Delay plans to allow practical questions to be answered
The NFFO says proposed plans to introduce compulsory electronic catch reporting for all under-10m vessels in England and Wales should be delayed to allow discussions with fishermen on the details of the scheme and practical issues, reports Tim Oliver
The federation says that the government should avoid the ‘arbitrary timetable’ being proposed, and move away from ‘a blanket approach’.
Instead, it should start talking to the different small-scale fisheries in the ports and creeks about the pros and cons of improved catch data, and the means available to secure it.
The NFFO concedes that this will involve effort and delay, but believes that in the long run, it will deliver better outcomes.
The federation made its comments in its response to the consultation that DEFRA, the MMO and the Welsh government are carrying out on the proposals (Fishing News, 7 March, ‘U10 e-catch reporting soon’).
Under the plans, all under-10m vessels would have to provide catch information on all species subject to quotas, catch limits or effort restrictions via a smartphone or tablet, before any fish leave the vessel.
Vessels catching only non-quota species would have to record their catches via a smartphone or laptop within 24 hours.
And for all catches – quota and non-quota – a declaration would be required within 48 hours providing accurate weights of all species landed.
The authorities plan to introduce the new scheme during the summer this year. Northern Ireland and Scotland plan to introduce their own measures.
The NFFO says that while it backs the need for improved catch reporting, the government’s proposed approach has not been well thought through.
It points out that fisheries such as skates and rays could be managed better if better catch data was available, and that the discards ban has increased the risks from data gaps ‘exponentially’.
It says that accurate catch data is likely to become more important in the future to help avoid choke risks, and to design ‘light-touch’ management measures for low-impact vessels.
The NFFO also agrees that modern technology can be more efficient in collecting and transmitting data than paper logbooks.
But it says that the current plans:
- Show inadequate understanding of the practicalities involved, or the specific circumstances of different fisheries
- Make little attempt to discuss the practical implementation issues with those who will be affected
- Pay insufficient attention to the range of fishing operations, types of vessel and patterns of landing in the under-10m sector
- Suggest a blanket ‘bulldozer’ approach, when a more discriminating application would deliver better results
- Potentially threaten to criminalise small-vessel operators for non-compliance, when the ability to comply is not in their hands
Potentially risk not catering for those who are not computer- or smartphone-literate.
“A good idea can be spoiled by poor implementation, and this consultation carries the hallmarks of a recipe for, if not wholesale failure, then sub-optimal outcomes,” says the NFFO.
Gulf between plans and ‘real-world’ practical issues
A sample of concerns raised by NFFO members in response to the consultation give a flavour of the gulf between the proposals and the real-world concerns that have arisen from very diverse fisheries:
- A requirement to submit a catch report before the boat lands is impractical, and could be unsafe from a navigation and safety at sea perspective. Submission within 24 hours would make more sense
- Practical issues associated with using mobile phones in an open boat
- Some fishermen will be landing up to 30 different species. The time it will take to enter data on a mobile app before landing fish could be considerably more than DEFRA’s estimates
- A risk of mistakes when fishermen are often tired after long hours at sea
- No mention is made of recording discards for non-quota species – and minimum sizes may vary around the country. How will such requirements be enforced?
- The question of presentation, and how weights are to be recorded – eg, for gutted fish
- The conversion factors to be used (not all fishermen in small vessels will have the conversion factors in their heads)
- Reservations about data protection and what information would be transmitted, and to whom, after Brexit
- How would data from iPads etc feed into the International Catch Certificate requirements and the EU fish transport documents?
- Considerable scepticism about the amount of duplication, or worse, involved in the weighing process – weights on landing, weights on arrival at auction, where fish are sorted and graded, and then weights again on sale (bureaucracy gone crazy?)
- Concern about possible losses of internet connection and how they would be dealt with, as well as the usual reservations about service when there are communications problems or technical glitches
- Is it intended – at least for an interim period – to continue with a back-up paper system? If so, does it also have to be expanded to cover the additional fisheries?
- Particular concern was expressed by the shellfish sector, where there are already considerable reporting requirements in place – MSAR monthly returns for crab and lobster; IFCA returns for cockles and mussels; whelk returns; Shellfish Registration Documents for cockles, mussels and whelks. How will all these returns (and other similar returns) be integrated into the new system? At the present time, considerable additional data is recorded (eg, cock and hen crabs) in much finer detail – is this to be lost? Or are further burdens to be placed upon fishermen?
Under-12m VMS ‘vital’ to understand inshore fleet
DEFRA has published the results of its consultation on the introduction of vessel monitoring systems (VMS) for all British-licensed under-12m vessels when fishing in English waters, reports Tim Oliver.
Justifying the introduction of inshore vessel monitoring systems (I-VMS) for the under-12 fleet, DEFRA said there are over 2,600 under-12m vessels that catch on average 63,000t of fish per year – worth an average £138m. “It is vitally important for regulators and policy-makers to gain a better understanding of fishing activity for the entire inshore fleet,” said DEFRA.
“The government and the MMO have developed this proposal in light of experience and insight gained from the VMS project applying to vessels of 12m and over. As a result, great care has been taken to consider and mitigate for all known risks.”
DEFRA plans to introduce I-VMS for the under-12 fleet during the summer. Scotland aims to roll out its own plans for I-VMS in 2020.
The consultation set out proposals to introduce I-VMS for all owners or operators of under-12m British fishing boats operating in English waters (Fishing News, 18 October, 2018, ‘VMS for under-12m fleet’), and ran from 4 October to 14 November, 2018.
It asked whether respondents agreed with the proposal, for comments, for possible alternative approaches, and for views on the costs and benefits of the plans. DEFRA received 181 responses.
There were mixed responses to the proposal. The main benefits outlined by respondents who supported the proposed legislation included:
- Improved enforcement, monitoring and fisheries management
- Managed access to MPAs
- Deterring of illegal, unreported and unregulated (IUU) fishing
- A useful tool for stock management, traceability and sustainability.
- The main issues raised by respondents who opposed the proposed legislation included:
- The cost of implementing I-VMS, and downtime costs
- Privacy, including access and use of data
- Operational issues, such as running I-VMS on a vessel with low/no power
- The relevance of monitoring smaller vessels in comparison to over-12m vessels
- Discrimination against the fishing industry.
Respondents who agreed with the introduction of I-VMS to the under-12m fleet predominantly said it would improve monitoring, enforcement and compliance, and assist fisheries management, particularly in terms of where and when vessels were fishing.
Many respondents said I-VMS was crucial for the management of MPAs. It would discourage fishing in no-take zones (NTZs), while also enabling access to specific areas. It would also help to manage stocks, aid traceability and guard against illegal fishing, and it would align VMS requirements for the whole fleet.
I-VMS would also help with conflict resolution, both conflict between fishermen (eg, gear conflict) and conflict between fishermen and other industries. It would provide evidence of fishing activity for spatial planning.
On the downside, many respondents raised practical concerns, particularly with regard to installation in small spaces and/or without electrical power.
Many respondents also said that I-VMS would be unreasonable and disproportionate for smaller vessels. Many offered alternative proposals, such as a requirement on over-7m vessels only.
Privacy and unnecessary bureaucracy were also objections, and that I-VMS would identify potential fishing grounds to other fishermen. There were concerns about the use of I-VMS data and who would have access to it. Several respondents suggested the use of AIS, catch reports and sales notes as alternative tools for understanding the fishing activities of the under-12m fleet.
The full report, including government responses to the points raised in the consultation, is available at: bit.ly/2G6mn1E
Defra u-12m I-VMS announcement – see page 6 of this week’s Fishing News.