Dear Mr Cameron,

At the Commonwealth Summit in Malta you announced £5.6m in aid to be spent next year to help the Caribbean Islands with their maritime economies of tourism, shipping and fishing.

I would say that was a very kind, generous, if not laudable, thing to do, if it were not for the fact that the small-scale coastal fishermen of this country are on the brink of ruination.

Government policy, or its own agenda that your fisheries departments (DEFRA/MMO) are working to, are responsible for the dire straits of the small-scale fishermen of this country.

My report ‘The Demise of the Low Impact Small Scale Fishing Communities’ fully explains the reasons for the current position they have been placed in.

I would ask you to debate the contents of the report in the House of Commons so as to find a solution for the small-scale fishermen’s problems, because your fisheries departments are unable to do so.

I sincerely trust that if you manage to debate this very important problem, it will be dealt with in a more democratic way than the debate on UK Sea Bass Stocks at Westminster Hall on the 3 December 2014. This is fully explained in the accompanying report.

I look forward to your reply.

Yours sincerely,

Stephen Gathergood

Report: The demise of the low impact small-scale coastal fishing communities (Profit and Loss Account)

Dear Commissioner Vella,

The UK under-10m artisan small-scale coastal fishing communities are in dire straits and on the verge of total collapse. The UK Government and its fisheries departments have created this situation for the low-impact small-scale coastal fishermen. Without intervention from the EU Commission these fishing communities will cease to exist at all.

I wish to formally outline the series of events and circumstances that has led up to the impossible situation that the UK small-scale fishermen have been placed in.

Loss Account

Quotas

The original UK fishing quotas were disproportionately, and inappropriately, allocated by the fisheries department – whether this was by design or incompetence is open to question. The small-scale under and over 10m vessels in the non-sector public pool, which accounts for 87% of the UK fishing fleet, only received a derisory 4% of the quotas.

The Common Fisheries Policy (CFP) has formally passed through its review, however quotas that are part and parcel of the CFP have not. I would ask you why the quotas were not reviewed for practicality, workability and fairness of allocation? The UK Fisheries Department are not allocating quota to low impact small-scale fishermen as in accordance with Article 17 of the reformed CFP.

I would also like to ask you what mediation process is in place for fishermen to make representation on what I believe has been a gross mis-allocation of UK fishing quotas?

The lack of quota allocation on pressure stock species has had a devastating effect on the small-scale coastal fishermen, many of who found the derisory quotas unsustainable. Many fishermen were forced, by lack of quota, into diversifying into non-pressure stock species such as bass.

UK Latent Capacity

If the UK fisheries department competently allocated the quotas in the first place, there would be no need for Latent Capacity capping. In an attempt to try to create the illusion of more quota for some, the UK fisheries department came up with this disingenuous idea and imposed a draconian method of preventing fishermen from using their legal quota entitlement.

Latent Capacity is applied to fishermen when they have not caught 300 kilo of pressure stock species in a certain time frame. They are then capped at 300 kilo of pressure stock species for the entire year. The chronic lack of quota in the small-scale under-10 sector is justifiably the fault of the UK fisheries department; it is not the fault of the fishermen. To add latent capacity capping just adds insult to injury and greater hardship.

Small-scale fishermen need to be allowed to take into account all the prevailing circumstances such as amounts of seaweed, weather and tidal conditions, available quota and what species of fish are available. The whole fundamental principle of a successful small-scale fisherman is to remain multi-purpose, because this is what makes his living sustainable. Latent Capacity, by its very design, nature and implementation, destroys these principals.

Another round of Latent Capacity has gone through its formal predetermined consultation process, which is surprising bearing in mind that no competent management report has been produced in terms of benefit or loss to the Latent Capacity planning policy for the previous round. It raises the question: do the fisheries managers care or are they acting in accordance with their own secret agenda?

The predetermined Latent Capacity capping consultation on shellfish has also been concluded and to my knowledge there is no national planning policy on its regulation. Again, small scale fishermen’s rightful entitlement to fish will be eroded along with their social and economic wellbeing, which has not been accounted for in any of the latent capacity capping processes.

Latent capacity capping is illegal and contrary to Article 17 of the reformed CFP. Social sustainability is one of the core CFP objectives and to prevent severe negative impacts on the viability of most vulnerable coastal communities that aim to achieve the following social objectives

  • Reversing the decline in employment in the fisheries sector, particularly in catching.
  • Increasing the attractiveness of the fisheries sector and turning it into a source of high quality jobs.
  • Ensuring the viability of coastal communities by promoting economic growth and jobs
  • Facilitating the transition to a sustainable fishing

Latent capacity capping destroys a fisherman’s opportunity to diversify so as to maintain or increase his income.

Inquiry

I would ask the EU Fisheries Commission to hold an inquiry into why the small-scale inshore coastal fishermen have received such a derisory 4% quota, and why they been discriminated against with latent capacity capping. Also, why do the UK Fisheries Department not allocate quota to low-impact small-scale fishermen in accordance with Article 17.

Equal access to a common resource

I’m sure that you’re aware that equal access to a common resource is supposed to be applicable to all fishermen, from all member states. However, this is not the case for the UK’s small-scale coastal fishing communities.

These fishing communities, for the most part, use low-impact, static, sustainable fishing methods such as long lining, rod and line, large mesh set nets and pots that produce insignificant discards.

The large EU Member State trawlers are continually trawling outside the UK’s six-mile fishery limit. This prevents the UK’s small-scale fishermen from setting their static fishing gear outside the six-mile fishery limit. Member state trawlers have therefore retained a monopoly over this area to the financial detriment of the local small-scale UK fishermen.

I would ask you, is this not contrary to the EU laws with regard to equal access to a common resource and the fair competition act? Notwithstanding this, the fact of the matter is that small-scale local fishermen have been forced into a vastly reduced area and are having their fish stocks reduced unfairly by the very large European trawler fleet that are fishing so close to the UK’s coast.

Equal access to a common resource does not work for everyone and in particular the local small-scale fishermen of the UK.

Spatial management

To rebalance the equal access to a common resource so that it is fair to all, I would suggest that the six to 12-mile fishery limits should be made into zones. A zone for no towed gear whatsoever and a zone for towed gear. These two zones should alternate and take up the entire area from the six-mile to the 12-mile fishery limit and should go all the way around the UK – it could be established in all member state countries.

The other benefit would be that all the zones that are static fishing gear only would, in essence, become conservation zones.

EU Fisheries Commission – Over capacity  

The EU Fisheries Commission is in part to blame for the demise of the UK’s small-scale coastal fishing communities. Apart for being responsible for the content (as explained in ‘equal access to a common resource’ above), the EU Fisheries Commission has never tackled the main problem that exists in the European fisheries and that is over capacity. The Commission has always allowed the over capacity to expand year-on-year without taking meaningful preventative measures.

There has been an immense expansion in over capacity in recent years with the introduction of wider and higher bottom fishing trawls, wider and deeper mid water trawls, twin trawls, triple trawls and multi trawl rig and electric beam trawls. The consequences of this have significantly reduced the economic returns for the local small-scale coastal fishermen, who are forced and confined to working inside the six-mile fishery limit.

It has allegedly been reported that some member state Governments have paid large subsidies to their fishing fleets, in particular, France. If this is the case, then subsidies increase over capacity and higher fish mortality and create even more unfair competition.

The net loss in the expansion of uncontrolled latent capacity has been an enormous rise in the level of discards by Member State trawlers and seiners.

Discards

Small-scale coastal fishermen (as previously mentioned) do not create significant discards. However, they will be disadvantaged by having to comply with the unnecessary forthcoming discard ban.

If the EU Fisheries Commission had acted responsibly on over capacity by banning twin, treble and multi rig trawls and decrease the width, height and/or depth of all other trawls, there would have been a huge reduction in over capacity and discards, and no need for a ban. Something the Commission should be looking into.

Aggregate dredging

The Crown Estate Commissioners are charged with gleaning as much profit out of the marine environment as prevailing circumstances allow and the surplus revenue is paid each year to H M Treasury. The Crown Estate is formally accountable to Parliament. The Monarch will receive from the Treasury a grant indexed to a percentage of the Crown Estate’s annual net revenue (currently set at 15%). The revenue the Crown Estate receives is reported to be in excess of £100 million per year, plus the Treasury would also collect the Value Added Tax.

In 2010, a UK Parliament Treasury Committee report on the Crown Estate stated “the Crown Estate has a monopoly over the marine environment, and has focused too strongly on collecting revenues rather than acting in the long-term public interest around ports and harbours.”

In recent years, aggregate production is meeting European demand and in excess of 50% of the total production is being exported directly from the licenced aggregate dredging areas.

Aggregate dredging completely destroys the marine environment by removing all the eco-systems and biodiversity. The, once prolific, feeding and breeding grounds for fish are turned into nothing more than a lunar landscape. The sediment fall-out also affects large areas outside the licenced area.

Fishermen have been forced off the aggregate licence areas thus losing part of their living now, and in the future. The Crown Estate have never considered recompensing the fishermen for the loss of their fishing grounds, in fact, they are only interested in gross revenue profit and have nothing to do with what is in the public interest. The combined total of marine licenced aggregate dredging areas is well in excess of 1500 square miles, mainly coastal inshore waters, and once again this is decreasing the area that small-scale coastal fishermen can operate in.

Wind farms

The real extent of the combined total sea area that will be taken up by wind farms – established around the coast of the UK – is not yet known. The formal determination process is still on going. However, the ones that have been completed have yet again decreased the small-scale coastal fishermen’s area of operation. All the future wind farms will also greatly decrease the fishermen’s area even more.

It’s been alleged that when all the wind farms are completed, the Crown Estates may receive five times more revenue than that of the aggregate dredging industry. If that is the case, the UK Monarch and the H M treasury are in for an enormous windfall. It would appear that the revenue from aggregate dredging and wind farms dwarf that of the inshore coastal small-scale fishing communities. These two industries will continue to expand and decrease the available fishing grounds.

European Marine Protected Areas

These areas have been recently introduced in the UK. They were hurried through their formal determination process because the European deadline was about to run out. In my area, the consultation was predetermined and therefore meaningless. There was no site-specific social and economic report and no scientific evidence.

A vast area was closed down and no bottom towed gear bylaw was introduced. The consequence to the local small-scale fishermen was a 20-25% decrease in their income for no reason. Again, more sea area lost for small-scale coastal fishing communities. I ask you, where do these fishermen seek compensation from?

Marine Protected Areas

Marine Protected Areas are being introduced mainly to appease what has become a very large increase in the environmental and green movements. They are also a very good ‘vote puller’ for any political party willing to dance to their tune. There are many like-minded people throughout the corridors of power. The only problem with this is that they are uncompromising and prejudiced towards the fishing industry. Their idealism lacks rationalisation and fairness, and there is no intention of coexistence with the fishermen.

Marine Protected Areas that have already been implemented are meaningless. No, or very little, scientific evidence has been provided and most have been implemented on a precautionary basis. Nobody seems to know what is being protected or why and more importantly, there is no way that future fisheries managers will be able to report on any net benefit in terms of profit or loss in a measured way to the main planning policy that established them in the first place.

The second round of Marine Protected Areas has passed through its predetermined consultation period. In my area, there are three MPAs, one of which is 550sq.km; the level of protection will not be known until after confirmation of consent. No site-specific socio-economic losses were taken into account. Fishermen are expected to subsidise other people’s conservation ideology free of charge. No compensation has been forthcoming.

The development of the marine environment is a total shambles because there is no coherent planning policy. It is just adhoc and piecemeal implementation. Again, small-scale coastal fishermen continue to lose their fishing grounds.

Department for Environment, Food & Rural Affairs (DEFRA), Marine Management Organization (MMO)

I’m of the opinion that DEFRA and the MMO are total ‘green’ environmental departments. Their consultations seem to be predetermined and they haven’t appeared to carry out meaningful socio-economic assessments when formally determining quotas, MPAs and other such matters.

These departments do not allocate quota in accordance with Article 17 of the reformed CFP. Ironically, they pushed for the reforms and now do not want to abide by them. Draconian rules are introduced like latent capacity capping, again contrary to Article 17. Fishermen feel discriminated against, alienated and are worried for the future. I believe that the departments show favour to RSA and environmental groups and do not take a balanced view from all stakeholders.

As a fisherman, I have found it very difficult, near impossible, to speak to a member of staff in authority over telephone. And all letters are answered by customer services with meaningless waffle, far removed from the issues raised.

Inshore Fisheries and Conservation Authority (IFCA)

The IFCA manage the UK fisheries out to the six-mile fishery limit and they boast that in excess of 25% of their district is taken up with Marine Protected Areas, the majority of which have fishing restrictions.

I get the impression that IFCA are preoccupied with introducing as many MPAs as they can so as to prevent commercial fishing from taking place, thus justifying their review every four years. There is no stakeholder involvement. They have given away part of their management responsibilities to environmental groups.

Environment Agency

Although recent surveyed water testing has resulted in nothing untoward, the Environment Agency has de-classified parts of my area from a B to a C using a year-old survey. This means fishermen cannot land the shellfish from these areas for human consumption.

Bass Nursery Areas

Fishermen support sensible, meaningful conservation measures such as this one, however the 34 Bass Nursery Areas collectively take up a vast area that the small-scale fishermen are unable to work.

Other Areas

There are many other areas where small-scale fishermen are prohibited from working, such as HM Dockyard and British Ports no fishing areas, capital dredging dumping sites and ships anchorages – to name just a few.

Summary

Through lack of rightful pressure stock quota provision, latent capacity capping and another round pending with shellfish capping, hundreds of small-scale coastal fishermen have been forced or steered into the last viable fishery open to them, which is the bass fishery. The areas that these fishermen can catch their meagre quota has diminished at an alarming rate and this will continue to be the case for some considerable time to come. All of the above mentioned combined factors have led the small-scale coastal fishermen to the very brink of ruination.

I sincerely trust that you can grasp and appreciate the importance of the dire position that the UK small-scale coastal fishing communities have now been placed in. I wish that I could inform you that this was the whole of the matter. Unfortunately, the worst is still to come.

Commissioner Karmenu Vella

Skipper Stephen Gathergood’s Gosport-based inshore catamaran, Phyllis John.

EU Fisheries meeting & international council for the Exploration of the Sea (ICES) Bass stock report

In 2014, a meeting of member state ministers convened to discuss the ICES report on bass stocks. The meeting closed without any agreement.

ICES Scientific Report Bass Stocks

ICES advise that when the Maximum Sustainable Yield (MSY) approach is applied, total landings in 2016 should be no more than 541t. The problem with managing a fishery with a tool such as the MSY approach is that it is not so much of a science it is more of an unknown gamble, and can go terribly wrong. It is based, in most parts, on pure assumptions. It tends to look at the benefits without looking at the costs.

The ICES scientific report presented to the Fisheries Commission is grossly flawed and lacking in data. In my opinion, it is a misrepresentation to the commission.

There has been no stakeholder input whatsoever, and global warming effects that are changing the dynamics of the bass fishery have also not been accounted for. I, like most fishermen, agree and accept conservations measures provided they are well founded, based on meaningful scientific evidence and with fishermen being included and giving input when appropriate to the process.

On this occasion, there is no evidence other than guesswork, assumption and scientists’ personal opinions and predictions. The only concrete scientific data that has been included into the MSY model is the landings. A well-managed fishery needs well-founded scientific data so the correct measures can be applied.

To be honest, I will support the scientists and say that it is not their fault that they have no data on bass recruitment and research; they lack funding. After the EU Fisheries Meeting, the UK Fisheries Minister Mr George Eustice attended a Westminster Hall debate on UK sea bass stocks.

Westminster Hall UK Sea Bass Stocks Debate

The debate was introduced by Mr George Hollingbery MP who, using the very poor scientific evidence, started to make a case for bass measures to be implemented and blaming the commercial fishermen for the alleged scientific evidence before him.

However, he took great pains in trying to lessen what the recreational landings were, as published in a report by the DEFRA, which stated the recreational sea anglers (RSA) landings were between 20-33%. Mr Hollingbery argued that the anglers landed a lot less bass than that. The Angling Trust (TAT) bass management proposals were introduced and appear to be formally adopted. TAT is a small minority group of RSAs and have found great favour in the corridors of power everywhere.

Mr Hollingbery introduced a report from Blue Marine Foundation (BMF), which is only a portrayal of their own environmental ideology and does not exactly allow for co-existence with the commercial fishing sector, and quoted from it: “The oceans are ours, its time we claimed them back”. The concocted BMF report calls for a hook only bass fishery.

Mr Hollingbery is a keen sea angler and the large majority of debating MPs are either anglers or close members of their families are. One former, and the current fisheries minister, also have angling self-interest.

The debate itself was nothing more than a private MPs members-only angling club debate with a like-minded report thrown in by an environmental group, and a management plan adopted from a small group of anglers. TAT’s proposals for bass measures, along with the BMF report, found good favour amongst the majority of MP’s with angling self-interest. The main theme of the debate centred on the BMF report and, in particular, the economic worth between the RSA and commercial fishing industry.

Mr Hollingbery stated, “We know for a fact that recreational bass fishing is worth far more to the economy than commercial fishing. It is also clear that the economic activity generated by recreational angling dwarfs that of the commercial sector. Sea Angling 2012 shows that there are 884,000 sea anglers in England. They directly pump £1.23 billion into the economy and 10,500 full-time jobs depend on that spending. Indirect spend is equivalent to £2.1 billion and 23,600 jobs. Those figures are direct from the Department.

“It is also worth noting that the VAT alone that is collected from sea anglers dwarfs the entire first sale value of all commercial fish landings in the UK. That demonstrates the scale of the economic benefit of recreational angling. All the evidence points inescapably towards it being an extremely important stream of revenue. Finally, does the Minister agree that the development of sea bass fishing as a recreational activity is the best long-term solution?”

It comes as no surprise that, with a large contingency of MPs with angling self-interest, the debate chose the economics of the RSA over that of the commercial fishing industry along with the majority requesting the bass fishery to be RSA fishery only. To me, the debate appeared to be anti-commercial and nothing short of a ‘lynch mob’. The debate was supposed to be about bass stocks, not about the economic worth between two different stakeholders or MPs with angling self-interest having the bass fishery for their own personal use.

At least one MP raised a balanced question. Mr Bernard Jenkin (Harwich and North Essex) said: “We also have very small-scale inshore fishermen who catch sea bass. Do they have a future in my hon. Friend’s scheme, or will they be squeezed out by the ban on commercial fishing?”

George Hollingbery (Meon Valley) replied: “People who run sub-10m boats will find that they make a much better living from taking out and guiding recreational fishing than from trawling for a few vulnerable sea bass out in the ocean. I think that reality will dawn and that most of them will end up in the recreational sector.”

I find it completely incomprehensible. The biased nature that the debate took on with regard to the economic worth between two different stakeholders and a ban on commercial fishing was shocking. And the Fisheries Minister and the chairman did not intervene and bring the debate to order.

The Fisheries Minister Mr George Eustice MP concluded the bass debate by stating, “First, on the value of recreational angling, I should declare an interest because my brother fishes bass in Cornwall and regularly lobbies me on bass stocks.” He also stated: “Finally, I will be going to Europe and to the Fisheries Council to get the best deal we can.”

With a large majority of MPs with angling self-interest giving favour to TAT’s bass management plan and choosing the economics of the RSA’s and calls for hook-only RSA bass fishery, and with no balanced view afforded from the fishing industry, this leads to only one conclusion. In my opinion, Fisheries Management is now being determined by abolishing democracy and using parliamentary privilege to introduce fishery policies conducive to some MPs with angling interests, at the cost and detriment of the commercial fishing industry.

The Fisheries Minister Mr George Eustice MP, primed with the calls and wishes for an angling-only bass fishery, based on the Government’s enormous vested economic interest in the RSA industry and the aspirations of the MP’s angling club members at Westminster Hall Debate, went off to Europe and to the Fisheries Council to get the best deal he can…

European Fisheries Council and introduction of current bass measures

At the European Fisheries Council meeting, the Fisheries Minister Mr George Eustice MP and/or members of his staff forced or pressurised the Fisheries Commission into introducing emergency measures for the European stock of bass. These measures were introduced early this year, and are now the current measures. It was also agreed that further measures would be introduced in 2016.

Current bass measures

The current measures are:

  • The introduction of a ban on pair trawling during the breeding season.
  • A decrease in quota/landing limitation, which varies in accordance with fishing method.
  • An increase in minimum landing size (MLS) from 36 to 42cm.
  • A three fish bag limit for the RSA.

Trawlers (that create most discards) received 1800kg, low impact longline/rod and line, which is an inherently sustainable fishing method, only received 1300 kg and low impact netting received 1000kg. ICES recommended an 80% decrease in landings and the quota/landing limitation is five tonnes per week. Your quota/landing limitations have far exceeded this recommendation. The pair trawl ban, increase in the MLS and three fish bag limit on anglers adds significantly to the already 80% plus decrease in landings.

It is disappointing to note that the EU Fisheries Commission did not allocate quota/landing limitation for low impact fishing methods as in accordance with Article 17 of the reveiwed CFP. Also, the Commission produced no report on the socio-economic effects for small-scale inshore fishing communities before the introduction of the current bass measures – another requirement of Article 17.

It raises the question as to why does the EU Fisheries Commission flaunt their own rules so as to disadvantage the low-impact small-scale coastal fishing communities?

Proposed bass measures for 2016

It appears that the Commission has acceded to the UK’s pressure to impose a six-month ban on the bass fishery (commencing 1 January 2016) and for a quota/landing limitation of 1000kg for the remaining six-months of the year.

Seiners, one of the largest discards creators, have been given favour by being allowed to land a 1% bycatch of bass during the banned period. This gives them the legal right to have bass on board their vessels, which is open to abuse.

A significant amount of fishermen have, through lack of quota and draconian rules such as latent capacity capping, been back into the bass fishery. Hundreds of small-scale coastal fishing vessels and their crews will be put out of business and, in some cases, whole fishing communities. These fishermen use rod and line and longlines to catch bass and are unable to fish for anything else.

The enormous amount of fishermen displaced from the bass fishery will bring their focus to bear on other fisheries. Massive amounts of bottom set nets will be deployed in mixed fisheries, which in turn will greatly increase the bass discards. Also, with no cod quota and with small derisory quotas for skate and plaice the discards on these three species will soar. Discards on protected species such as tope, undulate ray and spur dog will also go through the roof.

The bass ban will create conflicts between RSA charter boats, private RSA with their own boats and commercial fishermen. Pollock still has a reasonable quota and inhabit the wrecks mostly, large shoals of cod and bass can also be found there. The RSA and charter boats will be displaced from the wrecks by the large volume of wreck nets. The inevitable discards on cod and bass will be enormous.

Fishermen still have to earn a living somehow.

Why have ICES not included displacement values for the above in their submitted report? It will not take long for other species to fall below the MSY B trigger because of the unpredicted and unmentioned knock-on effects. Finally, one of the largest losses to is due to weather (a natural conservation measure) that only exists for the low impact small-scale inshore coastal fishing communities.

…This concludes the ‘Loss’ part of the Profit and Loss Account…

As stated in the Westminster Hall Debate, the revenue from the small-scale coastal fishing communities is of very little value or worth to the Government. The UK Government has an enormous vested financial interest in the aggregate dredging, wind farm and RSA industries. They also have massive voting potential by appeasing the vast numbers of RSAs and environmentalists by implementing their single-minded ideology for the search of a pristine marine environment and the want to destroy small coastal fishing communities in the process.

Fisheries management in the UK has become more about vested financial interest and environmental implementation and less about fisheries management. The socio-economic wellbeing of low-impact small-scale coastal fishing communities is of no importance to the Fisheries Managers.

In my opinion, and considering all of the aforementioned, I am left to conclude that coastal fishing communities are being destroyed purposely to make way for the areas for sustaining the Government’s vested financial interests and the areas that are vote pullers. If this is not the case, then the Government and their fisheries departments are so out of touch and oblivious to the above-mentioned affects on small-scale fishing communities that they are forcing to the brink of ruination.

Profit account

For the vast amount of small-scale fishers, the meagre derisory quotas, latent capacity capping and lack of areas to fish means opportunities to derive an income are very limited. Allowing for all the running expenses incurred and the hours worked, most small-scale fishermen at this time in the UK are earning well below the minimum wage.

If the quotas had been proportionately allocated in the first place, and the yearly quotas were allocated in accordance with Article 17 of the reformed CFP, then the small-scale coastal fishers would have been in a far more comfortable position than they are now. And they may have been able to withstand a six-month ban on bass, even more so if the insidious latent capacity capping was not introduced.

…That concludes the ‘Profit’ part of the Profit and Loss Account…

The UK – that’s to say the MPs with angling self-interest, a minority group of anglers and an environmental organisation – have collectively pressured the EU Fisheries Commission into introducing the current measures on bass, and proposed measures for next year. I believe there real motivation is to have the entire bass fishery for their exclusive use and to achieve this, have seized upon non-existent scientific data. I sincerely trust that the proposed six-month ban is not a knee jerk reaction from the Commission to the enormous pressure applied by the angling and environmental fraternities.

The basic, fundamental principles of good fisheries management are (in a nutshell): identify problem, create planning policy for it, implement measures, measure and report effectiveness of measures, readjust planning policy if needed.

The current measures introduced this year are far in excess of ICES recommendations; they have not been given enough time for any meaningful appraisal. I therefore suggest you do not introduce the six-month ban as yet. With regard to the proposed six-month ban for next year, no consultation or socio-economic report has been taken into account as in accordance with the CFP. Ordinarily, the UK fisheries department and the EU Fisheries Commission do not bother with balancing the socio-economic effects on small-scale fishers when formally determining and implementing restrictive conservation measures and quotas. There is a requirement to do so under the Habitats Act and Article 17 of the CFP reform.

Please accept this letter/report as an honest and factual account of the current socio-economic state of small-scale coastal fishers of the UK.

In light of the above report and the facts contain herein, if you still wish to proceed with the six-month ban on the bass fishery, I should inform you that the Fisheries Commission will be destroying the UK’s low-impact, small-scale fishermen and there coastal fishing communities. In the first instance, over 1000 men will be without employment and a significant number will follow over time.

It would be prudent and fully acceptable within the framework and intended spirit of the reformed CFP, to mitigate the demonstrable affects to the most vulnerable small-scale fishers in the coastal communities, not just in the UK but in the whole of Europe. I would suggest that if the bass ban does go ahead, the most vulnerable under-10m low-impact small-scale coastal fishermen that use rod and line and long lines (hooks) be given a quota. This would prevent massive unemployment loses and ensure the maintenance of there socio-economic wellbeing, even at its present low level. Quotas for the six-month banned period could be underpinned at a minimum guaranteed level.

There is, as I see it, a problem of non-compatibility between the assumption based MSY model (deficient of any creditable data) and the aims of Article 17 regarding the socio-economics. This type of MSY model creates unemployment.

I would suggest that scientists should be able to obtain grant funding from the European Fisheries Fund for data collection on recruitment to fish stocks and research. If the MSY model was updated with enough scientific data, then better management decisions would be made, which in turn would prevent fishermen from becoming unemployed. The MSY model may then be more compatible with Article 17 of the CFP.

The decision regarding the six-month bass ban – that may leave thousands of vulnerable low impact fishers unemployed – rests solely with the Fisheries Commission. Please make the right decision based on a balance between the poor assumption-based MSY model, which lacks any creditable data whatsoever, and the need to fulfil the spirit of Article 17 of the CFP on socio-economics for low-impact small-scale fishing communities.

Finally, it is time for the EU Fisheries Commission to sort out the mess that the UK Fisheries Departments have created with regard to the inadequate quotas and latent capacity capping that are contrary to Article 17. This is of paramount importance and should be remedied as soon as possible so as to secure employment and a sustainable future for the low-impact, small-scale fishers of the UK; only the Fisheries Commission can save the UK scale fishers.

Yours sincerely,

S.P.Gathergood

Gosport

Hampshire

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Dear Mr Cameron,

At the Commonwealth Summit in Malta you announced £5.6m in aid to be spent next year to help the Caribbean Islands with their maritime economies of tourism, shipping and fishing.

I would say that was a very kind, generous, if not laudable, thing to do, if it were not for the fact that the small-scale coastal fishermen of this country are on the brink of ruination.

Government policy, or its own agenda that your fisheries departments (DEFRA/MMO) are working to, are responsible for the dire straits of the small-scale fishermen of this country.

My report ‘The Demise of the Low Impact Small Scale Fishing Communities’ fully explains the reasons for the current position they have been placed in.

I would ask you to debate the contents of the report in the House of Commons so as to find a solution for the small-scale fishermen’s problems, because your fisheries departments are unable to do so.

I sincerely trust that if you manage to debate this very important problem, it will be dealt with in a more democratic way than the debate on UK Sea Bass Stocks at Westminster Hall on the 3 December 2014. This is fully explained in the accompanying report.

I look forward to your reply.

Yours sincerely,

Stephen Gathergood

Report: The demise of the low impact small-scale coastal fishing communities (Profit and Loss Account) Dear Commissioner Vella, The UK under-10m artisan small-scale coastal fishing communities are in dire straits and on the verge of total collapse. The UK Government and its fisheries departments have created this situation for the low-impact small-scale coastal fishermen. Without intervention from the EU Commission these fishing communities will cease to exist at all. I wish to formally outline the series of events and circumstances that has led up to the impossible situation that the UK small-scale fishermen have been placed in. Loss Account Quotas The original UK fishing quotas were disproportionately, and inappropriately, allocated by the fisheries department – whether this was by design or incompetence is open to question. The small-scale under and over 10m vessels in the non-sector public pool, which accounts for 87% of the UK fishing fleet, only received a derisory 4% of the quotas. The Common Fisheries Policy (CFP) has formally passed through its review, however quotas that are part and parcel of the CFP have not. I would ask you why the quotas were not reviewed for practicality, workability and fairness of allocation? The UK Fisheries Department are not allocating quota to low impact small-scale fishermen as in accordance with Article 17 of the reformed CFP. I would also like to ask you what mediation process is in place for fishermen to make representation on what I believe has been a gross mis-allocation of UK fishing quotas? The lack of quota allocation on pressure stock species has had a devastating effect on the small-scale coastal fishermen, many of who found the derisory quotas unsustainable. Many fishermen were forced, by lack of quota, into diversifying into non-pressure stock species such as bass. UK Latent Capacity If the UK fisheries department competently allocated the quotas in the first place, there would be no need for Latent Capacity capping. In an attempt to try to create the illusion of more quota for some, the UK fisheries department came up with this disingenuous idea and imposed a draconian method of preventing fishermen from using their legal quota entitlement. Latent Capacity is applied to fishermen when they have not caught 300 kilo of pressure stock species in a certain time frame. They are then capped at 300 kilo of pressure stock species for the entire year. The chronic lack of quota in the small-scale under-10 sector is justifiably the fault of the UK fisheries department; it is not the fault of the fishermen. To add latent capacity capping just adds insult to injury and greater hardship. Small-scale fishermen need to be allowed to take into account all the prevailing circumstances such as amounts of seaweed, weather and tidal conditions, available quota and what species of fish are available. The whole fundamental principle of a successful small-scale fisherman is to remain multi-purpose, because this is what makes his living sustainable. Latent Capacity, by its very design, nature and implementation, destroys these principals. Another round of Latent Capacity has gone through its formal predetermined consultation process, which is surprising bearing in mind that no competent management report has been produced in terms of benefit or loss to the Latent Capacity planning policy for the previous round. It raises the question: do the fisheries managers care or are they acting in accordance with their own secret agenda? The predetermined Latent Capacity capping consultation on shellfish has also been concluded and to my knowledge there is no national planning policy on its regulation. Again, small scale fishermen’s rightful entitlement to fish will be eroded along with their social and economic wellbeing, which has not been accounted for in any of the latent capacity capping processes. Latent capacity capping is illegal and contrary to Article 17 of the reformed CFP. Social sustainability is one of the core CFP objectives and to prevent severe negative impacts on the viability of most vulnerable coastal communities that aim to achieve the following social objectives

  • Reversing the decline in employment in the fisheries sector, particularly in catching.
  • Increasing the attractiveness of the fisheries sector and turning it into a source of high quality jobs.
  • Ensuring the viability of coastal communities by promoting economic growth and jobs
  • Facilitating the transition to a sustainable fishing

Latent capacity capping destroys a fisherman’s opportunity to diversify so as to maintain or increase his income. Inquiry I would ask the EU Fisheries Commission to hold an inquiry into why the small-scale inshore coastal fishermen have received such a derisory 4% quota, and why they been discriminated against with latent capacity capping. Also, why do the UK Fisheries Department not allocate quota to low-impact small-scale fishermen in accordance with Article 17. Equal access to a common resource I’m sure that you’re aware that equal access to a common resource is supposed to be applicable to all fishermen, from all member states. However, this is not the case for the UK’s small-scale coastal fishing communities. These fishing communities, for the most part, use low-impact, static, sustainable fishing methods such as long lining, rod and line, large mesh set nets and pots that produce insignificant discards. The large EU Member State trawlers are continually trawling outside the UK’s six-mile fishery limit. This prevents the UK’s small-scale fishermen from setting their static fishing gear outside the six-mile fishery limit. Member state trawlers have therefore retained a monopoly over this area to the financial detriment of the local small-scale UK fishermen. I would ask you, is this not contrary to the EU laws with regard to equal access to a common resource and the fair competition act? Notwithstanding this, the fact of the matter is that small-scale local fishermen have been forced into a vastly reduced area and are having their fish stocks reduced unfairly by the very large European trawler fleet that are fishing so close to the UK’s coast. Equal access to a common resource does not work for everyone and in particular the local small-scale fishermen of the UK. Spatial management To rebalance the equal access to a common resource so that it is fair to all, I would suggest that the six to 12-mile fishery limits should be made into zones. A zone for no towed gear whatsoever and a zone for towed gear. These two zones should alternate and take up the entire area from the six-mile to the 12-mile fishery limit and should go all the way around the UK – it could be established in all member state countries. The other benefit would be that all the zones that are static fishing gear only would, in essence, become conservation zones. EU Fisheries Commission – Over capacity   The EU Fisheries Commission is in part to blame for the demise of the UK’s small-scale coastal fishing communities. Apart for being responsible for the content (as explained in ‘equal access to a common resource’ above), the EU Fisheries Commission has never tackled the main problem that exists in the European fisheries and that is over capacity. The Commission has always allowed the over capacity to expand year-on-year without taking meaningful preventative measures. There has been an immense expansion in over capacity in recent years with the introduction of wider and higher bottom fishing trawls, wider and deeper mid water trawls, twin trawls, triple trawls and multi trawl rig and electric beam trawls. The consequences of this have significantly reduced the economic returns for the local small-scale coastal fishermen, who are forced and confined to working inside the six-mile fishery limit. It has allegedly been reported that some member state Governments have paid large subsidies to their fishing fleets, in particular, France. If this is the case, then subsidies increase over capacity and higher fish mortality and create even more unfair competition. The net loss in the expansion of uncontrolled latent capacity has been an enormous rise in the level of discards by Member State trawlers and seiners. Discards Small-scale coastal fishermen (as previously mentioned) do not create significant discards. However, they will be disadvantaged by having to comply with the unnecessary forthcoming discard ban. If the EU Fisheries Commission had acted responsibly on over capacity by banning twin, treble and multi rig trawls and decrease the width, height and/or depth of all other trawls, there would have been a huge reduction in over capacity and discards, and no need for a ban. Something the Commission should be looking into. Aggregate dredging The Crown Estate Commissioners are charged with gleaning as much profit out of the marine environment as prevailing circumstances allow and the surplus revenue is paid each year to H M Treasury. The Crown Estate is formally accountable to Parliament. The Monarch will receive from the Treasury a grant indexed to a percentage of the Crown Estate’s annual net revenue (currently set at 15%). The revenue the Crown Estate receives is reported to be in excess of £100 million per year, plus the Treasury would also collect the Value Added Tax. In 2010, a UK Parliament Treasury Committee report on the Crown Estate stated “the Crown Estate has a monopoly over the marine environment, and has focused too strongly on collecting revenues rather than acting in the long-term public interest around ports and harbours.” In recent years, aggregate production is meeting European demand and in excess of 50% of the total production is being exported directly from the licenced aggregate dredging areas. Aggregate dredging completely destroys the marine environment by removing all the eco-systems and biodiversity. The, once prolific, feeding and breeding grounds for fish are turned into nothing more than a lunar landscape. The sediment fall-out also affects large areas outside the licenced area. Fishermen have been forced off the aggregate licence areas thus losing part of their living now, and in the future. The Crown Estate have never considered recompensing the fishermen for the loss of their fishing grounds, in fact, they are only interested in gross revenue profit and have nothing to do with what is in the public interest. The combined total of marine licenced aggregate dredging areas is well in excess of 1500 square miles, mainly coastal inshore waters, and once again this is decreasing the area that small-scale coastal fishermen can operate in. Wind farms The real extent of the combined total sea area that will be taken up by wind farms – established around the coast of the UK – is not yet known. The formal determination process is still on going. However, the ones that have been completed have yet again decreased the small-scale coastal fishermen’s area of operation. All the future wind farms will also greatly decrease the fishermen’s area even more. It’s been alleged that when all the wind farms are completed, the Crown Estates may receive five times more revenue than that of the aggregate dredging industry. If that is the case, the UK Monarch and the H M treasury are in for an enormous windfall. It would appear that the revenue from aggregate dredging and wind farms dwarf that of the inshore coastal small-scale fishing communities. These two industries will continue to expand and decrease the available fishing grounds. European Marine Protected Areas These areas have been recently introduced in the UK. They were hurried through their formal determination process because the European deadline was about to run out. In my area, the consultation was predetermined and therefore meaningless. There was no site-specific social and economic report and no scientific evidence. A vast area was closed down and no bottom towed gear bylaw was introduced. The consequence to the local small-scale fishermen was a 20-25% decrease in their income for no reason. Again, more sea area lost for small-scale coastal fishing communities. I ask you, where do these fishermen seek compensation from? Marine Protected Areas Marine Protected Areas are being introduced mainly to appease what has become a very large increase in the environmental and green movements. They are also a very good ‘vote puller’ for any political party willing to dance to their tune. There are many like-minded people throughout the corridors of power. The only problem with this is that they are uncompromising and prejudiced towards the fishing industry. Their idealism lacks rationalisation and fairness, and there is no intention of coexistence with the fishermen. Marine Protected Areas that have already been implemented are meaningless. No, or very little, scientific evidence has been provided and most have been implemented on a precautionary basis. Nobody seems to know what is being protected or why and more importantly, there is no way that future fisheries managers will be able to report on any net benefit in terms of profit or loss in a measured way to the main planning policy that established them in the first place. The second round of Marine Protected Areas has passed through its predetermined consultation period. In my area, there are three MPAs, one of which is 550sq.km; the level of protection will not be known until after confirmation of consent. No site-specific socio-economic losses were taken into account. Fishermen are expected to subsidise other people’s conservation ideology free of charge. No compensation has been forthcoming. The development of the marine environment is a total shambles because there is no coherent planning policy. It is just adhoc and piecemeal implementation. Again, small-scale coastal fishermen continue to lose their fishing grounds. Department for Environment, Food & Rural Affairs (DEFRA), Marine Management Organization (MMO) I’m of the opinion that DEFRA and the MMO are total ‘green’ environmental departments. Their consultations seem to be predetermined and they haven’t appeared to carry out meaningful socio-economic assessments when formally determining quotas, MPAs and other such matters. These departments do not allocate quota in accordance with Article 17 of the reformed CFP. Ironically, they pushed for the reforms and now do not want to abide by them. Draconian rules are introduced like latent capacity capping, again contrary to Article 17. Fishermen feel discriminated against, alienated and are worried for the future. I believe that the departments show favour to RSA and environmental groups and do not take a balanced view from all stakeholders. As a fisherman, I have found it very difficult, near impossible, to speak to a member of staff in authority over telephone. And all letters are answered by customer services with meaningless waffle, far removed from the issues raised. Inshore Fisheries and Conservation Authority (IFCA) The IFCA manage the UK fisheries out to the six-mile fishery limit and they boast that in excess of 25% of their district is taken up with Marine Protected Areas, the majority of which have fishing restrictions. I get the impression that IFCA are preoccupied with introducing as many MPAs as they can so as to prevent commercial fishing from taking place, thus justifying their review every four years. There is no stakeholder involvement. They have given away part of their management responsibilities to environmental groups. Environment Agency Although recent surveyed water testing has resulted in nothing untoward, the Environment Agency has de-classified parts of my area from a B to a C using a year-old survey. This means fishermen cannot land the shellfish from these areas for human consumption. Bass Nursery Areas Fishermen support sensible, meaningful conservation measures such as this one, however the 34 Bass Nursery Areas collectively take up a vast area that the small-scale fishermen are unable to work. Other Areas There are many other areas where small-scale fishermen are prohibited from working, such as HM Dockyard and British Ports no fishing areas, capital dredging dumping sites and ships anchorages – to name just a few. Summary Through lack of rightful pressure stock quota provision, latent capacity capping and another round pending with shellfish capping, hundreds of small-scale coastal fishermen have been forced or steered into the last viable fishery open to them, which is the bass fishery. The areas that these fishermen can catch their meagre quota has diminished at an alarming rate and this will continue to be the case for some considerable time to come. All of the above mentioned combined factors have led the small-scale coastal fishermen to the very brink of ruination. I sincerely trust that you can grasp and appreciate the importance of the dire position that the UK small-scale coastal fishing communities have now been placed in. I wish that I could inform you that this was the whole of the matter. Unfortunately, the worst is still to come.

Commissioner Karmenu Vella

Skipper Stephen Gathergood’s Gosport-based inshore catamaran, Phyllis John.

EU Fisheries meeting & international council for the Exploration of the Sea (ICES) Bass stock report In 2014, a meeting of member state ministers convened to discuss the ICES report on bass stocks. The meeting closed without any agreement. ICES Scientific Report Bass Stocks ICES advise that when the Maximum Sustainable Yield (MSY) approach is applied, total landings in 2016 should be no more than 541t. The problem with managing a fishery with a tool such as the MSY approach is that it is not so much of a science it is more of an unknown gamble, and can go terribly wrong. It is based, in most parts, on pure assumptions. It tends to look at the benefits without looking at the costs. The ICES scientific report presented to the Fisheries Commission is grossly flawed and lacking in data. In my opinion, it is a misrepresentation to the commission. There has been no stakeholder input whatsoever, and global warming effects that are changing the dynamics of the bass fishery have also not been accounted for. I, like most fishermen, agree and accept conservations measures provided they are well founded, based on meaningful scientific evidence and with fishermen being included and giving input when appropriate to the process. On this occasion, there is no evidence other than guesswork, assumption and scientists’ personal opinions and predictions. The only concrete scientific data that has been included into the MSY model is the landings. A well-managed fishery needs well-founded scientific data so the correct measures can be applied. To be honest, I will support the scientists and say that it is not their fault that they have no data on bass recruitment and research; they lack funding. After the EU Fisheries Meeting, the UK Fisheries Minister Mr George Eustice attended a Westminster Hall debate on UK sea bass stocks. Westminster Hall UK Sea Bass Stocks Debate The debate was introduced by Mr George Hollingbery MP who, using the very poor scientific evidence, started to make a case for bass measures to be implemented and blaming the commercial fishermen for the alleged scientific evidence before him. However, he took great pains in trying to lessen what the recreational landings were, as published in a report by the DEFRA, which stated the recreational sea anglers (RSA) landings were between 20-33%. Mr Hollingbery argued that the anglers landed a lot less bass than that. The Angling Trust (TAT) bass management proposals were introduced and appear to be formally adopted. TAT is a small minority group of RSAs and have found great favour in the corridors of power everywhere. Mr Hollingbery introduced a report from Blue Marine Foundation (BMF), which is only a portrayal of their own environmental ideology and does not exactly allow for co-existence with the commercial fishing sector, and quoted from it: “The oceans are ours, its time we claimed them back”. The concocted BMF report calls for a hook only bass fishery. Mr Hollingbery is a keen sea angler and the large majority of debating MPs are either anglers or close members of their families are. One former, and the current fisheries minister, also have angling self-interest. The debate itself was nothing more than a private MPs members-only angling club debate with a like-minded report thrown in by an environmental group, and a management plan adopted from a small group of anglers. TAT’s proposals for bass measures, along with the BMF report, found good favour amongst the majority of MP’s with angling self-interest. The main theme of the debate centred on the BMF report and, in particular, the economic worth between the RSA and commercial fishing industry. Mr Hollingbery stated, “We know for a fact that recreational bass fishing is worth far more to the economy than commercial fishing. It is also clear that the economic activity generated by recreational angling dwarfs that of the commercial sector. Sea Angling 2012 shows that there are 884,000 sea anglers in England. They directly pump £1.23 billion into the economy and 10,500 full-time jobs depend on that spending. Indirect spend is equivalent to £2.1 billion and 23,600 jobs. Those figures are direct from the Department. “It is also worth noting that the VAT alone that is collected from sea anglers dwarfs the entire first sale value of all commercial fish landings in the UK. That demonstrates the scale of the economic benefit of recreational angling. All the evidence points inescapably towards it being an extremely important stream of revenue. Finally, does the Minister agree that the development of sea bass fishing as a recreational activity is the best long-term solution?” It comes as no surprise that, with a large contingency of MPs with angling self-interest, the debate chose the economics of the RSA over that of the commercial fishing industry along with the majority requesting the bass fishery to be RSA fishery only. To me, the debate appeared to be anti-commercial and nothing short of a ‘lynch mob’. The debate was supposed to be about bass stocks, not about the economic worth between two different stakeholders or MPs with angling self-interest having the bass fishery for their own personal use. At least one MP raised a balanced question. Mr Bernard Jenkin (Harwich and North Essex) said: “We also have very small-scale inshore fishermen who catch sea bass. Do they have a future in my hon. Friend’s scheme, or will they be squeezed out by the ban on commercial fishing?” George Hollingbery (Meon Valley) replied: “People who run sub-10m boats will find that they make a much better living from taking out and guiding recreational fishing than from trawling for a few vulnerable sea bass out in the ocean. I think that reality will dawn and that most of them will end up in the recreational sector.” I find it completely incomprehensible. The biased nature that the debate took on with regard to the economic worth between two different stakeholders and a ban on commercial fishing was shocking. And the Fisheries Minister and the chairman did not intervene and bring the debate to order. The Fisheries Minister Mr George Eustice MP concluded the bass debate by stating, “First, on the value of recreational angling, I should declare an interest because my brother fishes bass in Cornwall and regularly lobbies me on bass stocks.” He also stated: “Finally, I will be going to Europe and to the Fisheries Council to get the best deal we can.” With a large majority of MPs with angling self-interest giving favour to TAT’s bass management plan and choosing the economics of the RSA’s and calls for hook-only RSA bass fishery, and with no balanced view afforded from the fishing industry, this leads to only one conclusion. In my opinion, Fisheries Management is now being determined by abolishing democracy and using parliamentary privilege to introduce fishery policies conducive to some MPs with angling interests, at the cost and detriment of the commercial fishing industry. The Fisheries Minister Mr George Eustice MP, primed with the calls and wishes for an angling-only bass fishery, based on the Government’s enormous vested economic interest in the RSA industry and the aspirations of the MP’s angling club members at Westminster Hall Debate, went off to Europe and to the Fisheries Council to get the best deal he can… European Fisheries Council and introduction of current bass measures At the European Fisheries Council meeting, the Fisheries Minister Mr George Eustice MP and/or members of his staff forced or pressurised the Fisheries Commission into introducing emergency measures for the European stock of bass. These measures were introduced early this year, and are now the current measures. It was also agreed that further measures would be introduced in 2016. Current bass measures The current measures are:

  • The introduction of a ban on pair trawling during the breeding season.
  • A decrease in quota/landing limitation, which varies in accordance with fishing method.
  • An increase in minimum landing size (MLS) from 36 to 42cm.
  • A three fish bag limit for the RSA.

Trawlers (that create most discards) received 1800kg, low impact longline/rod and line, which is an inherently sustainable fishing method, only received 1300 kg and low impact netting received 1000kg. ICES recommended an 80% decrease in landings and the quota/landing limitation is five tonnes per week. Your quota/landing limitations have far exceeded this recommendation. The pair trawl ban, increase in the MLS and three fish bag limit on anglers adds significantly to the already 80% plus decrease in landings. It is disappointing to note that the EU Fisheries Commission did not allocate quota/landing limitation for low impact fishing methods as in accordance with Article 17 of the reveiwed CFP. Also, the Commission produced no report on the socio-economic effects for small-scale inshore fishing communities before the introduction of the current bass measures – another requirement of Article 17. It raises the question as to why does the EU Fisheries Commission flaunt their own rules so as to disadvantage the low-impact small-scale coastal fishing communities? Proposed bass measures for 2016 It appears that the Commission has acceded to the UK’s pressure to impose a six-month ban on the bass fishery (commencing 1 January 2016) and for a quota/landing limitation of 1000kg for the remaining six-months of the year. Seiners, one of the largest discards creators, have been given favour by being allowed to land a 1% bycatch of bass during the banned period. This gives them the legal right to have bass on board their vessels, which is open to abuse. A significant amount of fishermen have, through lack of quota and draconian rules such as latent capacity capping, been back into the bass fishery. Hundreds of small-scale coastal fishing vessels and their crews will be put out of business and, in some cases, whole fishing communities. These fishermen use rod and line and longlines to catch bass and are unable to fish for anything else. The enormous amount of fishermen displaced from the bass fishery will bring their focus to bear on other fisheries. Massive amounts of bottom set nets will be deployed in mixed fisheries, which in turn will greatly increase the bass discards. Also, with no cod quota and with small derisory quotas for skate and plaice the discards on these three species will soar. Discards on protected species such as tope, undulate ray and spur dog will also go through the roof. The bass ban will create conflicts between RSA charter boats, private RSA with their own boats and commercial fishermen. Pollock still has a reasonable quota and inhabit the wrecks mostly, large shoals of cod and bass can also be found there. The RSA and charter boats will be displaced from the wrecks by the large volume of wreck nets. The inevitable discards on cod and bass will be enormous. Fishermen still have to earn a living somehow. Why have ICES not included displacement values for the above in their submitted report? It will not take long for other species to fall below the MSY B trigger because of the unpredicted and unmentioned knock-on effects. Finally, one of the largest losses to is due to weather (a natural conservation measure) that only exists for the low impact small-scale inshore coastal fishing communities. …This concludes the ‘Loss’ part of the Profit and Loss Account… As stated in the Westminster Hall Debate, the revenue from the small-scale coastal fishing communities is of very little value or worth to the Government. The UK Government has an enormous vested financial interest in the aggregate dredging, wind farm and RSA industries. They also have massive voting potential by appeasing the vast numbers of RSAs and environmentalists by implementing their single-minded ideology for the search of a pristine marine environment and the want to destroy small coastal fishing communities in the process. Fisheries management in the UK has become more about vested financial interest and environmental implementation and less about fisheries management. The socio-economic wellbeing of low-impact small-scale coastal fishing communities is of no importance to the Fisheries Managers. In my opinion, and considering all of the aforementioned, I am left to conclude that coastal fishing communities are being destroyed purposely to make way for the areas for sustaining the Government’s vested financial interests and the areas that are vote pullers. If this is not the case, then the Government and their fisheries departments are so out of touch and oblivious to the above-mentioned affects on small-scale fishing communities that they are forcing to the brink of ruination. Profit account For the vast amount of small-scale fishers, the meagre derisory quotas, latent capacity capping and lack of areas to fish means opportunities to derive an income are very limited. Allowing for all the running expenses incurred and the hours worked, most small-scale fishermen at this time in the UK are earning well below the minimum wage. If the quotas had been proportionately allocated in the first place, and the yearly quotas were allocated in accordance with Article 17 of the reformed CFP, then the small-scale coastal fishers would have been in a far more comfortable position than they are now. And they may have been able to withstand a six-month ban on bass, even more so if the insidious latent capacity capping was not introduced. …That concludes the ‘Profit’ part of the Profit and Loss Account… The UK – that’s to say the MPs with angling self-interest, a minority group of anglers and an environmental organisation – have collectively pressured the EU Fisheries Commission into introducing the current measures on bass, and proposed measures for next year. I believe there real motivation is to have the entire bass fishery for their exclusive use and to achieve this, have seized upon non-existent scientific data. I sincerely trust that the proposed six-month ban is not a knee jerk reaction from the Commission to the enormous pressure applied by the angling and environmental fraternities. The basic, fundamental principles of good fisheries management are (in a nutshell): identify problem, create planning policy for it, implement measures, measure and report effectiveness of measures, readjust planning policy if needed. The current measures introduced this year are far in excess of ICES recommendations; they have not been given enough time for any meaningful appraisal. I therefore suggest you do not introduce the six-month ban as yet. With regard to the proposed six-month ban for next year, no consultation or socio-economic report has been taken into account as in accordance with the CFP. Ordinarily, the UK fisheries department and the EU Fisheries Commission do not bother with balancing the socio-economic effects on small-scale fishers when formally determining and implementing restrictive conservation measures and quotas. There is a requirement to do so under the Habitats Act and Article 17 of the CFP reform. Please accept this letter/report as an honest and factual account of the current socio-economic state of small-scale coastal fishers of the UK. In light of the above report and the facts contain herein, if you still wish to proceed with the six-month ban on the bass fishery, I should inform you that the Fisheries Commission will be destroying the UK’s low-impact, small-scale fishermen and there coastal fishing communities. In the first instance, over 1000 men will be without employment and a significant number will follow over time. It would be prudent and fully acceptable within the framework and intended spirit of the reformed CFP, to mitigate the demonstrable affects to the most vulnerable small-scale fishers in the coastal communities, not just in the UK but in the whole of Europe. I would suggest that if the bass ban does go ahead, the most vulnerable under-10m low-impact small-scale coastal fishermen that use rod and line and long lines (hooks) be given a quota. This would prevent massive unemployment loses and ensure the maintenance of there socio-economic wellbeing, even at its present low level. Quotas for the six-month banned period could be underpinned at a minimum guaranteed level. There is, as I see it, a problem of non-compatibility between the assumption based MSY model (deficient of any creditable data) and the aims of Article 17 regarding the socio-economics. This type of MSY model creates unemployment. I would suggest that scientists should be able to obtain grant funding from the European Fisheries Fund for data collection on recruitment to fish stocks and research. If the MSY model was updated with enough scientific data, then better management decisions would be made, which in turn would prevent fishermen from becoming unemployed. The MSY model may then be more compatible with Article 17 of the CFP. The decision regarding the six-month bass ban – that may leave thousands of vulnerable low impact fishers unemployed – rests solely with the Fisheries Commission. Please make the right decision based on a balance between the poor assumption-based MSY model, which lacks any creditable data whatsoever, and the need to fulfil the spirit of Article 17 of the CFP on socio-economics for low-impact small-scale fishing communities. Finally, it is time for the EU Fisheries Commission to sort out the mess that the UK Fisheries Departments have created with regard to the inadequate quotas and latent capacity capping that are contrary to Article 17. This is of paramount importance and should be remedied as soon as possible so as to secure employment and a sustainable future for the low-impact, small-scale fishers of the UK; only the Fisheries Commission can save the UK scale fishers. Yours sincerely,

S.P.Gathergood

Gosport

Hampshire

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