UK Fishermen Organisation opposes zero TACs for spiny dogfish and porbeagle
National Federation of Fishermen’s Organisations ( NFFO )
12. December 2012
Except in a single species fishery in urgent need of dramatic remedial action, zero TACs have no place in fisheries management. The recent history of the CFP is sufficient to demonstrate that in fisheries where a certain level of by-catch is inevitable, or completely unpredictable, a zero TAC can only mean discards. A zero TAC is therefore best understood as a wholly ineffective measure driven by gesture politics rather than any clear strategy or idea about how to address a specific problem.
Zero TACs on spurdog and porbeagle fall into this category. Their purpose seems to be about creating the illusion of dealing with a problem, rather than putting in place steps that would lead to a solution.
Nothing is clearer than the fact that throwing dead spurdog and porbeagle, caught as incidental by-catch, over the side is not a solution to accidental by-catch.
It is usually easier to describe a problem rather than define a workable solution and that is the situation with these stocks.
We have to concede, it’s not easy. Vessels have not targeted these species in our waters for some time but although great progress has been made in improving the selectivity of fishing gear generally, and further progress can be expected in the future, at present there is no sign of a technical solution to inadvertent by-catch of spurdog or porbeagle. They turn up in a range of fishing gears, if not regularly, then regularly enough to represent a problem.
But real solution requires a reduction of fishing mortality on these vulnerable species, which according to ICES advice are now seriously depleted.
We propose a 5 stage approach:
- Remove the zero TAC; it is achieving nothing.
- Replace the zero TAC with a by-catch provision that will allow vessels to land what they catch but dissuade any vessel owner from thinking about targeting the species again
- Use the data collected from these landings in an enhanced data programme to improve the prospects of defining a solution.
- Identify a solution or solutions: There are a number of potential candidates, at present unexplored:
- Gear design to aid escape (this is tricky but if a turtle escape hatch can be successfully designed, a solution by skippers working with gear technologists may be just around the corner)
- Spatial/ temporal avoidance: With enhanced data, It may be possible to identify areas and seasons in which aggregations of these species occur, providing the basis for real time closures or equivalent
- New technologies may provide an answer either through alarms which dissuade these particular species from entering the gear, or which provide skippers with the ability to spot and avoid aggregations or even single fish
- Other options
- The integration of these species into a comprehensive ecosystem fisheries plan. Continuous monitoring and adaption of the plan, to take into account new data available from the fleets
The critics will claim that all this is too little, too late, and too slow. But the point is that it would be to move problem in the right direction for a solution. The Zero TAC approach only masks inactivity and the absence of any real progress in any direction.
It is very significant that ICES advice on these stocks nowhere says that they should be subject to a Zero TAC. Defining a workable solution should now be the preoccupation of the fishing industry, fisheries scientists, environmental NGOs and fisheries managers.