Landing obligations and application in the Clyde: EIR release

Information requested

1. Can you confirm if the landing obligation applies to the nephrops trawlers in the Clyde. If so, I write to request data for how much weight in fish has been landed via the landing obligation from the Clyde area?

2. I note that the estimate of just cod by catch based on Clyde fisherman's association claims is approx 100 ton per year and that would equate to roughly 2 ton a week of cod alone and with the other quota species being much more prevalent I would imagine the figures to be significant. Can you confirm?

3.  Does the landing obligation apply in the Clyde nephrops trawl fishery?

4. If so please can you confirm the overall weight of fish disposed either by week, month and or since the beginning of the obligation?

5. Do you have a breakdown by species if so can you please supply that?

6. We noticed that although there is an extensive trawl fishery for 6 months in the inner sound, we see no discarding facilities, can you please explain or clarify this situation, is it that no fish are being caught or there is no obligation to land them?

Response

1. Can you confirm if the landing obligation applies to the nephrops trawlers in the Clyde. If so, I write to request data for how much weight in fish has been landed via the landing obligation from the Clyde area?

The landing obligation (LO) does apply to Nephrops trawls in the Firth of Clyde, as it does to any catches of quota fish. The landing obligation was introduced in 2015 and has been fully in force since January 2019. Its goal is to eliminate discards by encouraging fishers to fish more selectively and to avoid unwanted catches.

As part of the reformed Common Fisheries Policy (CFP) it has been agreed that catches of quota fish may no longer be discarded. Instead, all of the catch must be landed and counted against quota. The discard ban, or Landing Obligation, only applies to species subject to catch limits and those subject to minimum size limits in the Mediterranean. There are some exceptions to this rule however, in the form of exemptions. High survivability exemptions are granted when a species is shown to have low mortality rate on catch and release in a specific fishery (e.g. nephrops from creels); de minimis exemptions are granted in situations whereby there are negligible catches of a quota species in a fishery and/or the cost of landing and disposing of them would inflict disproportionate costs upon the fishers. There are also prohibited species which must not be landed, which come with their own set of rules (e.g. cetaceans). These exemptions in no way equate to free fish however as, for every exemption put in place, a deduction of the overall quota for that species is made to account for this.

To clarify, while there is no “fish landed via the LO”, only fish that is landed. It could be expected that there may be a slight increase in certain types and sizes of fish landed because of the LO, but there is not a separate ‘discards’ element.

At present, there are significant selectivity measures in place for Nephrops trawlers in the equipment they use to fish. These measures are in place to seek to minimise unwanted catch in the first instance. I would refer you to our published LO guidance, which gives significant detail on these selectivity measures. The level of selectivity of gear used in the Firth of Clyde typically results in a clean Nephrops fishery with little bycatch. Any fish caught above minimum conservation reference size (MCRS) would typically be retained by the crew for personal consumption. Given that masters are only required to record catches of more than 50kg of a species (for over MCRS) in their logbook, and catches of fish in the Clyde Nephrop trawl fishery are negligible, we do not have any data on the quantity of fish retained for crew consumption. It should also be noted that previous High Survivability trials on Nephrop fisheries did allow for some discarding as a result of bycatch survivability. This trial was not region-specific to the Clyde, covering instead the wider Scottish fishery.

2. I note that the estimate of just cod by catch based on Clyde fisherman's association claims is approx 100 ton per year and that would equate to roughly 2 ton a week of cod alone and with the other quota species being much more prevalent I would imagine the figures to be significant. Can you confirm?

Regarding the claim by the Clyde Fisherman’s Association, this is a claim by a private organisation which is not a component of the Scottish Government, however it is worth noting that there is no directed cod fishery anywhere on the West Coast and any catches of cod recorded are and should be recorded as bycatch. There is no cod quota allocated to west coast fishing vessels.

3. Does the landing obligation apply in the Clyde nephrops trawl fishery?

Yes, to confirm in addition to the above, the landing obligation does apply in the Clyde Nephrops trawl fishery.

4. If so please can you confirm the overall weight of fish disposed either by week, month and or since the beginning of the obligation?

Again, for clarification, landed catch does not necessarily mean it is disposed of.

The discard ban was phased in over a number years, starting in 2015 with pelagic fisheries, extending to demersal fisheries in 2016, and being fully implemented across all TAC species by 2019. As such, this will impact the overall weight recorded, as it has not been applied across fisheries from the outset. It is worth noting as well that figures for physical disposal of fish by weight would be hard to come by in instances where an exemption was in place, as the quota would have been adjusted according to need at the start of the year and the species subsequently returned to the sea under the exemption. For example the west coast 3% haddock de minimis was implemented to alleviate disproportionate costs to west coast fishermen who caught very small numbers of fish, but under the landing obligation would have had to pay high costs for the transport and disposal of this small measure of fish. In such cases, as outlined above, the 3% would have been taken from the haddock quota at the start of the year, ensuring that it was all fully accounted for and allowing fishers to return this species to the sea instead of landing it. Note, this only applies to below MCRS catch.

For vessels in the Clyde, these may be recording small quantities of Below Minimum Size (BMS) catch. Under EIR guidelines, an exemption applies to this specific point. Owing to the small size of vessels which have recorded BMS fish caught in the Clyde over this time period, releasing this information would be disclosure of third party personal information, and is therefore exempt from release per exemption 11(2) - Third party personal data.

5. Do you have a breakdown by species if so can you please supply that?

Per above points.

6. We noticed that although there is an extensive trawl fishery for 6 months in the inner sound, we see no discarding facilities, can you please explain or clarify this situation, is it that no fish are being caught or there is no obligation to land them?

By inner sound, I assume you are referring to the area off Skye. There are no facilities to receive BMS fish in this or surrounding areas. This is owing to the catch amounts being so small there has been no need for councils or Port Authorities to have the infrastructure to handle this. Landed BMS fish typically goes to local creel vessels for bait and as already mentioned there are de minimis exemptions for certain whitefish species (specifically haddock and whiting on the west coast) in order to alleviate the disproportionate costs of landing and disposing of the below MCRS bycatch.

You may also find it helpful to consult the Scottish Sea Fisheries Statistics (most recent published data for 2020), which can be a helpful reference source.

I trust that you will find this information useful.

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