Ref. Ares(2018)3458435 - 29/06/2018
Ref. Ares(2019)2387732 - 04/04/2019
UK Comments on STECF Requests
Exemption
Shortfalls
UK Comments
Common sole (undersized
Location of sole nursery grounds has again This sole exemption has already been approved and is in force at
only) caught with trawl
not been provided. Provision of this
the moment. When the exemption was finalised in previous years
gears in area VIId
material is a condition in the Delegated
France asked that text was added to exclude nursery grounds. From
Act and should be supplied .
a UK perspective we would like this nursery ground exclusion to be
Lead: UK
removed as we have the following concerns:
It is not easy to define nursery areas and there is no current legal
definition of what the term means. We are concerned about the
legal precedent any definition drafted now would set.
Data in a recent UK Cefas paper on sole nursery areas is ten years
out of date – we don’t know how consistent this data is and how
much matters have changed in the past ten years.
If we did want to try and determine specific nursery areas to
exclude from this exemption, we would need to formally consult
our industry and regional delivery bodies – and we do not have
time to do this in the very limited time until the next STECF
meeting.
The evidence for this exemption has already been considered and
has already been deemed strong enough for an exemption (with
an over 80% survival rate). Our arguments were that the discard
rate in the affected fisheries is very low anyway and the gear is as
selective as it can be – so the possibility of excessive mortality is
limited. The use of this exemption will not increase mortality as
most of the fish survive. But mortality will increase if fishermen
are made to land all their undersized sole catch in particular
areas.
Nursery areas are associated with concentrations of juvenile fish,
which for sole is fish below 13cm. (The MCRS for sole is higher at
24cm.) The vessels affected by this exemption are very unlikely to
catch this juvenile sole because of their selectivity measures. So
we see no reason to exclude nursery areas from this exemption.
Skates and ray species
Very few landings and discards data
We have supplied all the relevant data generated and published on the
caught by any gear in the
provided. EWG18-06 recognises these
STECF FDI database – which is the best data to use to ensure consistency.
North Western Waters
The same data could be disaggregated, but we do not think this will
(areas VI and VII)
data are sparse and that there are quite a
lot of species, however, Regional Group
provide any more useful information. However we have attached a
should provide whatever they do have to spreadsheet of the raw data for reference.
assist inform the evaluations.
Alternatively all Member States would need to independently produce
Lead: UK, NL
data on skate and ray catches and discards by metier which would be very
time consuming, and would probably not be consistent across Member
States. We do not think this will be a useful exercise.