SIFT Comments on Clyde IFG Draft Management Plan July 2011
Comments on Clyde Inshore Fisheries Group
Draft Management Plan
July 2011
Introduction
SIFT is a Scottish charity founded in 2011 with the assistance of Fish Legal (a part of the Angling Trust), COAST (Community of Arran Sea-bed Trust), SCAD (Scottish Creelers & Divers) and others. Its aim is to achieve the sustainable management of Scotland’s inshore waters so that they provide the maximum long term benefits to all coastal communities. At SIFT’s core is a coalition of community and maritime interest groups that object to their local inshore waters being damaged by unfair, short-term fisheries policies. No other organisation represents these diverse community interests and campaigns for fair, sustainable and resilient maritime livelihoods. SIFT has three strategic objectives:
· Protect the inshore marine ecosystem by introducing area bans on shellfish trawls and dredges;
· Adopt fishery policies that take account of the full costs and benefits of all uses of inshore waters;
· Empower communities to have a fairer stake in the management of their local waters.
We have assessed the Clyde IFG draft Local Objectives in terms of their compliance with the High Level Objectives as set out in the Strategic Framework for Inshore Fisheries in Scotland (the Strategic Framework). We comment as follows:
Clyde IFG Local Objectives
Objective (B) (1) “To ensure current target stocks are fished sustainably”
Objective (B) (1) focuses on current target stocks (i.e. shellfish). To be compliant with the Strategic Framework [para.28] the draft should address all commercial stocks. The Strategic Framework specifically advocates against overreliance on one species and further states “where there has been a decline in a particular stock, there is a responsibility to consider scope for restoration”. As members of the IFG will be aware there has been a catastrophic collapse in landings of demersal and pelagic fish within the Firth of Clyde over the last 20 years. A recent report has shown that whilst there are plenty of demersal fish species present, however they are not reaching harvestable size. The report concludes that “changes in demersal community properties had their origins...in the 1960s when the Clyde as a whole was opened up to demersal trawling”[1].
The scale of the problem is illustrated by the following tables:
CLYDE / cod / whiting / haddock / hake / saithe / plaice1984 (20yr.av) / 1730 / 1187 / 432 / 647 / 1660 / 187
1984 (actual) / 1350 / 800 / 200 / 200 / 600 / 180
2009 / 0 / 0 / 0 / 0 / 0 / 0
The above table shows the commercial landings figures for selected white fish species in 1984 in metric tonnes together with a 20 years average annual landings figures estimated at 1984 and landings returns for 2009 for the Firth of Clyde.[2]
The loss of such a fishery is substantial in financial terms. The following table shows what the value of the 1984 (20 year average) landing would be worth based on 2009 fish prices:
CLYDE / cod / whiting / haddock / hake / saithe / plaice1984 (20yr.av) / 1730 / 1187 / 432 / 647 / 1660 / 187
Price (£) per tonne 2009 / 1996 / 1120 / 1150 / 1850 / 950 / 1000
£ / 3453080 / 1329440 / 496800 / 119650 / 1577000 / 187000
Contrary to the requirements of the Strategic Framework this issue has not been examined by the Clyde IFG. The probable reason for this is that the IFG executive committee is constitutionally dominated by the Commercial Fishermen’s Associations of the mobile sector whose member’s trawlers contributed to that collapse.
In conclusion this objective is far too narrowly drawn and does not begin to address SIFAG’s high level biological goal to ‘conserve, enhance and restore commercial stocks in the inshore and its supporting ecosystem’.
Objective (B) (2) “to develop new fisheries on a sustainable basis”
Whilst there is no objection to developing new fisheries if they are genuinely sustainable, we would suggest that this is an economic objective rather than a biological one. In general terms we would suggest that the IFG addresses itself to the collapsed demersal and pelagic fisheries in the Firth of Clyde before addressing the development of new fisheries. We believe that until the lessons of those collapses are fully addressed and learnt, there can be little confidence that new fisheries will not share the same fate of overexploitation and collapse.
Objective (Ec) (3) to maximise returns from fisheries and ensure marketing and processing support is in place for new fisheries.
The Strategic Framework [para.29] states that economic objectives should be sustainable and based upon a long term view. The draft plan, by focussing on ‘maximising returns’ could be construed as legitimising unsustainable short-term fishing practices and short-termism.
The Strategic Framework advises that IFG’s should examine the fisheries in their areas with a view to maximising long term economic benefit. For example, the IFG might have considered the comparative profitability of the mobile and the static nephrops fishery and considered whether the overall profitability of the fishery could be improved by measures that promote a substitution of effort from trawling to creel fishing.
Objective (En) (4) to develop more efficient catching-practices to reduce unwanted catch of target and non-target species.
The Strategic Framework [para.30] advocates the integration of environmental considerations into fisheries management. We would consider that this requires a broad assessment of the damage being done to the marine environment by current fisheries practice. Such an assessment would certainly examine the implications of the huge bycatch of nephrops trawling, however it should also address other widely recognised damages caused by fishing, such as over fishing and damage to the benthos caused by the used of trawled fishing gears[3]. In other words this objective is too narrowly drawn.
Whilst the stated objective of reducing bycatch is welcomed, we are not able to identify any effective measures within the plan that might deliver on this objective or any meaningful indicators which may allow progress to be measured.
Objective (S) (5) to ensure a viable fishing industry and support renewed confidence within fishing communities.
We would suggest that the Strategic Framework [para.31] requires IFGs to examine the wider social benefits that are related to the management and exploitation of our inshore waters. Historically inshore fisheries have been of huge importance to coastal communities both as a cheap and readily available source of food and as a source of employment. Sadly, overexploitation and collapse of finfish populations within the inshore have led to a destruction of those benefits other than to a small and declining number of commercial fishermen.
If confidence is low within fishing communities it is probably because it is recognised that they are now no longer able to benefit from their fishery in way that previous generations would have taken for granted. For example the Firth of Clyde as well as supporting a substantial commercial fin fishery also had a famous recreational sea fishery, which generated income and social benefits for the local populations. Because there are now very few fish to catch the recreational fishery has all but disappeared with the loss of 100s of jobs. Unless the drivers of fishery collapse are addressed as a matter of urgency there will be no viable fisheries and no economic benefit to coastal communities in the foreseeable future. The objective as stated evinces no confidence that the drivers of what makes a fishery ‘viable’ are understood or are likely to be addressed by the Clyde IFG.
Objective (G) (6) to improve decision making and reduce conflict in the sector and between other marine sectors
Improved decision making appears an attractive objective, however it begs the question of what is meant by ‘improved’. The Strategic Framework demands a structure that is ‘transparent, accountable and flexible’ and that places fishermen at the centre of the decision-making process. We agree with that, however we would suggest that it should also be genuinely locally constituted, fair and fit for purpose.
It is our view that the current constitutional arrangements of IFGs are most unlikely to improve decision making in inshore fisheries management other than for the short term benefit of the sectoral interests of the commercial mobile sector. This is for the simple reason that IFG’s are constitutionally dominated by the mobile sector via their commercial fishermen’s associations, therefore any plans generated by them will inevitably reflect their sectoral interests rather than those of other local stakeholders. This reflects a critical failure in the architecture of IFGs. Whilst this situation remains there can be no confidence that management plans produced by IFGs will seriously address either the management issues demanded by an eco-system approach to management or the imperatives of fair access and exploitation of inshore fisheries.
As a secondary point we believe that the draft plan is unlikely to facilitate the achievement of ‘good environmental status’ under the Marine Strategy Framework Directive or indeed ‘good ecological status’ for coastal waters under the Water Framework Directive. More seriously, we believe that the Clyde IFG as currently constituted is unlikely to generate any plan that is compliant with the strategic framework, the High Level Marine Objectives or the 11 descriptor of Good Environmental status.
Conclusions
1. The Clyde draft plan is not compliant with the requirements of the Strategic Framework or other overarching objectives of fisheries governance set out by SIFAG, DEFRA and the EU.
2. The constitutional domination of the IFGs by the mobile sector via their commercial fishermen’s associations is highly likely (as demonstrated by the draft Clyde plan) to result in fisheries plans that reflect their sectoral interests and not the legal priorities that are set out by SIFAG, DEFRA and the EU.
3. The constitutional set up of IFGs needs to be adjusted as a matter of urgency to address the above problems.
29 August 2011
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[1] Heath, M.R. & Speirs D.C. Changes in species diversity and size composition in the Firth of Clyde demersal fish community (1927-2009) Proc.R.Soc.B published online 6 July 2011
[2] Information is summarised from landings data included in Thurstan & Roberts Ecological Meltdown in the Firth of Clyde, Scotland; Two Centuries of Change in a Coastal Marine Ecosystem.
[3] See s. 3.3 Symes, D. & Ridgway, S. (2003); Inshore fisheries regulation and management in Scotland:meeting the challenge of environmental integration SNH Commissioned Report FO2AA405