Submission on final proposals for fishing opportunities for 2018

Nov 21

Re: Submission on final proposals for fishing opportunities for 2018

The Irish Wildlife Trust (IWT) is an Irish non-profit organisation concerned with the conservation of Ireland’s biodiversity. As an island nation our marine and fisheries resource is a vital component of our natural and cultural heritage. Its sustainable use is therefore an essential element in preserving our rich biodiversity as well as our economic well-being. Article 2(2) of the Common Fisheries Policy Regulation states that “the CFP shall apply the precautionary approach to fisheries management, and shall aim to ensure that exploitation of living marine biological resources restores and maintains populations of harvested species above levels which can produce the maximum sustainable yield” (my emphasis). Allowing fish stocks to grow beyond their current levels is an essential component of building fisheries for long-term exploitation as well as repairing damaged marine ecosystems.

To meet these targets it is essential that the Irish government takes a strong position in adhering to scientific advice across all stocks.

The IWT has particular concerns with regard to the continued overexploitation of sea fish and other marine life in Irish waters. In particular, the continued widespread use of bottom trawling is linked with the destruction of marine habitats, reduction in biodiversity and gargantuan levels of waste through ‘discarding’. The IWT believes that bottom trawling is incompatible with meeting the aims of ending overfishing (due to its indiscriminate nature), ending discarding (as it is impossible to avoid unwanted bycatch) and protecting the marine environment as enshrined in the Marine Strategy Framework Directive (MSFD). The IWT would like to see greater scientific investigation, through the Marine Institute, of the potential benefits of ending bottom trawling along with the creation of large Marine Protected Areas (as required under the MSFD).

The IWT acknowledges the short term social impacts of following scientific advice, and in particular implementing the cuts proposed by ICES for 2018. Last year, Bord Iasciagh Mhara, in their Sustainability Impact Assessment (SIA), suggested that following scientific advice would result in the loss of “350-400 full and part time jobs either through reduced incomes, partial lay-offs or redundancies”. The supporting evidence for these figures is not presented. Assuming these calculations are accurate however – the SIA completely ignores the positive effect on employment through ending overfishing and rebuilding fish populations. Any SIA which fails to balance the short term negative effects with the long-term positive effects is failing to present a full and accurate analysis. This is something which needs to be corrected.

The Commission advice is proposing a TAC of 292 tonnes for cod in the Irish Sea for 2018. This is the first time since 2004 that catch advice from ICES has been greater than zero. Such a proposed increase, from a state of ‘collapse’ only a year ago, is contrary to the precautionary principle. ICES itself highlighted that the increase in population – welcome as it is – is due to a very successful single year class, and that numbers are likely to decrease even with no increase in TAC. To increase the TAC this year is therefore irresponsible.

Yours sincerely,

Pádraic Fogarty – IWT Campaigns Officer

21st November 2017