Examination of Witness (Questions 203-219)
Dr Euan Dunn
26 MARCH 2008
Q203 Chairman: Good morning. Welcome.
Thank you for finding the time both to prepare your written evidence
that has been submitted but also to come along this morning and
help us with our inquiry. How would you like to proceed? Would
you like to make an opening statement and then go on to the specific
questions we have or do you want to go straight on to questions
and answers?
Dr Dunn: I think we could go straight into questions
and answers really. Perhaps I might just introduce myself. I am
Euan Dunn, I am Head of Marine Policy at the RSPB. I have worked
mainly on the Common Fisheries Policy and the environmental integration
of that. I am also, in other capacities, on the board of the Marine
Stewardship Council, so I have a linkage into the sustainability
of the food chain and sustainable use in that way. I very much
welcome this review. I thought the questions were spot on: the
sorts of questions that elicit the sorts of responses you want
to hear, I think. We were very engaged to get your set of questions
and I look forward to elaborating on any issues that they throw
up and answering any new ones.
Q204 Chairman: Why is the RSPB interested
in the Common Fisheries Policy?
Dr Dunn: For a number of reasons. First of all,
fishing is probably the most pervasive influence on the whole
of the marine environment, with the possible exception of climate
change which is beginning to kick in as a major driver of change.
That has fundamentally changed the ecosystem over the last 100
years. We have shifted, for example, the assemblage of seabirds
into a much more scavenging role as a result of the mass production
of discards and we have fundamentally changed habitats, not just
for seabirds but for all marine wildlife. There are also much
more specific issues, like the control of industrial fishing,
which is at the base of the food chain and therefore a fundamentally
important prey species for not just seabirds but for cetaceans
and for other marine wildlife. If we are looking at the array
of human activities in the oceans and we are looking at the environmental
impacts, fishing is right up at the top, and therefore the governance
and the institutional framework and the structures and measures
that are put in place by the Common Fisheries Policy are absolutely
central to conservation of seabird populations and the ecosystem
at large.
Q205 Chairman: Thank you. Perhaps
I could kick off with the first question. As you know, article
2 of the Common Fisheries Policy Framework Regulation mandated
the progressive development of an ecosystem-based approach to
fisheries management. What do you think that should mean? How
has it developed in practice? How would it be best delivered?
Dr Dunn: Of course that was a fundamentally
important shift in the reforms in 2002 as were a number of others,
so it has been a very important benchmark. Up until now and even
since 2002 the implementation of an ecosystem approach has been
very piecemeal, ad hoc, reactive. We have been fire-fighting.
We have been lacking a coherent strategy by the European Commission
to embed the ecosystem-based approach to fisheries management
in the operational aspect of the Common Fisheries Policy. That
is about to change. We imminently expect a communication from
the European Commission, from DG Fisheries and Maritime Affairs
this spring, on how they will implement an ecosystem-based approach.
We await that with interest. We will be looking for a fairly robust
approach. What is an ecosystem approach? There is a lot of obfuscation
around this and fishermen often say they hear so many definitions
and even decision-makers say they hear so many definitions. It
is rather like one of these fuzzy balls. Sustainable development
is often put in the same box. How can you get hold of it? To me,
it is very simple. As someone once put it: "Fishing needs
to try to adapt to the marine environment, not the other way around,"
and so it is simply how you manage fisheries to take account of
its undoubted environmental impacts. There are direct impacts
and there are indirect impacts. Often the indirect impacts are
the important ones. These are the ones where fishing changes the
food chain, which has knock-on effects for other elements of the
system. The single biggest thing the eco-system approach could
do if you were to implement it would be to reduce fishing pressure.
That would relieve pressure on the ecosystem across a whole raft
of elements, and that is sometimes overlooked. Secondly, if we
are looking to do it strategically, we need to develop what have
been pioneered in the United States and are known as the fisheries
ecosystem plans for regional seas. Defra is in the process of
embarking on developing an ecosystem-based approach to South West
Waters and so that will be a very important initiative. It will
build on the Invest in Fish project which is already taking place
there. You assess the most important aspects of the fishery, you
develop some objectives and some indicators, and then you adapt
the fishing activity through a variety of means to address the
gulf between current practice and sustainability. You monitor
the situation, you assess it, you adapt your management as you
go along. There are two other things we need to say about this.
It needs to be a bottom-up stakeholder-led approach. That has
been very much a hallmark of the reformed CFP and I am sure Defra
will do it that way. Lastly, if we are looking to get an ecosystem
approach embedded in the Common Fisheries Policy, we have a real
problem with the Commission. The Commission has precious little
environmental capacity in DG Fisheries and it has very little
dialogue with DG Environment, and the institutional framework
is just not, in my view, geared up to delivering an ecosystem
approach effectively. That has to change. I do not want to sound
too gloomy. International Council for the Exploration of the Seas
(ICES) has set down some very, very good frameworks for developing
and implementing an ecosystem-based approach. So it is all to
do, but I think we can make a lot more progress from the spring
onwards.
Q206 Chairman: How would an ecosystem
approach impact on the individual fishermen? What would they see
as being different?
Dr Dunn: The problem with the Common Fisheries
Policy, if I can preface it like this, is that up until probably
2002 there was a divorcing of the whole sustainability of the
fish stock situation from the ecosystem element. Seas were seen
as a production unit for fish and it was divorced from the wider
ecosystem impacts. An ecosystem approach needs to look at all
those things in the round. If you like, the fish themselves are
part of the ecosystem and part of the elements that need to be
protected. The fishermen will have to take on board things like
the need to protect juvenile fish, protecting critical areas for
spawning and recruitment. Things like minimum landing size will
need to be looked at to make sure that fish have enough time to
breed before they get caught, and we also need to look at reducing
bycatch of sensitive species like sharks and rays and any other
seabirds and whatever. This will not just be some environmental
add-on, it will become root and branch, embedded in the way that
the fisheries are managed and regulated.
Q207 Viscount Ullswater: Perhaps
I could return to the present. In your excellent memorandum you
note that about four-fifths of stocks remain outside safe biological
limits. Could you give your view on the initial application of
recovery and management plans under the reformed CFP. What measures
could be taken to improve their effectiveness and to facilitate
their adoption?
Dr Dunn: It has to be said that, in the first
place, the introduction of two changes of direction in the Common
Fisheries Policy was fundamentally important. The first was the
introduction of long-term management plans for species which are
not in deep trouble but to maintain them above safe biological
limits; that is, those species which are already above the line,
if you like, but to keep them there. The importance of that long-term
management approach was to break the vicious cycle of the annual
horse trading that goes on in the Fisheries Council. The fishermen
that I speak to are planning long-term strategies for their businesses,
they like the idea of stability from year to year. They do not
like the horse trading, if you really get down to the nitty-gritty
of it. Therefore, for those sorts of fish, long-term management
plans, and, for fish that are below safe biological limits—like
cod, which is still well below safe biological limits—the
recovery plans. So far, precious few of the European fish stocks
have been subjected to either of these—I think about 16%
in total. It is too early to say, I think, in most cases whether
these long-term management plans or recovery plans are working.
The jury is out. We have to give the Commission a little bit of
slack to see. They are trying to ratchet down the fishing mortality,
the number of fish that are killed on an annual basis, along agreed
targets—to ratchet it down year by year, and pull these
fish stocks back into a safe situation. In most cases we have
only had two or three years of that. Already, though, it is contentious.
The cod recovery plan has already been opened up to revision after
really being in place for quite a short time. To answer your question
on what we need to do to improve them: the first thing, clearly,
is that we need a much closer adherence by ministers to scientific
advice. We need to lock as much of the December Council as we
can into fixed harvesting rules, so that the ministers cannot
play politics with these recovery plans. We need to have a much
greater scrutiny of what is happening on the decks of fishing
boats. That means we need to have representative observer programmes—which
are routine in fisheries in many of the well-managed fisheries
in other parts of the world and which have not been properly addressed,
no doubt for resourcing reasons, in the European Union. There
are now tried and tested technical measures which work, and most
of these at the moment are voluntary. In my view, separator grids
in nephrops (langoustine) trawls which allow whitefish to escape
should be made mandatory, once they are shown to be more useful
than not, and the same for panels that allow the whitefish to
escape in bottom trawls. Therefore, there is a need for observer
programmes; a need for much greater mandatory requirements for
technical measures to create a level playing field across the
EU fleets; and a greater need for scientific advice. I think the
recovery plans themselves probably need to be tightened up in
a number of places. For example, they allow a latitude—some
of them are plus or minus 15%—in the total allowable catch
that can be set every year. For some species that is not enough:
you need a greater reduction than that. I believe they are going
to bring improvements, and they are already doing so for a number
of species like Northern Hake and Biscay Sole and a number of
others. I think we are on the right track and the Commission should
stick to its guns and strengthen where necessary.
Q208 Viscount Ullswater: Would the
sort of things you are suggesting be implemented through a licence
requirement?
Dr Dunn: Yes.
Q209 Viscount Ullswater: So that
you would not get a licence unless you took an observer with you
or whatever?
Dr Dunn: The observer schemes are most needed
in the demersal fisheries, for cod and haddock and whiting and
the like. The pelagic fisheries are in fairly good health, although
herring has taken a big knock. It is really the demersal, the
bottom trawl fisheries which desperately need some onboard scrutiny
and monitoring and assessment, particularly when the Commission's
discard policy begins to bite. That would be, as you say, written
into the criteria for gaining a licence; for example, in the southern
ocean, in the CCAMLR waters (Convention for the Conservation of
Antarctic Marine Living Resources), there is 100% observer coverage
on all its vessels paid for by the industry, and you cannot get
a licence to fish unless you carry an independent observer on
board. We regard that system in many ways as best practice. I
do not think we are looking for 100% in the EU but we need to
have sufficient for it to act as an enforcing stick.
Q210 Lord Palmer: Would you recommend
that that be industry funded again?
Dr Dunn: I think that would need to be looked
at. It could be a combination of things. To me that could be something
that could have some linkage to the European Fisheries Fund and
there could also be an industry element in paying for it. It is
something that needs to be explored. I would not want to be prescriptive
about it at this point.
Q211 Baroness Jones of Whitchurch:
Are you suggesting an observer on every vessel on every trip,
or that, randomly, you will turn up one day and suddenly find
there is somebody going out with you? Are you talking about them
doing it all the time? Because that would be fantastically expensive,
would it not?
Dr Dunn: Forgive me, I tried to say that my
thinking is on this that we should have observers on a representative
proportion of the fleet. There is quite good practice from around
the world which suggests, for different kinds of fisheries, what
would be an appropriate percentage of vessels on which to carry
an observer if you are going to get (a) the data scrutiny and
(b) the sort of interaction between the fishermen that has almost
sufficient critical mass to have an enforcing effect on the fleet
as a whole. Clearly, if you only have an observer on, say, one
in 20 vessels, that is a fairly soft, low-key intervention. On
other fisheries around the world we are looking at 20 or 30%,
something of that nature. It would have to be tailored to individual
fisheries. There is no one-size-fits-all on these things. It would
be a fishery-led thing and it would probably start on a trial
basis to see how it works and to iron out the teething problems.
Q212 Chairman: One is tempted to
ask if there is any data on the mortality rates of these observers!
Dr Dunn: They have to sleep and that is often
when—
Q213 Chairman: That is when it all
happens!
Dr Dunn: They cannot stay awake all night, these
guys.
Chairman: Let us move on.
Q214 Lord Cameron of Dillington:
On that last point, I have heard it put forward that possibly
having cameras on mast tops might be a way of continually checking.
Dr Dunn: If I may say, that is a serious point.
CCTV, if you like, onboard fishing vessels is proving very effective
in some parts of the world and the fishermen are taking it seriously.
If you have a camera based on the aft deck, where all the landing
and the discarding is going on, it really is like an additional
surveillance tool to the satellite vessel monitoring which tells
you where the vessel is at any point in time. There is real mileage
in what you suggest there.
Q215 Lord Cameron of Dillington:
I would like to move on to other methods of promoting sustainable
fisheries outside the quota system. You and other NGOs seem to
think that particularly marine conservation areas or effort limitation
programmes would be successful. On the marine conservation area,
in your evidence you talk about the failed ten-week closure for
cod in 2001. I would be quite interested to know about that in
detail, why it failed and how it failed and the rationale that
has been deduced from its failure.
Dr Dunn: It was a disastrous thing in many ways
because it was the first attempt by the Commission to try to deal
with the advice that was coming from ICES—which gives its
advice on stock assessment on an annual basis. It was the Commission's
attempt to address their advice in that year and in a number of
years since, that the fishing for cod in the North Sea and other
parts of the UK waters west of Scotland should be closed, that
there should be no fishing for cod. The Commission was struggling
to try to find something that was tractable and workable and they
came up with a ten-week closure in 2001. It was something like
February to the end of March or middle of April.
Q216 Lord Cameron of Dillington:
Over the whole of the North Sea?
Dr Dunn: No, it was an area of the North Sea.
It was not the whole of the North Sea. It had one fundamental
effect: it displaced the fishing that had hitherto taken place
in that area into the surrounding areas where the fleet had not
frequently fished in the past, and it damaged those areas. It
damaged haddock grounds. It was counterproductive. The fundamental
lesson to be learned from that was that, if you are going to implement
an area of closure, you first of all have to have very, very clear
objectives about what you hope to achieve by that closure and
you need to do a bit of modelling to see what are the likely "unintended"
consequences—which I think is the buzz word these days in
fisheries—but, secondly, as part of that first thing you
need to take account of the fact that you cannot just shift fishing
effort about and expect nothing to happen. The fishermen were
fishing around the edge of that closed area. They were putting
very intense pressure on the margins—fishing the "line"
I think is the word that was used—and you have to reduce
the effort across the board to make sure that you do not intensify
the effort in the places that are neighbouring the closed area.
That was never thought through properly. It set the whole thing
back, because it put the fishing industry in the frame of mind
that closures were fundamentally wrong and they would not achieve
conservation objectives, especially for highly mobile fish like
cod and mackerel. There have been trials and pilots in the North
East United States, in Georges Bank, which are admittedly quite
difficult to interpret because a lot of changes in management
were going on at the same time, but there is some prima facie
evidence that the closures did assist a number of stocks quite
considerably: flounder and haddock and so on. I feel that the
baby has been thrown out with the bathwater a bit with the area
closures of that kind, and they have not been properly considered
in the round. We are now seeing, of course, a different kind of
closure. The fishermen themselves are becoming more confident
and taking more control of their own activity. In Scotland we
now have the fishermen voluntarily having so-called cod avoidance
schemes, where they choose not to fish in areas where there are
concentrations of spawning cod or concentrations of juvenile fish.
After many years, you have to say, where this has been said, this
is finally taking on board some of the best practices in the Norwegian
model. The fishermen themselves are beginning to take on board
the idea of area closures but in a more sensitive, less of a blunt
instrument sort of way, where the area is closed as long as is
necessary—whereas here we had a rather arbitrary ten-week
closure of an area where the consequences of doing so had not
been really figured out.
Q217 Lord Cameron of Dillington:
How about "days at sea"? Is that effective?
Dr Dunn: I think it is here to stay. My own
view is that we are always going to have TACs and quotas around
as a fundamental building block of the regulations and measures.
I looked at the original question that was sent and the advice
the Committee had had from an economist. Is it better to control
fishing by outputs than inputs? You will get as many answers as
you ask people, but there is a case to be said that TACs and quotas
have been a pretty blunt instrument—like that closure I
mentioned—and, in principle, it is a more sensitive approach
to control how many vessels are fishing in an area for how much
time than to try to control what comes out at the end of the pipe.
Of course, total allowable catches are not really even that: they
are total allowable landings, when it comes to inspection and
control. I welcome the fact that the emphasis is shifting to a
significant degree in the execution of long-term management plans
and control recovery plans towards effort control, although TACs
and quotas are still behind those, and I think it is important
that that continues.
Q218 Lord Cameron of Dillington:
Going back to the marine conservation areas for a moment: if you
were trying to control the fishing of cod, for example—which
is obviously one of the more critical areas—in the North
Sea using marine conservation areas, would there be any other
regime or system you would use apart from the voluntary system
being implemented by the Scots which you mentioned earlier?
Dr Dunn: Absolutely. The key to the cod fishery
is the control of bycatch. It is a sad state of affairs but something
like 95% of cod are caught before they have a chance to breed
even once, which is why, interestingly, in the Scots fishermen's
criteria for avoiding these areas of juvenile fish, the trigger
for closure is when the cod reach 50 cm. The minimum landing size
is about 35 cm and it was originally 35 cm in the criteria, but
it was expanded to 50 cm because that means that those fish are
a bit older and are likely to be approaching breeding age. You
have cut yourself a bit of slack, if you like, so far as the sustainability
of the cod population is concerned. To me, the discarding policy
is absolutely crucial. An awful lot of the cod are being lost
through bycatch in other fisheries, like the nephrops (langoustine)
fisheries. I think the European Commission estimated that something
like two-thirds of the juvenile cod were being lost in fisheries
other than the directed cod fishery. I support the Commission's
proposal for a total allowable bycatch, if you like.
Q219 Lord Cameron of Dillington:
My question is on marine conservation areas. Could only the voluntary
system work? Could the Commission implement any form of marine
conservation area that would work effectively in the North Sea?
Dr Dunn: My view at the moment is that there
is a lot to be said for going with the bottom-up approach: the
fishermen coming forward with their own ideas, their own proposals.
Working in the Regional Advisory Council, as I do, for the North
Sea, that is where your compliance comes from. We have to get
away from the more top-down approach, where fishermen will find
a reason to resist the command and control. I think it is good
the way it is going. The cod avoidance plans I think need to be
very well observed, monitored, assessed, to see if they work.
We are not just going to give them a tick and let them rip.
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