline in successive years). Total bass landings were estimated as the product of cpue and vessel numbers. The scheme was stratified by area, gear and vessel

36 New Economics Foundation (NEF) Working paper on bass

characteristics. Selected vessels from the strata kept logbooks for periods ranging from 1 to 25 years, and comprised what could be described as a “reference” fleet as opposed to a randomised selection of vessels each year. The scheme is described by Armstrong and Walmsley (2012), who identified some issues with the survey related to over stratification and extensive imputation needed due to small and declining numbers of logbooks, and the non-random nature of vessel selection for logbooks. Sufficient logbooks were available only for inshore vessels using fixed/driftnets or lines. The scheme was terminated in 2007 and 2008, and reinstated for a further two years (2009 and 2010) before being terminated again. The scheme has now been sus-pended permanently. Despite the potential biases, the survey results for commercial vessels confirm that the historical official reported landings of sea bass are likely to be underestimates (Figure 2.2.1.2.1). For fixed/driftnets, the landings including the Cefas logbook estimates for under-10 m vessels results in a landings series that is on average around three times higher than the official statistics.’

Summary courtesy of Malcolm Gilbert, January 2015.

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Glossary (MMO, 2013)

Term Meaning

Demersal The term demersal fish covers species living on or near the sea bed.

Fishing areas are defined by international convention. The immediate waters around the UK are subdivided into ICES sub-areas IV (North Sea), VI (West of Scotland) and VII and its divisions the Irish Sea, VIIa; Celtic Sea, VIIg,h; Fishing areas Bristol Channel, VIIf; and the English Channel, VIId,e. See Appendix 3 of publication (http://www.marinemanagement.org.uk/fisheries/statistics/annual.htm)

Fixed gears are mainly used for demersal species. They are normally Fixed gears vertically hung curtains of netting which enmesh or entangle the fish, fixed to

the seabed with anchors or weights and held upright with floats.

Mass (or weight) of a product at the time of landing, regardless of the state in Landed which it has been landed. Landed fish may be whole, gutted and headed or weight filleted.

Live weight The mass or weight of a product, when removed from the water.

The term pelagic fish covers species found mainly in shoals in midwater or Pelagic near the surface of the sea.

Seining is a method used exclusively for demersal fishing. The net, lighter than for trawling, is set on very long ropes designed to herd or contain the Seining fish for capture in the net. After the fish have been surrounded by the ropes, the net is slowly hauled back to the vessel.

Shellfish The term shellfish covers all crustaceans and molluscs.

Trawling may be used either for bottom-dwelling (demersal) or mid-water Trawling (pelagic) species, the net being of a basic funnel-shaped construction and

towed behind a vessel or between two vessels (pair trawling).

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Endnotes

1 http://ec.europa.eu/information_society/newsroom/cf/mare/itemdetail.cfm?item_id=20186 European Commission, 2015 2https://nebula.wsimg.com/17ce16211194bfe53215bb754444686d?AccessKeyId=68F83A8E994328D64D3D&disposition=0&all oworigin=1 Natural Capital Committee 3rd state of Natural Capital Report (2015). 3 http://ec.europa.eu/fisheries/cfp/fishing_rules/tacs/info/com_2014_670_en.pdf European Commission (2014) 4 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 5 Multi-criteria decision-making for fisheries management: A case study of Mediterranean demersal fisheries (2015) http://www.sciencedirect.com/science/article/pii/S0308597X1400298X 6 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES (2014) 7 https://marinescience.blog.gov.uk/2014/06/16/conservation-seabass/ Cefas (2014) 8 https://marinescience.blog.gov.uk/2014/12/19/c-bass-in-action/ Cefas (2015) 9 Ibid. 10 http://www.martins-seafresh.co.uk/buy-bass.html Accessed December 2014 11 https://marinescience.blog.gov.uk/2014/06/16/conservation-seabass/ Cefas (2015) 12 http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf STECF Plenary report (2014) 13 The Bristol Channel trawl fishery must be considered a directed bass fishery with discards of bass less than 36cm as high as 90% and averaging 30%. The description of gear used in this fishery within the Marine Stewardship Council accreditation report (http://www.msc.org/track-a-fishery/fisheries-in-the-program/exiting-the-program/withdrawn/Bristol-Channel-seabass/assessment-downloads-1/17.02.2011-Bass_Assessment_PCDR_140211_FINAL.pdf - it failed to achieve MSC accreditation) draws attention to the uniqueness of the gear that is designed specifically for bass. Likewise the trawl bass fishery that takes place off Sussex close to shore is a directed fishery. That a proportion of all bass landings from trawls do consist of fish taken whilst trawling for other species is not questioned but to simply state that all trawl catches of bass derive from a mixed demersal fishery must be considered incorrect. http://www.bluemarinefoundation.com/wp- content/uploads/2014/12/20141128-Final-Bass-Report-BMF-MRAG.pdf 14 http://www.msc.org/track-a-fishery/fisheries-in-the-program/exiting-the-program/withdrawn/Bristol-Channel-seabass/assessment-downloads-1/17.02.2011-Bass_Assessment_PCDR_140211_FINAL.pdf Chapter 4, page 17. 15 STECF (2014) ‘…a fishery involving around 30 French pair-trawlers, and smaller numbers of UK pair trawlers’. http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pd 16 Multi-criteria decision-making for fisheries management: A case study of Mediterranean demersal fisheries (2015) ‘policies aimed at reducing mortality rates of the most vulnerable species can achieve a high level of performance in the short run’ http://www.sciencedirect.com/science/article/pii/S0308597X1400298X 17 Effects of fishing during the spawning period: implications for sustainable management Harrie¨t M. J. van Overzee, Adriaan D. Rijnsdorp http://library.wur.nl/WebQuery/clc/1944153 18 https://www.gov.uk/government/statistical-data-sets/uk-sea-fisheries-annual-statistics-2012 MMO (2014) 19 http://www.ices.dk/marine-data/maps/Pages/ICES-statistical-rectangles.aspx ICES (2014) 20http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/en/agricult/146304.pdfhttp://www.consilium.europa.eu/ued ocs/cms_Data/docs/pressdata/en/agricult/146304.pdf European Commission (2014) 21 http://cfp-reformwatch.eu/wp-content/uploads/2013/06/2013-06 14_Basic_regulation_on_the_CFP_final_compromise_text.pdf Accessed December 2014 22 measures in the 12-200 nm zone could only apply to UK vessels if implemented unilaterally 23 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:354:0022:0061:EN:PDF European Commission (2014) 24 Defra (2014) see Annex 2. 25http://ec.europa.eu/information_society/newsroom/cf/mare/itemlongdetail.cfm?item_id=20186&subweb=343&lang=en European Commission (2015) 26 Malcolm Gilbert, personal comment, January 2015. 27 ‘In order to reach the objective of progressively restoring and maintaining populations of fish stocks above biomass levels capable of producing maximum sustainable yield, the maximum sustainable yield exploitation rate shall be achieved by 2015 where possible and, on a progressive, incremental basis at the latest by 2020 for all stocks.’ (CFP Article 2) European Commission (2014) 28 http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52011PC0425&from=EN European Commission (2014) 29 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:354:0022:0061:EN:PDF European Commission (2014) 30 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 31 ‘By-catches in demersal trawling also have an impact on mortality, but with the current selectivity measures available on the market it is not possible to avoid catching seabass in the first place. Therefore if demersal vessels catch sea bass the fish should be landed, as any obligation to discard would have no conservation effect for the stock at this point in time.’ http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 32European Anglers Alliance (EAA) Accessed December 2014 http://www.eaa- europe.org/fileadmin/templates/uploads/news/News_2014/EAA_EFTTA_IFSUA_bass_briefing_paper_13_Nov_2014_final.pdf 33 http://www.rspb.org.uk/Images/IEEP_2014_Practical_implementation_of_CFP_Art_17_tcm9-385886.pdf RSPB (2014) 34 Bass Management considerations - joint comments from the Low Impact Fishers of Europe [LIFE] & the New Under Ten Fishermen’s Association [NUTFA]. 2014. 35 ‘During the period of application of this Regulation, it shall be prohibited to fish for sea bass (Dicentrarchus labrax) in ICES divisions IVb,c, VIIa,d-k using pelagic trawls (referred to as OTM — midwater otter trawls, PTM — midwater pair trawls) with a cod end mesh size of 70 mm or greater.’ European Commission (2015) 36 http://www.bluemarinefoundation.com/wp-content/uploads/2014/12/20141128-Final-Bass-Report-BMF-MRAG.pdf (MRAG, ‘Defining the Economic and Environmental Values of Sea Bass’, report for Blue Marine Foundation, 2014)

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37 http://www.sussex-ifca.gov.uk/index.php?option=com_content&view=article&id=63&Itemid=159 (SxIFCA, 2011) 38 Available literature states that stern trawling and pair trawling are responsible for the majority of catches (SxIFCA, 2011) 39 ‘ICES has predicted that by 2016 the abundance of adult bass may fall close to the lowest previously observed which was in 1992. That is, unless the European Commission and Member States can urgently agree measures to substantially reduce the fishing pressure on the stock.’39(ICES, 2014) 40 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf (ICES, 2014) 41 Ibid. 42 http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf (STECF, 2014) 43 The current limit applies to UK and French vessels (5 tonnes per week/15 tonnes per month) Seafish, 2011. http://www.seafish.org/media/Publications/SeafishResponsibleSourcingGuide_seabass_201102.pdf. 44 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 45 Ibid. 46 CEFAS, 2012 ‘The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M. 47 http://ec.europa.eu/information_society/newsroom/cf/mare/itemdetail.cfm?item_id=20186 EC (2014) 48 http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf STECF (2014) 49 http://www.nifca.gov.uk/wp-content/uploads/2014/01/sa2012finalreport.pdf Sea Angling 2012. MMO. (accessed December 2014 via Northeast IFCA) 50http://ec.europa.eu/information_society/newsroom/cf/mare/itemlongdetail.cfm?item_id=20186&subweb=343&lang=en EC (2014) 51 http://www.cefas.defra.gov.uk/publications/lableaflets/lableaflet75.pdf Cefas, 1995. 52 http://www.piscoweb.org/files/file/science_of_marine_reserves/SMR_EU-HR.pdf PISCO ‘Science of Marine Reserves’ accessed December 2014. Partnership for Interdisciplinary Studies of Coastal Oceans. 2011. The Science of Marine Reserves (2nd Edition, Europe). www.piscoweb.org. 22 pages. 53http://www.cefas.defra.gov.uk/media/168267/fsp_2008_09_prog_08_bass_gill_net_selectivity_final_report.pdf Cefas (2008) 54 http://www.ukbass.com/bmp/bmpdraft.pdf B.A.S.S accessed December 2014 55 Courtesy of Malcolm Gilbert, January 2015. Other research concerning selectivity has been conducted by Cefas: 51 CEFAS (1992) http://www.cefas.defra.gov.uk/publications-and-data/publication-abstract.aspx?abstract=1411 and 52 CEFAS (1992) http://www.cefas.defra.gov.uk/publications-and-data/publication-abstract.aspx?abstract=1411

56 Courtesy of Malcolm Gilbert, January 2015. Other research concerning selectivity has been conducted by Cefas. 51 CEFAS (1992) http://www.cefas.defra.gov.uk/publications-and-data/publication-abstract.aspx?abstract=1411 and 52 CEFAS (1992) http://www.cefas.defra.gov.uk/publications-and-data/publication-abstract.aspx?abstract=1411

57 ‘The gear groupings reflect groups of vessels that may have used a particular gear on its own, or may have used a variety of different gears and meshes during the year. The latter vessels are often referred to as “polyvalent”. A number of these gear groupings in which bass are the dominant species landed may be considered as bass “metiers” – i.e. clusters of vessels or trips that use similar gear, mesh and have similar catch compositions and areas/times fished. (A more formal statistical analysis is needed to identify metiers.)’ The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012. Cefas. 58https://nebula.wsimg.com/17ce16211194bfe53215bb754444686d?AccessKeyId=68F83A8E994328D64D3D&disposition=0&a lloworigin=1 Natural Capital Committee, 3rd State of Natural Capital Report, UK 2015. 59 The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012. Cefas. 60 http://data.consilium.europa.eu/doc/document/ST-5687-2015-INIT/en/pdf Proposal for a COUNCIL REGULATION amending Regulation (EU) 2015/104 as regards certain fishing opportunities for seabass. Interinstitutional File: 2015/0025 (NLE). 61 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES, June 2014. 62 http://www.ukbass.com/inshore-rules/ UK B.A.S.S accessed December 2014 63 http://www.cefas.defra.gov.uk/publications/techrep/Bass.pdf Cefas Bass Nursery Areas (MAFF) 64https://nebula.wsimg.com/17ce16211194bfe53215bb754444686d?AccessKeyId=68F83A8E994328D64D3D&disposition=0&a lloworigin=1 Natural Capital Committee: 3rd State of Natural Capital Report, 2015. 65 ‘In order to provide effective protection to spawning aggregations, which are highly variable in location, the emergency measures should cover the entire distribution area of the stock, i.e. the Celtic Sea, Channel, Irish Sea and southern North Sea (ICES divisions IVb,c and VIIa,d-h) and include fisheries using pelagic trawls. In addition ICES areas VIIj,k are included to prevent displacement in fishing activity as stock distribution is not fully determined.’ European Commission (2015) 66 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 67https://nebula.wsimg.com/17ce16211194bfe53215bb754444686d?AccessKeyId=68F83A8E994328D64D3D&disposition=0&a lloworigin=1 Natural Capital Committee, 3rd State of Natural Capital Report, UK 2015. 68 http://www.association-ifca.org.uk/Upload/Appendix%20D%20-%20A-IFCA%20Annual%20Plan%202013%2014.pdf Association of IFCAs annual plan (2013/14) 69 The IFCA costs are original estimates prior to the IFCA's creation based on expected functions. 70 Armstrong and Drogou, 2014 [report No. SI2.680348 in http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014- 07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf STECF, 2014 71 http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf STECF, 2014 72 Some European countries are now conducting recreational fishery surveys to meet the requirements of the EU Data Collection Framework, and the design and accuracy of these surveys will be reviewed by the ICES Planning Group on Recreational Fisheries Surveys. (CEFAS, 2012) e.g. DCR bass was excluded from the compulsory stock in the Netherlands. Need to spend money to bring these figures into the DCF. 73 Cefas (Pickett and Pawson,1994) http://www.cefas.defra.gov.uk/publications/techrep/tech118.pdf 74 Cefas: Solent Bass Survey in 2014, and update of bass recruitment index time series] (2014) 75 https://marinescience.blog.gov.uk/2014/12/19/c-bass-in-action/ Cefas, 2014.

40 New Economics Foundation (NEF) Working paper on bass

76 http://www.cefas.defra.gov.uk/media/617317/bass_solent_survey_report.pdf Cefas, 2014. 77 The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012. Cefas. 78 The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012. Cefas. 79 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:354:0022:0061:EN:PDF European Commission (2013) 80 http://ec.europa.eu/fisheries/cfp/fishing_rules/tacs/info/com_2014_670_en.pdf European Commission (2014) 81Most major fish stocks included in this assessment by Cefas are under CFP quota management (Cefas data) 82 http://www.seafish.org/media/1327189/clg_nov2014_cefas_stockstatus2.pdf Seafish (2014) 83 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES (2014) 84 ICES has previously identified that a TAC may not be the most suitable means to effectively control mortality for this stock. Some Member States have also mentioned the CFP reform (landing obligation) as an argument against the introduction of a new TAC. http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf 85 http://www.rspb.org.uk/Images/IEEP_2014_Practical_implementation_of_CFP_Art_17_tcm9-385886.pdf RSPB (2014) 86 http://www.seafish.org/responsible-sourcing/conserving-fish-stocks/discards/the-discard-action-group Seafish (2014) 87 http://nffo.org.uk/news/discards-ban.html NFFO accessed December 2014 88 http://www.pewtrusts.org/en/research-and-analysis/statement/2011/05/03/essential-steps-towards-tackling-the-eu-discarding- problem-joint-ngo-position PEW (2014) 89 http://ec.europa.eu/fisheries/reform/proposals/index_en.htm European Commission (2013) 90 For more information on recreational bass angling in the UK see B.A.S.S. http://www.ukbass.com/bmp/bmpdraft.pdf 91https://nebula.wsimg.com/17ce16211194bfe53215bb754444686d?AccessKeyId=68F83A8E994328D64D3D&disposition=0&a lloworigin=1 Natural Capital Committee, 3rd State of Natural Capital Report, UK 2015. 92 The UK commercial bass fishery in 2010’, Walmsley, S. and Armstrong, M., March 2012. Cefas. 93 http://www.kentandessex-ifca.gov.uk/wp-content/uploads/2014/08/B4.pdf KEIFCA, 2014 94 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 95 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 96 http://www.bluemarinefoundation.com/wp-content/uploads/2014/12/20141128-Final-Bass-Report-BMF-MRAG.pdf 97 http://www.linecaught.org.uk/ 98 http://www.parlament.gv.at/PAKT/EU/XXV/EU/05/41/EU_54117/imfname_10526448.pdf 99 ‘’The economic output of recreational bass fisheries in Sussex is therefore estimated to be approximately 3.4 times higher than commercial bass fisheries. The employment generated by recreational bass fisheries is estimated to be approximately 3.2 times higher than commercial bass fisheries. However it is important to note both that bass may have an important role in the overall operation of some commercial fisheries, in particular because it is a non-quota species, and commercial fishing can represent an important indigenous industry.’’99 100 http://www.bluemarinefoundation.com/blog/bass-should-slip-through-the-net/ Defining the Economic and Environmental Values of Sea Bass (MRAG, 2014) 101 http://www.bluemarinefoundation.com/wp-content/uploads/2014/12/20141128-Final-Bass-Report-BMF-MRAG.pdf 102 http://www.sussex-ifca.gov.uk/repository/Baseline_Fisheries_Information_v2.pdf Sussex IFCA (2013) 103 http://www.bluemarinefoundation.com/blog/bass-should-slip-through-the-net/ Accessed December 2014 104 Funding was cut last year for the only survey [Cefas: Solent Bass Survey in 2014, and update of bass recruitment index time series] capable of showing the structure of the pending year classes. 105 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES (2014) 106 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES (2014) 107 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2014/2014/bss-47.pdf ICES (2014) 108 The minimum landing size (MLS) for bass is set by the EU at 36cm but can be increased my Member States or by IFCAs within England. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/183442/minimumfishsizes.pdf Accessed January, 2015. 109 http://www.publications.parliament.uk/pa/cm201415/cmhansrd/cm141203/halltext/141203h0001.htm Accessed January 2015 110 Ibid. 111 Ibid. 112 Ibid. 113 Ibid. 114 https://marinescience.blog.gov.uk/2014/06/16/conservation-seabass/ Cefas (2014) 115 http://www.nsrac.org/wp-content/uploads/2014/04/Paper-6.1-EAA-Paper-on-Sea-Bass-for-discussion.pdf NSRAC, 2014 116 http://ec.europa.eu/fisheries/cfp/fishing_rules/tacs/info/com_2014_670_en.pdf European Commission (2014) 117 https://www.gov.uk/government/statistical-data-sets/uk-sea-fisheries-annual-statistics-2012 MMO (2012) 118 ‘Total Bass Landings’ includes UK ports and UK vessels combined. 119 http://stecf.jrc.ec.europa.eu/documents/43805/812327/2014-07_STECF+PLEN+14-02_Final+Report_JRCxxx.pdf STECF (2014) 120 https://www.gov.uk/government/statistical-data-sets/uk-sea-fisheries-annual-statistics-report-2013 MMO (2013)