Fisheries TAC S and Quotas 2013
Fisheries TAC’s and Quotas 2013
Sustainability Impact Assessment
December 2012
Sustainability Impact Assessment of EU Commission Proposal for
“for a Council Regulation fixing for 2013 the fishing opportunities available to European Union vessels for certain fish stocks and groups of fish stocks which are not subject to international negotiations or agreements” - COM (2012) 608 final
1 Summary
This Sea Fisheries Sustainability Impact Assessment on the EU Commissions proposals for certain fishing opportunities for 2013, draws it’s conclusions from a consultation process with all major stakeholders and expert contributions from The Marine Institute(MI) and Bord Iascaigh Mhara (BIM). The Commissions proposal is only in relation to certain mainly whitefish stocks and does not cover some pelagic stocks, such as mackerel which economically is Irelands most important stock, or albacore tuna, or inshore fish and shellfish stocks not subject to TAC and quotas such as lobster and crab.
In the preamble to the proposals the Commission itself states:-
“All fishing opportunities regulations must limit the harvesting of the fish stocks to levels which must be consistent with the overall objectives of the Common Fisheries Policy (CFP). In this respect, Council Regulation (EC) No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy sets out the objectives for the annual proposals for catch and fishing effort limitations to ensure that Union fisheries are ecologically, economically and socially sustainable.”
It goes on to state that
“This year, the Communication from the Commission concerning a Consultation on Fishing Opportunities for 2013 (COM(2012)278 final, hereinafter "Commission Consultation on Fishing Opportunities") provides an overview of the state of the stocks based on the findings of the scientific advice issued in 2011. The Communication thus reports that 65% of fish stocks in EU waters are not fully assessed. It also signals some trends that are of concern, notably a decrease in the proportion of stocks within safe biological limits, but also some positive ones: where the state of stocks has been assessed, they seem to be improving slowly. In the Atlantic and nearby areas, the proportion of overfished stocks has fallen almost by half, down to around 47% from 94% in 2004.
The underlying ethos of the Impact Assessment results support both these statements.
What is undeniable is that the Irish fishing fleet depends on healthy and sustainable stocks for it’s medium and long term viability. What is also made clear is that managing fisheries is a complex undertaking, more so in the context of mixed fisheries which is the nature of the fisheries in the waters around Ireland.
The EU Commission has put forward a new vision for Europe’s ocean and seas. The new policy will tackle all maritime activities and sustainable development, including the marine environment in an overarching fashion. The Marine Strategy Framework Directive (MFSD) aims to achieve Good Environmental Status (GES) of the EU’s marine waters by 2020, and to protect the resource base (e.g. fish stocks) upon which marine related economic and social activities depend. A key objective of the MFSD is to have fishing mortality values equal to or lower than FMSY to ensure sustainable development. These objectives are in line with the CFP, to achieve MSY exploitation rates “where possible” by 2015 and 2020 for all stocks.
The Impact Assessment acknowledges that while many stocks in which the Irish fleet have an interest are not in a healthy biological state, there has been an improvement in 2012 on the state of the resource base in relation to pressure and state indicators. Of the 59 stocks in which Ireland has a share of the EU TAC, 42% are now fished below FMSY compared to 36% in 2011. The state of the resource base in terms of SSB in relation to biomass trigger points has also improved, with 34% above Btrigger, an increase of 8% on last year. The number of depleted stocks has declined from 12 to 8 and now 14% of stocks are assessed to be depleted. The number of stocks with unknown SSB, no assessments or undefined Btriggers remains relatively high at 51%.
It is also noted that the activities of the fleet have other impacts on the wider marine ecosystem. Greater efforts are necessary to achieve a more harmonious and eco-friendly interaction with the broader environment and to ensure compliance with European Environmental Directives. These efforts will be required to be imposed at European level on all EU fleets fishing in shared fisheries under the EU Common Fisheries Policy.
Specific details of the status and scientific advice on a stock by stock basis can be found in the following pages, and in the accompanying Stock Book.
This Impact Assessment agrees with the need to cut the quotas for many of the stocks as per the Commission proposals, though the level of these cuts is queried in some cases, while in others there is clear scientific data to suggest that a cut is unwarranted.
In 2012 in response to a request from the EC, ICES addressed the issue of providing a quantitative advice where a precise assessment may not have been possible. Implementing this has required ICES to develop a decision framework based on a categorisation of the information on the stock and fishery and to use expert judgement in estimating the fishing pressure and state of the stock. This has resulted in some inconsistencies with the implementation of available information to produce advice. In these cases the Marine Institute has provided a clear advice and a rationale for doing so, for instance Plaice in VIIa and Pollack in VII.
There are a number of stocks where ICES provide no advice (6 stocks), due to the uncertainty in landings the stock is a minor component in mixed fisheries, and/or the TAC is well in excess of landings. In these cases the MI has provided advice and a clear rationale.
In one important instance, Celtic Sea Herring, the ICES advice is for a TAC of 19,000 tonnes but the management plan, agreed by industry, proposes a lower TAC of 17,200 t.
The Commissions approach to the science appears contradictory and inconsistent and they are ignoring additional pieces of scientific advice (ie. trends in landings and effort), that while not giving detailed forecasts of future catches, does give indications on the state of the stock and should inform the TAC setting exercise.
It is clear that decisions on quota levels must be made on a fishery by fishery basis, a position which the Commission in their statements at October Council have now accepted. However, the Commission demand that we should have MSY advice in all cases is simply not attainable. For instance the fisheries for Sole and Plaice in VIIb and VIIc are so small that it is not economically viable or justifiable to do a comprehensive scientific sampling programme. However, the science that is available indicates that neither stock is in trouble and should not be subject to cuts proposed.
One major concern surrounds managing for fisheries that need remedial action in a mixed fishery by means of landing restrictions only. It is a fact that in mixed fisheries it is often the case that if you cut quotas without introducing additional technical measures there is a likelihood that this will only increase discards. In addition, it is clear that if you cut quotas in a situation where the science is indicating increasing biomass you will also increase discards. This is the situation in the mixed cod, haddock , whiting fishery in the Celtic Sea.
Practical, prudent and carefully thought out measures are clearly required.
At the June 2012 Fisheries Council the Cypriot Presidency achieved a General Approach on the Common Fisheries Policy basic regulation which places solving the discards problem high on the list of priorities. Decisions on TAC’s particularly in the case of mixed fisheries which exacerbate the problem are of major concern and need to be carefully considered.
At an overall level, reductions in fishing levels on certain stocks are both justified and inevitable. These reductions will come at a social and economic cost.
It is estimated that the proposal as it currently stands will result in a net reduction in fishing opportunity, (i.e. quotas) for the Irish whitefish and prawn fishing industry of 21% by volume. In financial terms this amounts to a direct income reduction, for the primary producers, the fishermen, of €15.4 million (14% on 2012). There would be resultant knock on decreases for processors, hauliers, etc.
At a regional level the 12% reduction in fishing opportunities (quotas) in the Celtic Sea and in waters off the west coast will result in a €10.6m primary production loss for the whitefish and prawn fleets operating there. This will directly impact the ports of Castletownbere, Ros an mhíl, Dunmore East, Dingle and Kilmore Quay, and other, smaller, ports along the south and west coasts.
The level of reductions in fishing opportunities, (quotas) in the Irish sea amounts to 44% with a resultant economic fisheries production loss to the fleets (whitefish and prawn) operating there of €2.2 million, impacting directly, the ports of Clogherhead and Howth, and other, smaller, ports along the east coast.
Turning to the North West fishing fleets they will say their opportunities (quotas) are being reduced by 20% with a fishery production income loss of €1.4 million for that demersal (whitefish and prawn) fleet, directly impacting the ports of Greencastle and Killybegs.
When landings are reduced there is a corollary knock on effect on the operation on the seafood processors dependent on this resource. In other ancillary industries such as net making, chandlery, engineering, refrigeration etc are also negatively impacted. Based on a total turnover generated per tonne of fish landed, BIM estimates that the full cost (direct and indirect) of the proposed quota reductions are in the order of €53 million.
It is estimated that reductions in economic activity across the seafood sector in the magnitude outlined would result in significant negative impacts for between 450 - 550 full and part time jobs either through reduced incomes, partial lay-offs or redundancies.
The proposal does not include the “Hague Preferences” which are a safety net for the Irish fleet on specific stocks where Total Allowable Catches (TAC’s) are in decline. They are negotiated annually at the Fisheries Council and when agreed offer additional quotas to Ireland. The loss of these allocations in 2013 would amount to 1,625 tonnes of fish with a direct value of €2.95 million. It is estimated that the full value (direct and indirect) of the Hague quotas in 2013 would be in the region of €9.2 million with an associated impact on between –90-100 full and part time jobs.
2 Background
Fishing opportunities (quotas and fishing effort) for each Member State are agreed on an annual basis in the EU Fisheries Council of Ministers on the basis of a proposal produced by the European Commission. A proposal which sets out 2013 fishing levels for certain stocks was circulated by the EU Commission on the 24th October 2012.
This proposal covers stocks which are not subject to third party international agreements and are in the main whitefish (demersal) stocks
The Programme for Government 2007 – 2012 states that a Sea Fisheries Sustainability Impact Assessment, based on consultation with all major stakeholders, will be brought before the Dáil annually before EU fisheries negotiations commence.
3 Objectives
The objective of this document is to look at the overall impacts the proposal could have on the sustainability of the fishing sector from a biological, economic, social perspective. and to put these conclusions before the houses of the Oireachtas for debate.
4 Process
4 (a) Consultation:
Stakeholders were asked to comment on the Commission proposal for fishing opportunities for 2013 – COM (2012) 608 final. From November 2nd, 2012 an online web portal on www.fishingnet.ie was activated to enable electronic submissions be forwarded for consideration. This facility was kept open until 20th of November, 2012.
In addition a meeting of stakeholders, which Minister Coveney attended, was held on the 15th of November to further assist and inform consideration of the proposal and the submission of comments.
In all 10 submissions were received by the closure date. Of the submissions received 5 from OCEAN2012 and its members had identical text outlining the position of the grouping. The full content of the submissions received are available on the website www.fishingnet.ie.
4 (b) Synopsis of key points from consultation process:
· A general welcome for the opportunity to partake in the consultation process.
· An acknowledgement of the improvement in overexploitation in the past few years while stressing the need for further measures to improve vulnerable stocks and reduce discards.
· Commitment to scientific advice to achieve the commitment given at the 2002 World Summit on Sustainable Development in Johannesburg of reaching “Maximum Sustainable Yield” (MSY) by 2015.
· In mixed fisheries FMSY to be set according to the most vulnerable stock to minimise discards.
· A commitment to maintaining or restoring stocks at levels that are capable of producing Maximum Sustainable Yield.
· Criticism of the Commissions arbitrary cuts in TACs and their view on what kind of science they are prepared to accept.
· Concerns that cuts in the TAC of certain species will lead to further discards and instances where an abundance of mature stock cannot be avoided (even when) using selective gear types.