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CORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 1278-i House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE ENVIRONMENT, FOOD AND RURAL AFFAIRS COMMITTEE (SUB-COMMITTEE On the Future for UK Fishing)
Tuesday 16 November 2004 MR BARRIE DEAS MR ALEX WEST and MR HAMISH MORRISON MS HELEN DAVIES and MR ANDREW LEE Evidence heard in Public Questions 1 - 72
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Environment, Food and Rural Affairs Committee Sub Committee on the Future for UK Fishing on Tuesday 16 November 2004 Members present Mr Austin Mitchell, in the Chair Ms Candy Atherton David Burnside Mr David Drew Mr Mark Lazarowicz Diana Organ ________________ Memorandum submitted by National Federation of Fishermen's Organisations
Examination of Witness
Witness: Mr Barrie Deas, Chief Executive, National Federation of Fishermen's Organisations, examined. Q1 Chairman: Welcome, Barrie Deas. You are Chief Executive of the National Federation of Fishermen's Organisations, and also a member of the Sustainable Fisheries Group, which is carrying on the work of the Strategy Unit in which you also played a part. We might be somewhat interrupted today because of the divisions intermittently, so we will have to play the time by ear. Let me kick off straight away because I think you have concerns about the 13 per cent decommissioning target. Could you tell us what needs to be done before that target can be addressed? Mr Deas: The Strategy Unit case for a further 13 per cent reduction in capacity is to achieve improved profitability for the whitefish fleet. That is not a principle that we in the NFFO have any great objection to; where we have concerns is that this projection is based on a model and, like all models, depends very much on the assumptions on which it is based. We consider that more work needs to be done to make those assumptions realistic. This is a point with which we are in discussion with DEFRA, through the working group structure that has been set up to look at the Strategy Unit recommendations. In particular, the one I recall is that the Strategy Unit model did not seem to take into account the improved profitability that would arise from an improved catch per unit effort that would be associated with improved stocks. So it is things like these that need to be looked at in some detail before we would have enough confidence in the model to make those kinds of projections. Then we would make a decision on what sort of level of fleet reduction would be acceptable or necessary in order to make the fleet internationally competitive. Q2 Chairman: There is also still the problem of what steps other European fishing nations are taking either to decommission or perhaps to enlarge their own fleet. What is happening there and what bearing is that going to have on our own decisions on decommissioning? Some of them are still building, are they not? Mr Deas: Some of them are still building on the basis of public funds to the end of this year, and then that is ended. You are quite right, from a stocks point of view and from an equity point of view, that is a very serious flaw in this approach. However, it should be recalled that the Strategy Unit proposal for reducing the size of the UK fleet was not primarily based on ideas about stocks and improving sustainability of stocks, it was about improving profitability and achieving some kind of optimum level of profitability. So it would be in those terms that we would have to think about a further round of decommissioning. But you are quite right that the Irish, French and Spanish fleets that operate in our waters and fish on the same stocks have been expanding and modernising their fleet and obviously that puts them at a competitive advantage. And of course there is what might be called "inherited toxicity" from the state support that has gone into those fleets over the last 20 years and has been denied the British fleet. Q3 Chairman: So the danger is that we shall decommission, reduce our fleet and they will have more effective and modernised fleets to take the stocks as they improve? Mr Deas: The first concern would be that the stocks would not have improved because you have this increased modernised capacity at work on them, but the second order question is that they would be in a stronger, competitive position, that is right. Q4 Chairman: You also described that the industry financed tie-up scheme was an ill-thought one, which is presumably because you are going to have to pay for it? Mr Deas: In an otherwise very well thought through report this proposal, this recommendation stands out as being patently absurd because the Strategy Unit has indicated that the whitefish fleet is not profitable, it is operating the very margins of profitability, and yet this proposal that the industry fund a tie-up scheme for four years to assist stock recovery should be introduced. So our question would be: where is the money going to come from? In the absence of external funding it is not going to happen, so I think we should put that one aside. Q5 Chairman: It should be financed by government, should it? Mr Deas: If we are going to go down that road the industry could be interested in a government funded tie-up scheme, but over the last ten years or so signals coming from government are quite clearly that the money is not going to be available for that. I think because of that it is really a distraction and we should focus on the other elements within this Strategy Unit that are a bit more positive. Q6 Mr Drew: The crunch point for all this change, as identified by the Strategy Unit, is the alteration in quota arrangements, and according to the evidence you see merit in this idea of Individual Transferable Quotas. But I also gather that you do not want to completely remove the Fixed Quota Allocations that we have grown used to over the years. Can you explain the logic of going to the one but wanting to keep the other? Mr Deas: I think the central point is that we already have tradable quotas and if you were to move to ITQs it would simply be a re-branding exercise in many respects. We have a functioning system which has evolved over time and it has struck a balance between a facility for fishermen to trade quota, to obtain quota if that is what they want to do; but also a collective element in as much as the allocations are made to producer organisations, and therefore there is a community or regional element involved. We think that is probably the right sort of balance. So the issue is not one of moving to trading quotas, because we already have that; the issue is whether the allocation should be made at vessel level, and we have some doubts whether it is practical to allocate 120 quotas then to vessel level. Q7 Mr Drew: So at what level should the quota be fixed? Mr Deas: I think the system that we have now serves us reasonably well; that is not to say that it could not be improved, we could perhaps give some more parity to the issue of legal entitlement, and we could make a number of improvements. Essentially I think the right balance is already there between tradability and the regional community based PO system - producer organisation system - that provides some kind of stability and administrative framework. It is interesting to note that although the Dutch started with a pure ITQ system they have evolved what they call a group system, which is actually very similar to ours in as much as individually owned quotas are grouped collectively and managed collectively because of the additional flexibility that that provides. Chairman: We will take a break now; we will be back in ten minutes. The Committee suspended from 3.45 pm to 3.56 pm for a division in the House Chairman: Can we start again, please? Diana Organ. Q8 Diana Organ: I want to ask some questions about improving UK and EU information and compliance. As you know, the Strategy Unit has recommended a number of measures to improve compliance and information, but do you feel that these are adequate and sensible measures? Are they realistic and are they really going to tackle enforcement and compliance issues within the industry? Mr Deas: I think if you do not have good information then you cannot have good management, and at the present time we have a broken system for a variety of reasons. Landings data is, shall we say, imperfect. As a consequence there is a great deal of uncertainty about the scientific assessments. So it is a vicious circle because as a result we get lower total allowable catches and that puts economic pressure on the fleets, and there is pressure therefore towards illegal landings, and the whole thing spirals downwards. If we are to break out of that system we need to establish a good information system and a good working relationship with the scientists. I think that is really the core of the matter. So we agree with the Strategy Unit that we should aim to move towards a high compliance system, but we also agree that a fundamental element of high compliance system is economic viability of the fleet. So it is how to move forward on all of these fronts at the same time. Our Federation has, over the last two years, with money from DEFRA, established Fishing Science Partnerships, where we supplement the official science, the more formal assessment techniques with particular projects aimed at specific problems of concern, both for the scientists and the industry, and I think that has been a very effective way of breaking out of the cycle. But to repeat myself, if we do not have information we do not have a good management system. Q9 Diana Organ: One of the things that the report also goes into is that it believes there would be a lot of improvement if there were introduction of progressive recovery of management costs from industry, and I know that the NFFO have said that at present they think it is inconceivable that the Government could move in this direction of cost recovery. What reservations do you have regarding this, and would there be any circumstances that you could foresee the industry contributing to management costs in the future? Or are you just right out into the long grass? Mr Deas: The view we take is that at present, under current economic circumstances, there simply is not the money in the fleet to make a contribution to management costs. On the other hand, in circumstances where the Strategy Unit outlined where you have a high profitability fleet operating, we think it would be fair and reasonable for the industry to make some level of contribution and we would be willing to discuss an appropriate level. So we are not saying no. We are saying two things: we are saying that the fleet has to be economically able to pay that amount; secondly, there needs to be some kind of level playing field within Europe because we cannot be put at an economic competitive disadvantage if we are the only ones within Europe paying for enforcement. So those would be the two pre-conditions, but we are not saying no. Q10 Diana Organ: Do you think that effort-based systems are the best way of being the most effective way of managing mixed fisheries? Mr Deas: No. I think that effort is a very crude way of managing fisheries, a very blunt way of managing fisheries, and the effort systems that we have in place should be regarded as temporary. The rationale for effort system is primarily that the TACs and quota system alone has not worked and needs to be supplemented to ensure that quotas are not exceeded. But if we are moving to a high visibility, high compliance system and we achieve that, then there is no rationale left for an effort system. Apart from our fundamental objection, which is, of course, that tying your principal capital asset to the quayside for a good part of the year does not make sense in terms of economic rationality, and which would be our starting point. Q11 Chairman: How would if affect relative stability if you had an effort-based system? Mr Deas: That is a good question as well. I think it would destabilise it. Q12 David Burnside: Mr Chairman, as I raised before the meeting started - and I think it is a national comment which reflects the whole of the industry - today, back home in our own industry, we have a funeral taking place of a young man who went down on the Emerald Dawn last week, Colin Donnelly, and I think we should all of us recognise that it is an industry that still has dangers, and our thoughts would very much be with the family of that young man today. Turning to some of the recommendations in the report on the regionalisation of management, perhaps you could flesh it out a little? Could regionalising the management function have gone further? And when the management structure takes place over the North Sea, the Channel, the Irish Sea and the different fishing regions, how does the UK Government nationally support these Advisory Councils? What do you expect the Government to do to support them? Is there a financial input? Mr Deas: First of all, I think that this part of the Strategy Unit report has received widespread support in the industry because rolling back the role of the Commission out of day to day management decisions, more towards an audit or refereeing role makes sense, particularly against the background of the last two December Councils where very poor decisions have been taken; and we have been working for the next six to nine months to rectify them before we come round to the next December Council. Q13 David Burnside: My understanding from my home ground or my home sea view point is that we have our own submissions for quotas, for example from the local areas, for the December quota meeting. So how does this new management structure affect it? Mr Deas: Under ideal conditions the Regional Advisory Councils would develop long-term management plans that would set harvest levels for various stocks, and we would operate on that basis, and that would have a buy-in from the industry, rather than the kind of horse-trading that goes on every year with the Commission in a kind of bullying role. That would be where we would want to move towards. As to what the UK overnments --- Q14 David Burnside: Or the Scottish Parliament or Northern Ireland. Mr Deas: Yes. As to what governments should be doing, I think first and foremost there needs to be financial and technical support for the stakeholder representatives on the Regional Advisory Councils, and I think that is already happening. The North Sea Regional Advisory Council has only been up and running a matter of a fortnight or so, but already we have seen willingness of government to provide the kind of technical support needed. It is going to be an evolving system and we are going to have to see how it works out, but I detect a change in attitude. I think things are changing. The question is whether other Member States will see this as the opportunity that the UK certainly does, and the Strategy Unit certainly does. Q15 David Burnside: How do you mean? Can you take that further? Mr Deas: The Regional Advisory Councils will only work if they are supported and provide credible advice to the Commission and the Council. So it is (a) the quality of the advice that is coming forward, and (b) the receptiveness of the Commission and the Council to that advice that will determine whether it is successful or not, and those are open questions. I think that the administrations in the UK can provide a great deal of technical support that would ensure that those Regional Advisory Councils are indeed effective and credible bodies. Q16 David Burnside: So overall you are happy? Mr Deas: Yes. Q17 Chairman: I think it is fair to say that success has many fathers, but now that many people are claiming the idea of regional management, the actual truth is that it came from the NFFO and the SFF as they retreated from their original policy of withdrawal from the Common Fisheries Policy. Would that be a fair summary? Mr Deas: Yes, it is an idea that evolved and that is, I think, where the different paternity suits came from. Q18 Chairman: What kind of role would you like the catching side to play in it, apart from running it? Would you like a defined role in the Regional Advisory Councils for the catching side? Mr Deas: The catching side has a defined role. Q19 Chairman: I meant a more powerful role really. Mr Deas: I am quite content with what we have. Two-thirds of the Executive Committee are from the catching sector, which I think is right and proper. It is one thing to have an interest in fisheries, it is another to have a livelihood dependent on it and I think that justifies the proportions that have been set. The first outing of the North Sea Regional Advisory Council in Edinburgh a fortnight or so again worked very well. There was input from all the stakeholders, but certainly the catching sector had full opportunity to play its part. I do not see it as a problem, though others may. Q20 Mr Lazarowicz: One of the recommendations from the Strategy Unit report is that fishing should be treated on the same basis as any other major user of marine environment and out of that they then raise the possibility of the application of the Strategic Environmental Assessment and the Environmental Impact Assessment tools as a way of achieving that. What is your reaction to that proposal? Mr Deas: Indeed, it would be difficult to argue the case that fishing should be treated in any special way different from any other industry. So I do not think our problem is with the level of principle, I think it is with the issue of practicality. One of the Strategy Unit recommendations is that new fisheries should be subject to environmental assessments, and in one of the recent working group meetings looking at this question we were deliberating on what a new fishery would look like, because I can think of one or two over the last 20 years but it is not exactly an every day occurrence - change within the fishing industry tends to be incremental. So I think that we have to look at this in more detail through the working group structures to see what the practical implications are. I do not have any particular problem. Q21 Mr Lazarowicz: In principle you have no objection to the conception, it is the very important question of the detail which you are concerned about? Mr Deas: That is right. Q22 Mr Lazarowicz: One of the other suggestions is the development on an experimental basis initially of Marine Protected Areas and that is something which I think the environmental organisations have been particularly keen to promote. Again, what is your reaction in the industry to that proposal? Mr Deas: It is already EU and UK law, so again we are not talking about principle here, we are talking about practicality, and the issue is what sort of scale Marine Protected Areas would take, what sort of conditions would apply and, above all, what are they for? Because the environmental lobby to date has been fairly vague about the function they would serve. They are seen to be a good thing in themselves to close off large areas - or indeed small areas - under the rubric of Marine Protected Areas. I think we have to have a much clearer idea before we could go down that line. It is very important that they have a defined purpose, that there is an objective there, that there are measurable results. So that we move away from the kind of woolly idea that Marine Protected Areas have a function in themselves towards having defined purposes. In the fishing industry in the Celtic Sea, the UK, Irish and French have nominated an area for closure during the spawning period, and that has scientific backing as something that would benefit the stocks in the area. So we are not opposed to closed areas in principle - indeed, in some areas we would advocate them very strongly - but I think we must be very clear about the purpose that they are going to serve, and we must move away from vague, ill-defined but warm, sanguine ideas about closing large areas. Q23 Mr Lazarowicz: But is it not the case that no matter what the purpose of the areas, that one of the effects could indeed be a beneficial effect on stock regeneration - perhaps more beneficial in some respects as compared to some of the other measures which all have their problems as well? Mr Deas: I think closed areas have proven benefits, particularly in tropical reef fisheries. But in the more diffuse fisheries that we have in our waters they are unproved, which is why I think we have to move forward with a case-by-case approach and look at each particular proposal in terms of what would be the benefit. I think it is not true to say that if we close down large areas there would be a benefit; indeed, the evidence from, for example, the Plaice Box off the Dutch coast is that there are dis-benefits because of transference of fishing effort on to juvenile areas, for example. So my central point is that I think we need to know what we are doing and to have objectives and to be able to measure up progress towards those objectives. What I am very strongly against is an ill-defined approach that simply has Marine Protected Areas or closed areas for the sake of them. Q24 Ms Atherton: To follow on from that, the Lundy Island experience is certainly something that this Committee should look at, and looking on a case-by-case basis is a very positive impact both on the closed area and on the surrounding areas, and if we are going to look at it in an even-handed way you were quite negative there, I thought, and that the Lundy Island experience is very positive. Mr Deas: I thought I was quite even in my approach, which said that if you are going to have a closed area it must be for a purpose and we must be able to measure our moving towards that objective. In the Lundy Island I think you are right that there have been benefits, but we must be very clear-headed about we are doing, I think would be our central point. Q25 Ms Atherton: It is coming up to Christmas and I am writing my Christmas cards and that can only mean one thing, the Fisheries Council meeting! And what a wonderful Christmas present I always think it is for all fishing communities and the way in which we all revel in this experience each year and the week running up to Christmas! What do you want the UK Government to be arguing this year? What Christmas message do you want the Minister to take with him? Mr Deas: I think the Minister should argue in relation to the Cod Recovery Programmes, that they should be based on as close to real time management as possible. In other words, it is not acceptable to base new measures on data that ends at the end of 2003 when there has been a significant de-commissioning round that has taken its main impact in 2004 and there has been the impact of technical measures and there has been effort control. None of these are taken into account in the assessment. If the Council is going to consider amending changing the Cod Recovery Measures it must take into account the impact of measures, particularly in 2004. We think that the Commission believes that there has been a reduction in fishing mortality for cod in the region of 20 to 30 per cent - the target is something like 60, 65 per cent. Our view is that the main impact of the de-commissioning scheme in the UK will have moved us much closer to that objective. The difficulty that the industry has is that we are in a cycle of permanent revolution. Every December Council comes round and everything is thrown up in the air, new measures are applied. It is the middle of November but, we do not know what our quotas are going to be, we do not know how many days we are going to be able to go to sea, we do not know where we are going to be able to fish because closed areas are under consideration. So a period of stability to allow the industry to survive, but also the existing recovery measures to work through and to demonstrate their effectiveness would be very welcome. The second thing is in relation to Western Channel sole, which is a very important stock for the southwest, where the Commission is proposing a recovery plan. The French and UK, both industry and government, have put forward a counter proposal based on technical measures - an increase in mesh size - that would achieve the recovery necessary but over a longer timeframe and would escape the very economically damaging effort-based proposals that the Commission is putting forward. So the two wishes would be for the cod recovery and the sole recovery, along those lines. If the Minister were to pick up those and run with them we would be very pleased. Q26 Chairman: We will be writing to the Minister to give some indication of what we think about the prospects and what he needs to do at the Council, so we will be able to incorporate those views. I just have one question, which is more geographical and personal to Grimsby. There was talk of community quotas in the Strategy Unit's report, and when it comes to communities, in other words communities dependent on fishing, English fishing ports have always suffered because they are towns, communities, industrial bases, like Grimsby, Hull or Lowestoft or Fleetwood, whereas clearly Scotland has communities directly dependent and almost totally dependent on fishing. If there were community quotas how would you define community? Mr Deas: I think you are right that there has been an anti-urban bias in fisheries' policy. Q27 Chairman: Would Grimsby be an eligible place? Mr Deas: I think the answer is probably to operate through producer organisations, which do have a regional base because the vessels operate out of particular ports, and a community based quota system linked to the existing producer organisations would probably be the most effective way forward. Chairman: Thank you very much, Barrie. Let us replace you now with the Scottish Fishermen's Federation, on the grounds that the Scots shall inherit not the earth but the seas!
Memorandum submitted by Scottish Fishermen's Federation
Examination of Witnesses
Witnesses: Mr Alex West, President, Scottish Fishermen's Federation and Mr Hamish Morrison, Chief Executive, Scottish Fishermen's Federation, examined. Q28 Chairman: Welcome, gentlemen. You are Alex West, President of the Scottish Fishermen's Federation and Hamish Morrison, Chief Executive of the Scottish Fishermen's Federation. We welcome you both because you, in a sense, embody the major part of the industry. So let me begin by asking you, as we asked Barrie Deas, about your objections to the removal of 13 per cent of whitefish fleet. Why do you think that recommendation is flawed, or the evidence on which it is based is flawed? Mr Morrison: Very similar to Barrie's reply but with a couple of local qualifications. Over the last two years we lost 170 vessels, which were destroyed, some of them less of five years old, which in anyone's language is quite shameful that assets of that age should have been destroyed. What was more galling about it was that the basic calculation on which these outtakes were determined was flawed. This arises because the demersal trawl fleet in Scotland and indeed in England is heavily skewed by the number of vessels who earn more than 70 per cent of their income in the nephrops fishery, which has almost no effect on cod at all. I think the whole nephrops fishery, by way of a by-catch, takes less than three per cent of the cod quota. Yet, for statistical reasons, they are lumped together. So instead of, for example in the Scottish case, a shade under 300 whitefish vessels but 700 were actually brought into the equation. I did correspond with the leader of the Strategy Unit and he conceded the point eventually that we were indeed correct about this. But, like Barrie, I would rather park that issue, which is going to be driven by other events in the coming months and years, rather than try to be definitive about it in the meantime. Like the NFFO we are, involved in trying to build a better model for the industry to try and determine its unit profitability once and for all. Q29 Chairman: I would like to push it a little further because you say the benefits of the reduction are theoretical and any reduction would have unintended consequences. What in your view would be the consequences of a 13 per cent decommissioning? Mr Morrison: I think there would be a very real risk. We have to believe in stock recovery or we are all wasting our time. There is a very real risk, even now, on the level of trawling capacity we have now, that if we were able to achieve the 30 per cent year-on-year target that is set in the cod recovery plan, in five years' time we would not have enough vessels to take it. In fact, this year we have undershot the cod quota - the cod quota, mind you - Here we are with six weeks left of the year and we have only caught 65 per cent of the quota; much of the rest we have had to trade away to Denmark to buy more haddock. That is already the position through effort reduction and the loss of vessels to decommissioning. I have some sympathy with officials because it is very difficult to get these calculations right, but I think everyone who goes into them must be aware of the fact that the unintended consequence rule is with you all the time. Q30 Chairman: You also think that the tie-up scheme is unworkable; why is that? Mr Morrison: It is a joke. Q31 Chairman: Apart from that! Mr Morrison: You say to someone, "You will just go out of business for nine months and that will be fine"; how do you pay the bills? It is not serious. Q32 Chairman: If you are saying that you do not want the decommissioning at that level and the tie-up scheme is unworkable, what alternatives do you have? Mr Morrison: The point I am making, Chairman, is that the fleet is actually capable of surviving in its present state; it is profitable. Q33 Diana Organ: I want to go on to Individual Transferable Rights. What do you perceive as the main disadvantages of the proposed ITQ system? Mr Morrison: The Strategy Unit report is internally inconsistent, if I can be kind about it, because you cannot have, on the one hand, Community Quotas and on the other ITQs - the one is the obverse of the other. If you tie quota to an area how can you then trade it? I do not understand that. I think - and rather like Barrie Deas was telling you - that in a kind of bumbling British way the FQA system is about right because you do not have title to the fish but that, interestingly, keeps speculators out because they are too nervous - 'You could not use investors money if you did not in the end have something you could liquidate and enforce at law. Therefore the only people who do trade tend to be fishermen and fishing companies, and that is entirely healthy. The trading is necessary because fishing patterns change, and if you happen to be someone who staked your all on cod ten years ago you will have needed to buy other quota in the meantime, to stay in business. I do not mean to sound complacent but I do think the FQA system is about right. Q34 Diana Organ: You did though say in your written evidence to us that the FQA system could and should be refined, and not so much in the bumbling British way. In what way would you like to see that refined? Mr Morrison: I would like to see the trades that happen reconciled on an annual basis, so that it is entirely transparent as to who at the end of the year owns what quota. I do not know if I would go as far as Iceland does and actually have it on a public website so that I could find out how much quota you had because there might be difficulties in keeping that up to date. But I do think that the Government should reconcile the position every year so that everybody knows where we start at the beginning of the year. Q35 Diana Organ: And a greater degree of transferability? Mr Morrison: I think the market probably handles it to the extent that it is necessary at the moment. At the moment, for example, you could not really give cod quota away - the market does work. Q36 Mr Lazarowicz: A brief question, if I may, about the idea of the Community Quota Schemes, of which I think you are in favour. Do you have any ideas as to what would be the most appropriate way of establishing that type of scheme in a way which is compatible with EU regulations, given the experience of Shetland and Orkney Islands? Mr Morrison: I think the Shetland and Orkney experience is highly relevant because they were inquired into and it was found to be acceptable. They still have the scheme; it still works. I think the next group in Scotland to try it is likely to be the Highland Council who, I understand, are examining the feasibility of buying quite a lot of prawn quota. I think it is more difficult than it looks because once you say, "That is Mallaig quota" you immediately halve its value because you cannot trade over the whole of the area in the way you can now - you can only sell it to another boat from Mallaig. I would suspect that one or two fishermen themselves might have a problem with this, but if you just had the Highland Council owning quota and leasing it on a preferential basis that might be alright, but I just wonder if they might not fall foul of discrimination under some kind of European law for doing that. I do not think it is as easy as it looks, that is what I am saying. The way it is done in Orkney and Shetland is very straightforward - a trust fund controlled by the Council at arm's length, owns the quota and leases it to their own boats, and that is all that happens. I think if you were trying the kind of scheme that was in any way bigger than that, and universal, it might be more difficult. Q37 Mr Lazarowicz: If it were to take off at a number of locations, but surely the state aid issue, which is obviously an issue in Orkney and Shetland, is going to be a much bigger issue if it were to be operating throughout large parts of Scotland, for example? It is not going to be a way forward which is going to have wide opportunities, is it? Mr Morrison: Without the geographical tie it is something that the Federation is deeply involved in anyway, and perhaps Alex West could tell you a bit more about it. Because after the decommissioning, some boats' quota went to the banks to cover outstanding debts and the banks still "own" that quota and are leasing it back, at really quite sharp rates. But perhaps if you would not mind, Alex, saying something about that? Mr West: I think you have to be careful in this area because generally speaking a lot of people do not know the difference between FQAs, ITQs and all of these things. What the Chairman spoke about earlier is the real danger of this. If we had internationally traded ITQs then relative stability goes right out of the window because the quota would then go to the man with the biggest pots and the deepest pockets. So relative stability is away. So it is a dangerous course. My view is that what we have - especially in the pelagic sector - is just about right. You have no legal title, but because there is not legal title you do not have third companies coming in and buying something if they are not sure about it, it is a bit dubious. But fishermen that need the quota; the people who should have it will buy it because they need to use it to keep their businesses viable. So in that way it is just about right. You see, people do not understand in general terms, but then you have three different fishing fleets in the UK: you have the pelagic fleet fishing single species, you have the whitefish fleet fishing mixed species, and then you have the huge and very important prawn fleet. Personally, I am a businessman, I have been to sea for 40 years, I have 16 whitefish boats and four pelagic ones and I have been very successful in this business. But the thing that is the biggest danger to us now is people interfering with the whole thing, politicians making decisions sometimes, to be honest, scientists making decisions as well. We have seen it in many areas. Monkfish, for example, is a prime example. We have to be careful. A lot of people come to ask you questions but they do not really know what FQAs are; they do not really know what ITQs are, and of course the thing that worries us to death above all else is the European dimension, which is one we have to deal with right now. Q38 Ms Atherton: I want to move on to traceability, and I was very pleased that you support Strategy Unit proposals, but then you put the caveats in, and there seem to be a lot of them. You alarmingly talk about a threat to civil liberties; you are opposed to the costs; you are worried about how the enforcement will operate. Are you really on board for this? Mr Morrison: I think that with traceability you have to be clear why you are doing it. There is a public health issue, where I do not think there is any dispute with anyone; you have to know where all food came from in case there is an epidemic or an outbreak, or whatever. Then there is the situation where the same legislation is extended to the quota system and other refinements are made to it. I think it is that area that we tend to worry about. Traceability is something that happens now, and every day that goes by it becomes more widespread. Apart from anything else it does not matter what the Government does. If you are selling fish to Marks & Spencer they will put far more controls on you than the EU or the British Government could ever dream of. So there is no point in railing against that, that is real. It is where you find that there is an attempt - and we see it in one or two places with the introduction of electronic logbooks and the rest - to actually screw down the flexibility that there is, and the flexibility which fishermen need in order to make a living. Q39 Ms Atherton: I suppose the debate comes to where does flexibility become abuse of the system, and that is always the problem, is it not? Mr Morrison: Absolutely, but it is very well defined, as I am sure you will be aware, in percentage terms right now. Q40 Chairman: You are opposed to a point system of penalties. Mr Morrison: Yes. Not opposed to it entirely, but making it the only possibility. Everyone should have their day in court if they think they have been wrongly arraigned. It is not for a Star Chamber of civil servants to abridge a licence or whatever; we cannot have that in this country. It is rather like exceeding the speed limit. If the policeman says to you, "Will you take the £40 or see the Sheriff?" most of us would take the £40, and that is okay. But it is saying that you can only take the fixed penalty that we do not like. Q41 Mr Lazarowicz: Mr West mentioned a moment or two ago the EU dimension and I want to ask some questions about that. I think everyone knows that regional management is the flavour of the month, flavour of the year. The question as to what it actually means in good practice is obviously the big issue. I understand, first of all, that the Federation is not in favour of moving to regionalised management in the fisheries sector. Can I ask you what action you would like to see the UK taking to take that concept forward? Mr Morrison: I think one of the points about the Strategy Unit's report, if I may just preface the answer, is that we seem to have lost sight of what that report was for. It is important to remember that this all happened with the Prime Minister being dragged into a situation at a late hour in December 2002 which, in summary, meant that two countries had been ganged up on by the others and had a wholly oppressive system imposed upon them. A system,, I may say, that was unravelled in the succeeding year because not only was it oppressive, it did not work. We saw the prime Minister in January of that year and he said he would have the Strategy Unit look at it. I do not mind at all that they went into all these areas like the economics and the fleet and traceability and environment, and so on, but this central question of how do we deal with a situation - and it has got worse since enlargement, it has not got better - where, if a country, in the Council of Ministers, has no vital interest in an issue, it supports the Commission? Since by its nature any fishing issue will rarely have more than five countries directly involved in any particular question the Commission always has this kind of sleeping majority of 20 countries sitting at its elbow. That, I believe, can only be solved by building on the Regional Advisory Councils that we have - and I do believe that within three to five years they will have devolved management powers, for no other reason than the present system in Brussels will begin to founder under its own weight. Q42 Mr Lazarowicz: Can I push a bit more on what those Regional Advisory Councils should actually be doing? How should this be developing? Mr Morrison: I would say at the moment that they advise on a number of areas and they ought actually to be able to take decisions on them. Technical measures, for example: standard mesh size, escape panels, things like that. Area and seasonal closures to conserve stocks, I would like to see them have those powers in due course. And real time, closures if there is a big run of small fish - and this happens now and indeed it happened in Scotland in a disastrous way two years ago, where everybody knew the area should be closed but the Commission's machinery would have taken a year and fish would have been wiped out in the meantime. A Regional Council could make a decision and the closure would happen almost straight away. For the tricky question of catch limits and quotas, I believe the Regional Advisory Council - or Regional Management Council as I hope it will become - would work in concert with the ICES, the Advisory Committee on Fisheries Management, where you would have empirical evidence from the Regional Council and scientific evidence from ICES, and the product of these two would be the basis for the decision. So it is that kind of gradual involvement in these very crucial management decisions that I would like to see happening. I am quite content for their role to be Advisory for the next two or three years. To be blunt, if they handed me the keys tomorrow I would run for my life; it is too difficult! We need to work our way forward and to get this right. Q43 Mr Lazarowicz: Turning to another recommendation, which is linked to what we have been talking about, but in a slightly different direction. The proposal in the Strategy Unit report to create five UK Regional Fisheries Managers and an Inshore/Shellfish Manager for each nation, what is your view of that proposal, and how do you think we could avoid a fragmentation of the system if we develop that kind of approach? Mr Morrison: I really do not understand these recommendations and I did actually ask the people at the Strategy Unit what they meant, and I am still not entirely certain. The idea seemed to be that these individuals would somehow be a champion for regionalising the UK system, which would then make it easier to regionalise the European system. Q44 Mr Lazarowicz: I think you did say you in your evidence that you were broadly in favour of the proposals? Mr Morrison: I think they could be adapted to work directly with the Regional Advisory Councils, but in the time since our original reactions were written I have been on a few of these strategy working groups and the original proposition is looking a bit hazy now. I am not even that sure what we are talking about are civil servants or, in the jargon, "fishing management tsars". It is not entirely certain what they are. I think that is the value of these groups, these working groups, where we can try and mould that concept to a pattern that will actually do some good. Q45 Chairman: How about marine conservation areas? What would persuade you to accept them? Mr Morrison: We have how many at the moment? Q46 Chairman: What safeguards would you like on them? Mr Morrison: There are 100s of them at the moment. Q47 Chairman: Yes. There is a problem, particularly with community quotas of communities depending on fishing. Mr Morrison: I think a lot of inshore conservation areas are actually more popular than is widely thought. A lot of our local fishermen's associations are very active in the management of various of these areas, and I will tell you why. Q48 Chairman: The proposal to extend it or enlarge on it, I suppose, as Marine Protected Areas. Mr Morrison: You have to say why - that is the question every time? Why would you want to do this? The question we asked about the Darwin Mounds, for example, which is the most recent one. Halfway to America, only four people in the world have ever seen these features. It is a serious point, yet environmentalists think these are so unique and so important that you have to stop fishing within four or five --- Q49 Chairman: You are in favour of one, but not of the other? Mr Morrison: We have a lot down the West Coast of Scotland, for example. Many of them are now becoming quite useful habitats for eco tourism, and the guys who take the people out in the boats some time recently were fishermen. So it is a bit like fish farming; you start off by being terribly anti, but providing they are not completely crazy they can sometimes be quite useful. Q50 Chairman: Just a final question, which we also put to Barry about our recommendations, our opinions to pass to the Minister when he comes to the December Council. What would you want the Minister to be negotiating for on behalf of the industry in the December Council? Mr Morrison: I think, as Alex was saying, we do have so many fishing fleets, all of which have their own particular issues, but I would have to say that our priority has to be a sensible nephrops management system because it is anything but sensible at the moment. Essentially the problem is that because of glitches in the scientific system, our prawn fishery is governed by so-called proportional DACs. This allows you only to move seven and a half per cent of the biomass in any given year, as opposed to a more typical fishery which would be 20 to 30 per cent a year. Somehow we have to try to bring commonsense into this because with people being driven out of white fish daily, this is now becoming a staple fishery and it is also a fishery that supports thousands of people with very small vessels all around the coast. We have to get the management of this on a much firmer footing than it is currently. Chairman: Thank you very much indeed. Memorandum submitted by World-Wide Fund for Nature Examination of Witnesses
Witnesses: Ms Helen Davies, Fisheries Policy Officer, and Mr Andrew Lee, Director of Campaigns, WWF-UK, examined.
Chairman: Welcome to the WWF. We are not going to have too much difficulty telling you apart. You are Helen Davies, the Fisheries Policy Officer, and Andrew Lee, the Director of Campaigns. I would like Diana to start the questions. Q51 Diana Organ: I wonder if you could tell me what you think are the positive benefits that Marine Protected Areas could bring not just to the marine environment but to the fishing industry as well? We have heard a lot from the fishing industry this afternoon and it is your turn to redress the balance somewhat. What contribution do you think that MPAs can make to stock regeneration in comparison to other methods, such as fishing effort, gearing, etcetera? Ms Davies: Thank you. There are lots of advantages of MPAs. You might expect that I would say that. I think the first point I would like to make is that they do represent good value for money insofar as they do promote stock recovery and we have seen that from a wide range of examples, not just in coral reef and tropical climates, as has been suggested by the industry, but also in temperate fisheries such as we have seen off the Georges Bank in America. They have the potential to aid stock recovery and also protect vulnerable seabed habitats like cold-water corals as seen at the Darwin Mounds and so on. Diana Organ: Even though only four people have ever seen them. Q52 Ms Atherton: We know about them though. Ms Davies: They do provide multiple benefits. There is lots of evidence for that in examples from New Zealand and all around the world to show that they can help stock recovery in sedentary species such as crayfish, and that has been studied extensively in New Zealand, and also with more mobile species, such as cod and haddock and so on, on the Georges Bank in America. They are easy to enforce in the sense that you can tell where a boat is fishing by GPS that is on board a lot of the vessels now. They can deliver multiple benefits. In terms of what we mean as regards the definition of MPAs, we are not just talking about closed areas, there is a whole variety of different types of protection from seasonal closures, gear restrictions, temporal and spatial restrictions and so on and so forth, so they are not just no-take zones where everything is prohibited, but in those areas where you have extractive activities which would be prohibited they provide very important control areas so that you can judge the effects of recovery, you can judge the impacts of fishing. For example, in New Zealand in one of the longer established no-take zones recently they found in the last couple of years that there was an 80 per cent drop in the population of crayfish but because that drop was seen all along the coast they knew that it was not just due to over-fishing, therefore they could look for solutions elsewhere and the finger was not pointed at the fishing industry. There are benefits in that sense. We know that the catches increase, the size of fish increases, the reproductive capacity of the stocks within those areas increases and obviously you have got the spill-over effects of fish migrating out of that area and then they are available to be harvested. Q53 Diana Organ: Who do you think ought to be responsible for their development? Should it be sovereign government, the EU, the European Commission, devolved administrations? Ms Davies: It really depends what type of MPA you are talking about. Obviously they have got to be adhered to by all nationalities so in that respect the EU would have a role to play, but in inshore areas, for instance, you might have a no-take zone within a Special Areas of Conservation, for instance, or a Special Protection Area and it might fall to individual Member States to enforce those. Mr Lee: If I can pick up on your question a little bit. Within 12 nautical miles, that is why WWF is advocating a Marine Act, because that is the only way of getting a joined-up approach, a proper spatial planning system. We take it for granted on land but we do not have it at all at sea. That would provide the context for this network of marine protected areas of different types with different levels of restrictions. Do not forget that a good system of Marine Protected Areas benefits the fishing industry, not just in terms of fish stock recovery but also protecting fish stocks and fisheries from other damaging activities, so it is providing more of a level playing field. Outside 12 nautical miles it gets more complicated when obviously you have got the regional management approach under the CFP but also a draft European Marine Strategy which is starting to look at how that might be done. Q54 Diana Organ: You talked in your example about New Zealand and how you could tell other things that were going on and migratory patterns. Do you agree with the SU report that protected areas need to encompass the whole of a migration route in order for it to be beneficial? In some areas these are vast routes, are they not? If we take some of the fish stocks that the fishermen are taking, the migratory route could be almost half the planet. Ms Davies: I am not sure that we would go that far. Normally what you would do is look at what we call migratory bottlenecks, in other words areas where fish congregate for breeding, for spawning or in nursery areas or along a certain migration route rather than the whole migration route. Even though the fish might only spend a small proportion of their time within that protected area, it is at a crucial stage in their life cycle, if you like, so when they are breeding or when they are spawning, when they are in vast aggregations, which is when they are most vulnerable to fishing. Q55 Diana Organ: You recognise in what you are saying that Marine Protected Areas will have an effect on fishing and will have an effect on fishing communities once they are established. How do you ensure the economic interests and livelihoods of those communities that might be to a large extent dependent on that activity, or are you not bothered about that? Ms Davies: Certainly we are very concerned about that and the social and economic implications of this are issues that we take very seriously. If you want to talk about no-take zones or closed areas, we would not advocate the use of those strictly on their own, they must be used in conjunction with effort controls otherwise you simply displace the effort and concentrate it in other areas. In terms of the social consequences it has been shown in other areas, for instance the improvement in the tourist industry has offset some of the losses. In fact, in terms of areas such as the mackerel box in the South West of England the effort was displaced so widely as to not really cause any impact at all. Those communities living closest to that area did receive a significant benefit. We are not closed to the idea of other consequences but we believe that over a period of time these MPAs will pay for themselves. Q56 Ms Atherton: Do you feel the introduction of Strategic Environmental Assessments and Environmental Impact Assessments will have a significant improvement on environmental practices within the fishing industry in general and particularly within commercial fishing? Mr Lee: If I could start to address this, and I am sure Helen would like to pick up on more. We think SEA is a good principle to apply for a number of reasons. Firstly, it is necessary to measure the impact of any major new proposed fisheries, new activities, but it also provides a bit of a level playing field provided there is a retrospective look at the impact of existing fisheries. SEA will prevent one part of the industry benefiting at the expense of another because it has lower environmental standards. Also it will provide benefits to the fishing industry and to other activities at sea, whether it is aggregates dredging, or the development of marine renewable energy, for example, both of which may be appropriate at certain places in the sea. If it is applied properly it does provide a level playing field. Also, it would generate a lot of data and one of the issues we have heard a lot about today is the lack of data upon which to make clear, firm long-term decisions which mitigate at the moment in favour of extreme caution in some areas, and we think that is right, but a properly applied SEA would generate a lot of the data that could fill some of the gaps. Q57 Ms Atherton: Who do you think should do these assessments? Individual fishermen? Industry representative groups? A N Other? Ms Davies: Just to complete what Andrew was saying, if I can come back to your question. Q58 Ms Atherton: I am sorry, we are aware that there is a vote coming up and that is why we are pushing on quickly. Ms Davies: Okay. I just wanted to make the point that one of the main advantages for the fishing industry in terms of SEA is integration with other sectors. To date, the fishing industry has stood alone. There is an opportunity to integrate this industry through spatial planning and other mechanisms. In terms of who should carry out SEA, obviously the ultimate decision at the moment as regards EIA falls to regulators, and we believe that should remain. It may be that when these SEAs are applied to fisheries, that is a new area and there is a lot of data and information to be gathered and we feel that some assistance from the new European Fisheries Fund, for instance, may be given to help them in that task. If you take the example of EIA at the moment, as is applied on land, the developer supplies the information and the regulators make the ultimate decision, but they need to have enough information on which to base that decision, which comes back to the point about gathering data. The benefits that would have are both in terms of assessing the impacts of fisheries but also in terms of regional management of fisheries, because obviously the data can be used for a variety of purposes. Q59 Ms Atherton: Okay. Should Strategic Assessments be conducted by area or fishery? Ms Davies: Strategic Assessments should be conducted on a wider scale, we believe, so that they can incorporate other marine uses. Environmental Impact Assessments could perhaps be applied to an individual fishery or the introduction of a new type of gear, for instance. The industry made the point that they did not foresee where a new fishery would arise but there are two very good examples, and one has come up recently, NEAFC - the North East Atlantic Fisheries Commission - which met last week, which we attended, with regard to deep-sea fisheries. That could be classed as a new fishery. Also, within the Strategy Unit Report there was quite a strong recommendation for new exploitation within inshore fisheries so, for instance, if a new shellfish fishery were to open, EIA should be applied to that we believe. Q60 Ms Atherton: Should the Assessments be open to a certain degree of flexibility to accommodate the different range and diversity of fishermen's operations, including the pursuit of seasonal time-limited fishing operations? Ms Davies: We have been supportive of real-time closures, as they are called, based on real-time data and there has been some difficulty in actually working out within the Common Fisheries Policy how that might implemented. As the industry has pointed out, there is a role for Regional Advisory Councils in that. Sorry, I have lost the thread of what I was saying. Ms Atherton: It does not matter, I think you have answered. I think we get the drift. Q61 Chairman: Let us move on to the final questions. You seem doubtful about individual transferable quotas from an environmental point of view, why is that? Do you see a better quota system being more effective from the environmental point of view? Mr Lee: I think the point for us is that ITQs, as they are being proposed, are an economic measure and they are about how you distribute the effort, not about the amount of the effort, and I think that point has been made by the industry already. The case is not yet proven on the environmental side that it will necessarily deliver. Q62 Chairman: You see it being effective in reducing fleet size, surely a smaller fleet is a more environmentally friendly fleet? Mr Lee: Not necessarily, because it is the number of boats and the amount of pressure, is it not? ITQ's might be a good way of streamlining the way the industry works from an economic point of view but, ultimately, it is the level of fishing effort on the ecosystem, on the fisheries that matters. I think it is an issue of public policy how much - and we heard the debate today - you intervene in the market in order to benefit coastal communities, for example, disproportionately. WWF is in favour of people and nature wherever we work in the world and certainly it applies to the fishing industry here. Basically, we are in favour of public intervention to ensure that some of that benefit remains with those communities. Regarding ITQs, I think it is a political issue between the Government and industry about how many jobs you want to keep in which areas and which parts of the community. It is not a measure primarily for tackling the biological problem of overfishing. Chairman: I see what you are saying. I was just a bit worried about it. Q63 Mr Lazarowicz: You support strongly the idea of the precautionary approach applying to fishing policy. Very briefly, can you tell us what you think that means in practice in terms of one or two headliner points? Ms Davies: In terms of the precautionary approach, certainly, I think we would like to see that applied more to TACs and quotas, so that they are set more in line with the scientific advice coming from ICES and that they set a precautionary level of fishing or harvesting. Often that is seemingly ignored when it comes to the December Fisheries Council. I think the important point to make about the precautionary approach is that it is enshrined in legislation and policy statements from internationally renowned fora and also at a national level. It is really a central tenet of the ecosystem based approach, where currently there is a large gap in information about ecosystems; how stocks interact with each other, predator/prey relationships and so on and so forth. In areas of uncertainty we would advocate the judicious use, not overuse, of the precautionary approach until we have more certainty which should come from more data. Then we can be a bit more relaxed and a bit more flexible. Q64 Mr Lazarowicz: I am not sure what that means in practice? Effectively, are you simply saying that the ICES recommendations are given a high level of credibility on decisions taken? Ms Davies: At the moment a precautionary level and a minimum level are set, so there are two levels of fishing mortality and advice is given. Many of the stocks, well over 75 per cent, are below that precautionary level. The precautionary approach is not really being implemented at the moment through the decisions that are made at the December Council meeting. It is not that they are being too widely used, they are not being used widely enough. As I say, until we have more data and certainty to be able to implement the ecosystem based approach, we would advocate caution where, in many instances, we simply do not know the impact of fishing and a prolonged over-exploitation of stocks. In that context and in that climate we feel it would be extremely unwise to proceed without any caution at all. Q65 Mr Lazarowicz: You have a specific recommendation that if fishing activities should cease, if spawning stock biomass falls below a certain level, who should determine the level and how would you enforce that level? Ms Davies: At the moment, that level is based on the catches and stock assessments from the previous year by ICES, which is the international scientific fora, which advises the European Commission. Obviously, that type of data can be augmented by data supplied by the industry, but they do set a precautionary level in order that the stocks can sustain themselves and reproduce to sufficient levels that can sustain fishing mortality in subsequent years. The precautionary approach is built into that criteria. Mr Lee: We feel that in practice the answer is not to attack a precautionary principle as an excuse for increasing fishing effort on over-fished stocks. There are two things: one is to get more data so we can make clearer and more precise decisions and the other one is to concentrate on the job of fish stock recovery, which is why we have put together the Invest in Fish Partnership in the South West of England with the fishing industry and the producers to see how we can do this. History speaks for itself, it says we have not taken enough precaution never mind too much, otherwise, we would not have 75 per cent of the stocks over-exploited. Q66 Chairman: Correct me if I am wrong. Insofar as the initiative for this Strategy Unit report came from everybody, it came from you in the sense that there was this suggestion that to invest in fishing, we had to scale down the effort and to help finance it from point A - which was bad - to point B - where there was an improvement - should be regarded as an investment. There is not much of that investment in the Strategy Unit report, in fact there is a deliberate avoidance of spending any Government money. Does this disappoint you? How do you feel about it? Mr Lee: I think that is a fair point that. That is why Invest in Fish was put together, to look at what the economic case is and what level of investment you would need in transition to take the industry and the fish stocks from where they are now to where they need to be. I think the balance between the industry paying and the public purse paying is a difficult one. Q67 Chairman: Which they are not Mr Lee: This is what we are being told. Q68 Chairman: Do you doubt that it cannot pay? Mr Lee: Yes. I would always question any industry position that says: "We cannot afford it, you should pay for it". That is healthy. Q69 Chairman: Touché. Mr Lee: But, there has to be some public investment in transition if we want a viable fishing industry as well as the fish stock recovery. We do, we want both and we think that is an important part of what we should be able to achieve here in the UK. Q70 Mr Lazarowicz: What is your message for the Fisheries Council meeting in December? We heard from the industry earlier on. What would be your Christmas wish? Ms Davies: I think I have talked about and relied a lot on the advice from ICES. It is the best information we have at the moment. It is not perfect, we recognise that, and we would urge the industry to try and improve that and input levels of data through whatever channels they can. Our message would be to set the quotas in line with the scientific advice and in line with the precautionary approach. Q71 Chairman: Part of the argument from the industry has been that in looking at the ICES recommendations, the Commission has chosen the worst case scenario and that that is outdated on the grounds that (a) it does not give account of decommissioning and (b) it does not take into account the improvements in the stocks since the figures were first collected in 2003, I think. Do you see any case for increasing the quotas? Ms Davies: With some stocks there is some room for manoeuvre and they are at less of a risk than others, but the vast majority of stocks are well below precautionary levels, the levels at which they can sustain themselves. We can argue about whether you base it on 2002 or 2003, year on year the quotas are set way above the scientific advice that is given. For instance, in the plaice fishery in the North Sea, which we have just been discussing, within the North Sea RAC, the industry is advocating a 15 per cent reduction in effort. The ICES advice recommends a 55 per cent reduction in effort, so you can see that there is quite a mismatch there. Q72 Chairman: What about cod? Ms Davies: We have not got around to discussing cod within the RAC as yet. I think there is a very strong message from ICES that there should be a zero quota for cod. I think we would support that insofar as we would recommend that there is no directed cod fishery, in other words, boats do not go out and specifically target cod. There may be some compromise to allow some of the boats to carry on fishing in a mixed fishery where they are allocated a quota where cod is caught as a by-catch, for instance, but it would be wrong to assume that juvenile cod is not caught within the by-catch of the fisheries and that issue has to be addressed and, where possible, fleets should be going out and targeting the areas where there are not aggregations of cod. There might be aggregations of other species. I think recovery plans is the final point that I would urge the Commission to implement. Chairman: Thank you very much indeed. That is a beautiful piece of timing, we are very impressed. Thank you.
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