Cyfarfod Grŵp Cynghori Cymru ar Gregyn y Brenin: 22 Mai 2024

Stakeholders: Christopher Chambers (CC), Jim Evans (JE), Natalie Holder (NH), Mark Roberts (MR), Alexander Scorey (AS), 

WG: Michelle Billing (MB), Julian Bray (JB), Tim Croucher (TC), Barrie John (BJ), Mattew Sayer (MS), Alun Mortimer (AM), Seb Evans (SE), Sanyie Smith (SS),

Apologies: John Gorman, Graham Green, Nicola Cusack

A few apologies but we will continue.

Review of actions and maters arising. One outstanding action. AM to request NH presentation for circulation. 

Doc 4 is a summary of King Scallop evidence priorities for Wales. Should add in here where stakeholders can contribute.

ACTION 1: Amend evidence summary to highlight where stakeholders can contribute

Minutes for 29 February meeting approved.

ACTION 2: Resend slides following changes made since the original circulation

AM briefly recapped priority actions from the FMP and delivered a presentation explaining current king scallop regulations in the Welsh zone. 

AM explained that the FMP obliges the Welsh Government to develop a new fishery management framework of measures and how this could be structured in a coherent way. A working definition of a fishery management framework was agreed –with the removal of “and complementary” which was unnecessary.

Fisheries are managed by implementing controls on fishing. Controls can be divided into output controls and input controls. We have chosen to consider technical controls as a sub-category of input controls.

Output controls – directly limit what can be taken from the fishery (for example by imposing a catch limit). 

Input controls – indirectly limits what can be taken from the fishery (for example by having a closed season). 

Technical controls – control fishing methods or practices (for example, gear specification or electronic vessel monitoring system specifications).

AM explained the current framework of measures and encouraged the group to highlight where they believed improvements would be beneficial and why.   

In discussion the following points were made (grouped by topic): 

Output control – catch limits

• JE - FMP priorities are centred around stock but there are other regulatory issues, particularly evidence gaps on the wider environmental impacts that need to be scoped. 
• JB - HRA on any changes wouldn’t be starting from zero. Developing the new framework of measures is the focus today.
• JE - REM should be considered, specifically in relation to gear-in, gear-out technology (GIGOT).
• NH – where would ecosystem controls such as sea floor sensitivity fit? AM – can differentiate between the type of control and the reason for the control, most environmental controls would be output controls or input controls. Can consider a separate subcategory of environmental controls so the purpose for the control is clear but not sure it is integral to the framework to do so. 
• There are no catch limits (quantitative output controls) for king scallop anywhere in the Welsh zone. The distinction was made between a total annual catch limit for a king scallop stock and a catch limit for an individual vessel. 
• With enough data about stocks, could have total catch limits for separate stocks within the Welsh zone rather than a single total catch limit for the whole Welsh zone. There are currently 3 areas under assessment so could have 3 local stock assessments and catch limits.
• It was noted that current fishing pressure would not necessitate a catch limit but that the idea is good in principle with appropriate stock assessment to avoid over-exploitation. Having the ability to impose a catch limit as a ‘ceiling’ or if fishing pressure increases would be a valuable management tool.
• If a catch limit were imposed, initially it would probably have to be based on historical catches but as stock assessment becomes available would be based on the scientific evidence and advice.
• Catch limits can be adaptive and responsive to stock levels or fishing pressure.
• NH – Isle of Man (IoM) are going down to a really fine spatial scale. IoM have also done a lot of work on real time data collection and Catch Per Unit Effort (CPUE) which can increase the burden on fishers.
• CC – IoM daily quota was so low that it wasn’t really viable for a lot of boats. Manx boats now have only 1-2 men on board just to make it pay. Overall management is good but is having a negative economic impact.
• Need to consider whether a catch limit is the most appropriate management measure or whether there are others such as days at sea which might be more suitable. 

Output Control – Minimum Conservation Reference Size

• It is not clear that there is a compelling reason for having different MCRS in the Welsh zone. It appears that the differences are because of historical changes in jurisdictions through the process of EU integration and exit and UK devolution.
• There is evidence that scallops mature at a slightly larger size further north but it is not significant and it could be environmental rather than genetic. 
• Having different MCRS is difficult to enforce around the ‘borders’ and it favours people fishing the smaller sized scallops further south. Potential impact on recruitment as a result too.
• Scallops in the protected area of Cardigan Bay tend to be smaller than the unprotected area but it may be because it is not as good a place to grow.
• Also need to consider harmonisation across the borders with other jurisdictions.

Input controls – licensing and permitting

• Consensus that having two separate permitting areas that only cover 0-6nm part of the Welsh zone is unnecessarily fragmented - historical due to the former North and South Wales Sea Fisheries Committee areas.
• Different vessel size, power and recording requirements inshore and offshore - smaller vessels fish smaller areas, take less and cannot travel as far. 
• A single permitting regime should be able to impose different requirements in different geographical areas for different sized/powered vessels.
• With appropriate legislation, a permitting regime can be used to underpin adaptive management as changes can be made by updating permit conditions.

Input controls – seasonal (temporal) closures

• Consensus that there does not appear to be a compelling reason for the different closed seasons within the Welsh zone. Difference in seasons seem to be historical and as such some of facts since they were imposed have changed. 
• The seasonal closures from the Scallop Fishing (Wales) (No.2) Order 2010, 1 May to 31 October make the most sense and have been made most recently but only apply to within the 0-12nm area, very few scallops left to catch in June. 
• EU vessels can no longer fish in Cardigan Bay year-round but there is an area further south in the Celtic Sea without any seasonal restrictions. It does not appear there is much scallop fishing in this area. 
• There is some evidence which suggests there may be both spring and summer spawning in the Irish Sea but not clear the evidence is adequate to support closures. Surveying beyond the 12nm line is prohibitively expensive. 
• Need to consider the impact across the median line of revoking the 1984 and 1986 closure orders. 

Input Controls – spatial closures

• The closed rectangles in Cardigan Bay were imposed before satellite positioning technology became common place. These areas could be reshaped to more closely protect the marine features they were designed for with modern VMS or REM.
• Worth noting that the small modiolus “egg” shaped closure north of the Llŷn is slightly different to the adjacent closure. It is not in the Pen Llŷn a’r Sarnau Special Area of Conservation (SAC). Changes to the western closure would need HRA assessment.

Technical Controls: dredge requirements

• Few concerns raised about existing gear controls.
• There is one issue with the 2010 Order rules relating to belly ring size. Rule does not specify the size of the belly ring only limits the number to 7 across. Should have specified 85mm ring diameter. Fishing with a smaller belly ring is allowed but it catches smaller scallops. Evidence is available that smaller belly ring catches more of everything which is unnecessary seabed disturbance. Bangor University doing work on enviro-dredges with adaptions (environmental impacts, fuel consumption etc).
• The 85mm size should be across the fleet in all areas so the legislation has the impact that was intended.
• It is also legal to have belly rings at the side of the bar as long as only 7 on the bar.
• There are far fewer regulations for gear specification in the offshore (beyond 12nm) area. There is a belly ring restriction – need further info.

ACTION 3: AM to research dredge requirements in 12nm to midline area of Welsh zone

• 10 dredges a side might be a reasonable restriction in the offshore area of the Welsh zone. 
• Would need rationale and evidence to justify any new restrictions even in the offshore area. Not clear that scallop stocks in the offshore area are sustainably managed. Further gear controls in the offshore could safeguard seabed integrity and provide equitable access.
• Current dredge requirements are in regulations but could be controlled through permit conditions. Changing rules in future would then be easier through targeted consultation and could be done as more evidence becomes available.

Technical Control: electronic monitoring

• Consensus in the group that REM alongside VMS would be an advantage. GIGOT would be ideal. Benefits: more detailed fishing data for management, clearer monitoring for enforcement, more accurate stock data and real time management. 
• Could link REM to e-log and CatchApp and integrate catching and recording in real time. Could be combined with time at sea restrictions rather than closures – even down to hours at sea as could strip out non-fishing time. 
• Some smaller vessels might not be able to fit the necessary gear on board so might need some proportionate rules for REM.
• Reason there are different “ping” rates within the Welsh zone for different vessels is historical and jurisdictional. Believe Wales has the power to change this now. There is no reason not to insist on the same “ping” rate across all vessels in all areas. 
• Bangor University focus group being held with fishers and a theme coming out is if enforcement can be improved and fairness this benefits trust and engagement.
• Permit conditions could be used to vary technical requirements too.
• Scotland are about to introduce REM requirements. Worth discussing this in more detail at a future meeting. 

ACTION 4: Arrange a meeting to consider REM in more detail 

Technical Controls – vessel size or power restrictions

• The main vessel size and power restrictions for the 0-12nm area are in the 2010 Scallop Fishing (Wales (No.2) Order 2010 - no issues were raised with these rules. 
• Different vessel size limit east and west of Great Orme’s head in former North Wales byelaws – reason for this is not known.
• Consensus that generally days at sea is a better control than fishing curfews. Inshore north of the Llŷn peninsula near Nefyn and north-east Anglesey suggested as areas where nighttime curfews may be appropriate. In most other areas the weather and tides are enough of a restriction without curfews. 
• Curfews would be difficult to manage from an enforcement perspective unless combined with REM. 
• There have been creel fishing trials in Scotland with different types of effort restriction. Found that where the stock levels were adequate, reducing fishing effort resulted in higher catch in shorter time and this had an improvement on wellbeing measures for fishers. 
• Days at sea is a good restriction because it means fishers can be flexible to tides and weather. Having fixed effort restrictions, such as weekend closures, risks fishers going out in worse conditions.
• Some evidence available on controls for ecosystem protection or to reduce carbon emissions – any changes for this purpose should consider evidence of impact on scallop stock sustainability. 
• Carbon footprint of the fishery could be reduced by limiting time at sea. Time at sea limits only economically viable for fishers with good stock abundance.
• Rotation of fishing grounds could achieve good stock abundance.
• When making any changes the potential for conflict with technical controls for other fisheries needs to be considered. 
• The Trade and Cooperation Agreement requirements will need to be considered for any changes to measures affecting EU vessels. 

ACTION 5:  Will take stakeholder discussion contributions and add to framework for further discussion

No AOB raised. 

Next meeting likely to include a review of catch data, a summary of contributions from the group to the new framework and an initial discussion on implementing FMP actions.

A more detailed discussion on REM at a future meeting has been captured as an action. 

Meeting closed.

1.  Amend evidence summary to highlight where stakeholders can contribute (AM) - outstanding
2. Resend slides due to tweaks since circulated (AM) -complete
3. AM to research dredge requirements in 12nm to midline area of Welsh zone (AM) - outstanding
4. ACTION 4: Arrange a meeting to consider REM in more detail (AM) - complete
5. Will take stakeholder discussion contributions and add to framework for further discussion (AM) -complete.