Memo
To:
North Sea Advisory Council Pulse Trawl Focus Group
From:
ClientEarth
Date:
18.12.14
Subject:
ClientEarth thoughts, concerns and questions regarding pulse trawl fishing
Licences and scope of pilot project(s)
We would like to know more about the pilot project(s) and the basis upon which licences were
granted. Specifically, we have the following questions:
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On what legal basis were the Dutch fleet’s licences granted in 2007, 2011 and 2014?
On what scientific basis were the Dutch fleet’s licences granted in 2007, 2011 and 2014?
As we understand that the 2014 licences were granted under Article 14, we note in
particular the requirement under Article 14 CFP that pilot projects be based on the best
available scientific advice, along with the requirement under Article 2(2) of the CFP for a
precautionary approach to be applied to fisheries management (see concerns below).
The IMARES research proposal distributed at the focus group meeting refers to the 5%
allowance for beam trawlers to use pulse trawl not being ‘sufficient to cover the interest
for the pulse trawl in the Dutch fleet’. What does this mean? On what basis was it
concluded at each stage that additional licences for the Dutch fleet were necessary?
What percentage of the Dutch fleet currently has a pulse trawl licence?
What timescale is envisaged for the pilot project?
What are the expected outcomes of the pilot project? What are the scientific research
objectives behind the pilot project?
Answers to each of the above questions are currently not sufficiently clear; more information
should be made available.
Concerns:
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As the pulse trawl derogations granted in 2014 as part of the pilot project were granted
under Article 14 of the new CFP, Article 2(2) requiring a precautionary approach to be
applied to fisheries management also applies. Given that there are significant (and
concerning) knowledge gaps with regards to pulse trawling, as was clear from the
IMARES presentation, the precautionary approach does not appear to have been
followed in granting the licences.
Under Article 14 of the CFP, Member States may conduct pilot projects based on the
best available scientific advice and taking into account the opinions of the relevant
Advisory Councils. It seems that the pilot project under this Article has begun but
consultation of the NSAC does not seem to have taken place before now.
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Document title
Document date
Marine Protected Areas:
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ClientEarth is particularly concerned about the use of pulse trawling in marine protected
areas in light of the significant knowledge gaps. For example, in Natura 2000 sites,
because of the current knowledge gaps it is not possible to ascertain that pulse trawling
will not adversely affect the integrity of the site. At this stage, and until conclusive
evidence can be produced, pulse trawling should not be permitted under any
circumstances in these protected sites.
Ecological effects
ClientEarth’s view is that there has not been enough research into the in situ impacts of pulse
trawling on marine ecosystems. The majority of studies that have been carried out have been in
the laboratory under experimental conditions, not in the systems in which pulse trawling occurs.
We note from the IMARES research proposal that further research into ecological effects will be
undertaken. This further research should be comprehensive, with a particular focus on:
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The long term ecosystem effects of pulse trawling. Research should take place outside
of the laboratory and in the areas where pulse fishing is used, with variations, particularly
temporal, to cover all scenarios.
The cumulative effects from continued pulse trawling upon marine ecosystems.
UK fishermen have expressed concern that they are catching increased dead fish,
particularly juvenile Dover sole, when fishing in areas previously fished by the Dutch
pulse trawlers. There needs to be further research on this with the involvement of the UK
and Dutch vessels.
Control and monitoring
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What voltage is permitted under the licences? (IMARES referred to the voltage used
being below the legal limits).
How is the voltage of the pulse trawl gear monitored to ensure it does not exceed the
allowance?
Does the gear itself have a voltage upper limit?
There needs to be a differentiation between the registration and monitoring of those
vessels using pulse trawl and those using beam trawl (not just within the Netherlands),
particularly in light of the VMS data that covers both (as per IMARES presentation).
Given the lack of knowledge about the effects of pulse trawling on ecosystems, along
with the different variables involved, the use of pulse trawl gear should be subject to
comprehensive monitoring. What monitoring systems are proposed?
Invu182213