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Dear Maria Damanaki

A letter exchange between Ian Kinsey, Scottish fisher and fisheries consultant, and Maria Damanaki, European Commissioner for Fisheries, concerning the Catch Quota scheme and the use of CCTV cameras .


Dear Mrs Damanaki,

The use of CCTV surveillance cameras has been in use on board fishing vessels now for some 30 years. Fishermen have in general reacted positive to having their place of work under surveillance, seeing the benefits of having the skipper being able to hold a watchful eye on what at times is a dangerous workplace.


The use of CCTV cameras to record and document catches, and working practises is something else. There are few occupations that are subject to the amount of micro management as the fishing industry - so whom in their "right mind" would voluntarily consent to more control? - A "madman"?, a "desperado"? - or maybe a fed up, desperate and conscientious hard working fisherman, with the courage to make positive changes, and document them in the making.


Fishermen all around the North Sea have been entrapped over a long period in a negative spiral of bone scraped fish quotas and the insane mandatory practise of returning under MLS, non-target species and over quota fish over MLS back to the sea, fish that in reality are either dead or dying.


A discarded dead fish is a dead fish - where dead fish over MLS are a loss of income for the fisherman in the present time, where as discarded dead fish under MLS are a loss of his future.


Minimum landing sizes need to be related towards the protection of fish under spawning age. The best protection for immature fish is by avoidance.


The fishermen blame the scientists for inaccurate data on which they base their quota recommendations on - the EU Fisheries Commission blames the fisherman and his "non compliance" for the terrible state of the stocks, and hence the need for low TAC's and even bigger reductions of days at sea.


The method used by the EU Fisheries Commission and it's under lying management is a classic sawing off the table legs, bit by bit in the hope of getting rid of the wobble - and sadly only resulting in the table being reduced to no more than just a plank! The intelligent approach would be to put a wedge or shim under the short leg, but no!, its more of the same old medicine, "chemotherapy and amputation", as the "cure", instead of the "carrot and the stick" approach.


The Catch quota scheme is a step in the right direction in documenting that it is fully possible to make huge reductions of fish that otherwise would have been discarded - the big shame is that it only covers cod and not other species.


Incentives to take part in the CQS come from amongst other reasons, the extra quota allowance of cod given to participating vessels, on the condition they document and land all cod catches.


So where do the "extra quota " allowances come from? When the scientists put forward their recommendations as to the size of the TAC's, they are made from an assumption as to the present state of the breeding stock biomass, and to some degree it's interaction with other species.

The scientist takes also into account assumed mortality due to discarding and unaccountable natural mortality due to predation etc. The extra allowances come from the "discard allowance" - fish that is assumed to be caught and discarded anyway.


Many fishermen ponder over why the scheme has not been expanded to include a greater number of vessels and to other species. Maybe the reason lies in the fact that the scheme has been subject to controversy, with for example: the scepticism to CCTV and the "surveillance society", cost of managing the scheme etc. The scheme cannot be expanded indefinitely due to the limits of "the discard quota" base.


So where is the CQS going, and what should it lead to in the near and not so distant future?

There reigns no doubt that catching and discarding both marketable and juvenile fish is an unethical misuse of much needed marine resources. The way forward can only be through reducing mortality, by using a combination of fishing gear with better selective and environmental properties, and spatial/ temporal restrictions - proof of this is documented by the CQS and numerous other selection and avoidance initiatives suggested and implemented by the industry over recent years.

It has been estimated that the Scottish fleet alone have discarded marketable fish over MLS to the value of approximately 30-40 million Gbp yearly. These figures do not take into account future losses due to discarding of juveniles.


The catching sector and management has an array of discard mitigating measures at their disposition. Management has also the legislative powers to implement them. The cost of implementing and legislating a fast tracking "gear change" must be seen only as a "drop in the ocean", compared to the vast amount of revenue the fishing industry loses each year through bad exploitation practises.

EU fisheries Commissioner Maria Damanaki informed the fishing industry in 2011, that funding will be made available through the EU Axis 4 European Fisheries Fund, to assist in making the transition to more sustainable fishing practises. Funds will not be available before the EFF 2014 funding period. Wasting good fish is unethical - wasting valuable time when we have the means to radically improve exploitation practises and minimise waste through discarding is outright stupidity.

The EU's fishing Industry cannot afford a two years wait for funding. A guarantee for funding "gear changes" should be given the highest priority.

Yours sincerely,

Ian Kinsey


The reply from Commissioner Damanaki


Dear Mr Kinsey,


Thank you for your thoughts on the catch quota scheme, which you sent to me by email on 20 February.


I can agree with many of the points you made in your email, especially concerning the waste of valuable resources that current discard practices represent. Solving the discard problem is not straightforward, but I believe it is possible.


Under the current regime of landing quotas, any fish caught in excess of quota, or undersized fish, have to be discarded. This was necessary both to discourage fishing in areas of high juvenile abundance and to prevent the continuation of targeted fisheries on stocks where the quota has been exhausted. The drawback of this approach is that the total removals from the stocks are not sufficiently controlled, with the consequent waste of resources. The catch-quota system tries to get around the problem by ensuring that all catches are counted against the quota, not just the landings. When properly enforced, the catch quotas themselves could be somewhat larger than the landing quotas, because we could include the quantities that scientists estimate would otherwise have been discarded. The advantage of such a system is that it creates an incentive for fishermen to be more selective, avoiding catches of juveniles in order to maximise the value of their catches.


Under this presumption fishermen would decide and implement measures like using more selective gear or/and avoiding concentrations of juveniles and others. Of course, a catch-quota system presents its own challenges. One is that it requires effective surveillance at sea to ensure that all catches really are counted against the quota. The installation of closed circuit television (CCTV) systems that record all aspects of the fishing activities is a possibility that is currently being explored.


The first trials have been with cod in the North Sea, and there have since been trials on sole in western waters, and there is a possibility that there will be trials on plaice in the North Sea in the near future. Some Member States want to extend the trials to other species in the North sea, notably haddock, whiting and saithe. However, although the Commission encourages these trials as a step in the right direction to reduce discards, it must be borne in mind that all of these stocks are jointly managed with Norway, who has been reluctant to agree to an expansion of trials until the results of the existing trials have been fully evaluated.


Concerning the availability of funds, I would like to inform you that the EFF may contribute to the financing of investments to achieve the selectivity of fishing gear under the conditions specified in Article 25 of Council Regulation (EC) No 1198/2006.


Yours sincerely,


Maria Damanaki



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