Examination of Witness (Questions 220-239)
Dr Euan Dunn
26 MARCH 2008
Q220 Chairman: Could you say a little
bit more on marine conservation areas or protection areas. If
you were to imagine a map, could you identify where they would
be and how big they would be? Are they temporary or permanent?
Are they one year, one month, five years? I just want to get a
feel for what they would look like.
Dr Dunn: You have a two sorts of critical areas:
spawning areas—and we are just talking about cod for the
purposes of argument—and nursery areas. Some of these are
fairly predictable from year to year, so they are not moving around
in a random way. These are areas that are used for very particular
environmental reasons by that species. The conditions suit the
purpose for which they are chosen. It is not a totally random
process. You can do quite a lot of marine spatial planning on
this. The fishermen know where the cod are spawning and they can
predict from year to year where it is likely to be. There is flexibility
in that. We are not necessarily talking about massive areas. These
can be quite circumscribed areas, so in that sense they are quite
tractable for applying a cod avoidance approach.
Q221 Chairman: What length of time
would they be in place?
Dr Dunn: Until such time as the spawning period
is over or the nursery period is over and the fish disperse into
other areas. John Pope knows a great deal about this. We have
a good handle on the dynamics of how the fish behave through the
months of the year.
Chairman: Perhaps we could go on to follow up on
bycatch and discards.
Q222 Baroness Jones of Whitchurch:
You have already touched on this and you quote this really shocking
figure in your evidence that almost two-thirds of the fish caught
in UK waters are discarded, so it is clearly a very, very serious
problem. Some of the submissions we have received are arguing
for a complete discard ban. Do you think that is feasible, operational,
desirable?
Dr Dunn: Yes, I think it is. It is something
Norway has practised for a while. They have simpler fisheries
than us. The fisheries are not so mixed, so the fish swim more
in unispecies shoals. Also, the age structure is generally better,
because they have conserved their fish better over the years,
so there are not so many juveniles. The fact that so many of our
fish stocks have an age structure which has too few old, mature
fish and too many of the younger ones creates the problem, because
these are fish which are often below the minimum landing size
and legally cannot be retained on board. My view is that the Commission's
proposals and its communication on discards is a good way to go.
I would like to see a trial—maybe two or three fisheries
could be used as trials—on a fishery-by-fishery basis of
a discard ban. A discard ban effectively means that you retain
the fish on board instead of dumping it over the side and you
land that retained fish as well as your marketable catch. This
is how it has proved in Norway: everybody knows in Norway that
the discard ban is not cast iron—as somebody said to me,
"The nights are long and the waters are deep"—I
am sure there is all sorts of malpractice, but, together with
these real-time closures which we spoke about a moment ago, when
you close an area for such time as juvenile fish are occupying
it, it creates a mindset in the fishermen that these are good
things to do for the sustainability of the stock. We are not looking
for 100% perfection here. I would like to see a discard ban attempted
on a trial basis based on this idea of the Commission's of a total
allowable, maximum acceptable bycatch, so you set a bycatch limit
for the fishery. The fishermen are incredibly inventive and creative.
They will come up with ways which they probably know about already,
in many ways, but have not had to operate in any sort of way,
in vengeance and anger, if you like. They know about these ways
of reducing their bycatch, and having a maximum acceptable bycatch
will bring all these things out of the woodwork and the fishermen
will find ways of reducing their bycatch. I am absolutely certain
of that. The European Parliament's view is not to have—
Q223 Baroness Jones of Whitchurch:
I am sorry to interrupt, but why do they not do that now? Why
do they not reduce their bycatch now?
Dr Dunn: Because it comes down to—the
other well-worn phrase you hear in fisheries a lot now—a
"level playing field": if I am fishing and I have a
separator grid in my fishing net which will allow things to escape
but I know that the chap over there, who might even be from another
Member State or another member of my own fleet, is not using that
and he is catching those fish—and they are often fish that
you want to keep because they may be of marketable value. For
example, on the West Coast of Scotland the voluntary use of separator
grids for nephrops trawls are not working as well as they should
because the fishermen really want to keep some of the things that
are escaping through those grids because they have market value.
That is why you need to create a level playing field across all
the vessels and all the Member States, so that everybody is working
to the same set of rules. It is this disparity between one fleet
and another, one Member State and another, which allows for individual
vessels to steal a march on their competitors. That is why it
does not work as well as it might.
Q224 Baroness Jones of Whitchurch:
You are saying—and you were alluding to this in the Norwegian
waters—that there will always be some discards. It is human
nature that people will try to keep the higher value stock. If
it is something they do not think has a saleable value, they will
ditch it, will they not?
Dr Dunn: Indeed. Also, of course, they do not
want to fill up their holds or any other part of their vessel
with fish which are not of high market value. That is a real problem.
I think you need two things. You need a degree of enforcement.
The main critics of discard bans say, "How will you ever
enforce it?" You do need a degree of enforcement and that
comes back to the observer programmes that I spoke about earlier.
They may not be permanent but, hopefully, they will inculcate
some kind of change in behaviour. Secondly, you need to give the
fishermen some incentive for landing the fish which they do not
regard, as you say, as of high marketable value. That is going
to be a very sensitive issue, because you must not create such
market value for those fish as to create an incentive to catch
fish which you would otherwise have sought to avoid catching.
In New Zealand there is a small amount of compensation and in
Norway there is some compensation for the commercially important
fish which you land as bycatch. It probably goes into offset the
fish-meal and oil processing industry, which is a good thing.
It might take some pressure of the sandeel fishery. I think it
needs to be explored. It is a difficult one, but if you do not
try it you will never find out if it works or not.
Q225 Chairman: I do not see immediately
the justification for requiring a fisherman to land or not discard
catch which comes from a species which is not subject to attack
and which has zero commercial value. Why would we require fisherman
to land that particular catch?
Dr Dunn: I think you are right to a degree.
There is a sort of hierarchy here. Clearly the most important
thing to do is to land the undersized fish from the stocks that
you are targeting, so landing undersized cod, haddock, or whatever.
But I think there is merit in landing fish for which there is
no TAC. Incidentally, experience of the Common Fisheries Policy
over the last ten years is that more and more fish stocks are
becoming quota species. Even shellfish are quite likely to become
quota species in the coming years because the shellfish industry
is hugely commercially important now as a sector. Apart from anything
else, you get a lot of information if you are bringing fish ashore.
There is a lot of scientific information to be gleaned from that,
and that in itself is a bonus although it is not going to be the
primary driver.
Q226 Chairman: There is the possibility
that a fisherman may set out on his boat—it is an expensive
business to take the boat out fishing—the only catch he
gets is the stuff that has no marketable value, and he has to
bring that back in. That is an expensive waste of time and effort
for him is it not?
Dr Dunn: I would imagine, in the event where
you have a discard ban, there will be laid down the particular
fish which you need to retain. In Norway it is commercially important
fish and nobody is saying that you should bring back every starfish
and sea urchin.
Q227 Chairman: I have that clarification.
I think that is quite important. Two little clarifications. On
the trial ban that you are advocating on discards, would the landed
bycatch count against the TAC?
Dr Dunn: That is a very good question. I think
that it probably should: they are all dead fish, they are all
lost from the population. But that is going to be one of the most
contentious issues and I think there will be a huge amount of
resistance to it. In the North Sea, at the moment, I think there
should be no directed cod fishery as such. I think there should
be a bycatch TAC, if you like. All the cod taken in fisheries
should be regarded as bycatch.
Q228 Chairman: Finally, if there
were to be a ban on discards, that would affect bird populations,
would it not?
Dr Dunn: Yes, it would. There are a few things
to say on that. We have done quite an elaborate study of this
over the last few years. We did a report on it about three years
ago. The first thing to say is that it is not widely recognised
that, although you have these very high discard burdens in the
North Sea and elsewhere, the total tonnage of discarding has been
going down quite dramatically over the last ten/15 years, especially
of small haddock and whiting and so on. That is basically because
the source populations themselves have been declining, so they
have not been generating discards at the same level they used
to. That is to disabuse any idea that discarding is rocketing
up decade by decade. It is not so. But over the last century or
so we have seen that discarding has probably fundamentally shifted
the balance of the ecosystem, particularly for scavenging seabirds,
so that you now have a different mixed assemblage than you used
to have. That is ecosystem disruption. It is not something that
I would defend. In many ways discarding is a symptom of unsustainable
fishing. I would never ever argue for the promotion of the maintenance
of discarding to sustain seabird populations.
Q229 Earl of Arran: Out of interest,
for how long can a fish survive on board before it is dead?
Dr Dunn: It depends which sort of fish you are
talking about. If you read Fishing News this week, trials
have been done in the South West on the survivability of some
of the fish in the South West or the Channel. Fish that have a
swim bladder, like the whitefish, when you bring them to the surface
the swim bladder, I think, pops—I am not too hot on my physiology
there, but they are effectively goners. Deep sea fish, of course,
have no chance whatsoever of surviving at the surface. But certain
fish do survive quite well. Skates and rays can be returned alive.
Some flatfish can survive. There is the possibility to put a fish
back which you do not want, but, obviously, the more handling
it has on deck and the longer it stays in the net and so on, the
less chance it has. But it is a good point, I think. It is an
important point for the idea of including in that bycatch the
whole concept of catching things like turtles and seabirds and
sharks—things that are important, vulnerable species for
which there is global concern. The idea of returning those to
the wild, so to speak, after capture is very important indeed
and should be, to my view, part of an integrated discard policy
of the Commission.
Chairman: Thank you. Lord Plumb on climate change.
Q230 Lord Plumb: You say in your
report that climate change has positive and negative implications
for fisheries in creating some opportunities for some and the
reverse for others. You have referred several times to the importance
of a level playing field. How can you bring about or adapt a policy
that is acceptable and suitable to meet these needs?
Dr Dunn: To a large degree down to work done
in the UK by the Sir Alister Hardy Foundation. Through a wonderful
device, the Continuous Plankton Recorder, which we have been using
now continuously for certainly most of this century, we have a
wonderful record of the plankton assemblage in our waters and
in other parts of the world. Since the 1980s there has been a
fundamental change in the plankton assemblage of the North Sea
and western waters. Scientists do not use this word lightly, but
it is a "regime" shift: the cold water plankton have
been replaced by a warmer water plankton—and I am speaking
now about the zoo plankton, the little tiny crustaceans—and
that has fundamentally changed the ecology of our seas. It is
the biggest change that has happened in decades and even, possibly,
the biggest change that has happened in the North Sea since it
formed after the Ice Age—who knows. We are seeing a fundamentally
different set of environmental conditions. These are favouring
some fish and not others. The coldwater species, cod—although
there has been a lot of new evidence lately to countermand some
of the more serious fears earlier on that they are finding these
changed conditions totally to their disliking—seem to be
disadvantaged by the warmer waters and the change in the plankton
mix. Sandeels certainly seem to be, for the same reason. With
sandeels, when the larvae hatch out from the eggs in the late
winter they have to find the right plankton they need to survive
and grow, and they are not finding the right plankton they need
to survive and grow. It is a very narrow window of opportunity
for them to break into the recruitment age group. They are not
doing that and sandeel populations are massively reduced compared
to what they were just five/ten years ago. To answer your question
more directly, I think fishing has to go with the grain of this.
This is not something that we will reverse in our lifetimes or
even our grandchildren's lifetimes, but we can do short-term things
about fishing. Fishing has to go with the grain of this and, in
my view, has to be more precautionary and take these changes into
account as part of the equation. For sandeel fishing, cod fishing,
herring fishing—herring has had a succession of very poor
recruitment years since 2000, probably due to sea warming again—you
simply have to ratchet back your effort to take account of these
changes which you cannot possibly control in the short-term. On
the other hand, you have species moving into our waters from the
south: mullet, bream, horse mackerel, squid. There is a thriving
squid fishery in the Moray Firth now which was not there years
ago. We can be alert to these new fishing opportunities, and it
will be particularly useful, I think, for the beleaguered inshore
fisheries to cash in on some of these smaller species. There are
fishing opportunities there but, on balance, I think it is negative.
I think these new opportunities are likely to be outweighed by
the disruption of our traditional coldwater stocks.
Q231 Lord Plumb: Whilst this is obviously
the long-term change, would you see much development in the next
decade?
Dr Dunn: I think so. Nothing that I have read
disabuses the thought that sea warming is continuing and will
continue to get worse. This will have some predictable effects
and it will have lots of unpredictable effects. An unpredictable
effect—and the jury is out on the implication now of the
involvement of sea warming—is that our seas are awash from
here to the Barents Sea, right up into the North, with pipefish.
They are little, leathery fish, with bony scales on the outside
like an exoskeleton. They are highly inedible. Seabirds are bringing
them ashore in vast quantities, maybe mistaking them for sandeel.
They have no nutritional value. They choke seabird chicks. They
are probably choking lots of other things as well that are trying
to eat them. Nobody even knows what they are doing to fish populations
that prey on them. There are a lot of unexpected changes happening
in our seas and we are not quite sure where it is all going to
end, I suppose.
Q232 Lord Plumb: Do you think sufficient
research is being done in that whole field?
Dr Dunn: I think Defra and the institutes, organisations
like SAHFOS (Sir Alister Hardy Foundation for Ocean Science) and
Plymouth University and others, are alive to this. There is a
lot of effort going in. It is a big worry. If we cannot understand
how the ecosystem is changing, we cannot properly introduce an
ecosystem-based approach. We have to keep our finger on the pulse
of these things and the pulse is racing.
Chairman: Lord Palmer on control and enforcement.
Q233 Lord Palmer: You have really
answered the question about the enforcement but how big a problem
do you think illegal fishing is within the EU waters? Perhaps
you could expand a little bit on how to control the enforcement
regulations to solve the problem, so to speak.
Dr Dunn: IUU, so-called—illegal, unreported,
unregulated fishing—has a very high profile now. You probably
know the High Seas Task Force, which was headed up by a UK minister
over the last five years, reported last year. It has a very high
profile. It is a global problem. In the EU, illegal fishing is
patchy in its distribution. I think there is probably a lot of
illegal fishing going on in the inshore fleet in England and Wales,
which is in desperate straits at the moment, and this was reported
in The Guardian yesterday. It was a very useful and well-researched
article, I felt. The Scottish fleet had a very, very bad record
of "black fish" landings up until a few years ago and
I am fairly convinced, having spoken to a number of the markets,
the processors and the practitioners, that they have cleaned up
their act. They have very, very good registration of landings,
they have very, very good monitoring of fish from net to plate,
if you like, and the Scottish fleet is doing an exemplary job
after a pretty muddy time in the 1980s and 1990s. With the inshore
fleet in England and Wales, I think there are issues there. Not
in Scotland. There is certainly a lot of illegal fishing going
on in other parts of the European Union. I think it is still,
to a large extent, being driven by overcapacity in a number of
fleets. We like to think that the CFP has kicked into that problem
pretty hard with the abolition of public aid for vessel building
and so on, but there is still overcapacity. I would say there
is overcapacity in the beam trawl fleet, particularly the Dutch
beam trawl fleet. There is overcapacity in the UK and Welsh inshore
fleet, I believe, and that will be slimmed down just by market
forces in the coming years. A lot of illegal fishing is driven
by fishermen finding themselves in straitened circumstances and
feeling compelled to cheat. If you reduce capacity to match the
stock resources then you certainly have to relieve that and balance
that equation.
Q234 Chairman: This is it, is it
not? Is not overcapacity the nub of the whole problem of the Common
Fisheries Policy?
Dr Dunn: Overcapacity is a combination of the
size of the fleet and the amount of effort it expends—if
you like, deployed capacity. I believe that is absolutely the
case. We still have overcapacity and there are a number of reasons
for that, not least of which is the whole issue of technical creep
or technological creep. The rate at which the vessels which are
not decommissioned are capable equally of fulfilling the capacity
of what was lost and surpassing that is quite profound. ICES reckons
that technical creep is of the order of 1 to 3% per annum, but
I have seen studies which have shown higher percentages, 4%. It
is a very, very difficult thing to measure but it is a combination
of new and more efficient gear; more efficient fish catching methods;
the high-tech: all the GPS and the sonar and the fish-finding
equipment; the power of the engines. Some of the inshore vessels
now are little power-packs. They may only be ten metres but they
have the fishing power of an older, larger, offshore fishing vessel.
That really is a problem. To me, the Commission have never successfully
managed to factor technical creep into their capacity reduction
targets over the years I have been doing this. Part of the reason
for that is that Member States have been so unforthcoming about
what is happening in their fleets. That is not entirely their
fault; it is partly because it is so hard to measure but it is
a problem.
Q235 Earl of Arran: Surely, any new
boat with technical creep on it can be policed and disallowed.
Dr Dunn: You would think so, but the one of
the loopholes in the European Fisheries Fund—or, at least,
it was a very highly contested point and not everybody was happy
with the outcome—is that the European Fisheries Fund can
be used to replace engines on fishing vessels. There are all sorts
of ways of using that as a smokescreen to introduce a more efficient
engine. It may not be more powerful in strict kilowatts or horsepower
but you can introduce an engine which enables your vessel to fish
much better. That is very, very hard to police, and it is often
not adequately policed in some of the southern European Member
States particularly. There are ways around it. My grandfather
was a fishermen and I spent a long time talking to him when he
was alive and fishermen are incredibly inventive and clever at
finding ways around all sorts of restrictions. It is in their
blood.
Lord Cameron of Dillington: A bit like
farmers really!
Chairman: You mentioned the European Fisheries
Fund and Earl of Dundee has some questions on that.
Q236 Earl of Dundee: If we look at
three connected aspects: firstly, the European Fisheries Fund;
secondly, current guidelines on state aid to the fisheries sector;
and, thirdly, the objectives of the Common Fisheries Policy, do
you believe these considerations are sufficiently aligned?
Dr Dunn: I think there has been a really good
attempt to align the European Fisheries Fund to the reformed Common
Fisheries Policy. I think the spirit and the intent and the substance
of the EFF its objectives, the criteria for deployment of funds,
it is really in harness pretty well with the aspirations of the
reformed CFP. Certainly it is a huge step forward compared to
the Financial Instrument on Fisheries Guidance (FIFG) which it
replaces. There is one health warning about the EFF which is sometimes
overlooked: the European Fisheries Fund is €3.8 billion.
The Financial Instrument on Fisheries Guidance which it will progressively
replace was €3.7 billion across 15 Member States, so now
we have virtually the same pot of money but across a hugely enlarged
European Union and, moreover, the FIFG gave an extra €270
million for the 10 new Member States between 2004 and 2006 as
a sort of precursor to the EFF, so it had already tried to bridge
that gap. We finish up with a European Fisheries Fund which is
a cake which is going to have to be sliced much more thinly than
its predecessor and that literally means we are going to be able
to do an awful lot less with it than we could have done with the
FIFG, albeit that the money will be, in my view, deployed in a
much more constructive way in terms of sustaining fishing and
fishing communities and the wider ecosystem.
Q237 Earl of Dundee: If that then,
as you say, is the downside and the anomaly, what can we do about
it?
Dr Dunn: There is no likelihood in the short
term of changing the budget. I think that is pretty carved in
stone and it is probably something that I assume we will come
back to in 2012/2013, because, after all, the EFF is set to run
from 2007 for the next five years. But I do think that it is going
to be very much down to Member States to use this money in a judicious
way and that is the fundamental difference between the FIFG and
the EFF. The EFF is not a structural fund, as such, in the old
mould. It gives much more subsidiarity to Member States on how
they deploy the money. What then becomes crucial is the so-called
Operational Programme of the Member State on how it deploys its
money. The UK has taken a long time to develop its Operational
Programme. It is a bit in the slow lane. A number of Member States
have already had their Operational Programmes signed off by the
Commission and are up and running with the EFF. I will not go
into detail but the reason we have struggled is because we have
had to deal with the whole issue of getting an Operational Pprogramme
agreed across four devolved countries: Scotland, England, Northern
Ireland and Wales. That has created its own problems. There has
been a lot of negotiating—you can just imagine it—but
we now have an Operational Programme under consultation by Defra.
The consultation is going on right now to a fairly tight deadline
because they know they have to speed up. I think it is very important
to scrutinise that official programme to see that it does support
the central pillars of the European Fisheries Fund; that it generally
supports small-scale fishing; that it incentivises the development
of more selective, less environmentally damaging fishing gear;
that it is thereby and in other ways more consistent with the
implementation of an ecosystem approach on a progressive basis.
What can you do about it was your question. At this stage now
I think you can make sure that Member States are doing the right
thing by the criteria that are set down in the funds, sort of
terms of reference.
Q238 Earl of Dundee: Bearing in mind
what you have said about overcapacity and overcapacity plus effort,
as it were, any form of funding from the fishery industry is a
negative, is it not, really? It is a downside. I am just wondering
whether the WTO is going to have any effect on this. Do you hold
out any hope?
Dr Dunn: You probably read my evidence on this.
Q239 Earl of Dundee: I did, yes.
Dr Dunn: It has been a very depressing experience,
the whole process of the fishing subsidies going through the WTO.
They are now trying to kick it into life. There is a draft resolution
or a draft document on the table which says all the right things.
If, hypothetically, the WTO states can agree this draft and the
European Union as a contracting party was then bound to follow
its edicts, that would put further pressure on the EU to row back
even more on existing subsidies. For example, through a rather
odd outlier of European funding called de minimis aid, it is a
de facto subsidy for fuel costs in the fishing industry.
If you are funding fuel, you are fuelling over-fishing. The RSPB,
through our European offices of Birdlife International, in conjunction
with other NGOs, fought quite hard against the changes in the
de minimis criteria and funding levels. Also, you will see from
my evidence that one of the hot issues in the WTO draft at the
moment is looking at the extent to which small-scale fishing around
the world should be seen as a special case. You can understand
why that is there, because in most of the world small-scale fishing
is artisanal fishing which supports the livelihoods of highly
dependent fishing communities. The European Commission, I think,
have been arguing in WTO talks that the European Union's fleets
are made up of something like 75-80% small vessels, so they have
been arguing to have the same rules applied to them as to developing
countries. I think this is a nonsense really. I do not think there
should be any special pleading in that way for inshore fisheries.
Inshore fisheries, as I have said, because of a point I made a
moment ago, can be just as destructive of fish stocks as their
offshore counterparts. I think we need to get into a situation
where fishing is driven mostly by market forces and the fleet
is slimmed down to what the fish stocks and the market can dictate.
I do not think we should be giving any special featherbedding
to any particular sector of the fleet. I think the inshore fleet
has had a pretty rough deal in this country and there are other
things that can be done to assist it, but not that.
Chairman: Earl of Arran on governance.
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